talent acquisition privacy notice

Last Updated: August 2026

Please note:

• If you are a visitor to Fairway’s website and mobile applications in the United States or otherwise provide personal information to obtain services as a consumer, please refer to our Privacy Policy.

Please take time to read this Notice in its entirety to ensure you are fully informed. If you have questions or concerns, please contact us by using the contact information below.

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Introduction

Fairway Independent Mortgage Corporation d/b/a Fairway Home Mortgage and its wholly owned subsidiary Frisco Lender Services, LLC, Fairway Home Services, and Fairway Home Insurance Agency, LLC (collectively “Fairway,” “we,” or “us”) respect the privacy of job applicants and individuals interested in potential employment opportunities with us in the United States (“Applicant” or “you”), and we are committed to protecting your Personal Information. We prepared this Talent Acquisition Privacy Notice (“Notice”) to give you a better understanding of our practices respecting the collection, use, disclosure, and retention of Personal Information obtained in connection with applying for a job at Fairway and Fairway’s recruitment process.

“Personal Information” includes any information related to or that can be used to identify, contact, or locate an individual.

APPLICABLE LAW

Where local laws impose greater obligations or restrictions on the use of Personal Information, or require additional information be provided to you, this Notice may be supplemented by local policies. In particular, job applicants who are residents of California should refer to Appendix A for additional information regarding how we collect and use your Personal Information in accordance with the California Consumer Privacy Act (CCPA).

INFORMATION WE COLLECT

Fairway may collect Personal Information in connection with your submitting to apply to, or searching for a position on, the Fairway Careers website, which includes information you provide as well as passive information collection, where permitted by applicable law, including:

• User log-in and password for the Careers website
• Information on how you found out about the job
• Identifiers and contact information, including names and addresses, telephone numbers, email addresses, signatures, account names, date of birth, Social Security number, driver’s license or state identification numbers, and other similar contact information and identifiers
• Professional and employment-related information, including employment history and experience, employment recommendations or references, employment preferences, willingness to relocate, willingness to travel, desired salary, CV, resume, cover letter, background check and criminal history, work authorization, and fitness for duty data and reports
• Education information, including education history, education level, school, major, certifications held, etc.
• Protected classification information, including characteristics of protected classifications under applicable law by your self-identification (e.g., age, gender)
• Internet and other electronic network activity information, including all activity on the Careers website and Fairway information systems, such as search history
• Geolocation data, including geolocation country code, IP address, and JA4 fingerprint
• Audio, electronic, visual, thermal, olfactory, and similar information (e.g., information collected from cameras and similar devices)

We do not require, but you may voluntarily choose to provide other relevant information as part of your application. However, please do not submit the following sensitive information unless specifically requested to comply with our legal obligations and internal policies relating to inclusion and anti-discrimination: sex, race, ethnic origin, religion, political and religious beliefs, disability, marital status, creed, nationality, national origin, color, and veteran status. By voluntarily submitting information about your racial or ethnic origin; physical or mental health or condition; job evaluations or educational records; commission (or alleged commission) of an offence or related proceedings; political opinions or beliefs; religious beliefs; sex life; membership in a trade union or political party, you expressly authorize Fairway to receive and process such information for the purpose of processing your application.

If you intend to provide a reference as part of your application, it is your responsibility to obtain their consent prior to providing their personal information to us.

Providing Personal Information is voluntary. Please note, however, failure to provide sufficient information may result in not being considered for employment.

Passive Information Collection: Cookies and Similar Technologies

We may use “cookies” and similar technologies on the Careers website. Cookies are data that a web server transfers to an individual’s computer for recordkeeping purposes. We use cookies and other technologies to better serve you with more tailored information and facilitate your ongoing access to and use of our Careers website. If you do not want information collected through the use of cookies, there is a simple procedure in most browsers that allows you to automatically decline cookies, or to be given the choice of declining or accepting the transfer of a particular cookie(s) from a particular website, to your computer. However, if you decline session management cookies, the Careers website may not function properly. Refer to our Cookie Policy for more information.

