Effective date: July 7, 2020
If you are a California resident, please see our Notice at Collection for California Residents.
- What Information Does Blend Title Collect?
We collect information in multiple ways, including when you provide information directly to us, and when we passively collect information from you, such as from your browser or device(s) you use to access our Website. We may also, with your prior consent, collect information when you use the Blend Platform.(A) Categories of InformationAs described further below and depending on what products/services you use and how you use the Service and interact with us, we may collect the following categories of information about you or your use of the Service:
- Identifiers (such as name and email address);
- Commercial information (such as transaction data);
- Internet or other network or device activity (such as browsing history and log data);
- Location information (such as general location information inferred from an IP address);
- Sensory information (such as audio or visual information);
- Insurance information;
- Financial data (such as loan amount);
- Inference data about you (such as profiles we develop based on how you use the Service); and
- Other information that identifies or can be reasonably associated with you.
(B) Categories of Sources of Information
(i) Information You Provide to Us
We may collect information from you during your use of or access to the Service and/or the Blend Platform, such as when you:
- Register for a Blend Platform account in connection with your mortgage or other loan application;
- Apply for a mortgage or other loan through the Blend Platform;
- Request a quote and/or apply for title insurance through the Service;
- Grant us access to information from your Blend Platform account, such as property type and personal information;
- Communicate with us;
- Request or change policy endorsements or coverages;
- Respond to surveys and customer service engagements.
(ii) Information Collected Automatically
Device/Usage Information: We may automatically collect certain information about the computer or device(s) (including mobile devices or tablets) you use to access the Service. As described further below, we may collect and analyze information such as (a) IP addresses (including city and state information), unique device identifiers, IMEI and TCP/IP addresses, and other information about your computer or device(s), browser types, browser language, operating system, mobile device carrier information, and the state or country from which you accessed the Service; and (b) information related to the ways in which you interact with the Service, such as: referring and exit web pages and URLs, platform type, the 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, the amount of time spent on particular pages, the date and time you used the Service, the 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 through the use of internet server logs, cookies, tracking pixels or other data collection and tracking technologies. A web 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 to: (i) recognize your computer; (ii) store your preferences and settings; (iii) understand the web pages of the Service you have visited; (iv), enhance your user experience by delivering content specific to your interests; (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 do this to improve the Service, or to improve marketing, analytics, or Service functionality. However, we do not collect personal data about your activities across third-party sites or services, nor do we control the privacy practices of third parties, which may be governed by separate privacy policies. Simultaneously, tags and Cookies help us with our advertising and promotional activities (only in an aggregate, anonymous and non-personally-identifiable fashion and which does not reveal your name, address, telephone number or e-mail address). We may update this Policy from time to time as we adopt new technologies to gather additional information through other methods, and your continued use of the Service indicates your understanding and acceptance of our use of these new technologies. Please keep in mind that certain features on our site may not function properly if you do not permit cookies.
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 for more information (e.g., Internet Explorer; Google Chrome; Mozilla Firefox; or Apple Safari). Please note that by blocking any or all cookies, you may not have access to certain features or offerings of the Website.
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 those of Blend Title. If you submit personal information to any of those websites, your information is governed by their privacy statements. We encourage you to carefully read the privacy statement or terms of cookie usage of any website you visit.
(iii) Information from Third Parties
We may also obtain information about you from third parties such as third parties that provide products or services related to the Service.
- How Will Blend Title Use My Information?Blend Title may use the information we collect from and about you for the following business purposes (as defined by applicable law) and commercial purposes:
- To process and fulfill a transaction that you initiate or to provide products or services through or in connection with the Service;
- To issue a title insurance policy;
- To send you information about your Service-related activities;
- To contact you with information or surveys regarding the Service;
- To process and respond to your inquiries or to request your feedback;
- For internal research and reporting;
- For account creation and maintenance;
- To promote customer reviews and testimonials in marketing and advertising material;
- To improve the content and features of the Service or develop new products or services;
- To personalize the content that you see on the Service (see “Personalize Content” section below);
- To process payments and billing and transactional matters;
- To prevent fraud and abuse of the Service;
- To enforce the legal terms that govern your use of the Service; and
- To administer and troubleshoot the Service.
