Last updated: November 2nd, 2022
Updates to This Policy
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 and includes (without limitation) your name, date of birth, the last four digits of your Social Security Number, email address, telephone number, fax number, postal address, credit card information and billing information, and all of the foregoing information about your business (except date of birth and Social Security Number) if you are a business. Non-personal information includes information that does not personally identify you. The non-personal information we collect from you includes your real property purchase transaction closing costs, tracking and usage information about your location, demographics, transaction information, and information on how you use our Site and the Services we provide.
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 arrange for the transfer of funds from your bank account to an account established to handle the closing of a real 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 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 user name, 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 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;
- Optimize or improve our products, services, and operations;
- Detect, investigate, or prevent activities that may violate our policies or be illegal; and
- Perform statistical, demographic, and marketing analyses of users of the Site and their purchasing patterns.
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. Subject to the foregoing, we may share all of your personal information as follows:
Title Companies, Escrow Companies, Closing Attorneys, and Similar Businesses that Handle Real Property Transaction Closings.
If you choose to use our Services we may share closing costs, payment information and wire instructions with title companies, escrow companies, closing attorneys and similar businesses that handle real property transaction closings (collectively, “Closing Businesses”).
Likewise, if you are using our Services 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.
If you are using our Services 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 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.
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.
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.
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.
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 are concerned about ensuring the security of your personal information. We use commercially reasonable efforts 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 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
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:
PO Box 200343
Austin, TX 78720
Attn: Abigail White
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.
PO Box 200343
Austin, TX 78720
Attn: Abigail White