Solidifi Privacy Notice

Last Updated: April 6, 2023

Purpose of This Notice

At Solidifi we are committed to providing our clients with financial products and services to meet their needs. Our commitment includes protecting personally identifiable information we obtain about you. This Privacy Notice (“Notice”) describes how we collect, use, disclose and protect Personal Information (as defined below) that Solidifi U.S. Inc. and its U.S. subsidiaries, affiliates and divisions (“Solidifi,” “we,” “us,” or “our”) collect about you. This Notice applies to any party whom we receive Personal Information from or about, including, but not limited to our clients, our clients’ consumers, vendors and users of our website and our mobile applications (collectively, “Sites”) that display or link to this Notice. By using our Sites, you consent to the collection, use and disclosure of your Personal Information in compliance with this Notice and subject to the applicable state and federal laws of the United States.

Privacy for Other Websites

Our Sites may contain links to the websites of non-affiliated companies. Solidifi is not, however, responsible for the privacy practices or the content of these websites. We recommend that you review the privacy notice of each linked website that you visit.

Information We Collect

We collect information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked to a particular consumer or device (also known as “Personal Information”). In particular, we may receive and/or obtain the following types of Personal Information: (i) contact information such as name, address, phone number, email address; (ii) demographic information such as date of birth, gender, marital status; (iii) government ID numbers such as social security number, driver’s license, passport; (iv) financial account information; (v) geolocation data (solely from certain third-party service providers with whom consumers directly interact with); (vi) responses to any surveys you complete in relation to or regarding your experience with our products or services; and/or (vii) any other information collected in the ordinary course of business in order to provide our products and/or services.

Collecting Personal Information is necessary for performance of the services and functionalities offered on the Sites. If you decline to provide the requested Personal Information, we may not be able to provide the requested products or services or process your inquiry or other requests.

We also collect browsing information from your Internet browser, computer, and/or mobile device if you visit or use our Sites, including, but not limited to, Internet Protocol (IP) address or device ID/UDID, protocol and sequence information, browser language and type, domain name system requests, browsing history (such as time spent at a domain, time and date of your visit and number of clicks), http headers, application client and service banners and operating system data (collectively, “Browsing Information”).

How Information is Collected

We obtain the types of Personal Information listed above from the following sources:

directly from you when you complete forms and applications in connection with the products and services we provide, use our products and services or otherwise interact with us and our Sites;

from our clients (i.e., lenders) when they provide us with information collected about you in connection with forms and applications completed by you or our clients on your behalf, products and services ordered by our clients on your behalf or other correspondence and communications between us and our clients related to your transaction; and

directly from any affiliates and third-party service providers performing services for us in relation to your transaction.

We may collect Browsing Information from the use of cookies and similar technologies. Please note that third-party ad networks and service providers may collect Browsing Information and use and disclose such information for their own purposes, subject to their privacy notices. You have the choice to set your browser to accept or reject cookies. Please consult the “Help” menu or other appropriate tool of your browser to learn how to change your cookie preferences.

We may also receive information about you from third parties. Such third parties may provide information about you and your use of its service to us. We may also collect Personal Information about you from commercially or publicly available sources, including government entities.

Use of Personal Information

We may use the Personal Information we collect for one or more of the following business purposes:

to fulfill or meet the reason you provided the information, including responding to your inquiries, questions and/or other requests or providing our services and products;

to support, develop and improve our Sites, products, services and/or overall consumer experience;

to create, maintain, customize and secure your account with us;

to process your requests, transactions and payments and prevent transactional fraud;

to help maintain the safety, security and integrity of our Sites, products and services, databases and other technology assets;

marketing purposes;

enforcing our Terms of Use; and/or

for such other purposes as may be described to you when collecting your Personal Information or as otherwise set forth in this Notice.

We will not collect additional types of Personal Information or use the Personal Information we collected for materially different, unrelated or incompatible purposes without providing you prior notice. See “Changes to our Privacy Notice” for further details.

Disclosing Personal Information

We may disclose your Personal Information to the following third parties:

our subsidiaries and affiliates;

our clients (i.e. lenders);

service providers and/or other third parties who provide or perform certain services on our behalf, or whom we otherwise engage in connection with our business, including those we engage to detect or prevent criminal activity, fraud, material misrepresentation or nondisclosure with respect to our title services;

law enforcement or other governmental authorities if we become legally compelled to do so (i.e. by deposition, interrogatory, subpoena, court order or to comply with applicable law) or otherwise upon good faith belief that such disclosure is necessary for fraud prevention or otherwise to investigate or prevent a violation of law;

lien holders, judgment creditors or other parties claiming an interest in title whose claim or interest must be determined, settled, paid or released prior to completing your transaction;

underwriters in connection with the title services that we provide;

a third-party purchaser or potential purchaser in connection with a potential merger, divestiture, restructuring, reorganization, dissolution or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which Personal Information held by Solidifi is among the assets transferred;

potential third-party investors in Solidifi or any of its affiliates; and

other parties for whom you have given us written authorization to disclose your Personal Information.

