PRIVACY POLICY

Last updated: June 13, 2025

We at ClosingLock, Inc. (“Closinglock,” “we,” “us,” or “our”) value the privacy of our customers and partners. The following privacy policy (the “Privacy Policy”), as modified from time to time, describes our practices in connection with information collected through our Closinglock.com website and any other linked pages, features, content, mobile applications, and any other services we offer from time to time in connection with any of the foregoing (collectively, the “Site”).

Updates to This Policy

We may revise this Privacy Policy from time to time. When we update our Privacy Policy, we will take appropriate measures to inform you, consistent with the significance of the changes we make. If you do not agree with our changes, please do not use the Site. Your continued use of our Site following the posting of changes to this policy means you accept those changes, unless additional consent is required under applicable law.

Children’s Data

We do not knowingly collect, solicit, use, or disclose personal information from children under the age of 13. If you are under 13, please do not attempt to register for the Site or send any information about yourself to us. No one under age 13 may provide any personal information to us. If we learn that a child under 13 has provided personal information to us without verification of parental consent, we will delete that information immediately.

We remind and encourage all parents to check and monitor their children’s online activities. Parents have the right to review and have deleted any personal information we may have inadvertently collected from their children and refuse to permit further collection of that information. If you believe that we might have any information from or about a child under 13, please contact us at [email protected].

What Information We Collect and How We Use It

We collect both personal information and non-personal information. Personal information is any information that can be used to individually identify you.  The personal information we collect includes your name, date of birth, demographics, the last four digits of your Social Security Number, email address, telephone number, fax number, postal address, credit card information and billing information and driver’s license or other government issued identification card. Additionally, you may be requested to verify your identity through the Site (the “Identity Verification Services”). In order to provide the Identity Verification Services, we may also collect certain biometric information, photos of you and your full Social Security Number.  Non-personal information includes information that does not personally identify you. The non-personal information we collect from you includes your real or personal property purchase transaction closing costs, tracking and usage information about your location, transaction information, information about your business and information on how you use our the Site .

Information You Provide Us

You may voluntarily provide us with your personal information in the following instances:

  • When you register for an account with the Site;
  • When you agree to our Terms of Service;
  • When you purchase and use products and services from the Site;
  • When you use the Site, including the Identity Verification Services;
  • When you arrange for the transfer of funds from your bank account to an account established to handle the closing of a real or personal property transaction;
  • When you sign up to receive email newsletters and other marketing or promotional materials from us;
  • When you request customer service from us;
  • When you participate in surveys, special events and promotions;
  • When you interact with Closinglock accounts via social media platforms and services; and
  • Any other place within the Site where you knowingly volunteer personal information.

Information We Automatically Collect

When you interact with the Site, our servers may keep an activity log that does not identify you individually. Generally, we automatically collect and store the following categories of non-personal information:

  • Demographic data of Site users;
  • Transaction information such as purchases and use of products and services when you do not provide your personal information to us when making such purchases or using such products or services;
  • Device information about your computer, mobile device, or other device that you use to access the Site, which may include your IP address, geolocation information, unique device identifiers, browser type, browser language, and other transactional information;
  • Usage information about your use of the Site, such as a reading history of the pages you view;
  • Additional traffic data, such as time and date of access, software crash reports, session identification number, access times, and referring website addresses;
  • Your search terms and search results; and
  • Other information regarding our users’ use of the Site.

We automatically receive and record information on our server logs from your browser, including your IP address, “cookie” information, and the page you requested.

Cookies and other tracking technologies (such as browser cookies, pixels, beacons, and Adobe Flash technology including cookies) are comprised of small bits of data that often include a de-identified or anonymous unique identifier. Websites, apps and other services send this data to your browser when you first request a web page and then store the data on your computer so the website can access information when you make subsequent requests for pages from that service. We may use these technologies to also collect and store information about your usage of the Site, such as the pages you have visited, content you have viewed, search queries you have run and advertisements you have seen.

Most browsers are initially set to accept cookies, but you can change your settings to notify you when a cookie is being set or updated, or to block cookies altogether. Please consult the “Help” section of your browser for more information. Please note that by blocking any or all cookies, you may not have access to certain features, content, or personalization available through the Site.

