Privacy Policy

1. Personal Information We May Collect

Depending on your relationship with Caelora and the services being provided, we may collect personal information and non-public personal information (“Personal Information”) from several sources.

Information You Provide to Us

We may collect information you provide through applications, order forms, closing documents, communications, online forms, or other interactions with us, including:

• Name;
• Mailing and property addresses;
• Email address;
• Telephone number;
• Date of birth, where necessary;
• Social Security number or taxpayer identification number, where necessary and legally permitted;
• Government-issued identification information;
• Marital or vesting information;
• Employment or income information when relevant to a transaction;
• Financial or asset information;
• Bank, payment, or wire-related information when required to facilitate an authorized transaction;
• Information contained in contracts, deeds, affidavits, settlement documents, loan documents, or other transaction records; and
• Other information you voluntarily provide to us.

Information Related to Your Real Estate Transaction

When providing title, settlement, escrow, closing support, notary, or related services, we may receive information concerning:

• The property involved in the transaction;
• Purchase and sale agreements;
• Ownership and title information;
• Mortgages and other liens;
• Judgments and other encumbrances;
• Property taxes and assessments;
• Loan and lender information;
• Escrow and settlement information;
• Payoff information;
• Closing costs and disbursements;
• Insurance information;
• Payment history;
• Transaction balances;
• Recording information; and
• Other information reasonably necessary to facilitate or complete a transaction.

Information From Third Parties and Public Records

We may receive information from third parties involved in or supporting a transaction, including, as applicable:

• Buyers and sellers;
• Real estate agents and brokers;
• Attorneys;
• Lenders and mortgage professionals;
• Title insurance underwriters;
• Title agents and abstractors;
• Surveyors;
• Appraisers;
• Inspectors;
• Homeowners’ or condominium associations;
• Municipalities and taxing authorities;
• Recording offices and other government agencies;
• Notaries;
• Escrow and settlement providers;
• Consumer or other reporting agencies, where permitted by law;
• Fraud-prevention and identity-verification providers;
• Service providers; and
• Publicly available records.

Information Collected Through Our Website

When you access or use our website or other online services, we may automatically collect certain technical information, including:

• Internet Protocol (IP) address;
• Browser type;
• Device type;
• Operating system;
• Pages viewed;
• Date and time of access;
• Referring website or source;
• Links clicked;
• General website activity; and
• Cookie or similar technology information.

We may use cookies and similar technologies to operate our website, understand website usage, improve functionality, maintain security, and enhance the user experience.

2. How We Use Personal Information

We may use Personal Information for legitimate business and legal purposes, including:

• Provide title, settlement, escrow, closing support, notary, and related services;
• Open and administer title and settlement files;
• Conduct title searches and examinations;
• Identify and address liens, judgments, encumbrances, and other title matters;
• Coordinate real estate closings;
• Prepare, review, process, and facilitate transaction documents;
• Communicate with transaction participants;
• Facilitate authorized escrow, settlement, payment, and disbursement activities;
• Coordinate the issuance of title insurance policies where applicable;
• Record or facilitate the recording of documents;
• Verify identity and help prevent fraud;
• Detect or investigate suspected unauthorized activity;
• Respond to customer inquiries;
• Maintain transaction and business records;
• Improve our services, website, and operations;
• Protect our customers, employees, business, systems, and property;
• Enforce agreements and protect legal rights;
• Meet regulatory, legal, tax, accounting, audit, and compliance obligations; and
• Carry out other purposes permitted or required by applicable law.

3. Disclosure of Personal Information

We may disclose Personal Information to third parties when reasonably necessary to provide requested services, complete a transaction, operate our business, protect against fraud, or comply with applicable law.

Depending on the transaction, recipients may include:

• Title insurance companies and underwriters;
• Title agents, abstractors, and search providers;
• Buyers and sellers;
• Real estate agents and brokers;
• Attorneys and legal representatives;
• Lenders, mortgage brokers, and loan servicers;
• Escrow and settlement service providers;
• Notaries and signing professionals;
• Surveyors and other property-related professionals;
• Government agencies and recording offices;
• Municipalities and taxing authorities;
• Homeowners’ or condominium associations and their representatives;
• Lienholders, judgment creditors, and parties claiming an interest or encumbrance affecting a property;
• Banks and financial institutions involved in authorized transaction processing;
• Technology, document-management, hosting, cybersecurity, communications, and other service providers;
• Accountants, auditors, consultants, insurers, and professional advisers; and
• Other parties authorized by you or permitted or required by law.

We may also disclose information where we reasonably believe disclosure is necessary to:

• Comply with applicable law or regulation;
• Respond to a subpoena, court order, warrant, or other lawful process;
• Cooperate with regulatory, governmental, or law-enforcement authorities;
• Detect, investigate, or prevent fraud, cybercrime, money laundering, identity theft, or other unlawful activity;
• Protect the rights, property, security, or safety of Caelora, our customers, employees, or others; or
• Establish, exercise, or defend legal claims.

We do not disclose Personal Information to nonaffiliated third parties except as described in this Privacy Policy, as authorized by you, or as otherwise permitted or required by law.

4. Affiliates and Related Entities

Caelora Settlement Services is a division of Caelora Inc.

Where permitted by applicable law, information may be shared within Caelora Inc. and with its divisions, affiliates, or related entities as reasonably necessary to provide requested services, administer transactions, operate our business, maintain security, meet compliance obligations, or otherwise carry out lawful business purposes.

