STEWART INFORMATION SERVICES CORPORATION GRAMM-LEACH BLILE

This Stewart Information Services Corporation Privacy Notice  (“Notice”) explains how we and our affiliates and majority-owned  subsidiary companies (collectively, “Stewart,” “our,” or “we”) collect,  use, and protect personal information, when and to whom we disclose such  information, and the choices you have about the use and disclosure of  your information.  Pursuant to Title V of the Gramm-Leach Bliley Act  (“GLBA”) and other Federal and state laws and regulations applicable to  financial institutions, consumers have the right to limit some, but not  all sharing of their personal information. Please read this Notice  carefully to understand how Stewart uses your personal information.

The types of personal information Stewart collects, and shares depends on the product or service you have requested.

Stewart may collect the following categories of personal and financial information from you throughout your transaction:

1. Identifiers:  Real name, alias, online IP address if accessing company websites,  email address, account name, unique online identifier, or other similar  identifiers.
2. Demographic Information: Marital status, gender, date of birth.
3. Personal  Information and Personal Financial Information: Full name, signature,  social security number, address, driver’s license number, passport  number, telephone number, insurance policy number, education,  employment, employment history, bank account number, credit card number,  debit card number, credit reports, or any other information necessary  to complete the transaction.

Stewart may collect personal information about you from:

1. Publicly available information from government records.
2. Information we receive directly from you or your agent(s), such as your lender or real estate broker.
3. Information  we receive from consumer reporting agencies and/or governmental  entities, either directly from these entities or through others.

Stewart may use your personal information for the following purposes:

1. To provide products and services to you in connection with a transaction.
2. To improve our products and services.
3. To communicate with you about our affiliates’, and others’ products and services, jointly or independently.

Stewart may use or disclose the personal information we collect for one or more of the following purposes:

1. To fulfill or meet the reason for which the information is provided.
2. To provide, support, personalize, and develop our website, products, and services.
3. To create, maintain, customize, and secure your account with Stewart.
4. To process your requests, purchases, transactions, and payments and prevent transactional fraud.
5. To prevent and/or process claims.
6. To  assist third party vendors/service providers who complete transactions  or perform services on Stewart’s behalf pursuant to valid service  provider agreements.
7. As necessary or appropriate to protect the rights, property or safety of Stewart, our customers, or others.
8. To  provide you with support and to respond to your inquiries, including to  investigate and address your concerns and monitor and improve our  responses.
9. To help maintain the safety, security, and integrity  of our website, products and services, databases and other  technology-based assets, and business.
10. To respond to law enforcement or regulator requests as required by applicable law, court order, or governmental regulations.
11. Auditing for compliance with federal and state laws, rules, and regulations.
12. Performing  services including maintaining or servicing accounts, providing  customer service, processing, or fulfilling orders and transactions,  verifying customer information, processing payments.
13. To evaluate  or conduct a merger, divestiture, restructuring, reorganization,  dissolution, or other sale or transfer of some or all our assets,  whether as a going concern or as part of bankruptcy, liquidation, or  similar proceeding, in which personal information held by us is among  the assets transferred.

Stewart will not collect additional  categories of personal information or use the personal information we  collected for materially different, unrelated, or incompatible purposes  without providing you notice.

Disclosure of Personal Information to Affiliated Companies and Nonaffiliated Third Parties

Stewart  does not sell your personal information to nonaffiliated third  parties.  Stewart may share your information with those you have  designated as your agent throughout the course of your transaction (for  example, your realtor, broker, or a lender).  Stewart may disclose your  personal information to non-affiliated third-party service providers and  vendors to render services to complete your transaction.

We share your personal information with the following categories of third parties:

1. Non-affiliated  service providers and vendors we contract with to render specific  services (For example, search companies, mobile notaries, and companies  providing credit/debit card processing, billing, shipping, repair,  customer service, auditing, marketing, etc.)
2. To enable Stewart to prevent criminal activity, fraud, material misrepresentation, or nondisclosure.
3. Stewart’s affiliated and subsidiary companies.
4. Parties involved in litigation and attorneys, as required by law.
5. Financial rating organizations, rating bureaus and trade associations, taxing authorities, if required in the transaction.
6. Federal  and State Regulators, law enforcement and other government entities to  law enforcement or authorities in connection with an investigation, or  in response to a subpoena or court order.