We implement and maintain physical, electronic and procedural safeguards reasonably designed to: (i) protect the security, confidentiality and integrity of your Personal Information; (ii) prevent unauthorized use, access to, disclosure, loss or theft of your Personal Information; and (iii) prevent and detect unauthorized intrusions into our systems. We do not disclose, make available or provide access to any of your Personal Information to any of our subsidiaries, affiliates, employees, contractors, service providers or third parties, other than (i) those who require such Personal Information in order for us to provide our products and services and who are bound by confidentiality obligations; or (ii) as otherwise provided for in this Notice. We carefully select and monitor any contractors, service providers, third parties, potential investors or potential third-party acquirers who have access to your Personal Information and we require them to keep it confidential. However, we are not able to guarantee the security of our Sites.

Your Rights and Choices

It is your choice to submit Personal Information to us, regardless of whether such information is provided to us directly or indirectly. If you choose to opt out of submitting Personal Information to us we may not be able to provide certain of our services or products.

As permitted by law, you may opt-out of disclosure or use of your Personal Information by notifying us by one of the methods at the end of this Notice.

Information from Children

Our Sites are meant for adults and are not intended or designed to attract children under the age of 16. We do not knowingly collect or sell Personal Information from any person under the age of 16 without permission from a parent or guardian. If you are under the age of 16, do not provide us with any information about yourself, including your name, address, email address, telephone number, etc. If we learn we have collected or received Personal Information from anyone under the age of 16 without parental consent, we will promptly delete that information. If you believe we might have any Personal Information from or about anyone under the age of 16, please contact us at:

Solidifi U.S. Inc.
701 Seneca Street, Suite 660
Buffalo, NY 14210

Attention: Compliance Department
Email: privacy@solidifi.com

Accessibility

In accordance with the Americans with Disabilities Act of 1990, we take all reasonable measures to aid consumers requiring assistance to address any disability related needs. As such, consumers with disabilities may access this Notice in an alternative format by calling us toll-free at (877) 240-6310 or by contacting us by email at privacy@solidifi.com. If you require telecommunication via teletype (TTY), please dial 711 for TTY.

Changes to our Privacy Notice

We reserve the right to amend this Notice in our sole discretion at any time. When we make changes to this Notice, we will post the updated Notice on our Sites and update the Notice’s effective date. Your continued use of our Sites and/or our products and services following the posting of changes constitutes your acceptance of such changes.

Contact Information

If you have any questions or comments about this Notice, the ways in which we collect, use, and disclose your Personal Information and/or your choices and rights regarding such use or your desire to exercise any such right contemplated in this Notice, please do not hesitate to contact us at:

Postal Address:

Solidifi U.S. Inc.
701 Seneca St, Suite 660
Buffalo, NY 14210
Attention: Compliance Department

Phone: (877) 240-6310
Website: www.solidifi.com
Email: privacy@solidifi.com

Additional Notice for California Consumers

Subject to the exemptions provided for in the California Consumer Privacy Act and its implementing regulations, as amended by the California Privacy Rights Act and its implementing regulations (collectively, the “CCPA”), this part of our Privacy Notice applies to consumers who reside in the State of California.

Personal Information We Collect About California Consumers

We describe the Personal Information we have collected in the twelve (12) months preceding the effective date of this Notice in the section titled “Information We Collect.” In particular, the information includes the following:

