PRIVACY POLICY

Introduction

IHL Escrow (“IHL”, “we”, “our”, or “us”) respects and is committed to protecting your privacy. That is why we have adopted this Privacy Notice (aka “Privacy Policy”). This Privacy Notice lets you know how and for what purposes we are collecting, processing, and using your Personal Information (as defined herein). We pledge that we will take reasonable steps to ensure that your Personal Information and Usage Information (as defined herein) will only be used in ways that comply with this Privacy Notice.

This Privacy Notice applies to any web page, email list, onsite electronic data collection, generic information, and Personal Information collected and/or owned by us, including but not limited to our IHL website, located at www.IHLEscrow.com. This Privacy Notice is in effect no matter the method of collection (such as by mail, facsimile, sign-up/sign-in page, survey, or promotion), including collection through our website and any online features, products, services, and/or programs we offer (collectively, the “Website”). IHL will treat any offline collection, uses, and disclosures of your Personal Information consistently with our online privacy practices set forth in this Privacy Notice.

This Privacy Notice does not apply to information collected by any third party, including through any application or content (including advertising) that may link to or be accessible from the Website, unless otherwise noted.

Please read this policy carefully to understand our policies and practices regarding your information and how we will treat it. If you do not agree with our policies and practices, your choice is not to use our Website. By accessing or using this Website, you agree to this privacy policy, and our Terms and Conditions of Use of this Website, which can be found here. This policy may change from time to time. Your continued use of this Website after we make changes is deemed to be acceptance of those changes, so please check the policy periodically for updates.

IHL is receiving your Personal Information as part of the escrow process to ensure proper title is in place. IHL may also be acting as a service provider to Century. In such cases, we may collect or receive Personal Information about or from individuals for the sole purpose of providing services to or on behalf of Century. In cases where we are providing services to or on behalf of Century, we do not share consumer information with third parties, other than (1) those with which Century has contracted to interface with the consumer application, (2) law enforcement or other governmental authority in connection with an investigation, or civil or criminal subpoenas or court orders, or (3) as otherwise set forth in this Privacy Notice. The privacy notices of Century shall apply to information collected by Century, including Human Resources.

Notice to Residents of CA, DE, or, NV, VT and users of the European Union

Additional privacy notices and policies specifically developed and maintained for residents of California, Delaware, Oregon, Nevada, Vermont and the European Union are entitled with the name of the jurisdiction and found near the end of this Notice.

Children Under The Age Of 18

Our Website is not intended for children under 18 years of age. No one under age 18 may provide any information to, or on, the Website. We do not knowingly collect personal information from children under 18. If you are under 18, do not use or provide any information on this Website, register on the Website, or provide any information about yourself to us, including your name, address, telephone number, email address, or any screen name or user name you may use. If we learn we have collected or received personal information from a child under 18 without verification of parental consent, we will delete that information. If you believe we might have any information from or about a child under 18, please contact us at contact@IHLescrow.com.

California residents under 16 years of age may have additional rights regarding the collection and sale of their personal information. Please see the section entitled “Your California Privacy Rights,” found below, for more information.

Personal Information We Collect About You On This Website And How We Collect It

We collect several types of personal information (“PI”) from and about users of our Website, including the following information:

Identifiers - name, postal address, e-mail address, unique personal identifier, IP address, and online identifier;
Personal information categories listed in the California Records statute Cal. Civ. Code § 1798.80(e) - name, address and telephone number;
Internet activity information – browsing history, your interaction with the Website.

We collect this information:

Directly from you when you provide it to us.
Automatically as you navigate through the site. Information collected automatically may include usage details, IP addresses, and information collected through cookies and other tracking technologies.
From Century Communities, Inc. and their subsidiaries as part of the purchase process. IHL is a wholly owned subsidiary of Century Communities, Inc. We will refer to Century Communities and their other affiliated companies as “Century”.
From third parties, for example, our website management vendor.

Personal Information We Collect About You Outside Of This Website And How We Collect It

We collect several types of personal information separate and apart from this Website - from and about our customers and potential customers, including the following information:

Identifiers - name, postal address, e-mail address, social security number, driver’s license number;
Personal information categories listed in the California Records statute Cal. Civ. Code § 1798.80(e) - name, signature, address, social security number, driver’s license, government identification documents, telephone number, financial information, including lender approvals, referral information and prequalification information;
Characteristics of protected classifications under California or federal law – gender, marital status, past marital status, age and national origin;
Internet activity – IP address, information about your interaction with the Website;
Geolocation data;
Commercial information;
Total annual household income, whether you are working with a realtor, as well as their name, company, and e-mail, whether you are working with a lender to finance property, whether you are paying in cash;
As to realtors, first name, last name, office telephone number, e-mail address, street address, city, zip code, metropolitan location, and community;
Professional or employment-related information – employment information, present employer, type of business, occupation, salary and combined gross income;
Any additional information you provide to us, and;
Other personal information needed to provide title related services to you.