The law does not  require your prior authorization or consent and does not allow you to  restrict the disclosures described above.  Additionally, we may disclose  your information to third parties for whom you have given us  authorization or consent to make such disclosure. We do not otherwise  share your Personal Information or browsing information with  non-affiliated third parties, except as required or permitted by law.

Right to Limit Use of Your Personal Information
You  have the right to opt-out of sharing of your personal information among  our affiliates to directly market to you.  To opt-out of sharing your  information with affiliates for direct marketing, you may send an “opt  out” request to Privacyrequest@stewart.com

Postal Address: Stewart Information Services Corporation
Attn: Mary Thomas, Chief Compliance and Regulatory Officer
1360 Post Oak Blvd., Ste. 100, MC #14-1
Houston, TX  77056

                                                                                                                                                   Effective  Date: January 1, 2020                
                                                                                                                                              Updated: August 24, 2023 

Stewart Information Services Corporation and its affiliates  and majority-owned subsidiary companies (collectively, “Stewart,” “our,”  or “we”) respect and are committed to protecting your privacy.   Pursuant to the California Consumer Privacy Act of 2018 (“CCPA”) and the  California Privacy Rights Act of 2020 (“CPRA”), we are providing this Privacy Notice (“CCPA  Notice”).  This CCPA Notice explains how we collect, use, and disclose  personal information, when and to whom we disclose such information, and  the rights you, as a California resident have regarding your Personal  Information.  This CCPA Notice supplements the information contained in  Stewart’s existing privacy notice and applies solely to all visitors,  users, consumers, and others who reside in the State of California or  are considered California Residents as defined in the CCPA (“consumers”  or “you”).  All terms defined in the CCPA & CPRA have the same  meaning when used in this Notice.

Personal information that is  collected, processed, sold, or disclosed pursuant to the Gramm-Leach  Bliley Act (GLBA) is exempt from the California Consumer Privacy Act  (CCPA). GLBA is a federal law that regulates the use and disclosure of  personal information by financial institutions. Personal information  obtained by AccountChek from financial institutions is regulated by  GLBA. Consumers grant AccountChek authorization to collect their personal information from financial  institutions and share it for specific purposes described in  AccountChek’s Terms of Service Agreement, which is presented to end  users in the AccountChek® application.

AccountChek has implemented  and maintains data security measures designed to ensure that personal  information is secure and encrypted at rest or in transit. 

Personal and Sensitive Personal Information Stewart Collects

Stewart  has collected the following categories of personal and sensitive  personal information from consumers within the last twelve (12) months:

1. 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.
2. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)). A name, signature, Social Security number, address, telephone number,  passport number, driver’s license or state identification card number,  insurance policy number, education, employment, employment history, bank  account number, credit card number, debit card number, or any other  financial information.
3. Protected classification characteristics under California or federal law. Age,  race, color, ancestry, national origin, citizenship, marital status,  sex (including gender, gender identity, gender expression), veteran or  military status.
4. Commercial information. Records of personal property, products or services purchased, obtained,  or considered, or other purchasing or consuming histories or  tendencies.
5. Internet or other similar network activity. Browsing history, search history, information on a consumer’s interaction with a website, application, or advertisement.
6. Geolocation data

Stewart obtains the categories of personal and sensitive information listed above from the following categories of sources:

• Directly  and indirectly from customers, their designees, or their agents (For  example, realtors, lenders, attorneys, brokers, etc.)
• Directly and indirectly from activity on Stewart’s website or other applications.
• From third parties that interact with Stewart in connection with the services we provide. 