We obtain the categories of Personal Information outlined above from the following sources:

• Directly from you if you provide your Personal Information to us, including through application forms, resume/CV, and other identity documents
• Directly and indirectly from activity on our websites (e.g., from your submissions through our websites’ forms or your website usage details collected automatically)
• Directly from our employees and recruiters, in connection with employment at Fairway or applying for a job at Fairway and Fairway’s recruitment process (e.g., through interviews or other forms of assessment)
• Directly and indirectly from third parties (e.g., references, background checks, recruiters)

If we need to process your Personal Information for an incompatible purpose not discussed in this Notice, we will provide notice to you and, if required by law, seek your consent. We may process your Personal Information without your knowledge or consent only where permitted by applicable law.

LEGAL BASES, USE, AND DISCLOSURE OF PERSONAL INFORMATION

Personal Information may be collected, used, transferred, and disclosed by Fairway’s employees, consultants, and/or service providers within the United States for Fairway’s recruitment functions and related management and planning purposes as permitted by local law, including:

• Collecting and processing employment applications, including confirming eligibility for employment, background and related checks, references, onboarding, and related recruiting efforts; evaluating an individual’s appropriateness for a particular position.
• Retaining your information for consideration with respect to future job vacancies with Fairway.
• Providing and maintaining access to the Careers website.
• Maintaining records and satisfying record retention requirements.
• Communicating with applicants about a current application, future job opportunities, or current or past employment.
• Complying with applicable state and federal health, labor, employment, disability, equal employment opportunity, workplace safety, and related laws, guidance, and recommendations.
• Preventing unauthorized access to, use, or disclosure of Fairway’s property, including information systems and network.
• Investigating complaints, grievances, and suspected violations of company policy.
• Facilitating the efficient and secure use of Fairway’s information systems; ensuring compliance with our information systems policies and procedures.
• Improving safety of applicants, employees, customers, and the public regarding use of Fairway property and equipment; improving efficiency.
• Protecting the legal rights, privacy, safety, and property of Fairway and/or its employees, agents, contractors, customers, and the public.
• Protecting against fraud or other illegal activity or for risk management purposes.
• Investigating, responding to, and managing legal claims against Fairway and/or its personnel, including litigation discovery.
• Facilitating other business administrative functions and strategic activities, such as risk management, information technology and communications, financial management and reporting, workforce and succession planning, merger and acquisition activities, and maintenance of licenses, permits, and authorization applicable to company operations.
• Sending surveys to collect feedback on your recruiting experience.
• Conducting and storing video interviews.
• For other lawful and legitimate purposes, which may be reasonably required for day-to-day operations.

Our processing of Personal Information for the purposes described in this Notice also includes the use of automated methods of processing, including machine learning, artificial intelligence, and generative intelligence capabilities to analyze your Personal Information, determine trends, and/or create AI-generated responses or other content. If you interact with a chatbot in our hiring software, we may also store the transcript for purposes described in this Notice.

If you are offered and accept employment with Fairway, the Personal Information collected during the job application, recruitment, and onboarding processes may become part of your employment record.

We will not collect additional categories of Personal Information or use Personal Information for materially different, unrelated, or incompatible purposes without providing you notice and, if required by law, seeking your consent.

Disclosure

Your Personal Information will be reviewed by Fairway employees or agents who have a business need to access such Personal Information and may include recruiters, human resources and legal personnel, technical services personnel, and managers or their designees.

We may share Personal Information with selected service providers or consultants acting on our behalf, such as third parties assisting Fairway with the operation of the Careers website. Those third parties are required by contract to use appropriate measures to protect the confidentiality and security of Personal Information.