We may also aggregate and/or de-identify the information we collect. We may use aggregated and/or de-identified information for improving the Service and developing business analytics and may also share such information and analytics with third parties. However, we never disclose aggregate or de-identified information to anyone in a manner that would identify you personally, as an individual.
- How Does Blend Title Personalize Content to My Interests?Online and Email Analytics
We may use third-party web analytics services in conjunction with providing the Service, such 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, provide certain features to you, improve and develop the Service, monitor and analyze use of the Service, aid our technical administration, and verify that users have the authorization needed for us to process their requests.To prevent Google Analytics or a third-party 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 opt-out cookies, and you will need to re-visit the relevant opt-out page.If you receive email 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. This information helps us make our communications with you more interesting and improve our Website.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 Website for third-party purposes, and that is why we provide choices provided by Google Analytics. However, we do not currently recognize or respond to browser-initiated DNT signals. Learn more about Do Not Track.
- How Will Blend Title Share My Information?We may share the categories of information identified above with the following categories of third parties as described in this section.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, customer support, fulfillment, wire transmission, data storage, 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 the Underwriter. 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 and every 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 within the Blend Title corporate family. 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. By using the Service, you acknowledge, consent, and agree that 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 (e.g., a subpoena, court order, or warrant); (b) enforce our Terms of Service, this Policy, or other contracts with you, including investigation of potential violations thereof; (c) respond to claims that any content violates the rights of third-parties; (d) respond to your requests for customer service; and/or (e) protect the rights, property, or personal safety of Blend Title, its agents and affiliates, and/or its users and/or the public. This includes exchanging information with other companies and organizations for fraud protection, spam/malware prevention, and similar purposes.
Business Transfers. As we continue to develop our business, we may buy or merge with other companies. In such transactions (including in contemplation of such transactions, e.g., due diligence), user information may be among the transferred assets. If a portion or all of Blend Title’s assets are sold or transferred to a third-party pursuant to a corporate purchase, sale, or merger, customer information may be one of the transferred business assets.
- 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 and anonymized form. We restrict access to your information to our employees and others who we feel must use it to provide our products and services. Their use of your information is limited by law and written agreements where appropriate. We also maintain physical, electronic and procedural safeguards to protect your information. 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.We recommend that you change your passwords periodically, including on the Blend Platform and, if applicable, through the Service. You are responsible for maintaining the security of your account username and password. If you believe that your account username and/or password have been stolen or been made known to others, it is your responsibility to immediately contact Blend Title at firstname.lastname@example.org and, if applicable, change your password. We are not responsible if someone else accesses your account through information they have obtained from you.
- What Rights Do I Have?
Email Communications. 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 email 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.
Updating and Deleting Your Information (Non-California Residents). You may be able to add, update, or delete certain information through the Service. When you update information, however, we may maintain a copy of the unrevised information in our records for legal compliance purposes. We retain information for as long as needed to provide the Service. We may also retain some of the information for reasons including, but not limited to, compliance with applicable regulations, resolving disputes, and enforcing our agreements. We may also continue to use any aggregated or de-identified information for improving the Service and developing business analytics, but not in a manner that would identify you personally.Nevada Residents. Under Nevada law, certain Nevada consumers may opt out of the sale of “personally identifiable information” for monetary consideration to a person for that person to license or sell such information to additional persons. “Personally identifiable information” includes first and last name, address, email address, phone number, Social Security Number, or an identifier that allows a specific person to be contacted either physically or online. We do not engage in such activity; however, if you are a Nevada resident who has purchased or leased goods or services from us, you may submit a request to opt out of any potential future sales under Nevada law by emailing us at firstname.lastname@example.org. Please note we will take reasonable steps to verify your identity and the authenticity of the request. Once verified, we will maintain your request in the event our practices change.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 policy in compliance with the California Consumer Privacy Act of 2018 (“CCPA”) and other applicable California privacy laws. Any terms used in this Notice that are not defined in the Notice itself have the same definition as used in the CCPA and its implementing regulations.