Use of Personal and Sensitive Personal Information

Stewart may use or disclose the personal or sensitive information we collect for one or more of the following purposes:

1. To fulfill or meet the reason for which the information is provided.
2. To provide, support, personalize, and develop our website, products, and services.
3. To create, maintain, customize, and secure your account with Stewart.
4. To process your requests, purchases, transactions, and payments and prevent transactional fraud.
5. To prevent and/or process claims.
6. To  assist third party vendors/service providers who complete transactions  or perform services on Stewart’s behalf pursuant to valid service  provider agreements.
7. As necessary or appropriate to protect the rights, property or safety of Stewart, our customers, or others.
8. To  provide you with support and to respond to your inquiries, including to  investigate and address your concerns and monitor and improve our  responses.
9. To personalize your website experience and to deliver  content and product and service offerings relevant to your interests,  including targeted offers and ads through our website, third-party  sites, and via email or text message (with your consent, where required  by law).
10. To help maintain the safety, security, and integrity of  our website, products and services, databases and other  technology-based assets, and business.
11. To respond to law enforcement or regulator requests as required by applicable law, court order, or governmental regulations.
12. Auditing for compliance with federal and state laws, rules, and regulations.
13. Performing  services including maintaining or servicing accounts, providing  customer service, processing, or fulfilling orders and transactions,  verifying customer information, processing payments, providing  advertising or marketing services or other similar services.
14. To  evaluate or conduct a merger, divestiture, restructuring,  reorganization, dissolution, or other sale or transfer of some or all  our assets, whether as a going concern or as part of bankruptcy,  liquidation, or similar proceeding, in which personal information held  by us is among the assets transferred.

Stewart will not  collect additional categories of personal or sensitive information or  use the personal or sensitive information we collected for materially  different, unrelated, or incompatible purposes without providing you  notice.

Disclosure of Personal Information to Affiliated Companies and Nonaffiliated Third Parties

Stewart  does not sell your personal information to nonaffiliated third  parties.  Stewart may share your information with those you have  designated as your agent throughout the course of your transaction (for  example, a realtor, broker, or a lender).

We share your personal information with the following categories of third parties:

1. Service  providers and vendors we contract with to render specific services (For  example, search companies, mobile notaries, and companies providing  credit/debit card processing, billing, shipping, repair, customer  service, auditing, marketing, etc.)
2. Affiliated Companies.
3. Parties involved in litigation and attorneys, as required by law.
4. Financial rating organizations, rating bureaus and trade associations.
5. Federal and State Regulators, law enforcement and other government entities

In the preceding twelve (12) months, Stewart has disclosed the following categories of personal information:

Category A:  Identifiers
Category B:  California Customer Records personal information categories
Category C:  Protected classification characteristics under California or federal law
Category D:  Commercial Information
Category E:  Internet or other similar network activity
Category F:   Non-public education information

• Your Consumer Rights and Choices Under CPPA and CPRA

The  CCPA and CPRA provide consumers (California residents as defined in the  CCPA) with specific rights regarding their personal information.  This  section describes your rights and explains how to exercise those rights.

• Access to Specific Information and Data Portability Rights

You  have the right to request that Stewart disclose certain information to  you about our collection and use of your personal information over the  past 12 months.  Once we receive and confirm your verifiable consumer  request, Stewart will disclose to you:

1. The categories of personal information Stewart collected about you.
2. The categories of sources for the personal information Stewart collected about you.
3. Stewart’s business or commercial purpose for collecting that personal information.
4. The categories of third parties with whom Stewart shares that personal information.
5. The specific pieces of personal information Stewart collected about you (also called a data portability request).
6. If  Stewart disclosed your personal data for a business purpose, a listing  identifying the personal information categories that each category of  recipient obtained.

• Deletion Request Rights

You  have the right to request that Stewart delete any personal information  we collected from you and retained, subject to certain exceptions. Once  we receive and confirm your verifiable consumer request, Stewart will  delete (and direct our service providers to delete) your personal  information from our records, unless an exception applies.

