Effective date: December 8th, 2021
If you are a California resident, please see our Notice at Collection for California Residents in section 6 further below.
Before you use or submit any information on or through the Service, please carefully review this Policy. Blend Title will continue to evaluate this Policy as we update and expand the Service and our offerings, and we may make changes to the Policy accordingly. Any changes will be incorporated into this Policy and made available to view through the Service. Your continued use of the Service will signify acknowledgement of the terms of this Policy including any updates.
1. What Information Does Blend Title Collect?
(A) Categories of Information
We collect information directly from you, indirectly from you, third parties you authorize, or publicly available information. The extent of information Blend Title collects depends on the products and services sought. The information in this policy is based on our data collection practices over the previous 12 months until present time. The following is a list of information we may collect:
- Common identifiers (such as a real name, postal address, IP address, email address, social security number, or other similar identifiers);
- Commercial information (such as transactional data or records of personal property, or other purchasing or consuming histories or tendencies);
- Financial information (such as financial or credit history or loan amount);
- Insurance information;
- Internet or other network or device activity (such as browsing history and log data);
- Sensory or identity verification information (such as faceprints, scans of hand or face geometry, voiceprints, iris or retina scans, and/or pictures of your identification cards);
- Geolocation information (such as general location information inferred from an IP address);
- Inference data about you (such as profiles we develop based on how you use the Platform); and
- Other information that identifies or can be reasonably associated with you.
(B) Categories of sources of information
Blend Title collects information in multiple ways, including when you provide information directly to us, information that is collected indirectly from your browser or device, and when we obtain information from third parties as indicated in this Policy.
Information You Provide Directly to Us
We may collect information from you during your use of or access to the Service, such as when you register for a user account, communicate with us, or grant us access to your information through a third-party account or the Blend Platform. For example, we may collect information such as your email address, phone number, or current address. All such information we collect from you or in connection with the Service is covered by this Policy.
Information Collected Indirectly
Device/usage information: Blend Title may automatically collect certain information about the computer or devices (including mobile devices or tablets) you use to access the Service. We may collect and analyze information such as (a) IP addresses, unique device identifiers, unique personal identifiers, and other information about your computer or device(s), browser types, browser language, operating system, mobile device carrier information, and the location from which you accessed the Service; and (b) information related to the ways in which you interact with the Service, such as mouse movements and scrolling, referring and exit web pages and URLs, platform type, number of clicks, domain names, landing pages, pages and content viewed and the order of those pages, statistical information about the use of the Service, amount of time spent on particular pages, date and time you used the Service, frequency of your use of the Service, error logs, and other similar information. As described further below, we may use third-party analytics providers and technologies, including cookies and similar tools, to assist in collecting this information.
Cookies and Other Electronic Technologies: We may also collect data about your use of the Service using internet server logs, cookies, and/or tracking pixels. An internet server log is a file where website activity is stored. A cookie is a small text file that is placed on your computer when you visit a website that enables us only to: (i) recognize your computer; (ii) store your preferences and settings; (iii) understand the web pages of the Service you have visited; (iv) enable your user experience in the Service; (v) perform searches and analytics; and (vi) assist with security administrative functions. Some cookies are placed in your browser cache. Tracking pixels (sometimes referred to as web beacons or clear GIFs) are tiny electronic tags with a unique identifier that are embedded in websites, online ads, and/or email and are designed to provide usage information like page clicks, measure popularity of the Service and associated content, and access user cookies. We may update this Policy from time to time as we adopt new technologies to gather additional information through other methods.
Blocking cookies through your browser settings: Please note that you can change your settings to notify you when a cookie is being set or updated, or to block cookies altogether. Please consult the “Help” section of your browser (e.g., Microsoft Edge; Google Chrome; Mozilla Firefox; or Apple Safari) for more information. Please note that by blocking any or all cookies, you may not have access to certain features or offerings of the Service.
Please also note that our Service may include links to other websites, including those of underwriters whose quotes we provide to you, whose privacy practices may differ from Blend Title. If you submit information to any of those websites, your information is governed by their privacy statements. We encourage you to carefully read the privacy statement of any website you visit.
Information from Third Parties
We may obtain information about you from third parties such as other financial institutions, credit reporting agencies, or social networks you allow to be shared. We may also obtain information about you from third parties that provide products or services related to the Service.
2. How will Blend Title use my information
Blend Title may use the information we collect from and about you for the following purposes:
- To process and fulfill a transaction that you initiate or to provide products or services through or in connection with the Service, including:
- Issuing a title insurance policy;
- Account creation and maintenance;
- Verifying your identity;
- Sending you communications on your Service-related activities;
- Promoting customer reviews and testimonials in marketing and advertising material;
- Personalizing content that you see on the Service;
- Processing payments, billing, and transactional matters;
- Administering and troubleshooting the Service;
- Detecting security incidents, protecting against malicious, deceptive, fraudulent, or illegal activity, and prosecuting those responsible for that activity;
- Responding to legal requests and demands, as well as exercising and defending legal claims.
