PRIVACY NOTICE

Last Updated: August 21, 2024

This Privacy Notice describes how Ardan, Inc. and its affiliates and subsidiaries, including Westcor Land Title Insurance Company, X1 Analytics, and Grid 151 (collectively, “Ardan”, “us”, “our”, “we”) collect, use, store, and share your information when: (1) you access or use this website or any of our following websites at www.wltic.com, www.x1analytics.com, www.ardaninc.com, and www.grid151.com (“Websites”); (2) when you access or use our products and/or services (“Services”); (3) when you communicate with us in any manner, including by email, telephone, and/or in person (“Communications”); and (4) from third party sources.

If you are a California resident, please see our California Privacy Notice.

WHAT TYPE OF INFORMATION DO WE COLLECT ABOUT YOU?

Depending upon how you interact with our Services, the nature of your Communications, how we interact with third-parties, and how you interact with our Websites, we may collect the following categories of information from and about you:

• Basic Identifying Information. Information such as your full name, postal address, e-mail address, phone number, and other similar identifiers.
• Additional Identifying Information Depending on the nature of your interaction with our Services, you may provide and we may collect the following:
  • Social Security Numbers.
  • Driver’s license numbers or related identification numbers.
  • Dates of Birth.
  • Bank account information.
  • Credit and debit card information.
• Demographic Information. Information such as:
  • Race, age, sex, gender, and ethnicity.
• Insurance Information. Information regarding your insurance purchases, including your title insurance policy number.
• Device Identifier and other Unique Identifiers. Information such as your device identifier, internet protocol (IP) address, cookies, beacons, pixel tags, mobile ad identifier, and other unique identifiers.
• Internet or Other Network Activity. Information such as your browsing or search history, and other information regarding your interactions with our Websites, emails, and advertisements.
• Geolocation Data. Information that permits us to determine your location so that we can determine the best Services to offer you.  
• Commercial Information. Information such as the nature of the Services you’ve considered from us, and related information.  
• User Content. Information such as your Communications with us and any other content you provide, such as social media profiles, photographs of receipts, images, videos, survey responses, comments, product reviews, testimonials, and other content.
• Audio and Visual Information. Information such as photographs, images, videos, and recordings of your voice (such as when we record customer service calls for quality assurance).
• Inferences. Information such as inferences drawn from or created based on the information identified above.

HOW DO WE COLLECT YOUR INFORMATION?

We collect your information in three ways:

Directly from you when you use our Services, Websites and engage in Communications, including but not limited to:

• Information you provide by filling forms in person or electronically, including information provided at the time of signing up for our Services, posting material or requesting further services or information.
• Information you provide when you access or use our Services.
• Information you provide when you enter a sweepstakes, contest or promotion sponsored or offered by us.
• Information you provide when you report a problem with our Websites.
• Records and copies of your correspondence (e.g., email address) if you contact us.
• Your responses to surveys that we might ask you to complete.
• Details of transactions you carry out through our Websites, and delivery of Services to you.
• Your search queries on the Websites.

Automatically when you access or use our Services and Websites, or when you engage in Communications, including but not limited to:

• Details of your visits to the Websites, including traffic data, location data, logs and other communication data.
• Information about your computer and mobile device, and internet connection, including your IP address, operating system, and browser type.
• Interactivity with an e-mail, including opening, navigating, and click-through information.

From third parties, including but not limited to:

• Data analytics providers for the purpose of receiving statistical data about your activity on our Websites.
• Third-party service providers, including but not limited to Internet service providers, fraud prevention services, claims processors, and related partners.
• Public sources, including local, state, and federal government agencies and departments, to facilitate your use of the Websites and to provide you with our Services.

HOW DO WE USE YOUR INFORMATION?

