Privacy Policy

This Privacy Notice ("Notice") describes how VergeTitle Agency, LLC and its subsidiaries and affiliates (collectively, "VergeTitle," "we," "us," or "our") collect, use, store, sell or share your personal information when: (1) you access or use our websites, mobile applications, web-based applications, or other digital platforms where this Notice is posted ("Sites"); (2) you use our products and services ("Services"); (3) you communicate with us in any manner, including by e-mail, in-person, telephone, or other communication method ("Communications"); (4) we obtain your information from third parties, including service providers, business partners, and governmental departments and agencies ("Third Parties"); and (5) you interact with us to conduct business dealings, such as the personal information we obtain from business partners and service providers and contractors who provide us certain business services ("B2B"). Personal information is sometimes also referred to as personal data, personally identifiable information or other like terms to mean any information that directly or indirectly identifies you or is reasonably capable of being associated with you or your household. However, certain types of information are not personal information and thus, not within the scope of our Notice, such as: (1) publicly available information; and (2) de-identified and aggregated data that is not capable of identifying you. If we use de-identified or aggregated data, we commit to maintain and use the information in a non-identifiable form and not attempt to reidentify the information, unless required or permitted by law.

This Notice applies wherever it is posted. To the extent a VergeTitle subsidiary or affiliate has different privacy practices, such entity shall have their own privacy statement posted as applicable.

Depending upon how you interact with our Sites and Services, the nature of your Communications, and the nature of our interaction with Third Parties, we may collect the following information from and about you:

• including but not limited to your unique online identifier, name, alias, social media handle, IP address, username and password, postal and/or e-mail address, phone number, account name and/or account number, social security number, driver's license number, passport number, and/or state identification number.
• Related identifiers, including but not limited to your date of birth, bank, credit, or debit card number, financial information, and/or insurance policy number.
• Physical characteristics, including protected characteristics under federal and state law, such as age, sex, race, and ethnicity.
• Commercial information, including records of products or services purchased, obtained, or considered, and other purchasing and consuming histories and tendencies.
• Biometric information, such as fingerprints.
• Internet or other electronic network activity information, with our Sites and in Communications, including browser type and version, browser settings, operating systems and platform, device type, operating information, mobile carrier, page response time and download errors.
• Geolocation data, such as your zip code and time zone.
• Audio, electronic, visual, and thermal information, including telephone recordings, electronic communication records, and security camera footage from applicable VergeTitle properties, and temperature reading.
• Professional or employment-related information, such as your work history, salary history, and education history.
• Inferences drawn from other information, such as profiles created about you that reflect on your preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and/or aptitude.

We collect your personal information in three ways:

• Directly from you when you access or use our Sites or Services, conduct business dealings with us in the B2B context or when you communicate with us in any manner, including but not limited to:
• • Personal information you provide by filling out forms in person or electronically through our Sites, including information provided at the time of registering for any Service or event, posting material, or requesting further services or information;
  • Personal information you provide when you access or use our Services;
  • Personal information you provide when you conduct B2B dealings with us;
  • Personal information you provide when you enter a sweepstakes, contest or promotion sponsored or offered by us;
  • Personal information you provide when you report a problem with our Sites;
  • Records and copies of your correspondence (e.g., email address) if you contact us;
  • Your responses to surveys that we might ask you to complete;
  • Details of transactions you carry out through our Sites, and the fulfillment of your orders; and
  • Your search queries on the Sites.
• Automatically when you access or use our Sites or Services, conduct business dealings or when you communicate with us, including but not limited to:
• • Details of your visits to the Sites, including traffic data, location data, logs and other communication data;
  • Information about your computer and mobile device, and internet connection, including your IP address, operating system, and browser type; and
  • Interactivity with an e-mail, including opening, navigating, and click-through information.
• From Third Parties, including but not limited to:
• • Data analytics providers for the purpose of receiving statistical data about your activity on our Sites;
  • Social media networks for the purpose of collecting certain of your social media profile information and activity, including your screen names, profile picture, contact information, contact list, and the profile pictures of your contacts, through the social media platform;
  • Service providers, including but not limited to internet service providers, fraud prevention services, and related partners; and
  • Public sources, including local, state, and federal government agencies and departments, to facilitate your use of the Sites, and to provide you with our Services.

We use the personal information outlined in What Type of Information Do We Collect About You for a variety of business and commercial purposes, including but not limited to:

• Provide the Sites to you;
• Provide the Services you have requested;
• Conduct business dealings with you;
• Fulfill a transaction you requested or service your policy;
• Handle a claim;
• Create and manage your account between VergeTitle and you or any other Third Party;
• Operate the Sites, including access management, payment processing, Site administration, internal operations, troubleshooting, data analysis, testing, research, and for statistical purposes;
• Respond to your requests, feedback, or inquiries;
• Comply with laws, regulations, and other legal requirements;
• Comply with relevant industry standards and our policies;
• Protect and enforce your rights and the rights of other users against unlawful activity, including identity theft and fraud;
• Protect and enforce our collective rights arising under any agreements entered between VergeTitle and you or any other Third Party;
• Protect the integrity and maintain security of our Sites and Services;
• Operate, evaluate, and improve our business;
• Provide you with information and advertisements about products, services, and promotions, from us or affiliates, that may interest you;
• Deliver content tailored to your interests and the way you use the Sites;
• Present content in a manner that is optimized for your device; and
• Measure and analyze the effectiveness of the Sites and Services we provide to you.