We may utilize email tracking systems that provide us with data such as who opened or forwarded an email, the time it was opened, and whether the reader clicked certain links within the email.

Information Provided by Our Service Providers

We may periodically obtain information about you from our partners, vendors, service providers and other independent third-party sources and will add it to our database of information. This may include any information that you provide to third parties that are associated with or whose products or services are integrated with the Site.

Information You Share on Social Media Sites

When you interact with any Closinglock account on a social media platform, such as Facebook, LinkedIn, Twitter, or Instagram, we may collect the personal information that you make available to us on that page or account, including your user ID and/or username, and any information you have made public in connection with that social media service.

How We Use Your Personal Information

We use the information we collect from you and about you to help us personalize and continually improve your experience with the Site.

We may use the information we collect from and about you in the following ways:

  • To provide you with the products and services you request from us;
  • To facilitate providing services to third parties, including Closing Businesses (as defined below), in connection with your use of the Site;
  • To post your user generated content to our Site as you request;
  • To communicate with you about your account or transactions with us and send you information about features on our Site;
  • To communicate with you about changes to our policies;
  • To personalize content and experiences on our Site;
  • To send you newsletters, offers, and promotions for our products and services;
  • Administer our contests, sweepstakes, promotions, and surveys; and
  • Detect, investigate, or prevent activities that may violate our policies or be illegal.

We may use, publish, share, distribute, or disclose personal information that has been aggregated with information from other users and otherwise anonymized and de-identified in a manner that does not allow third parties to de-identify the data or identify it as originating from you. Such information may help Closinglock identify and analyze training, demographic, and psychographic trends and information and report to third parties how many people saw, visited, or clicked on certain content, areas of the Site, or other materials. We may also use such data for research purposes and optimizing the Site’s functionality.

How We Share Your Personal Information

We do not and will not sell your personal information to any third party outside of Closinglock. We will only share personal information as provided below and within our company. We do not share your personal information with third parties for their marketing purposes unless you consent.

As further detailed below, you may provide personal information to us to facilitate your access to and interaction with a third-party provider. If you direct us to provide or consent to us providing your personal information to a third party, any usage of that information will be subject to the agreement(s) in place between you and that third party.

Subject to the foregoing, we may share your personal information as follows:

Title Companies, Escrow Companies, Closing Attorneys, and Similar Businesses that Handle Real or Personal Property Transaction Closings.

If you choose to use the Site we may share closing costs, payment information and wire instructions with title companies, escrow companies, closing attorneys and similar businesses that handle real or personal property transaction closings (collectively, “Closing Businesses”).

Likewise, if you are using the Site to communicate or exchange information with a Closing Business, we will share with them your personal information and any other documents or information that you use our services to deliver to them.

Lenders

If you are using the Site to communicate or exchange information with a lender, we will share with them your personal information and any other documents or information that you use our services to deliver to them.

Bank Transfer Providers

If you choose to use our service to transfer money from your bank account to an account of a Closing Business or other account established for the closing of a real or personal property transaction (a “closing account”), we will share your personal information with the banks or other financial institutions that will receive your funds and transmit them to the closing account.

Service Providers

We may make your information available to certain third-party service providers, such as contractors, agents, or sponsors, who help us manage or provide the services offered on our Site, such as hosting, billing, payment processing, marketing, analytics, customer service, fraud protection, etc. We require that all of our service providers keep personal information confidential and not disclose it to third parties and not use it for any other purpose.

Identity Verification Services

A Closing Business may require you to verify your identity through the Identify Verification Services. We may share your information with our third-party service provider that may collect additional personal information, including your biometric information, to verify your identity. The service provider will send us a summary of the results (including related personal information), which we may then share with the requesting Closing Business.

Emergency Situations

We may disclose your personal information if required to do so by law or in the good-faith belief that such action is necessary to: (a) conform to applicable law or comply with a legal process served on us or the Site; (b) respond to requests from public and government authorities; (c) protect and defend our rights or property, the Site, or our users; and (d) act under emergency circumstances to protect the personal safety of us, our affiliates, agents, or the users of the Site or the public.