We use the information outlined in What Type of Information Do We Collect About You? for a variety of business and commercial purposes, including but not limited to:

• Provide the Websites to you;
• Provide the Products you have requested;
• Fulfill a transaction you requested or service your policy;
• Handle a claim;
• Create and manage your account;
• Operate the Applications and Websites, including access management, payment processing, Application and/or Website administration, internal operations, troubleshooting, data analysis, testing, research, and for statistical purposes;
• Respond to your requests, feedback, or inquiries;
• Comply with laws, regulations, and other legal requirements;
• Comply with relevant industry standards and our policies;
• Protect and enforce your rights and the rights of other users against unlawful activity, including identity theft and fraud;
• Protect and enforce our collective rights arising under any agreements entered into between us and you or any other third party;
• Protect the integrity and maintain security of our Websites and Services;
• Operate, evaluate, and improve our business;
• Provide you with information and advertisements about products, services, and promotions, from us or  affiliates, that may interest you;
• Deliver content tailored to your interests and the manner in which you use the Websites;
• Present content in a manner that is optimized for your device; and
• Measure and analyze the effectiveness of the Applications, Websites, and Products we provide to you.

HOW DO WE SHARE YOUR INFORMATION?

We do not sell your information. We may, however, disclose or share the information referenced in What Type of Information Do We Collect About You? with others for a variety of business and commercial purposes, including:

• With your consent. We may disclose or share your information with your consent. We may obtain your consent in writing; online, through “click-through” agreements; when you accept the terms of use on Websites; orally, either in person or on the phone; or by other means.
• In a business transfer. We may disclose or share your information as part of a corporate business transaction, such as a merger or acquisition, joint venture, corporate reorganization, financing, or sale of company assets, or in the unlikely event of insolvency, bankruptcy, or receivership, in which such information could be transferred to third parties as a business asset in the transaction.
• To non-affiliated third parties. We may disclose or share your information with certain third parties to facilitate your access and use of our Websites and Services, including but not limited to Internet service providers, advertising networks, data analytics providers, governmental entities, operating systems and platforms, and service providers who provide us a service (e.g., credit / debit card processing, claims processing, billing, shipping, repair, customer service, auditing, marketing, debugging to identify and repair errors that impair existing intended functionality on our Websites, and/or protecting against malicious, deceptive, fraudulent, or illegal activity).
• To subsidiaries and affiliates. We may disclose or share your information with our subsidiaries and affiliates to further facilitate your use of our Websites and Services, and to ensure the smooth and consistent operations of our Websites and Services by identifying and repairing errors that impede intended functionality and to protect against malicious, deceptive, fraudulent, or illegal activity.
• For legal process and protection. We may disclose or share your information to satisfy any law, regulation, legal process, governmental request, or where we have a good faith belief that access, use, preservation or disclosure of such information is reasonably necessary to:
  • Enforce or apply agreements, or initiate, render, bill, and collect for Services;
  • Protect our rights or interests, property or safety or that of others;
  • In connection with claims, disputes, or litigation – in court or elsewhere;
  • Protect users of our Websites and Services and other carriers or providers from fraudulent, abusive, or unlawful use of, or subscription to, such services;
  • Facilitate or verify the appropriate calculation of taxes, fees, or other obligations due to a local, state, or federal government.

LINKS TO THIRD PARTY SITES

Our Websites may contain links to third party websites and services. Please note that these links are provided for your convenience and information, and the websites and services may operate independently from us and have their own privacy policies or notices, which we strongly suggest you review. This Privacy Notice applies to our Websites only, and we do not accept any responsibility or liability for the policies or practices of any third parties.

THIRD PARTY TRACKING / DO NOT TRACK

Our Websites may, from time to time, collect information about your online activities, over time and across our different Websites. When you use our Websites, third parties may also collect information about your online activities, over time and across different internet websites, online or cloud computing services, online applications, or mobile applications. Some browsers support a “Do Not Track” feature, which is intended to be a signal to websites that you do not wish to be tracked across different websites you visit. Our Websites do not currently change the way they operate based upon detection of a “Do Not Track” or similar signal.

HOW DO WE STORE AND PROTECT YOUR INFORMATION?

Although no system can guarantee the complete security of your information, we take all commercially reasonable steps to ensure your information is protected in alignment with all applicable laws and regulations, as appropriate to the sensitivity of your information.