We collect this information:

Directly from you when you provide it to us;
From lenders and realtors;
By acting as a service provider to Century;
Through Century’s homebuyer survey;
From third parties, for example, our remarketing vendor (for geolocation).

Personal information does not include:

Publicly available information from government records.
Deidentified or aggregated consumer information.
Information excluded from the CCPA's scope, like:
- Health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and the California Confidentiality of Medical Information Act (CMIA) or clinical trial data;
- Personal information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FRCA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver's Privacy Protection Act of 1994.

Length of Pi Retention

We retain personal information for as long as needed or permitted in light of the purposes for which it was obtained and consistent with applicable law. The criteria used to determine our retention periods include:

The length of time we have an ongoing relationship with you and provide our products and services to you (for example, for as long as you have an account with us or keep using our products and services);
Whether there is a legal obligation to which we are subject (for example, certain laws require us to keep records of your transaction or communications for a certain period of time before we can delete them); and
Whether retention is advisable in light of our legal rights (such as in regard to applicable statutes of limitations, litigation or regulatory investigations).

You are not required to provide any of this information, but if you choose not to provide certain information, we may not be able to provide you the requested service or complete your transaction.

Information We Collect Through Automatic Data Collection Technologies

As you navigate through and interact with our Website, our third-party vendor may use automatic data collection technologies to collect certain information about your equipment, browsing actions, and patterns, including:

Details of your visits to our Website, including traffic data, location data, logs, and other communication data and the resources that you access and use on the Website.
Information about your computer and internet connection, including the equipment you use to access our Website, usage details, and geolocation.

The information collected automatically may include personal information. It helps us to improve our Website and to deliver a better and more personalized service, including by enabling us to:

Estimate our audience size and usage patterns.
Store information about your preferences, allowing us to customize our Website according to your individual interests.
Speed up your searches.
Recognize you when you return to our Website.
Identify individual preferences for marketing purposes.

The technologies used for this automatic data collection may include:

Cookies: From time to time, we may use “cookies” to keep track of your visit and your use of the Website. A cookie is a small piece of data that your browser stores on your computer’s or device’s hard drive and is used to collect information, such as identifying those areas of the Website that you have visited in the past in order to enhance your next visit to the Website. You can choose whether to accept cookies by changing the settings of your browser, but some functionality of the Website may be impaired or not function as intended if you choose not to accept cookies.

Flash Cookies: Certain features of our Website may use local stored objects (or Flash cookies) to collect and store information about your preferences and navigation to, from, and on our Website. Flash cookies are not managed by the same browser settings as are used for browser cookies. For information about managing your privacy and security settings for Flash cookies, see the section entitled Choices About How We Use and Disclose Your Information, found below.

Web Beacons: Some of our web pages and electronic communications may contain images, which may or may not be visible to you, known as Web Beacons (sometimes referred to as “clear gifs”). Web Beacons collect only limited information that includes a cookie number, time and date of a page view, and a description of the page on which the Web Beacon resides.

Unique Identifier: We may assign you a unique internal identifier to help keep track of your future visits. We use this information to gather aggregate demographic information about our visitors, and we use it to personalize the information that you see on the Website and some of the electronic communications you receive from us. We keep this information for our internal use.

Third-Party Use of Cookies and Other Tracking Technologies

Some content or applications, including advertisements, on the Website are served by third-parties, including advertisers, ad networks and servers, content providers, and application providers. These third parties may use cookies, alone or in conjunction with web beacons or other tracking technologies, to collect information about you when you use our website. The information they collect may be associated with your personal information or they may collect information, including personal information, about your online activities over time and across different websites and other online services. They may use this information to provide you with interest-based (behavioral) advertising or other targeted content.

We do not control these third parties' tracking technologies or how they may be used. If you have any questions about an advertisement or other targeted content, you should contact the responsible provider directly. For information about how you can opt out of receiving targeted advertising from many providers, see the section entitled Choices About How We Use and Disclose Your Information, found below.

Google Analytics

Our Website uses Google Analytics, a web analytics service provided by Google. Google Analytics uses cookies and similar technologies to collect and store anonymous information about you, which may include the non-personal information described above. You can read information about how Google Analytics may use your data at http://www.google.com/policies/privacy/partners/, Google’s Privacy Policy at http://www.google.com/intl/en/policies/privacy/, and Google Analytics Terms of Use at http://www.google.com/analytics/terms/us.html. Our Website may use certain features of Google Analytics, including:

(a) “Demographics and Interest Reporting” to analyze information regarding the interests and demographics of users of the Website. We use such non-personal information in the same manner as we use other non-personal information as described in this Privacy Policy.