Merger or Sale

If we sell all or part of our business or make a sale or transfer of our assets or are otherwise involved in a merger or transfer of all or a material part of our business, Closinglock may transfer your information to the party or parties involved as part of that transaction.

Former Customers

When you are no longer our customer, we may continue to share your personal information as disclosed above.

“Do Not Track” Practices

At this time, we do not honor do-not-track signals from browsers or other consumer choice mechanisms regarding the collection of behavioral tracking data. While we collect personal information from you as described above, we do not collect personal information from you to monitor your online activities across third party websites or online services and over time (also known as behavioral advertising or interest-based advertising). We do not use or allow third parties to collect personal information from you in the Site in order to monitor your online activities across third party websites or online services and over time.

Email and Other Communications

We may contact you by email or other means. For example, we may send you promotional offers or our newsletter. If you do not want to receive email from us, please let us know through the “unsubscribe” feature included in our communications.

Data Retention

We retain your personal information for as long as we have a business relationship with you. We may retain your account information and order information for our records for up to 7 years after your last transaction or as long as necessary to align with a legal or business need for such information. We will never retain your personal information for longer than permitted by applicable law or regulation.

Security

We are concerned about ensuring the security of your personal information. We use commercially reasonable efforts and at least the efforts required under applicable law or regulation to protect your personal information collected through the Site from access, loss, misuse, alteration, or destruction by any unauthorized party. Please understand, however, that no transmission of data over the internet or any other public network can be guaranteed to be 100% secure. We do not promise, and you should not expect, that your personal information or private communications will always remain private.

Links To or From Other Sites

Please note that, in addition to disclosures in the “How We Share Your Personal Information” above, the Site may link to other websites and online services operated by third parties. These websites and applications operate independently from us, and we do not control their privacy policies, which may be different from ours. We encourage you to review the privacy policies of any third party websites or applications to understand their data processing practices.

Notice to Non-US Users

If you are located outside of the United States of America, please be aware that your personal information will be transferred to the United States of America, the laws of which may be deemed by your country to have inadequate data protection. If you are located outside of the United States of America and voluntarily submit personal information to us, you thereby consent to the general use of such information as provided in this Privacy Policy and to the transfer of that information to, and/or storage of that information in, the United States of America.

California’s Shine the Light Law

California Civil Code Section 1798.83 permits users of our Site that are California residents to request certain information regarding our disclosure of the information you provide through the Site to third parties for their direct marketing purposes. To make such a request, please contact us by email at [email protected] or at the following address:

ClosingLock, Inc.

100 Congress Ave.

Suite 300

Austin, TX 78701

Attn: Compliance Officer

Any such request must include “California Privacy Rights Request” in the first line of the description and include your name, street address, city, state, and ZIP code. Please note that we are only required to respond to one Shine the Light request per consumer each year, and we are not required to respond to requests made by means other than through the e-mail address or mailing address provided in this Policy.

Participation in Financial Incentive Programs

We will notify you in the event we offer any financial incentive for the use of your personal information. Please note that participating in incentive programs is entirely optional, you will have to affirmatively opt-in to the program and you can opt-out of each program (i.e., terminate participation and forgo the ongoing incentives) prospectively by following the instructions in the applicable program description and terms.

Accessing and Updating Your Personal Information

To the extent provided by the law of your jurisdiction, you may:

  • Have the right to access certain personal information we maintain about you and request details about how we process it;
  • Request certain information regarding our disclosure of personal information to third parties;
  • Request that we update or correct inaccuracies regarding your personal information;
  • Object to our use of your personal information;
  • Ask us to block or delete your personal information from our database;
  • Request to download the information you have shared on the Services; and
  • Confirm whether Closinglock stores your data in the United States of America.

You may make these requests and any other inquiries about this Privacy Policy by contact us as set forth below. Any such requests are subject to the protection of other individuals’ rights and applicable law. Additionally, to help protect your privacy and maintain security, we may take steps to verify your identity before granting you access to the requested information.

Contact

If you have any questions about this Privacy Policy or its implementation, please contact:

ClosingLock, Inc.
100 Congress Ave. Suite 300
Austin, TX 78701
Attn: Compliance Officer
[email protected]