Fairway may disclose Personal Information to:

• Protect the legal rights, privacy, safety, or property of Fairway and/or its employees, agents, contractors, customers, and the public;
• Protect the safety and security of visitors to Fairway’s websites and other properties;
• Protect against fraud or other illegal activity or for risk management purposes;
• Respond to inquiries or requests from legal authorities and comply with the law and legal process;
• Exercise, establish, and defend our legal rights;
• Seek to enforce or apply our website Terms of Use;
• Respond to an emergency we believe in good faith requires us to disclose Personal Information to prevent harm;
• Effect a license, sale, or transfer of a business or assets (including in connection with any bankruptcy or similar proceeding); and
• Manage acquisitions, mergers, and reorganizations.

Sales or Sharing of Personal Information

We do not sell Personal Information and will not sell it without providing required notices and/or opt-in/opt-out rights.

Data Retention

We are required to retain information relating to candidates applying for jobs via the Careers website within the United States. We will retain your Personal Information for three years after your disposition date if not hired or seven years after termination if hired, or a longer timeframe if required by applicable law, during which time we may contact you regarding open positions.

ACCESS, CORRECTION, AND DELETION

If you choose to register on our Careers website, you may access, review, and change some of the Personal Information collected about you and stored on the Careers website by logging into the Careers website and choosing to update your account information. We encourage you to promptly update your Personal Information if it changes or is inaccurate.

You may access, modify, or object to the use of Personal Information as permitted by applicable law. Applicants who wish to review, update, or request we delete their Personal Information should complete an online submission, email privacy@fairwaymc.com, or call (877) 699-0353. Please note, however, certain Personal Information may be exempt from access, correction, or deletion rights pursuant to applicable data protection laws.

LINKS TO OTHER SITES

The Careers website may contain links to other websites. The operators of those other websites may collect information about you, through cookies or other technologies. If you link to another website, you will leave the Careers website and this Notice will not apply to your use of and activity on those other sites. If you provide Personal Information through or on any other site, your transaction will occur on that website and the Personal Information you provide will be collected and controlled by that website operator’s privacy policy.

Links on the Careers website to other websites are provided only as a convenience and does not imply endorsement of the linked site. We encourage you to read the legal notice posted on those sites, including their privacy policies. We have no responsibility or liability for your visits to, or the data collection or use practices of, other sites.

CHILDREN

The Careers website is not intended for minors under the age of 15 or the lawful age of employment, whichever is greater.

CHANGES TO THIS NOTICE

Fairway reserves the right to amend this Notice at any time without advance notice to address future developments of Fairway, the Careers website, and changes in industry or legal trends. You can see when this Notice was last updated by checking the Last Updated date displayed at the top of this Notice. Any changes will become effective upon the posting of the revised Notice. By continuing to use the Careers website following such changes, you will be deemed to have agreed to such changes. If you do not agree with the terms of this Notice, in whole or part, you can choose not to continue to use the Careers website.

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Appendix A

California Residents – Notice at Collection

This Appendix A applies to individuals who are residents of the State of California as required under the California Consumer Privacy Act, as amended (CCPA). The other provisions of the Talent Acquisition Privacy Notice continue to apply, as applicable, except as modified in this Appendix.

This Notice at Collection (“Notice”) describes the categories of Personal Information Fairway may collect from California residents and the purposes for which such information may be collected and used. It also provides information concerning Fairway’s record retention practices and rights you may have under the CCPA. Any terms defined within the CCPA have the same meaning when utilized within this Appendix.

Categories of Personal Information Collected

• Identifiers and Contact Information. This category includes names, addresses, telephone numbers, email addresses, signatures, account names, date of birth, log-in and password for the Careers website, and other similar contact information and identifiers.
• Protected Class Information. This category includes characteristics of protected classifications under California or federal law.
• Internet and Other Electronic Network Activity: This category includes, without limitation:
  
