Privacy Policy

1. We Respect Your Privacy

Cohivra, Inc. and its wholly owned subsidiary, Cohivra India Tech Private Limited (together, “Cohivra”, “we”), are committed to protecting the personal information entrusted to us. This policy covers information submitted through our website and information we handle when providing services to our clients.

Personal information you submit through our website inquiry forms is securely and confidentially stored and processed. Contact details, including name, telephone, fax and email, are used only for communicating with you about our products and services.

Your personal information will never be shared, leased, sold, or distributed to any third-party entities for marketing purposes without your prior consent. We implement appropriate technologies and processes to prevent unauthorized access, use, and/or disclosure of personal data.

No mobile information will be shared with third parties/affiliates for marketing/promotional purposes. All other categories exclude text messaging originator opt-in data and consent; this information will not be shared with any third parties.

2. Client and Borrower Information

Cohivra provides mortgage, title and servicing support services to lenders, servicers, banks, credit unions and title companies (“clients”). This section explains how we handle personal information, including nonpublic personal information protected by the Gramm-Leach-Bliley Act (GLBA), when we perform those services.

Our role

We act as a service provider on our clients’ behalf. The client owns the relationship with its customers and borrowers, decides how their information is used, and is responsible for giving them privacy notices and honoring their choices. Cohivra does not collect borrower information for its own purposes.

Information we handle

Loan, title, servicing and insurance files may include names, contact details, Social Security numbers, income, asset, credit, bank and payment information, and property records. We work on this information only inside the client’s own systems. We do not download, store or retain it on Cohivra devices or storage.

How we use it

Only to perform the services the client has contracted, and only on the client’s instructions.
Never for marketing, profiling, product development or any purpose of our own.
Never sold, rented or shared for anyone else’s marketing.

Disclosure

We do not disclose client or borrower information to anyone except:

to the client, or to parties the client directs;
to our own subsidiary and personnel who need it to perform the services;
to service providers that support our operations, only where needed and under written confidentiality and security obligations at least as protective as ours; or
where required by law, subpoena or regulatory request, in which case we notify the client first unless the law prohibits it.

Our services are delivered by personnel of Cohivra India Tech Private Limited in Bengaluru, India, under U.S. management. They access client information remotely inside the client’s systems and are bound by the same controls as U.S. personnel.

How we protect it

We maintain an information security program certified to ISO/IEC 27001:2022 and examined under SOC 2 for Security, Confidentiality and Privacy. It includes multi-factor authentication, access only from encrypted, company-managed devices, least-privilege access, monitoring and alerting, background screening, confidentiality agreements, and GLBA and privacy training for all personnel. The program is designed to meet the Interagency Guidelines Establishing Information Security Standards and the FTC Safeguards Rule as they apply to service providers.

Retention and disposal

Because client and borrower information stays in the client’s systems, we do not keep copies. When an engagement ends, our access to client systems is removed and the client is asked to revoke credentials. Our own business records are kept and disposed of under our Data Retention and Disposal Policy, and devices are wiped before reuse or disposal.

Security incidents

If we become aware of a security incident that affects, or may affect, a client’s information, we notify the client without unreasonable delay and within 24 hours, and give the client the facts and cooperation it needs to meet its own obligations to customers and regulators.

Requests from borrowers and customers

If you are a borrower or customer of one of our clients, please contact that institution directly about your information. If we receive your request, we will forward it to the client promptly.

Cookies are used on our websites to provide you with a more personalized and effective user experience. We analyze cookie data only to help us improve our service offerings and website features. These cookies do not grant us remote access to your systems or to any confidential information you have not shared with us. We will never make any data related to your location or any other customer-centric information public.

Cookies are stored and restricted to your browser or system memory. They can be disabled by changing your browser’s settings. But turning off cookies may prevent you from obtaining the full benefits of using our website. For more information, visit www.allaboutcookies.org.

4. Links to External Sites

Any links on our website to external third-party sites are for your convenience only and should be accessed at your own risk. Cohivra, Inc. is not responsible in any manner for the security features, content, or privacy policies of these third-party websites.

Basic identification details provided by you on our websites such as name, email address, company name, telephone number, and country, as well as web data like IP address, system location, and cookies are securely and confidentially stored. This information is used for communication with clients and potential customers about our products and services.

We will not retain this personal information any longer than necessary to achieve the purposes defined in this privacy policy unless a longer retention period is specified by the law or for directly related legitimate business purposes. You may request us to provide copies of your personal information, how and where the data is stored, and the purpose of storing this data.

By providing your telephone number through our website inquiry forms, you consent to receive SMS text messages from Cohivra, Inc. related to our products and services. Message and data rates may apply. You can opt out at any time by replying STOP, or get additional help by replying HELP.

No mobile information will be shared with third parties, affiliates, or partners for marketing or promotional purposes. SMS opt-in data and consent are collected only when you voluntarily provide your phone number through our website forms, and this information will not be shared with any third parties.

7. Changes to Our Privacy Policy

Cohivra, Inc. will review, change or update our privacy policy as and when required. We will ensure that our updated privacy policy is made available on our website, and we will notify clients of material changes.

8. Contact Us

Cohivra, Inc., 13492 Research Blvd, Suite 120, Austin, TX 78750 | contactus@cohivra.com | Privacy and security questions: pankaj@cohivra.com