(b) “Remarketing with Google Analytics” to place ads on other sites directed to people who have visited the Website.

(c) “Google Display Network Impression Reporting” to report how people’s interactions with our ads relate to their visits to the Website.

You can opt-out of Google Analytics for Display Advertising and customize Google Display Network ads by changing the ad settings at https://support.google.com/ads/answer/2662856. You also can opt-out from being tracked by Google Analytics in the future by downloading and installing Google Analytics Opt-out Browser Add-on for your current web browser at https://tools.google.com/dlpage/gaoptout/.

Third Party Collection

The following third parties may collect your personal information when you visit our Website:

Workday - https://www.workday.com/en-us/privacy.html
ADP - https://www.adp.com/privacy.aspx
Sterling - https://privacy.sterlingcheck.com
Fidelity - https://www.fidelity.com/privacy-policy
UMR - https://www.umr.com/tpa-ap-web/?navDeepDive=publicPrivacyStatement
Voya Financial - https://www.voya.com/privacy-notice
Delta Dental - https://www.deltadental.com/us/en/about-us/privacy-policy.html
EyeMed - https://www.eyemed.com/en-us/online-privacy-policy
Kognitiv: https://kognitiv.com/legal/privacy-policy/
Brown & Brown: https://www.bbrown.com/privacy-policy/ and https://www.bbinsurance.com/ccpa-privacy-notice/?_gl=1%2A15sai5x%2A_ga%2AMTc4OTk1NTgwNS4xNjcxNzM0ODU0%2A_ga_C939J7GPRT%2AMTY3MTczNDg1My4xLjEuMTY3MTczNDg3Mi40MS4wLjA
One Source Virtual: https://www.onesourcevirtual.com/privacy
Alerus: https://alerus.com/about/privacy-legal/
JobVite: https://www.jobvite.com/privacy-policy/
Traliant: https://learn2.traliant.com/privacy-policy/
com: https://www.salary.com/legal/pp/#:~:text=Customer%20Data%20consists%20of%20data,of%20Salary's%20Service(s).

Business Purposes For Collection Of Your Personal Information

We collect personal information from you for the following business purposes, and use it in the following ways:

To present our Website and its contents to you.
To fulfill or meet the reason you provided the information. For example, if you share your name and contact information to request additional information or marketing materials, we will use that personal information to respond to your inquiry. If you provide your personal information to confirm information for the purchase a home, we will use that information to assist in the closing of the sale of the home.
To provide you with products and services or any affiliate or third party who is obtaining services on your behalf or in connection with a transaction involving you.
To improve our products and services.
To conduct sales and marketing analysis.
To personalize your experience on the Website.
To communicate with you.
To inform you about IHL’s, our affiliates’ and third parties’ products and services, jointly or independently.
To fulfill any other purpose for which you provide it.
To notify you about changes to our Website or any products or services we offer or provide through it.
In any other way we may describe when you provide the information.
For any other purpose with your consent.
To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.
As described to you when collecting your personal information or as otherwise set forth in the CCPA.
To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of Century's assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by Century about our Website users is among the assets transferred.

IHL 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 Your Information

We may disclose aggregated information about our users, and information that does not identify any individual, without restriction.
We may disclose personal information that we collect, or you provide as described in this privacy policy:
To our subsidiaries and affiliates.
To our outside marketing consultant.
To our outside lending and escrow/title companies.
To our outside option vendors.
To our outside survey companies.
To other outside contractors, service providers, and third parties we use to support our business.
To a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of IHL’s assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by IHL about our Website users is among the assets transferred.
To fulfill the purpose for which you provide it.
For any other purpose disclosed by us when you provide the information.
For any other purpose with your consent.

We may also disclose your personal information:

To comply with any court order, law, or legal process, including to respond to any government or regulatory request.
To enforce or apply our Terms and Conditions of Use of this Website https://www.IHLescrow.com/terms-of-use and other agreements.
If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of IHL, our customers, or others. This includes exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction.

Sharing Personal Information

IHL may disclose your personal information to a third party for a business purpose. When we disclose personal information for a business purpose, we enter a contract that describes the purpose and requires the recipient to both keep that personal information confidential and not use it for any purpose except performing the contract.