Notice at Collection for California Residents
(i) What Information We Collect: We collect the categories of information disclosed above in the “What Information Does Blend Title Collect” section of the Policy. The exact information we collect about you depends on what products/services you use and how you use our Website and interact with us. We base the information in this disclosure on our data collection practices over the previous 12 months until present time.
(ii) How We Use Your Information: We use your information for the business or commercial purposes described above in the “How Will Blend Title Use My Information” section of the Policy. Exactly how we use your information depends on what products/services you use and how you use our Website and interact with us. We base the information in this disclosure on our data collection practices over the previous 12 months until present time.
(iii) Blend Title does not “sell” your personal information as defined by the California Consumer Privacy Act and its implementing regulations.
Right to Know: California law provides California consumers with the right to request that certain covered businesses provide you (i) the categories of personal information we collect, use, disclose or sell about you; (ii) the categories of sources of such information; (iii) the business or commercial purpose for collecting or selling your personal information (as applicable); (iv) the categories of personal information we sell or have sold or disclosed for a business purpose about the consumer and the categories of third parties to whom we’ve disclosed your personal information and, (v) specific pieces of personal information that a business has collected about the consumer. This “Right to Know” is subject to certain exceptions, and we may refuse to disclose the information requested under one or many of these exceptions.
Right to Delete: California law provides California consumers with the right to request that certain covered businesses delete personal information that they have collected from you. This “Right to Delete” is subject to certain exceptions. Furthermore, Blend Title is not required to respond to requests for the Right to Know from users acting as an employee, owner, director, officer, or contractor of another entity or within the context of another entity in conducting due diligence regarding, or providing or receiving a product or service to or from such company. Please note, we need certain types of information so that we can provide the services to you. If you request deletion of your information and we are required to delete your information, you may no longer be able to access or use the services we provide.
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 we understand that term to be defined by the California Consumer Privacy Act and its implementing regulations. In addition, Blend Title does not have actual knowledge that it sells the personal information of minors under 16 years of age.
Authorized Agent: 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):
i. Provide the authorized agent signed permission to do so.
ii. Verify their own identity directly with the business.
iii. 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/.
Financial Incentives: We do not offer financial incentives for the collection of your data. If this changes, we will notify you prior to doing so, and we will obtain your consent to opt-in to this program before enrolling you.
Non-discrimination Rights: You also have the right to not be discriminated against for exercising certain of your rights under the CCPA. If you exercise your rights under the CCPA, we will not:
i. Deny you goods or services.
ii. Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.
iii. Provide you a different level or quality of goods or services.
iv. Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.
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 requests to access or delete data.
Contact us: If 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.
- 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 18 or age of majority in their jurisdiction. If you are under 18 or age of majority in your jurisdiction, please do not attempt to register for the Service or send any personal information about yourself to us. If we learn that we have collected Personal Information for anyone under the age of 18 or age of majority in their jurisdiction, we will delete that information as quickly as possible. If you believe that anyone under the age of 18 or age of majority in their jurisdiction may have provided us Personal Information, please contact email@example.com.IF YOU ARE UNDER THE AGE OF 18 OR AGE OF MAJORITY, YOU MAY NOT USE OR ACCESS THE SERVICE OFFERED BY BLEND TITLE.
- Will Blend Title Change This Policy?We reserve the right to change this Policy at any time to reflect changes in the law, our data collection and use practices, the features of the Service, or advances in technology. Please check this page periodically for changes. Your continued use of the Service following the posting of changes to this Policy will mean you accept those changes.
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