HOW LONG DO WE KEEP YOUR PERSONAL INFORMATION?

We keep your information for as long as necessary in accordance with the purpose for which it was collected, our business needs, and our legal and regulatory obligations. If we dispose of your information, we will do so in a way that is secure and appropriate to nature of the information subject to disposal.

COOKIES AND RELATED TECHNOLOGY

We may use cookies (browser and flash), beacons, pixel tags, scripts, and other similar technologies from time to time to support the functionality of our Websites and Services. A cookie is a piece of information contained in a very small text file that is stored in your Internet browser or elsewhere on your hard drive. Cookies are transferred from our Websites to your computer, phone or tablet, and allow us to identify your device whenever you return to our Websites. These technologies provide a better experience when you use our Websites and Services, and allow us to improve our services.

We may also use analytic software, such as Google Analytics and others, to help better understand how our Applications and Websites function on your device(s) and for other analytical purposes. To learn more about how Google uses data when you use our Applications and Websites, see How Google uses data when you use our partners’ sites or apps. You can opt-out of Google Analytics by installing Google’s opt-out browser add-on here https://tools.google.com/dlpage/gaoptout.

Below is an overview of the types of cookies and related technology we deploy, and your choices.

• Browser Cookies. A browser cookie is a small file placed on the hard drive of your computer. That cookie then communicates with servers, ours or those of other companies that we authorize to collect data for us and allows recognition of your personal computer. You may use the tools available on your computer or other device(s) to set your browser to refuse or disable all or some browser cookies, or to alert you when cookies are being set. However, if you refuse or disable all browser cookies, you may be unable to access certain parts or use certain features or functionality of our Websites. Unless you have adjusted your browser settings so that it refuses all cookies, we may use cookies when you direct your browser to our Websites.
• Beacons. Our Websites and e-mails may contain small electronic files known as beacons (also referred to as web beacons, clear GIFs, pixel tags and single-pixel GIFs) that permit us to, for example, to count users who have visited those pages or opened an e-mail and for other website-related statistics. Beacons in e-mail marketing campaigns allow us to track your responses and your interests in our content, offerings and web pages. You may use the tools in your device to disable these technologies as well.
• Third Party Technology. Our service providers, advertising partners, and ad networks may also use cookies and beacons to collect and share information about your activities both on our Websites and on other websites and applications. In addition, third parties that are unaffiliated with us may also collect information about you, including tracking your browsing history, when you use our Websites. We do not have control over these third party collection practices. If you wish to minimize these third party collections, you can adjust the settings of your browsers or install plug-ins and add-ins.
• Your Choices. You may wish to restrict the use of cookies or completely prevent them from being set. Most browsers provide for ways to control cookie behavior, such as the length of time they are stored. If you disable cookies, please be aware that some of the features of our Websites may not function correctly. To find out more on how to manage and delete cookies, visit www.aboutcookies.org. For more details on your choices regarding use of your web browsing activity for interest-based advertising, you may visit the following sites:
  • http://networkadvertising.org/
  • http://optout.aboutads.info/
  • http://youradchoices.com/

YOUR CHOICES

We provide you the ability to exercise certain controls and choices regarding our collection, use, storage, and sharing of your information. Please note that for some of these rights, such as the Right to Know and Right to Delete, we will verify your identity before we respond to your request. To verify your identity, we will generally match the identifying information provided in your request with the information we have on file about you. Depending on the sensitivity of the personal information requested to be deleted, we may also utilize more stringent verification methods to verify your identity, including but not limited to requesting additional information from you and/or requiring you to sign a declaration under penalty of perjury.

