Privacy Policy
Website and Borrower Portal
Effective Date: September 1, 2026
J.G. Romack and Sons Inc., doing business as The Private Client (collectively, “JGRS,” “The Private Client,” “we,” “us,” or “our”), respects the privacy of clients and prospective clients. This Privacy Policy explains how we collect, use, protect, retain, and disclose personal information and nonpublic personal information in connection with mortgage inquiries, applications, transactions, and related services.
This Policy applies to information collected through www.jgromackandsons.com, The Private Client’s secure ARIVE borrower portal, mortgage applications and related forms, email, telephone, text message, postal mail, and other communications or documents submitted in connection with a mortgage inquiry, application, or transaction.
This Policy supplements, but does not replace, any separate financial privacy notice, electronic-consent agreement, credit authorization, disclosure, or other agreement provided in connection with a mortgage inquiry, application, or transaction.
1. Information We Collect
Depending on the services requested, we may collect:
Name, address, telephone number, email address, and other contact information
Social Security number, date of birth, government identification, and similar identifying information
Employment, income, asset, liability, credit, banking, tax, insurance, and property information
Mortgage inquiry, application, loan, property, and transaction information
Supporting documents and electronic signatures
Information obtained from credit-reporting agencies, verification providers, lenders, public records, and other sources authorized by the applicant
Communications, authorizations, consents, audit records, and transaction history associated with an inquiry or application
Technical information associated with use of our website or borrower portal, such as device, browser, IP address, cookies, security information, and activity information
We may collect information directly from the individual; from an authorized co-borrower or agent; from documents, communications, and transactions; and from third parties involved in or authorized to support the requested mortgage transaction.
2. How We Use Information
We use information for legitimate mortgage, operational, security, compliance, and legal purposes, including to:
Respond to mortgage inquiries and communicate with clients and prospective clients
Evaluate, price, process, place, and manage mortgage applications and requested services
Identify and compare potentially appropriate mortgage products or pricing
Obtain and document borrower authorizations and consents
Verify identity, employment, income, assets, liabilities, credit, property, insurance, and other application information
Request, receive, review, authenticate, and transmit documents and electronic signatures
Coordinate disclosures, processing, underwriting, appraisal, title, insurance, settlement, closing, funding, and related services
Submit information to a lender selected or authorized by the borrower
Detect, investigate, and prevent fraud, misuse, security incidents, and unlawful activity
Operate, protect, support, and improve our website, borrower portal, systems, and services
Maintain business, licensing, compliance, audit, quality-control, evidence, and transaction records
Resolve disputes, enforce agreements, and satisfy legal or regulatory requirements
An inquiry, application, transaction-related communication, or completed loan does not by itself authorize unrelated promotional communications.
3. When We May Disclose Information
Borrower information remains within the authorized mortgage process. We do not sell personal information, nonpublic personal information, borrower lists, mortgage applications, supporting documents, leads, client contact information, mobile telephone numbers, or SMS consent records.
We may disclose information when authorized by the borrower, as reasonably necessary to process or administer a requested mortgage transaction, to service providers performing authorized services for us, or as permitted or required by law.
3.1 Lender Selection and Borrower Authorization
Before lender selection, we may use limited loan-scenario information to compare potentially available mortgage products or pricing.
We will not provide a prospective lender with the borrower’s complete mortgage application or supporting documentation unless the borrower has provided documented authorization or consent, or the disclosure is otherwise permitted or required by law.
After the borrower and JGRS select or authorize a lender, the application and supporting documentation may be provided to that lender for authorized evaluation, processing, underwriting, closing, funding, servicing, and related transaction purposes. The lender’s handling of information is governed by its own privacy notices, policies, and legal obligations.
3.2 Access to the Complete Application
Access to a complete mortgage application and supporting documentation is limited to:
The borrower and any authorized co-borrower
JGRS personnel whose assigned duties require access
A specifically authorized contractor serving in a mortgage-processing capacity, subject to written confidentiality, information-security, purpose, and access limitations
A lender selected or authorized by the borrower
Persons acting under the selected lender’s authority as necessary to process the transaction
An agent acting under a valid power of attorney accepted for the requested purpose
3.3 Service Providers and Transaction Participants
We disclose only information reasonably necessary for a provider or transaction participant to perform an authorized function. These parties may include:
Credit-reporting and verification providers
Electronic-signature and disclosure-document providers, including DocMagic
Automated underwriting systems
Title, settlement, appraisal, insurance, flood, tax, and fraud-prevention providers
Secure portal, communications, data-hosting, cybersecurity, compliance, and record-retention providers
A lender, investor, or other participant involved in the borrower-authorized transaction
ARIVE serves as JGRS’s loan-origination and borrower-portal platform. ARIVE hosts and processes information submitted through The Private Client’s authorized portal solely to provide, secure, maintain, support, and document the mortgage services requested by the borrower, subject to applicable agreements and legal requirements.
