Privacy Notice

Effective date: January 1, 2023

If you are a California resident, please see our Notice at Collection for California Residents

This Privacy Policy (“Policy”) applies to the applications, products, services, customer service, and platform (referred to collectively as the “Service”) owned, operated, and provided by Blend Title Insurance Agency, Inc., Title365 Company, and their affiliates (collectively referred to as “Blend Title”, “we”, “our”, or “us”). Further, Blend Title is an affiliate of but separate entity from Blend Labs, Inc. (“Blend”) where you may have previously used Blend products, services, and platform to apply for a mortgage or other loan (referred to collectively as the “Blend Platform”). The Service facilitates the process of collecting and providing your information to title insurance underwriters (“Underwriters”) for the purposes of providing you with quotes and issuing title insurance policies. For purposes of this Policy, “you” and “your” mean the Service account creator, authorized signer, authorized representative, delegate, and/or other authorized Service users. This Policy describes and governs the information collection, use, and disclosure practices of Blend Title with respect to the Service.

Before you use or submit any information on or through the Service, please carefully review this Policy. IF YOU DO NOT AGREE TO THIS PRIVACY POLICY, PLEASE DO NOT USE THE SERVICE. By using any part of the Service, you consent to the collection, use, and disclosure of the information you provide as further outlined in this Policy.

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 (such as insurance policy data and evidence of insurance);
• Internet or other network or device activity (such as browsing history and log data); 
• Geolocation information (such as general location information inferred from an IP address); 
• Inference data about you; 
• Sensitive personal information (such as social security, driver’s license, state identification card and passport numbers; and Third-Party Account Credentials, as defined in Section 4 below); 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

Blend Title  may also obtain information about you from third parties such as other financial institutions with which you have a relationship, third-party data provider partners (see below), and credit reporting agencies, among others. These third parties provide data, products, and services that enable us to provide the services you have requested through 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 disclose 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. 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 at All About Do Not Track.

3. How Will Blend Title Disclose My Information?

We may disclose your information to the following categories of parties as described in this section. We base the information in this section on our data disclosure 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 disclose this information to underwriters to issue a policy to you. We may disclose the information you provide to, 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 disclose your information to select service providers and third parties who perform services on our behalf to facilitate and expand 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 disclose information to service providers and third parties as necessary to effect, administer, or enforce a transaction that you request or authorize. These service providers are only permitted to use your personal information in order to perform services on our behalf or as permitted by law. 
• Affiliates and subsidiaries of Blend. With your authorization, we may disclose information we collect from and about you (and your device) to 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. With your consent, we may also 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, 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 disclose information to keep all personal information secure and confidential.

5. What Choices do I have?

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. 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. 

Any information that cannot be updated or edited through the Service will require you to contact us for further assistance. To submit a request please use the Data Request Form or call 866-602-9022. We may have a reason under the law why we do not have to comply with your request, or why we may comply with it in a more limited way than you anticipated. If we do, we will explain that to you in our response.

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"), as amended by the California Privacy Rights Act (“CPRA”), 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/CPRA and its implementing regulations.

What Information We Collect 

We collect the categories of information described above in the “What Information Does Blend Title Collect?” section of the Policy, and we collect that information from the categories of sources described above in “Categories of Sources of Information.” The exact information we collect about you, and the sources, depends on what products or services you use and how you use our Services and interact with us. We base the information in this disclosure on our data collection practices over the previous 12 months until present time. 

How We Use and Disclose 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, and we disclose your information to the categories of third parties described above in “How Will Blend Title Disclose My Information.” Exactly how we use and disclose your information depends on what products or services you use and how you use our Services and interact with us. We base the information in this disclosure on our data collection and disclosure practices over the previous 12 months until present time.

Right to Know

You have a right to know what personal information is being collected about you. This includes the following: the categories of personal information collected; the categories of sources of that information; the business or commercial purpose for collecting, selling, or sharing personal information; the categories of third parties to whom the business discloses personal information;  the specific pieces of personal information collected; and, to the extent applicable, the categories of personal information sold or shared (and to which categories of third parties) and the categories of personal information disclosed for a business purpose (and to which categories of persons). However, this “right to know” is subject to certain exceptions. Please see below under “Contact us” for information on how to submit an access request.

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.

Right to Correct 

You have a right to request correction of inaccurate information about you. However, this “right to correct” is subject to certain exceptions. Please see below under “Contact us” for information on how to submit a correction request.   

Right to Limit 

You have a right to limit the use or disclosure of sensitive personal information that is collected or processed with the purpose of inferring characteristics about you. However, this “right to limit” is subject to certain exceptions. Please see below under “Contact us” for information on how to submit a limit request.

While the CCPA/CPRA provides California consumers with the right to request that covered businesses limit the use and disclosure of sensitive personal information collected or processed with the purpose of inferring characteristics about them (subject to certain exceptions), Blend Title does not use or disclose sensitive personal information that is subject to the CCPA/CPRA for any purposes other than those specified in the CCPA/CPRA and its implementing regulations.

Blend Title Does Not Sell Your Data

While the CCPA/CPRA provides California consumers with the right to opt out of the “sale” or “sharing” of their personal information (subject to certain exceptions), Blend Title has not “sold” or “shared” consumer personal information or sensitive personal information in the preceding 12 months and does not “sell” or “share” your personal information or sensitive personal information, as those terms are defined under the CCPA/CPRA and its implementing regulations.

Authorized Agents

When a consumer uses an authorized agent to submit a request to know, correct or 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 the section titled “Contact us” further below.

Financial Incentives

Blend Title does not offer financial incentives for the collection of your data.

Right of No Retaliation 

You have the right to not be discriminated against for exercising your rights under the CCPA/CPRA.

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/CPRA requests to access, correct, limit or delete data.

Contact us

If you would like to exercise any of these rights, please use this Data Request Form or call  866-602-9022. 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.

7. What is Blend Title’s Responsibility for Third-Party Links?
The Service may contain links to or “from” 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. If you submit information to any of those websites, your information is governed by their privacy statements.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 privacy@blend.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. 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.

11. What if I have questions about this Privacy Policy?

If you have any questions or concerns regarding our Privacy Policy, please send us a detailed message to privacy@blend.com and we will try to resolve your concerns. 

Blend Title Insurance Agency, Inc.

41 Madison Ave, 31st Floor

New York, New York 10010