Please note, SMS opt-in consent or phone numbers collected for SMS purposes will NOT be shared with third parties or affiliates for marketing purposes.

We may disclose personal information referenced in What Type of Information Do We Collect About You to others for a variety of business and commercial purposes, including:

• With your consent. We may disclose your personal information with your consent. We may obtain your consent in writing; online, through "click-through" agreements; when you accept the terms of use on our Sites; orally, either in person or on the phone; or by other means.
• In a business transfer. We may disclose your personal information as part of a corporate business transaction, such as a merger or acquisition, joint venture, corporate reorganization, financing, or sale of company assets, or in the unlikely event of insolvency, bankruptcy, or receivership, in which such information could be transferred to Third Parties as a business asset in the transaction.
• To non-affiliated third parties, such as service providers and contractors. We may disclose your personal information with other parties, such as service providers and contractors, to facilitate your access and use of our Sites and Services, including but not limited to internet service providers, advertising networks, data analytics providers, governmental entities, operating systems and platforms, social media networks, and service providers who provide us a service (e.g., credit / debit card processing, billing, shipping, repair, customer service, auditing, marketing, debugging to identify and repair errors that impair existing intended functionality on our Sites or Services, and/or protecting against malicious, deceptive, fraudulent, or illegal activity).
• To subsidiaries and affiliates. We may disclose your personal information with our VergeTitle subsidiaries and affiliates to further facilitate your use of our Sites and Services, and to ensure the smooth and consistent operations of VergeTitle by identifying and repairing errors that impede intended functionality and to protect against malicious, deceptive, fraudulent, or illegal activity.
• For legal process and protection. We may disclose your personal information to satisfy any law, regulation, legal process, governmental request, or where we have a good faith belief that access, use, preservation or disclosure of such information is reasonably necessary to:
• • Enforce or apply agreements, or initiate, render, bill, and collect for Services;
  • Protect our rights or interests, property or safety or that of others;
  • In connection with claims, disputes, or litigation in court or elsewhere;
  • Protect users of our Sites and Services and other carriers or providers from fraudulent, abusive, or unlawful use of, or subscription to, such services; and
  • Facilitate or verify the appropriate calculation of taxes, fees, or other obligations due to a local, state, or federal government.

Our Sites may contain links to Third Party websites and services. Please note that these links are provided for your convenience and information, and the websites and services may operate independently from us and have their own privacy policies or notices, which we strongly suggest you review. This Notice applies to our Sites only, and we do not accept any responsibility or liability for the policies or practices of any Third Parties.

We honor opt-out preference signals. An opt-out preference signal is a signal that is sent by a platform, technology or mechanism on your behalf that communicates your choice to opt-out of the sharing for targeted advertisements or sale of your personal information. You can learn more about implementing opt-out preference signals here or by exploring other developing technologies and services that offer this tool.

We treat opt-out preference signals as valid requests to opt-out of the sale or sharing of your personal information under privacy laws. Ordinarily, your opt-out preference signal is sufficient for us to honor your request, but in some instances, we may request additional information to help facilitate your request for offline sales or sharing. We will not use, disclose or retain this additional information for any purpose other than to facilitate the request.

Some browsers have incorporated "Do Not Track" features. Most of these features, when turned on, send a signal or preference to the websites you visit indicating that you do not wish to be tracked. Because there is not yet a common understanding of how to interpret the do not track signal, we currently do not respond to the browser do not track signals. However, as noted above, we do honor opt-out preference signals.

Our Sites and/or Services may, from time to time, contain links to and from social media platforms. You may choose to connect to us through a social media platform, such as Facebook or Twitter. When you do, we may collect additional information from or about you, such as your screen names, profile picture, contact information, contact list, and the profile pictures of your contacts, through the social media platform. Please be advised that social media platforms may also collect information from you. We do not have control over the collection, use and sharing practices of social media platforms. We therefore encourage you to review their usage and disclosure policies and practices, including their data security practices, before using the social media platforms.

Although no system can guarantee the complete security of your personal information, we take all commercially reasonable steps to ensure your personal information is protected in alignment with all applicable laws and regulations, as appropriate to the sensitivity of your personal information.

We keep your personal information for as long as necessary in accordance with the purpose for which it was collected, our business needs, and/or our legal and regulatory obligations. If we dispose of your information, we will do so in a way that is secure and appropriate to the nature of the information subject to disposal.