Stewart may deny your deletion request if retaining the information is necessary for us or our service providers to:

1. Complete  the transaction for which we collected the personal information,  provide a good or service that you requested, take actions reasonably  anticipated within the context of our ongoing business relationship with  you, or otherwise perform our contract with you.
2. Detect  security incidents, protect against malicious, deceptive, fraudulent, or  illegal activity, or prosecute those responsible for such activities.
3. Debug products to identify and repair errors that impair existing intended functionality.
4. Exercise  free speech, ensure the right of another consumer to exercise their  free speech rights, or exercise another right provided for by law.
5. Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 ).
6. Engage  in public or peer-reviewed scientific, historical, or statistical  research in the public interest that adheres to all other applicable  ethics and privacy laws, when the information’s deletion may likely  render impossible or seriously impair the research’s achievement, if you  previously provided informed consent.
7. Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
8. Comply with a legal obligation.
9. Make other internal and lawful uses of that information that are compatible with the context in which you provided it.

• Opt-Out of Information Sharing and Selling

Stewart  does not share or sell information to third parties, as the terms are  defined under the CCPA and CPRA.  Stewart only shares your personal  information as commercially necessary and in accordance with this CCPA  Notice.

The CCPA provides consumers with the right, at any time,  to opt-out of a business’s sale of a consumer’s personal information to  third parties. Businesses that sell personal information to third  parties are required to provide notice that personal information may be  sold and that consumers have the right to opt-out. IR does not send  marketing communications directly to consumers nor do we sell consumer  information to other third parties. If you would like to opt-out of  credit offers and stop Trigger leads generated by the bureaus, please  take the following steps:

1. Register for Opt-Out Prescreen at  optoutprescreen.com. This will stop all credit bureaus (Equifax,  Experian, and TransUnion) from selling their name as a trigger lead for  at least a 5-year period. Once requested, it takes approximately 5 days  to become effective.
2. Register name and phone number to reduce  telemarketing efforts on the National Do Not Call Registry at  donotcall.gov or call 1-888-382-1222 from each phone number they wish to  register. Once requested, it takes approximately 31 days to become  effective.

Register with the Direct Marketing Association’s  Mail Preference Service to opt out of commercial mailings for 5 years  with a $1 processing fee at dmachoice.org. DMA distributes its lists  quarterly, so effective date can vary upon when your request is  submitted.

• Correction of Inaccurate Information

You have the right to request that Stewart correct any inaccurate information maintained about.

• Limit the Use of Sensitive Personal Information 

You  have the right to limit how your sensitive personal information, as  defined in the CCPA and CPRA is disclosed or shared with third parties.

Exercising Your Rights Under CCPA and CPRA

If  you have questions or comments about this notice, the ways in which  Stewart collects and uses your information described herein, your  choices and rights regarding such use, or wish to exercise your rights  under California law, please submit a verifiable consumer request to us  by the available means provided below:

1. Emailing us at OptOut@stewart.com; or ComplianceDepartment@InformativeResearch.com
2. Visiting http://stewart.com/ccpa or https://www.informativeresearch.com/privacy-policy/
3. By Mail:
   Informative Research
   Compliance Department
   California Privacy Rights Request
   PO Box 2379
   Garden Grove, CA 92842

 Only  you, or someone legally authorized 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, if applicable.

To designate an authorized agent, please contact Stewart through one of the methods mentioned above.

You  may only make a verifiable consumer request for access or data  portability twice within a 12-month period. The verifiable consumer  request must:

• Provide sufficient information that allows us  to reasonably verify you are the person about whom we collected personal  information or an authorized representative.
• Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

Stewart  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.

Making a verifiable consumer request does not require you to create an account with Stewart.

Response Timing and Format

We  endeavor to respond to a verifiable consumer request within forty-five  (45) days of its receipt.  If we require more time (up to an additional  45 days), we will inform you of the reason and extension period in  writing.
A written response will be delivered by mail or electronically, at your option.
Any  disclosures we provide will only cover the 12-month period preceding  the verifiable consumer request’s receipt.  The response we provide will  also explain the reasons we cannot comply with a request, if  applicable.
Stewart does 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.