Service providers are not authorized to use information received from JGRS for their independent marketing. We apply a minimum-necessary standard: information is disclosed only when reasonably necessary for the borrower-authorized transaction, operations supporting that transaction, protection of the borrower or JGRS, or compliance with law.
3.4 Legal and Business Requirements
We may disclose information to government agencies, regulators, courts, law-enforcement authorities, auditors, counsel, insurers, or other appropriate parties:
When permitted or required by law
To respond to legal process or regulatory requests
To investigate or prevent fraud, security incidents, or unlawful activity
To protect the rights, safety, systems, property, or lawful interests of a borrower, JGRS, or another person
To resolve disputes or enforce agreements
In connection with a lawful merger, acquisition, reorganization, financing, or transfer of business records
Any successor receiving protected information in connection with a lawful transfer must remain subject to applicable privacy, confidentiality, security, and record-retention obligations.
3.5 Authorized Agents and Powers of Attorney
Application information and supporting documentation may be disclosed to an agent specifically appointed by the borrower under a valid and effective power of attorney after applicable identity, authority, and acceptance requirements are satisfied.
An accepted agent receives only the access reasonably necessary to exercise the accepted authority. The agent must not use the borrower’s portal credentials. Any electronic access must use a separately verified identity and an access method approved by JGRS and, when applicable, the selected lender.
4. Affiliates and Nonaffiliated Third Parties
JGRS does not share nonpublic personal information with affiliates or nonaffiliated third parties for their independent marketing.
We do not provide borrower information to real estate agents, insurance agents, financial-service providers, marketing companies, referral partners, or other parties so they may independently advertise or market products or services to the borrower.
We may disclose information to nonaffiliated parties that perform services necessary to process, administer, protect, document, or complete a requested mortgage transaction. They may use the information only for their assigned function or as otherwise permitted or required by law.
5. No Sale of Personal Information or Consent Data
JGRS does not sell, rent, exchange, or provide personal information, nonpublic personal information, borrower lists, mortgage applications, supporting documents, leads, client contact information, mobile telephone numbers, or SMS opt-in and consent data in exchange for payment or other value for an unrelated party’s independent marketing.
Compensation paid to JGRS for mortgage-origination or mortgage-brokerage services is compensation for arranging or facilitating the borrower-authorized mortgage transaction. It is not payment for the sale of personal information.
JGRS does not disclose account numbers or similar access information to nonaffiliated third parties for marketing use.
6. Information-Sharing Choices
JGRS does not currently disclose nonpublic personal information to affiliates or nonaffiliated third parties for unrelated marketing purposes.
Information may be disclosed without an opt-out election when necessary to process or administer a consumer-requested transaction, when provided to a service provider performing an authorized function for us, when authorized by the borrower, or when otherwise permitted or required by law.
If our practices change in a manner that gives a consumer a legal right to opt out, we will provide the required notice and instructions before beginning the new practice.
7. Former Customers
We protect personal and nonpublic personal information concerning former customers in accordance with this Policy, except as permitted or required by law.
8. Information Security
We maintain administrative, technical, and physical safeguards designed to protect personal and nonpublic personal information against unauthorized access, use, alteration, disclosure, or destruction. Safeguards may include access controls, authentication, user permissions, confidentiality restrictions, vendor oversight, contractual controls, backup and recovery, monitoring and logging, security testing, incident response, and secure document-handling and disposal procedures.
No method of transmission or storage can be guaranteed to be completely secure.
Clients should use The Private Client’s secure ARIVE borrower portal for sensitive documents. Clients should not send Social Security numbers, tax returns, bank statements, identification documents, or similar sensitive information through ordinary email or text message.
If a security incident involving personal information occurs, JGRS will investigate and provide notifications as required by applicable law.
9. Retention and Disposal
We retain information for as long as reasonably necessary to:
Process or complete a requested mortgage transaction
Provide authorized ongoing or post-closing services
Maintain business, licensing, compliance, audit, and transaction records
Resolve disputes or enforce agreements
Satisfy legal, regulatory, examination, reporting, and record-retention requirements
Preserve information relevant to litigation, investigations, or audits
When information is no longer required, it is disposed of using methods appropriate to its sensitivity and applicable legal requirements.