	Category	Examples	Parties to whom this Personal Information was Disclosed
A.	Identifiers	A real name, alias, postal address, unique personal identifier, online identifier, IP address, email address, account name, social security number, driver’s license number, passport number, or other similar identifiers.	-our subsidiaries and affiliates -our clients -service providers and/or other third parties who provide or perform certain services on our behalf -law enforcement or other governmental authorities -lien holders, judgment creditors or other parties claiming an interest in title -underwriters -other parties for whom you have given us written authorization to disclose
B.	Personal Information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e))	The personal information listed in the preceding category as “identifiers,” physical characteristics or description, telephone number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information.	-our subsidiaries and affiliates -our clients -service providers and/or other third parties who provide or perform certain services on our behalf -law enforcement or other governmental authorities -underwriters -other parties for whom you have given us written authorization to disclose
C.	Protected classification characteristics under California or federal law	Age, race, color, ancestry, national origin, citizenship, marital status, sex, and veteran or military status.	-our subsidiaries and affiliates -our clients -service providers and/or other third parties who provide or perform certain services on our behalf -law enforcement or other governmental authorities -underwriters -other parties for whom you have given us written authorization to disclose
D.	Commercial information	Transaction records.	-our subsidiaries and affiliates – our clients -law enforcement or other governmental authorities -underwriters -other parties for whom you have given us written authorization to disclose
E.	Internet or other similar network activity	Browsing history, search history, information on a consumer’s interaction with our Sites.	-our subsidiaries and affiliates -law enforcement or other governmental authorities -other parties for whom you have given us written authorization to disclose
F.	Geolocation data (solely from certain third-party service providers with whom consumers directly interact with)	Physical location or movements.	-our subsidiaries and affiliates -law enforcement or other governmental authorities -other parties for whom you have given us written authorization to disclose
G.	Sensory data	Electronic information in the form of Internet or other electronic network activity information as described in the section of our Notice titled “Information We Collect.”	-our subsidiaries and affiliates -law enforcement or other governmental authorities -other parties for whom you have given us written authorization to disclose
H.	Sensitive Personal Information	Social security number, driver’s license number, state identification card, passport number, racial or ethnic origin.	-our subsidiaries and affiliates -our clients -service providers and/or other third parties who provide or perform certain services on our behalf -law enforcement or other governmental authorities -lien holders, judgment creditors or other parties claiming an interest in title -underwriters -other parties for whom you have given us written authorization to disclose

Personal Information does not include:

publicly available information or lawfully obtained, truthful information that is a matter of public concern; and
de-identified or aggregated consumer information.

We keep the Personal Information we collect from you for so long as is reasonably necessary and proportionate to the original purpose for which it was collected. We base our criteria in determining appropriate retention periods on regulatory and legal requirements, contractual requirements, business needs and your expectations.

For more information on the sources from which we collect Personal Information and our business purposes for using Personal Information, please see “How Information is Collected” and “Use of Personal Information.”

Disclosure of Personal Information

Within the last 12 months, we may have disclosed your Personal Information of all or substantially all of the categories listed in the section of this Notice titled “Personal Information We Collect About California Consumers” to other businesses, service providers or third parties for various business purposes. For more information about the categories of Personal Information we have disclosed for business purposes, the categories of entities to whom we have disclosed this information and the purposes for which we have disclosed this information, please see “Information We Collect,” “Use of Personal Information,” and “Disclosing Personal Information.”

Within the last 12 months, we have disclosed certain categories of information to third parties, such as Google Analytics, who provide services to us in connection with our data and market analysis efforts. Some of these third parties may retain rights to use this data for their own purposes. While this may not be deemed a sale of personal information in the traditional sense, this sharing of information with these third-party providers may qualify as a “sale” of personal information under California law. The information disclosed by us to these third parties consists only of anonymized, statistical data. It includes data relating to internet or other similar network or browsing activity collected as you navigate through and interact with our Sites. This information may be provided to such third parties who help us analyze such data to improve our Sites and provide better service to our customers. We do not otherwise “sell” any Personal Information, including Sensitive Personal Information, that we collect from you. Similarly, we do not use any of your Sensitive Personal Information other than for the purposes permitted by the CCPA and do not collect or process your Sensitive Personal Information for the purpose of inferring characteristics about you.

Your California Privacy Rights and Choices

The CCPA provides California residents with specific rights regarding their Personal Information. This section describes your CCPA rights and explains how to exercise those rights. We will honor your requests received to the extent required by applicable law and within the timeframe provided by applicable law.

Access to Specific Information and Data Portability Rights
You have the right to request that Solidifi disclose the following information to you about its collection and use of your Personal Information:

the categories of Personal Information we collected about you;

the categories of sources for the Personal Information we collected about you;

our business or commercial purpose for collecting, selling or sharing that Personal Information;

the categories of third parties with whom we share that Personal Information;

the specific pieces of Personal Information we received or obtained about you;

the categories of Personal Information about you, if any, that we have disclosed for monetary or other valuable consideration; the categories of third parties to whom we have disclosed the information; and, for each of those third parties, the categories of Personal Information we have disclosed to them; and

the categories of Personal Information about you that we have disclosed for a business purpose.

Deletion Request Rights
You have the right to request that we delete any of your Personal Information that we have collected from you, subject to certain exceptions.