- For internal purposes to improve our services, including:
- Undertaking internal research, analytics, and reporting; and
- For development, such as to improve the content and features of the Service.
We may also work with non-affiliated companies or organizations to provide you with opportunities to buy products or services offered by us or jointly with other companies, including financial institutions. Blend Title may also collect, use, and share your information in an anonymized, aggregated, and de-identified form (that does not identify you personally) for our business purposes.
Online and Email Analytics: Blend Title may use third-party web analytics services, such as those of Google Analytics. These service providers use the sort of technology previously described in the “Cookies and Other Electronic Technologies” section to collect information (including your IP address) to help us analyze how users use the Service, including by noting the third-party website from which you arrive, improving and developing the Service, monitoring and analyzing use of the Service, aiding our technical administration, assisting in our troubleshooting and customer support efforts, and verifying that users have the authorization needed for us to process their requests. To prevent Google Analytics from using your information for analytics, you may install the Google Analytics Opt-out Browser Add-on by clicking here. If you get a new computer, install a new browser, erase or otherwise alter your browser’s cookie file (including upgrading certain browsers), you may clear the Google Analytics opt-out cookies, and you will need to re-visit the relevant opt-out page. If you receive email communication from us, we may use certain tools, such as clear GIFs, to capture data such as when you open our message or click on any links or banners our email contains.
Notice Concerning Do Not Track Signals: Do Not Track (“DNT”) is a privacy preference that users can set in certain web browsers. We are committed to providing you with meaningful choices about the information collected through the Service for third-party purposes, and that is why we provide choices provided by Google Analytics. However, we do not recognize or respond to browser initiated DNT signals, as the internet industry is currently still working toward defining exactly what “DNT” means, what it means to comply with DNT, and a common approach to responding to DNT. You can learn more about DNT by clicking here.
3. How will Blend Title share my information?
We may share your information with the following categories of parties as described in this section. We base the information in this disclosure on our data sharing practices over the previous 12 months until present time.
- Underwriters. We collect information for the purpose of providing you with quotes for title insurance policies, and to issue such policies on behalf of underwriters with whom we have a relationship. We share this information with underwriters to issue a policy to you. We may share the information you provide with, and/or make that information available to, underwriters and/or their successors-in-interest in order to facilitate that process.
- Service Providers and other third parties. We may provide access to or share your information with select third parties who perform services on our behalf to facilitate the operation and functionality of the Service. For example, we may use companies that assist with billing, consumer support, fulfillment, wire transmission, data storage, to mitigate fraud and verify your identity, analysis and processing, legal services, and other relevant operations including your other settlement services providers. We may also provide access to or share information with third parties as necessary to effect, administer, or enforce a transaction that you request or authorize. The Service may contain links to or “frame” third-party websites, applications, and other services available to support Service operations and functionality. By using the Service, you grant us the right to retrieve information from the relevant third-party on your behalf and transmit such information to an underwriter. We encourage our users to be aware when they access third-party websites and/or leave the Service to read the privacy statement of each site they visit that collects their information.
- Affiliates. We may share information we collect from and about you (and your device) with a parent, subsidiary or affiliate entity of our corporate family, to deliver products and services to you, ensure a consistent level of service across our products and services, establish your eligibility for consumer credit, insurance or deposit accounts not solely related to your transaction with us, and enhance our products, services, and the customer experience. Any organization to which we provide such information is required to keep your information confidential and to only use such information in accordance with this privacy statement.
- Consent. If we have your consent, we may disclose your information to any third party that provides products or services in support of the provision of the Service.
- Protection of Blend Title and others. We may access, preserve, and disclose your information, including but not limited to any user content, if required to do so by law or in a good faith belief that such access, preservation, or disclosure is reasonably necessary to: (a) comply with legal process; (b) enforce any agreements, including investigation of potential violations thereof; (c) respond to claims that any content violates the rights of third parties; and/or (d) protect the rights, property, or personal safety of Blend Title, its agents and affiliates, and/or its users and/or the public.
- Business transfers. As we continue to develop our business, we may buy or merge with other companies. In such transactions (including in contemplating of such transactions, e.g., due diligence), user information may be transferred to continue providing services through or in connection with the Service.
4. How does Blend Title secure my data?
We have implemented administrative, technical, and physical security measures to protect against the loss, misuse, and/or alteration of your information. These safeguards vary based on the sensitivity of the information that we collect and store. For example, we store usernames, passwords, PINs, and other log-in information in encrypted form. However, we cannot and do not guarantee that these measures will prevent every unauthorized attempt to access, use, or disclose your information because despite our efforts, no internet and/or other electronic transmissions can be completely secure. For your added protection, we also require non-affiliated companies with whom we share information to keep all personal information secure and confidential.
5. What choices do I have?
If you have provided contact information through the Service and decide that you do not want Blend Title to use that information for anything other than communications regarding your Service-related activities, you can opt-out of future use at any time by sending us an e mail at email@example.com. Please note that you will not be able to opt-out of emails about your Service-related activities, such as email alerts regarding your Service account, requests, or inquiries. Separately, you will be able to opt-out of marketing communications by clicking the “unsubscribe” link in the email.