We may use browser cookies, beacons, pixel tags, scripts, and other similar technologies from time to time to support the functionality of our Sites and Services. A cookie is a piece of information contained in a very small text file that is stored in your Internet browser or elsewhere on your hard drive. Cookies are transferred from our Sites to your computer, phone or tablet, and allow us to identify your device whenever you return to our Sites. These technologies provide a better experience when you use our Sites and Services, and allow us to improve our services. We may also use analytic software, such as Google Analytics and others, to help better understand how our Sites function on your device(s) and for other analytical purposes. To learn more about how Google uses data when you use our Sites, see How Google uses data when you use our partners' sites or apps (opens in a new tab/window). You can opt-out of Google Analytics by installing Google's opt-out browser add-on here https://tools.google.com/dlpage/gaoptout (opens in a new tab/window).

Below is an overview of the types of cookies and related technology we deploy, and your choices.

• Browser Cookies. A browser cookie is a small file placed on the hard drive of your computer. That cookie then communicates with servers, ours or those of other companies that we authorize to collect data for us and allows recognition of your personal computer. You may use the tools available on your computer or other device(s) to set your browser to refuse or disable all or some browser cookies, or to alert you when cookies are being set. However, if you refuse or disable all browser cookies, you may be unable to access certain parts or use certain features or functionality of our Sites. Unless you have adjusted your browser settings so that it refuses all cookies, we may use cookies when you direct your browser to our Sites.
• Beacons. Our Sites and e-mails may contain small electronic files known as beacons (also referred to as web beacons, clear GIFs, pixel tags and single-pixel GIFs) that permit us to, for example, to count users who have visited those pages or opened an e-mail and for other website-related statistics. Beacons in e-mail marketing campaigns allow us to track your responses and your interests in our content, offerings and web pages. You may use the tools in your device to disable these technologies as well.
• Third Party Technology. Our service providers, advertising partners, and ad networks may also use cookies and beacons to collect and share information about your activities both on our Sites and on other websites and applications. In addition, third parties that are unaffiliated with us may also collect information about you, including tracking your Browse history, when you use our Sites. We do not have control over these third-party collection practices. If you wish to minimize these third-party collections, you can adjust the settings of your browsers or install plug-ins and add-ins.
• Your Choices. You may wish to restrict the use of cookies or completely prevent them from being set. Most browsers provide for ways to control cookie behavior, such as the length of time they are stored. If you disable cookies, please be aware that some of the features of our Sites may not function correctly. To find out more on how to manage and delete cookies, visit www.aboutcookies.org. For more details on your choices regarding use of your web Browse activity for interest-based advertising, you may visit the following sites:
• • http://networkadvertising.org/
  • http://optout.aboutads.info/
  • http://youradchoices.com/

We provide you the ability to exercise certain controls and choices regarding our collection, use, storage, and disclosure of your personal information.

• Right of Correction. Regardless of where you live, you may submit a request that we correct or update the information we have about you.
• Right to Change Preferences. Regardless of where you live, you may change your choices for subscriptions, newsletters, and alerts.
• Right to Control Advertising and Online Tracking. Regardless of where you live, you have a right to control how your personal information is tracked online. To learn more about these rights, see Cookies and Related Technologies.
• Right of Non-Discrimination. Regardless of where you live, you have a right to exercise your rights under this section free of discrimination. VergeTitle will not discriminate against you in any way if you choose to exercise your rights under this section.

Our Sites and Services are not intended for children under the age of 18. This includes any links to other websites that we provide for our convenience. We do not knowingly collect the personal information of children for any reason.

Our Sites and Services are hosted and offered in the United States of America (US), and are subject to US federal, state, and local law. If you are accessing the Sites or Services from another country, please be advised that you may be transferring your information to us in the US, and you consent to that transfer and use of your personal information in accordance with this Notice. You also agree to abide by the applicable laws of applicable US federal, state, and local laws concerning your use of the Sites and Services, and your agreements with us. Any persons accessing our Sites or Services from any jurisdiction with laws or regulations governing the use of the Internet, including the collection, use, or disclosure of information, different from those of the jurisdictions mentioned above may only use the Sites or Services in a manner lawful in their jurisdiction. If your use of the Sites or Services would be unlawful in your jurisdiction, you may not use the Sites or Services.

We are committed to making our content accessible and user friendly to everyone. To request a copy of this Notice in an alternative format, please contact us at info@vergetitleagency.com.

We may change this Notice from time to time. Any and all changes will be reflected on this page, and where appropriate provided in person or by another electronic method. The effective date will be stated at the top of this Notice. You should regularly check this page for any changes to this Notice.

YOUR CONTINUED USE, ACCESS, OR INTERACTION WITH THE SITES OR SERVICES, OR YOUR CONTINUED COMMUNICATIONS WITH US AFTER THE UPDATED NOTICE HAS BEEN POSTED WILL REPRESENT THAT YOU HAVE READ AND UNDERSTOOD THIS NOTICE.

If you have any questions, please contact us at info@vergetitleagency.com or by calling (646) 225-9570.