  • All activity on our information systems, such as email communications, stored documents and emails, usernames and passwords
  • All activity on our communications systems, including phone calls, call logs, voicemails, text messages, etc.
• Geolocation Data, including geolocation country code and JA4 fingerprint.
• Audio, Electronic, Visual, Thermal, Olfactory, and Similar Information. This category includes, for example, information collected from cameras and similar devices.
• Professional and Employment-Related Information. This category includes, without limitation, where permitted by law, data submitted with employment applications, employment history, employment recommendations and references, etc.
• Education Information. This category includes, without limitation, education history.
• Sensitive Personal Information. This category includes sensitive information, such as: Social Security number, driver’s license, state identification card, or passport number; content of mail, email, and text messages (unless Fairway is not the intended recipient); background check and criminal history; work authorization; fitness for duty.
• Inferences Drawn from the Personal Information in the Above Categories. This category includes engaging in human capital analytics, including, without limitation, identifying correlations between certain characteristics and job success.

Purposes Personal Information (Including Sensitive Personal Information) Is Used

• Collecting and processing employment applications, including confirming eligibility for employment, background and related checks, references, onboarding, and related recruiting efforts; evaluating an individual’s appropriateness for a particular position.
• Retaining your information for consideration with respect to future job vacancies with Fairway.
• Providing and maintaining access to the Careers website.
• Maintaining records and satisfying record retention requirements.
• Communicating with applicants about a current application, future job opportunities, or current or past employment.
• Complying with applicable state and federal health, labor, employment, disability, equal employment opportunity, workplace safety, and related laws, guidance, and recommendations.
• Preventing unauthorized access to, use, or disclosure of Fairway’s property, including information systems and network.
• Investigating complaints, grievances, and suspected violations of company policy.
• Facilitating the efficient and secure use of Fairway’s information systems; ensuring compliance with our information systems policies and procedures.
• Improving safety of applicants, employees, customers, and the public regarding use of Fairway property and equipment; improving efficiency.
• Protecting the legal rights, privacy, safety, and property of Fairway and/or its employees, agents, contractors, customers, and the public.
• Protecting against fraud or other illegal activity or for risk management purposes.
• Investigating, responding to, and managing legal claims against Fairway and/or its personnel, including litigation discovery.
• Facilitating other business administrative functions and strategic activities, such as risk management, information technology and communications, financial management and reporting, workforce and succession planning, merger and acquisition activities, and maintenance of licenses, permits, and authorization applicable to company operations.
• Sending surveys to collect feedback on your recruiting experience.
• Conducting and storing video interviews.

Sources of Personal Information

We may collect Personal Information from the following sources:

• You. We may collect Personal Information directly from you; your device, such as through use of our Careers website or systems; when you visit one or more of our locations/facilities, send us an email, contact us by phone, or otherwise communicate or interact with us.
• Related Entities and Affiliates. We may collect Personal Information from our related parties and affiliates.
• Social Media and Related Services. We may collect Personal Information through your social media services consistent with your settings on such services.
• Third Parties and Service Providers. We may collect Personal Information from third parties, such as your references, applicant tracking systems and talent acquisition vendors, background check vendors, staffing agencies, recruiters, Fairway customers and clients, or other third-party sources lawfully entitled to share your data with us, including service providers/contractors who collect or process your Personal Information on our behalf.

Disclosures of Personal Information

To carry out the purposes outlined above, we may disclose your Personal Information to our affiliates, service providers, contractors, and government entities.

We may also disclose your Personal Information to third parties, if necessary, to comply with federal, state, and local laws; comply with a civil, criminal, or regulatory inquiry, investigation, subpoena, or summons by federal, state, or local authorities; cooperate with law enforcement agencies concerning conduct or activity that we reasonably in good faith believe may violate federal, state, or local laws; or exercise or defend legal claims.

Lastly, we may transfer Personal Information to a third party as part of a merger, acquisition, bankruptcy, or other transaction in which the third party assumes control or acquires all or part of the assets of our business.

We do not sell or share, as those terms are defined under the CCPA, the above categories of Personal Information.

We do not use or disclose your Sensitive Personal Information for purposes that, with limited exceptions, are not necessary for the application or recruitment related purpose for which we collect it, as reasonably expected by an average individual in this context or for other permitted purposes under the CCPA, or as authorized by regulation.