You may be able to add, update, or edit certain information while using the Service. When you update information, however, we may maintain a copy of the unrevised information in our records to the extent necessary for legal compliance purposes and where permitted by applicable law. Any information that cannot be updated or edited through the Service will require you to contact us for further assistance. Additionally, to the extent applicable law affords you rights regarding personal information, such as access or deletion rights, please reach out to us to inquire about your data rights.
For example, federal law gives you the opportunity to limit the sharing of “non-experience information” among affiliates of Blend Title or limit an affiliates’ use of your information that we share with them. “Non-experience information” includes information that is used, expected to be used, or collected for the purpose of establishing your eligibility for consumer credit, insurance or deposit accounts, and is not related solely to your transactions or other experiences with us, including information from your applications, credit history, or sources used to verify representations made by you.
If you prefer that we not share non-experience information about you with an affiliate of Blend Title for marketing purposes, you may opt-out. That is, you may direct us not to share this information by making a written request to us at firstname.lastname@example.org.
6. Notice at Collection for California Residents.
This section of the Policy applies solely to those individuals who reside in the State of California (“consumers” or “you”). We are providing this section in compliance with the California Consumer Privacy Act of 2018 (“CCPA”) and other applicable California privacy laws. Any terms used in this section that are not defined in the Policy itself have the same definition as used in the CCPA and its implementing regulations.
Right to Know
You have a right to know what personal information is being collected about you. This includes the following: categories of personal information; categories of sources of such information; the business or commercial purpose for collecting, selling, or sharing personal information; and specific pieces of information collected. However, this “right to know” is subject to certain exceptions.
Right to Delete
You have a right to request deletion of personal information collected about you. However, this “right to delete” is subject to certain exceptions. Please note, we need certain types of information so that we can provide the Service. If you request deletion of your information and we are required to delete your information, you access or use of the Service may be impacted.
Blend Title does not sell your data
While the CCPA provides California residents with the right to opt out of the “sale” of their personal information, Blend Title has not “sold” consumer personal information in the preceding 12 months and does not “sell” your personal information, as that term is defined under the CCPA and its implementing regulations.
When a consumer uses an authorized agent to submit a request to know or a request to delete, a business may require that the consumer do the following (this does not apply when a consumer has provided the authorized agent with power of attorney pursuant to Probate Code sections 4000 to 4465):
Provide the authorized agent signed permission to do so.
Verify their own identity directly with the business.
Directly confirm with the business that they provided the authorized agent permission to submit the request.
A business may deny a request from an authorized agent that does not submit proof that they have been authorized by the consumer to act on their behalf. To make an authorized request on behalf of another pursuant to consumer rights provided by California Law, please visit https://title.blend.com/policies/personal-data-requests/.
Blend Title does not offer financial incentives for the collection of your data.
You also have the right to not be discriminated against for exercising certain of your rights under the CCPA.
How other data privacy laws may affect your ability to request access to, or delete, your data
Please note that your rights and choices regarding your personal information are often subject to other laws. Personal information collected pursuant to other laws, such as information governed by the Fair Credit Reporting Act, the Gramm-Leach-Bliley Act, and the California Financial Information Privacy Act, may be exempt from CCPA requests to access or delete data.
If you would like to exercise any of these rights, please submit a request at email@example.com or visit https://title.blend.com/policies/personal-data-requests/. You will be required to verify your identity before we fulfill your request. You can also designate an authorized agent to make a request on your behalf. To do so, you must provide us with written authorization or a power of attorney, signed by you, for the agent to act on your behalf. You will still need to verify your identity directly with us. If you have any questions regarding your rights under California law, you may reach out to us at firstname.lastname@example.org.
7. What is Blend Title’s Responsibility for Third-Party Links?
The Service may contain links to or “frame” third-party websites, applications, and other services available to support operations and functionality. Please be aware that we are not responsible for the privacy practices of such other sites and services. We encourage our users to be aware when they access third-party websites and/or leave the Service and to read the privacy statements of each site they visit that collects their information.
8. What is Blend Title’s policy on children?
We do not knowingly collect or solicit personal information (as defined by the “Children’s Online Privacy Protection Act”) from anyone under the age of 13. If you are under 13, please do not attempt to send any personal information about yourself to us. If we learn that we have collected personal information from a child under age 13, we will delete that information as quickly as possible. If you believe that a child under 13 may have provided us personal information, please contact email@example.com.
9. What is Blend Title’s policy on retaining information?
We keep your information in identifiable form for no longer than necessary to process and fulfill a transaction that you initiate or to provide products or services through or in connection with the Service. The length of time for which we retain information depends on the purposes for which we collect and use it and/or as required to comply with applicable laws. We may, if necessary, retain some of the information for compliance with applicable banking and lending regulations, fraud prevention and identity verification, resolving disputes, and enforcing our agreements. Blend Title may also continue to use any aggregated or de-identified information but not in a manner that would identify you personally.
10. What is Blend Title’s policy on retaining information?
Blend Title Insurance Agency, Inc.
1140 Broadway, Suite 800
New York, NY 10001