We may deny your deletion request if retaining the information is necessary for us or our service provider(s) to:

complete the transaction for which we collected the Personal Information, fulfill the terms of a written warranty or product recall conducted in accordance with federal law, provide a good or service that you requested or reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you;

help ensure security and integrity to the extent the use of your Personal Information is reasonably necessary and proportionate for those purposes;

debug products to identify and repair errors that impair existing intended functionality;

exercise a legal right provided for by law, including exercising free speech or ensuring the right of another consumer to exercise their free speech rights;

comply with the California Electronic Communications Privacy Act pursuant to Chapter 3.6 (commencing with Section 1546) of Title 12 of Part 2 of the Penal Code;

engage in public or peer-reviewed scientific, historical or statistical research if: (i) the research conforms or adheres to all other applicable ethics and privacy laws; (ii) deleting the Personal Information is likely to make the research impossible or seriously impair the ability to complete such research; and (iii) if you provided informed consent during the initial data collection;

enable internal uses that are reasonably aligned with your expectations based on your relationship with us and that are compatible with the context in which you provided the information; and/or

comply with a legal obligation.

Right to Correct Inaccurate Personal Information
You have the right to request that we correct inaccurate Personal Information that we have collected about you. We will take into account the nature of the Personal Information and the purposes of the processing of the Personal Information in responding to your request.

Right to Opt Out
You have the right to opt out of the disclosure of Personal Information about you. To opt out, complete the “Do Not Sell/Share My Personal Information Form” located on https://www.solidifi.com/our-offices/. You may also use any of the methods listed in “Exercising CCPA Consumer Rights” to opt out.

Exercising CCPA Consumer Rights
To exercise your rights described above, please submit a verifiable consumer request to us by either:

calling us at: (877) 240-6310;

completing the CCPA Request Form located on https://www.solidifi.com/our-offices/; or

emailing us at: privacy@solidifi.com.

Only you, or a business entity that you authorize to act on your behalf, may make a verifiable consumer request related to your Personal Information. You may also make a verifiable consumer request on behalf of your minor child. You may only make a verifiable consumer request for access or data portability twice within a twelve (12) month period.

The verifiable consumer request must:

provide sufficient information that allows us to reasonably verify that you are the person about whom we collected Personal Information or are an authorized representative of such person; and

describe your request with sufficient detail that allows us to properly understand, evaluate and respond to it.

In general, the verifiable consumer request should include the following information: (i) date of request; (ii) your name, address and telephone number; (iii) your service type (i.e. appraisal, title, etc.); (iv) order number(s) (if applicable); and (v) type of request (e.g. request to know – categories of information, request to know – specific information, request to correct, request to delete information, etc.). We may consider other requests or require additional information in some circumstances in our discretion as permitted by applicable law. Upon submission of your verifiable consumer request, we will confirm receipt within 10 days of submission and provide information about how we will process the request, the verification process and when you should expect a response. In determining the method by which we will verify your identity, we will, whenever feasible, match the identifying information provided by you to your Personal Information already maintained by us. In addition, the method by which we will verify your identity upon receipt of a verifiable consumer request will depend on: (i) the type, sensitivity and value of the Personal Information collected and maintained about you; (ii) the risk of harm to you posed by any unauthorized deletion, correction or access (iii) the likelihood that fraudulent or malicious actors would seek the personal information; (iv) whether the Personal Information to be provided by you is sufficiently robust to protect against fraudulent requests or being spoofed or fabricated; (v) the manner in which we interact with you; and (vi) available technology for verification purposes.

We cannot respond to your request or provide you with Personal Information if we cannot verify your identity or authority to make the request and confirm the Personal Information relates to you. We will only use Personal Information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request. Making a verifiable consumer request does not require you to create an account with us. We may limit our response to your exercise of the above rights as permitted under applicable law.

Under California law, you may designate an authorized agent to make a request on your behalf. You may make such a designation by providing the agent with written permission to act on your behalf. As permitted by law, we may require you to verify your own identity in response to a request even if you choose to use an authorized agent. We may also require authorized agents to provide verification that they have been authorized to act on your behalf, as permitted by applicable law.

We will deliver our written response to you by mail or electronically. We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.

Do Not Track
Please note that our Sites are not designed to respond to “do not track” requests from Web browsers.

Non-Discrimination
We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, if you choose to exercise any of your CCPA rights, we will not:

deny you products or services;

charge you different prices or rates for products or services, including through granting discounts or other benefits or imposing penalties;

provide you a different level or quality of products or services; or

suggest that you may receive a different price or rate for products or services or a different level or quality of products or services.