10. Website Technologies and External Services
Our website and service providers may use cookies or similar technologies necessary for website operation, security, user preferences, performance, and analytics. Browser settings may permit users to limit certain cookies, although doing so may affect website or borrower-portal functionality.
Our website or borrower portal may contain links to services operated by other organizations. Their privacy practices are governed by their own notices, policies, and terms.
We do not place advertising trackers on secure application pages for the purpose of creating or selling borrower marketing profiles.
11. Relationship and Transaction Communications
JGRS may contact an individual in response to an inquiry or concerning an existing or requested mortgage relationship or transaction. Communications may concern:
Application receipt, information, or status
Requested documents or verification
Appointments and deadlines
Product or pricing information requested by the individual
Disclosures, consent requests, and electronic signatures
Processing, underwriting, appraisal, title, insurance, closing, or funding matters
Security, fraud prevention, privacy, or account administration
Legal, regulatory, record-retention, or post-closing matters directly related to the transaction
JGRS may communicate through the secure portal, email, telephone, postal mail, or text message as authorized and appropriate. A transaction-related communication is not an advertisement, loan solicitation, purchased-lead communication, or permission for unrelated marketing.
12. SMS Communications and Mobile Information
The Private Client sends only first-party, non-promotional, transaction-related text messages under the consent described in this section. We do not use this consent to send loan advertisements, rate promotions, invitations to apply, purchased-lead messages, third-party loan solicitations, or unrelated marketing.
Consumers initiate a mortgage inquiry or application directly with The Private Client through our authorized secure ARIVE borrower portal. During that process, a consumer may provide a mobile telephone number and affirmatively select an optional, unchecked SMS-consent box. Consent is not a condition of applying for or receiving mortgage services.
After affirmative consent, The Private Client may send text messages concerning the consumer’s mortgage inquiry or application, including application-receipt confirmations, appointment reminders, document or electronic-signature requests, secure borrower-portal activity notifications, application-status updates, and responses to borrower support questions.
Message frequency varies with borrower activity. Message and data rates may apply. Reply STOP to opt out or HELP for assistance. A request to stop text messages will be honored, although necessary communications may continue through another lawful channel.
The Private Client does not share, sell, rent, or provide mobile telephone numbers or SMS opt-in and consent data to third parties or affiliates for their marketing or promotional purposes. Information may be provided to communications and technology service providers only as necessary to operate and deliver the messaging service, subject to restrictions against independent marketing or promotional use.
Initial SMS consent may be collected through The Private Client’s Request Mortgage Guidance form or through the borrower-facing ARIVE web form. In either process, the consumer may provide a mobile telephone number and affirmatively select an unchecked SMS-consent box. Consent is not a condition of applying for or receiving mortgage services.
13. Electronic-Communication Choices
Consent to electronic communications may be withdrawn as described in the applicable electronic-consent terms. Withdrawal may require JGRS to use another permitted communication method and may delay electronic processing.
Consent to receive transaction-related SMS messages is separate from any consent to receive optional informational or promotional communications. Declining or withdrawing SMS consent will not affect the availability or terms of mortgage services.
Any optional informational or promotional communication program will require a separate, voluntary, clearly identified opt-in and will not use the transactional SMS consent described in this Policy.
14. Children’s Information
Our mortgage services are not directed to individuals under 18. We do not knowingly solicit mortgage applications or personal information from children.
15. Access, Correction, and Communication Preferences
Individuals may contact us to request access to or correction of personal information maintained by JGRS, or to communicate privacy and communication preferences. We may verify identity before responding. Certain information may be retained or withheld when permitted or required by law.
Credit-report information and disputes may be subject to separate procedures under federal law and may need to be directed to the applicable credit-reporting agency.
16. Changes to This Policy
We may revise this Policy to reflect changes in our practices, services, technology, vendors, or legal obligations. The updated Policy will be posted with a revised effective date. Material changes will be communicated when required by law.
JGRS will review and revise this Policy before beginning any materially different information-sharing, data-use, or marketing practice.
17. Contact Information
Questions, privacy requests, correction requests, communication preferences, or concerns may be directed to:
J.G. Romack and Sons Inc.
Trade name: The Private Client
1519 Amelia Circle
Fernandina Beach, Florida 32034
Email: jgromack@jgromackandsons.com
Telephone: (904) 321-7104
Company NMLS: 2688731
Florida Mortgage Broker License: MBR7770