• Right of Correction. Regardless of where you live, you may submit a request that we correct or update the information we have about you.
• Right to Know. If you are a California resident, you have a right to ask that we disclose to you the categories and specific pieces of personal information we have collected about you in the 12 months preceding the date of your request, including a description of the categories of sources from which we have collected that information, the business or commercial purpose for collecting or sharing that information, and the categories of third parties with whom we have shared that information. To submit such a request, you may submit an e-mail to dataprivacy@wltic.com or call toll-free at (866) 629-5842. You may also designate an authorized agent to submit a request on your behalf.
• Right to Delete. If you are a California resident, you have a right to ask that we delete your personal information, subject to appropriate legal exceptions. To submit such a request, you may submit an e-mail to dataprivacy@wltic.com or call toll-free at (866) 629-5842. You may also designate an authorized agent to submit a request on your behalf.
• Right to Change Preferences. Regardless of where you live, you may change your choices for subscriptions, newsletters, and alerts. Please e-mail dataprivacy@wltic.com
• Right to Unsubscribe from Our Marketing and Advertising Communications. Regardless of where you live, you may choose whether you want to receive marketing and advertising from us. Please e-mail dataprivacy@wltic.com.
• Right to Control Advertising and Online Tracking. Regardless of where you live, you have a right to control how your information is tracked online. To learn more about these rights, see Cookies and Related Technologies.
• Right of Non-Discrimination. You have a right to exercise your rights under this section free of discrimination. We will not discriminate against you in any way if you choose to exercise your rights under this section.

CALIFORNIA RESIDENTS

California Consumer Privacy Act (CCPA). All terms and phrases used under this section shall have the same meaning as those terms are defined under the California Consumer Privacy Act of 2018 and related regulations (“CCPA”).

• Rights. Under the California Consumer Privacy Act of 2018 and its implementing regulations, you have a Right to Know, Right to Delete, Right to Correct and Right to Non-Discrimination. To learn more about these rights, see Your Choices.
• Notice of Sale and Sharing. Except for the limited business purpose stated below, We do not sell or share California resident personal information, nor have we sold California resident personal information in the past 12 months. We have no actual knowledge of selling the personal information of minors under the age of 16.
  

Category of Personal Data	Examples of Personal Data we Collect	Categories of Third Parties with Whom We Share Personal Data and How Long Available	Purpose for Disclosure
Government Identifiers you provide via val-ID™ by Westcor (“val-ID™”)	Government identification in the form of driver’s license, military identification cards, passports or other form of government-issued identification and information contained within such Government identification.	When you provide Identifiers via val-ID™ in response to an identity validation request, the Government Identifiers are made available to the entity that submitted the identity validation request via val-ID™ The Government Identifiers are available to the Third Party for 14 days after which the Government Identifiers are anonymized.	The Government Identifiers are disclosed for Permitted Purposes including for the purpose of verifying customer information, helping to ensure security and integrity by resisting illegal actions directed at our business. Specifically, the Government Identifiers are disclosed for the purpose of verifying the authenticity of the Government Identifiers provided.

• Notice of Collection. To learn more about the categories of personal information we have collected about California residents over the last 12 months, see What Information Do We Collect About You. To learn about the sources from which we have collected that information, the business and commercial purpose for its collection, and the categories of third parties with whom we have shared that information, please see How Do We Collect Your Information, How Do We Use Your Information, and How Do We Share Your Information.
• Notice of Disclosure. To learn more about the categories of personal information we have disclosed for a business purpose about California residents over the last 12 months, including the categories of third parties with whom we have shared that information, please see How Do We Share Your Information.

CHILDREN

Our Applications, Services, and Websites are not intended for children under the age of 18. This includes any links to other websites that we provide for our convenience. We don’t knowingly collect the information of children for any reason.

INTERNATIONAL JURISDICTIONS

Our Websites are hosted and offered in the United States of America (US), and are subject to US federal, state, and local law. If you are accessing the Websites from another country, please be advised that you may be transferring your information to us in the US.

CHANGES TO OUR PRIVACY PRACTICES

We may change this Privacy Notice from time to time. Any and all changes will be reflected on this page, and where appropriate provided in person or by another electronic method. The effective date will be stated at the top of this Privacy Notice. You should regularly check this page for any changes to this Privacy Notice. Your continued use, access, or interaction with our websites, services, and your continued communications with us after this statement has been updated represents you have read and understood this privacy notice.  

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