Non-Discrimination

Stewart will not discriminate against you for exercising any of your CCPA rights.  Unless permitted by the CCPA, we will not:

• Deny you goods or services.
• Charge  you a 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.
• Suggest  that you may receive a different price or rate for goods or services or  a different level or quality of goods or services.

Record Retention

Your  personal information will not be kept for longer than is necessary for  the business purpose for which it is collected and processed.  We will  retain your personal information and records based on established record  retention policies pursuant to California law and in compliance with  all federal and state retention obligations.  Additionally, we will  retain your personal information to comply with applicable laws,  regulations, and legal processes (such as responding to subpoenas or  court orders), and to respond to legal claims, resolve disputes, and  comply with legal or regulatory recordkeeping requirements.

Changes to This CCPA Notice
Stewart  reserves the right to amend this CCPA Notice at our discretion and at  any time.  When we make changes to this CCPA Notice, we will post the  updated Notice on Stewart’s website and update the Notice’s effective  date.

Link to Privacy Notice
Stewarts Privacy Notice can be found on our website at https://www.stewart.com/en/privacy.html.

Contact Information
Stewart Information Services Corporation
Attn:  Mary Thomas, Chief Compliance and Regulatory Officer
1360 Post Oak Blvd., Ste. 100, MC #14-1
Houston, TX  77056

Automated Asset Verification

AccountChek™  is an automated, web-based service that allows lenders to verify and  monitor a potential borrower’s asset accounts during the credit  application and approval process. AccountChek eliminates a borrower’s  need to engage in the time-consuming process of locating, copying and  transmitting important financial documents to their lender, often  through insecure channels. Our service eliminates issues –like missing  pages and lost or misplaced documents– that slow down the review and  approval process. Because we obtain the asset information directly from  the borrower’s financial institution or brokerage, our service also  minimizes transcription errors and maximizes accuracy. This means that  lenders are sure that they are basing their decisions on accurate  information. Our service saves time for everyone involved in the  transaction and reduces lender losses, which makes credit less expensive  and more available to more customers.

AccountChek™ 3n1 by Informative Research
Automated Asset, Employment, and Income Verification
AccountChek™  3n1 is an automated, web-based service that allows lenders to verify  and monitor a potential borrower’s asset accounts and verify the  borrower’s employment status and income during the credit application  and approval process. AccountChek 3n1 eliminates a borrower’s need to  engage in the time-consuming process of locating, copying, and  transmitting important financial documents to their lender, often  through insecure channels. Our service eliminates issues –like missing  pages and lost or misplaced documents– that slow down the review and  approval process. Because we obtain the asset information directly from  the borrower’s financial institution or brokerage and employment and  income information from the borrower’s payroll provider, our service  also minimizes transcription errors and maximizes accuracy. This means  that lenders are sure that they are basing their decisions on accurate  information. Our service saves time for everyone involved in the  transaction and reduces lender losses, which makes credit less expensive  and more available to more customers.

We understand the  importance of protecting individuals’ sensitive financial information.  We designed this Privacy Statement to help you understand how the  AccountChek and AccountChek 3n1 services will collect, use and disclose  borrowers’ financial data.

Special note on children’s privacy:  AccountChek and AccountChek 3n1 are not designed or intended to attract  or be accessible to minors (children under age 18). We will not  knowingly collect personal information from minors.

This policy covers the following topics:

• Information we collect about borrowers and how we use it;
• Who we share borrowers’ information with; and
• How we protect borrowers’ personal information.

INFORMATION COLLECTION AND USE
We  collect personal and non-personal information from borrowers based on  borrowers’ consent. We are acting as an intermediary for the borrower’s  lender when we do so. We collect this information in order to provide  the AccountChek and AccountChek 3n1 services and to improve our  services.

