Last Updated: December 18, 2019
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 parent companies, 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 this 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 (SSN), driver’s license, passport; (iv) financial account information; (v) responses to any surveys you complete in relation to or regarding your experience with our products or services; and/or (vi) any other information collected in the ordinary course of business in order to provide our products and/or services.
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 also receive information about you from third parties such as if you access our products and services through a third party (e.g., through LinkedIn). 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.
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 and services;
- 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;
- to respond to law enforcement requests and as required by applicable law, court order or other governmental regulations;
- to evaluate or conduct 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 (an “Acquisition Transaction”);
- marketing purposes;
- 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, including, but not limited to, the maintenance and support of our online services and marketing research and analysis, 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 an Acquisition Transaction;
- 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 those who require such Personal Information in order for us to provide our products and services and who are bound by confidentiality obligations or 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 is not intended or designed to attract children under the age of 16. We do not knowingly collect 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
Additional Notice for California Consumers
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:
|A.||Identifiers||A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, Social Security number, driver’s license number, passport number, or other similar identifiers.|
|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.|
|C.||Protected classification characteristics under California or federal law||Age, race, color, ancestry, national origin, citizenship, marital status, sex, and veteran or military status.|
|D.||Commercial information||Transaction records.|
|E.||Internet or other similar network activity||Browsing history, search history, information on a consumer’s interaction with our Sites.|
|F.||Geolocation data||Physical location or movements.|
|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.”|
Personal Information does not include:
- publicly available information from government records;
- de-identified or aggregated consumer information; and
- information excluded from the scope of the California Consumer Protection Act (“CCPA”), including, but not limited to, Personal Information covered by certain sector-specific privacy laws, including the Gramm-Leach-Bliley Act (GLBA).
For more information on how we collect Personal Information, please see “How Information is Collected.”
Disclosure of Personal Information
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.”
As described in “How Information is Collected,” we collect Browsing Information via cookies or other similar technologies. We may have disclosed within the twelve (12) months preceding the effective date of this Notice certain identifiers, information about the use of our Sites and Personal Information to our social media, advertising and analytics partners for monetary or valuable consideration.
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 over the twelve (12) months preceding the date of your request:
- 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 or selling 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;
- detect security incidents, protect against malicious, deceptive, fraudulent or illegal activity, or prosecute those responsible for such activities;
- 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 in the public interest if: (i) the research 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 research’s achievement; 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;
- comply with a legal obligation; and/or
- make other internal and lawful uses of the Personal Information that is compatible with the context in which you provided the information.
Right to Opt Out
You have the right to opt out of the disclosure of Personal Information about you for monetary or other valuable consideration. To opt out, complete the Do Not Sell My Personal Information Form located on https://www.solidifi.com/our-offices/.
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: firstname.lastname@example.org.
- Only you, or a person registered with the California Secretary of State 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.
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.
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 require authorized agents to provide verification that they act on your behalf, as permitted by applicable law.
We will deliver our written response to you by mail or electronically, at your option. 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.
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 goods or services;
- charge you different prices or rates for goods or services, including through granting discounts or other benefits or imposing penalties;
- provide you a different level or quality of goods or services; or
- suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.
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 website and update the Notice’s effective date. Your continued use of our website and/or our products and services following the posting of changes constitutes your acceptance of such changes.
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:
Solidifi U.S. Inc.
701 Seneca Street, Suite 660
Buffalo, NY 14210
Attention: Compliance Department
Phone: (877) 240-6310