Information obtained from consumer or credit reporting agencies will be handled and disclosed in accordance with applicable law.

5. Service Providers

We may engage third-party companies and professionals to perform services on our behalf, including technology hosting, cybersecurity, document processing, title research, transaction support, payment processing, communications, record storage, analytics, and other operational functions.

These parties may receive Personal Information when reasonably necessary to perform services for us and are expected to handle information in accordance with applicable contractual, privacy, confidentiality, and legal requirements.

6. Sale of Personal Information

Caelora does not sell Personal Information for monetary consideration as part of its ordinary title and settlement operations.

Certain state privacy laws may define terms such as “sale,” “sharing,” or “targeted advertising” more broadly than an ordinary monetary sale. To the extent such laws apply to Caelora’s website or operations, Caelora will provide any notices, disclosures, or choices required by applicable law.

7. Confidentiality and Information Security

We recognize the sensitive nature of information involved in real estate transactions.

Caelora maintains administrative, technical, and physical safeguards designed to protect Personal Information against unauthorized access, disclosure, alteration, loss, destruction, or misuse.

Access to Personal Information is intended to be limited to employees, contractors, service providers, and other authorized persons who have a legitimate business need for the information.

However, no electronic communication, internet transmission, or information-storage system can be guaranteed to be completely secure. Accordingly, while we take reasonable measures to safeguard information, we cannot guarantee absolute security.

8. Wire Fraud and Email Security

Real estate transactions are frequent targets of wire fraud, business email compromise, phishing, and impersonation schemes.

Never rely solely on wiring instructions received by email.

Before transferring funds in connection with a transaction, independently verify all wiring instructions using a trusted telephone number or another established verification procedure.

If you receive an email, text message, telephone call, or other communication that appears suspicious or requests a change to previously provided wiring instructions, do not transfer funds until you have independently verified the request.

Caelora may establish additional verification procedures for financial instructions and transaction-related communications.

9. Data Retention

We retain Personal Information for as long as reasonably necessary to provide services, administer transactions, maintain business and transaction records, resolve disputes, enforce agreements, respond to claims, and satisfy legal, regulatory, tax, accounting, contractual, title insurance, or record-retention requirements.

Because title and real estate records may remain relevant for an extended period, certain information may be retained for longer periods where permitted or required by law.

10. Your Privacy Rights

Depending on your state of residence and applicable law, you may have certain rights concerning your Personal Information, which may include the right to:

• Request access to Personal Information maintained about you;
• Request correction of inaccurate Personal Information;
• Request deletion of certain Personal Information;
• Request information concerning categories of Personal Information collected or disclosed;
• Request information about certain third parties or categories of recipients to whom information has been disclosed;
• Opt out of certain uses or disclosures where applicable; and
• Exercise other privacy rights provided by applicable law.

These rights are not absolute and may be subject to exemptions. For example, we may be legally required or otherwise permitted to retain information associated with title, escrow, settlement, insurance, regulatory, fraud-prevention, litigation, or other business records.

We may take reasonable steps to verify your identity before processing a privacy request. Where permitted by law, we may request additional information reasonably necessary to authenticate the request and protect Personal Information from unauthorized disclosure.

11. Children’s Privacy

Our website and services are not directed toward children under the age of 13, and we do not knowingly use our website to solicit Personal Information from children under 13.

If we learn that information has been collected through our website from a child in violation of applicable law, we will take appropriate steps to address the information.

12. Cookies and Website Technologies

Our website may use cookies, pixels, analytics tools, and similar technologies to:

• Enable website functionality;
• Maintain website security;
• Understand visitor interactions;
• Measure website performance;
• Diagnose technical problems; and
• Improve our website and services.

Where required by applicable law, visitors will be provided with appropriate notice or choices regarding non-essential cookies and similar technologies.

13. Third-Party Websites

Our website may contain links to websites or services operated by third parties.

Caelora is not responsible for the privacy, security, content, or practices of third-party websites or services. We encourage users to review the applicable privacy policies before providing Personal Information to third parties.

14. Email and Electronic Communications

If you communicate with us electronically, we may retain those communications as part of our business or transaction records.

Email and ordinary electronic communications may not always be secure. You should not transmit Social Security numbers, financial account credentials, wire instructions, government identification documents, or other highly sensitive information through unsecured email or unsecured website forms unless specifically instructed to use an approved secure method.

15. Business Transfers

If Caelora Inc. or any relevant portion of its business is involved in a merger, acquisition, reorganization, financing, sale of assets, transfer, or similar business transaction, Personal Information may be disclosed or transferred as part of that transaction, subject to applicable law.

16. Changes to This Privacy Policy

We may revise this Privacy Policy periodically to reflect changes in our services, business practices, technology, or legal and regulatory requirements.

When we make changes, we will post the revised Privacy Policy on our website and update the “Last Updated” date above.

Material changes will be communicated as required by applicable law.

17. Contact Us

Questions, concerns, or requests regarding this Privacy Policy or Caelora’s handling of Personal Information may be directed to:

Privacy requests should include sufficient information for us to identify and respond to the request. Additional identity verification may be required before Personal Information is accessed, corrected, deleted, or otherwise disclosed.

NOTICE: This Privacy Policy describes Caelora Settlement Services’ general privacy practices. Additional privacy notices or disclosures may apply to particular products, services, transactions, jurisdictions, or consumers as required by federal or state law.