Information We Collect from Borrowers

Information to Verify Asset Accounts: The AccountChek service allows lenders to verify a borrower’s assets  through direct read access to a borrower’s financial account data.  Borrowers must expressly agree to allow AccountChek to obtain and  furnish financial account information to a prospective creditor, and to  provide his/her identifying credentials for the accounts that need to be  verified. The borrower’s credentials may include username, password and  answers to challenge questions. While the accounts are being verified  and lenders are able to update that information (the refresh period;  usually 30 to 90 days) the credentials are stored in a secure  hardware-encrypted repository that is inaccessible to humans managed by  AccountChek’s designated data access vendor.

Information to Verify Employment and Income: The AccountChek 3n1 service allows lenders to verify a borrower’s  employment through direct read access to a borrower’s payroll account  data. Borrowers must expressly agree to allow AccountChek 3n1 to obtain  and furnish payroll account information to a prospective creditor, and  to provide his/her identifying credentials for the accounts that need to  be verified. The borrower’s credentials may include username, password  and answers to challenge questions. While the accounts are being  verified and lenders are able to update that information (the refresh  period; usually 30 to 90 days) the credentials are stored in a secure  hardware-encrypted repository that is inaccessible to humans managed by  AccountChek 3n1’s designated data access vendor.

Log information: Our servers automatically collect log information from site visitors.  This information may include the Web page request, Internet Protocol  (IP) address, browser type, browser language, the date and time of the  request, and one or more cookies that may uniquely identify the  visitor’s browser. We collect log information so that we can properly  administer our system and gather aggregate information about how our  site is being used, including the pages visitors are viewing.

Cookies: We use session cookie technology to keep track of visitors as they  navigate from one page to the next on the site. When the session is  ended and the visitor closes his/her browser, the session cookies are  automatically deleted.

Browser software can be set to reject all  cookies or to accept cookies only from our site. Most browsers offer  instructions on how to reset the browser to reject cookies in the “Help”  section of the toolbar. Rejecting cookies will prevent further use of  the AccountChek and AccountChek 3n1 services.

Information We Collect from Others
We  collect information about borrowers from the lender who orders the  account verification, from the financial institution(s) that provide the  account verification data, and from the payroll provider’s that provide  the employment and income verification data.

The information  provided by the lender includes the borrower’s name, e-mail address,  telephone number, the last four digits of his/her Social Security Number  (for identity authentication), and the name of the borrower’s  employer(s).

The information we receive from the borrower’s  financial institution(s) includes the summary and transactional  information from the accounts the borrower allows us to verify.

The  information we receive from the borrower’s payroll provider(s) includes  the summary of employment information and income information from the  accounts the borrower allows us to verify.

We will share this  information in individually identifiable form only in accordance with  this statement and our policies. We may share aggregated, non-personal  information. This may include information we obtained from third parties  in a form that does not reasonably permit the borrower to be  identified.

AccountChek works to deliver accurate, complete, and  current borrower information by pulling information directly from the  borrower’s financial institution and payroll provider via online  credentials. Data can be refreshed by the lender as needed to fulfill  underwriting obligations for the duration of the order.

HOW WE USE THE INFORMATION WE COLLECT
AccountChek  and AccountChek 3n1 use the information we collect to provide  verification and analysis of a borrower’s asset accounts, employment  information, and income data, respectively, to the requesting lender, to  administer our web site, and to improve our service.

AccountChek  and AccountChek 3n1 do not sell, share, license or transmit borrower  information with or to third parties without the express authorization  of the borrower.

WHO SEES THE INFORMATION WE COLLECT?
We will not disclose this information except as described in this policy.

Verification Service delivery: We will disclose the information we receive from the borrower’s  financial institutions and/or payroll provider to the requesting lender,  as well as to any other parties that the borrower authorizes us to  provide such information, to deliver the Verification of Deposit, Asset,  Income, and/or Employment services.

Disclosure for legal reasons: We may release personal information to third parties: (1) to comply  with valid legal requirements such as a law, regulation, search warrant,  subpoena or court order; or (2) in special cases, such as a physical  threat to the borrower or others, a threat to homeland security, a  threat to our system or network, or cases in which we believe it is  reasonably necessary to investigate or prevent harm, fraud, abuse, or  illegal conduct. If we are legally compelled to disclose your personal  information to a third party, we will make reasonable efforts to notify  the borrower unless doing so would violate the law or court order.