Retention

We retain your Personal Information for as long as necessary for the recruitment process, assess and/or process your employment application, consider you for future positions, and in accordance with Fairway’s record retention schedule. Specifically, we will retain your Personal Information for three years after your disposition date if not hired or seven years after termination if hired, or a longer timeframe if required by applicable law, during which time we may contact you regarding open positions.

We may retain your Personal Information for longer if it is necessary to comply with our legal or reporting obligations, resolve disputes, enforce our legal agreements and policies, address other legitimate business needs, and as permitted by applicable law.

We may also retain your Personal Information in a deidentified or aggregated form so it can no longer be associated with you.

Individual Rights Request

Individuals who are residents of the State of California have certain individual rights, as outlined below.

Right to Know About Personal Information Collected or Disclosed. As a California resident, you have the right to request additional information, beyond that disclosed above, regarding the following, to the extent applicable:

• The categories of Personal Information that Fairway collected about you
• The categories of sources from which that Personal Information was collected
• The business or commercial purpose for which Personal Information was collected, sold, or shared
• The categories of third parties to whom Personal Information was disclosed
• The specific pieces of Personal Information collected

Upon receipt of a verifiable request to know, and as required by applicable law, we will provide a response to such request.

Right to Request Deletion of Your Personal Information. You have the right to request we delete Personal Information we collected or maintain about you. Once we receive your request, we will let you know what, if any, Personal Information we can delete from our records, and will direct any service providers and contractors to whom we disclosed your Personal Information to also delete your Personal Information from their records. There may be circumstances where we cannot delete your Personal Information or direct service providers or contractors to do so. Such instances include, without limitation, when the Personal Information at issue is maintained to enable solely internal uses reasonably aligned with your expectations based on your relationship with Fairway and compatible with the context in which you provided the information or to comply with a legal obligation.

Upon receipt of a verifiable request to delete, and as required by applicable law, we will provide a response to such requests.

Right to Request Correction. You have the right to request Fairway correct any inaccurate Personal Information we maintain about you, taking into account the nature of such information and purpose for processing it. Upon receipt of a verifiable request to correct, and as required by the CCPA, we will provide a response to such requests.

Right to Non-Discrimination for the Exercise of Privacy Rights. We will not discriminate or retaliate against you for exercising any of the rights described above.

Submitting CCPA Rights Requests

To submit a California Consumer Rights request, please choose one the following methods:

• Complete an online submission
• Email privacy@fairwaymc.com
• Call (877) 699-0353

We reserve the right to only respond to verifiable consumer requests to know, delete, or correct.

What to Submit. If we request, you must provide sufficient information to verify your identity and/or authority to act on behalf of a California resident. In general, we may ask you to provide identifying information we already maintain about you. In either event, we will attempt to avoid asking you for Sensitive Personal Information to verify your identity. We may not be able to respond to your request or provide you with Personal Information if we cannot verify your identity or authority to make the request and confirm the Personal Information relates to you. However, please note, making a verifiable consumer request does not require you to create an account with us.

Additionally, you will need to describe your request with sufficient detail to allow us to review, understand, assess, and respond. We will not use Personal Information collected from an individual to determine a verifiable request for any other purpose, except as required or permitted by law.

Our Response. We reserve the right to charge a fee to process or respond to your request if it is excessive, repetitive, or manifestly unfounded. If we determine a request warrants a fee, we will attempt to notify you as to why we made that decision and provide a cost estimate before completing your request. We will endeavor to respond to a verifiable consumer request within 45 calendar days of receipt, but we may require an extension of up to 45 additional calendar days to respond and will notify you of the need for the extension.

Spouses and Dependents. If you have knowledge Fairway collected Personal Information related to your spouse and/or dependent, please share a copy of this Notice with all such individuals.

Changes to This Notice. We reserve the right to amend this Notice.