Agents and contractors: Contractors who assist in operating our business and providing products  or services sometimes have access to borrowers’ personal information.  These contractors include vendors and suppliers that provide us with  technology, services, and/or content for the operation and maintenance  of our site. Access to borrowers’ personal information by these  contractors is limited to the information reasonably necessary for the  contractor to perform its limited function. Contractors have an  obligation under their contracts with us to keep borrower information  confidential and to comply with our privacy and security policies.

Some  of these relationships may be with companies that co-brand portions of  their site and services, or that provide services to borrowers on our  behalf. Co-branded sites may have their own privacy policies posted on  their sites. If you visit a co-branded site, please read the privacy  policy that is posted on that site.

Direct Employees of AccountChek: Employees are NOT authorized to download information that is not  directly related to their work. Prior to downloading any software tools,  all employees are advised to notify an Operations staff member of this  intention. If help is needed, the local system administrator will  provide support. Employees are NOT authorized to download data from any  production, stage, or QA system without prior written approval. Prior to  downloading any data, all employees must follow the Data Privacy  Download Procedures. This includes any and all data that is  confidential, sensitive or legally protected, including log files.

AccountChek  is owned by Informative Research (“IR”). Employees must follow the IR  Privacy Policy and adhere to the IR Privacy Principles or be subject to  disciplinary action per the IR Employee Handbook. Employees will be  required to sign off yearly that they have read and understand this  policy.

Changes in our corporate structure: If all or part of our  company is sold, merged or otherwise transferred to another entity, the  personal information you have provided to us may be transferred as part  of that transaction. We will take steps to ensure that any personal  information that is transferred will not be used or shared in a manner  inconsistent with the Privacy Policy under which it was collected.

HOW WE SAFEGUARD PERSONAL INFORMATION
We  are committed to protecting the security of borrowers’ private  information through procedures and technology designed for this purpose.  This includes, but is not limited to:

• Limiting access to  personal information to only those employees who have a reasonable need  to access this information in order to provide our products and  services. Employees who misuse information are subject to disciplinary  action, including termination;
• Utilizing physical, technical, and procedural safeguards to help protect borrowers’ personal information; and
• Using  secure transport layer security (TLS) to help protect this information  while it is in transit between our servers and others’ computers and  hardware encryption devices. We use AES-256 encryption while it is being  stored on our servers.

WHAT BORROWERS CAN DO TO HELP KEEP PERSONAL INFORMATION SECURE
Log  out and close the browser: Closing the browser at the end of a session  erases any information it may have temporarily stored on your computer.

Install  antivirus software and spyware protection: Installing up-to-date  antivirus software and running it often will help thwart viruses and  other unwanted programs that can capture the contents of a borrower’s  system, including passwords.

CHANGES TO THIS POLICY
We  may change our privacy policy in the future, but we will not change our  practices until they have been posted at this website. If changes  occur, we will also show the date of revision. By using our web sites,  to which this privacy policy applies, you agree that we may notify you  of changes in our privacy policy through this website.

Responsibility  and accountability for developing, documenting, implementing,  enforcing, monitoring, and updating the Privacy Policy falls to the  Compliance Team whose contact information is available on the company  intranet and web page.

Privacy Incident of Breach
In  the event that IR suspects that borrower information has been  compromised, IR will make every effort to contact and inform borrowers  per its Incident Response Plan. This will include phone call or email.

CONTACT
The  AccountChek suite of products are automated asset, employment, and/or  income verification services provided by Informative Research. If you  have questions or comments about this privacy policy, please e-mail us  at info@informativeresearchcompany.com or write to Informative Research Inc., 13030 Euclid St, Ste 209, Garden Grove, CA 92843.

To request a copy of your consumer data supplied by Informative Research or an amendment to that information please email info@informativeresearchcompany.com  , or contact your lender directly.