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

Sellers of property
Service providers
Contractors
Outside marketing consultant
Lenders and escrow/title companies

Business Purpose Of Disclosure Of Personal Information

In the preceding twelve (12) months, IHL has disclosed the following categories of personal information for a business purpose:

Identifiers - name, social security number, driver’s license number and postal address;
Personal information categories listed in the California Records statute Cal. Civ. Code § 1798.80(e) - name, address, telephone number;
Characteristics of protected classifications under California or federal law – gender, marital status, past marital status and age;
Commercial information – records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories;
Professional or employment-related information – employment information, present employer, type of business, occupation, salary and combined gross income.

Business Purposes Of Sharing Of Your Personal Information

We have shared personal information from you for the following business purposes:

To present our Website and its contents to you.
To fulfill or meet the reason you provided the information. For example, if you provide your personal information to purchase a home, we will share that information to assist in closing the sale of the home.
To provide you with information, products, or services that you request from us.
To verify funding, lending and referral payments.
To conduct sales and marketing analysis.
To fulfill any other purpose for which you provide it.
In any other way we may describe when you provide the information.
For any other purpose with your consent.

Choices About How We Use and Disclose Your Information

We strive to provide you with choices regarding the personal information you provide to us. We have created mechanisms to provide you with the following control over your information:

Tracking Technologies and Advertising. You can set your browser to refuse all or some browser cookies, or to alert you when cookies are being sent. To learn how you can manage your Flash cookie settings, visit the Flash player settings page on Adobe's website. If you disable or refuse cookies, please note that some parts of this site may then be inaccessible or not function properly.
Disclosure of Your Information for Third-Party Advertising. If you do not want us to share your personal information with unaffiliated or non-agent third parties for promotional purposes, you can opt-out by checking the relevant box located on the form on which we collect your data. You can also always opt-out by sending us an email with your request to contact@IHLescrow.com.
Promotional Offers from the IHL. If you do not wish to have your contact information used by the IHL to promote our own or third parties' products or services, you can opt-out by checking the relevant box located on the form on which we collect your data or by sending us an email stating your request to contact@IHLescrow.com. If we have sent you a promotional email, you may send us a return email asking to be omitted from future email distributions. This opt out does not apply to information provided to the IHL as a result of a product purchase, product service experience or other transactions.

We do not control third parties' collection or use of your information to serve interest-based advertising. However, these third parties may provide you with ways to choose not to have your information collected or used in this way. You can opt out of receiving targeted ads from members of the Network Advertising Initiative ("NAI") on the NAI's website.

Data Security

We have implemented measures designed to secure your personal information from accidental loss and from unauthorized access, use, alteration, and disclosure. All information you provide to us is stored on our secure servers behind firewalls.

The safety and security of your information also depends on you. Where we have given you (or where you have chosen) a password for access to certain parts of our Website, you are responsible for keeping this password confidential. We ask you not to share your password with anyone.

Unfortunately, the transmission of information via the internet is not completely secure. Although we do our best to protect your personal information, we cannot guarantee the security of your personal information transmitted to our Website. Any transmission of personal information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on the Website.

Privacy Outside the Website

The Website may now or in the future contain links to other websites. IHL is not and cannot be responsible for the privacy practices or the content of any of those other websites. Please check with those websites in order to determine their privacy policies and your rights under them.

We may use the services of third party service providers, for example to process payments and other transactions or to provide analytics services. By using our Website, you grant us all necessary rights and consents under applicable laws to disclose to the third party service providers – and/or allow those third party service providers to collect, use, retain and disclose to us – any Personal Information for purposes of providing services to you, including data that we may collect directly from you using cookies or other similar means.

European Union Users

The Website and our products and services are hosted in the United States and are governed by United States law. If you are using the Website or our products or services from outside the United States, please be aware that your Personal Information may be transferred to, stored, and processed in the United States where our servers are located and our central database is operated. The data protection and other laws of the United States and other countries might not be as comprehensive as those in your country. By using the Website or our products and services, you consent to your Personal Information being transferred to our facilities and to the facilities of those third parties with whom we share it as described in this Privacy Notice.

For Delaware Residents: We will not share your Personal Information with nonaffiliated third parties, except as permitted by law. Currently, we do not recognize “do not track” requests from Internet browsers and similar devices. To find out more about “do not track,” you may wish to visit www.allaboutdnt.com.

For California Residents: If you are a California resident, California law may provide you with additional rights regarding our use of your personal information. To learn more about your California privacy rights, see the following portions of this privacy policy.

California's "Shine the Light" law (Civil Code Section § 1798.83) permits users of our Website that are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please send an email to contact@IHLescrow.com or write us at: IHL Escrow, Attn: Privacy Officer, 4695 MacArthur Court, Suite 350, Newport Beach, California 92660.

This privacy notice for California residents supplements the information contained in the previous portions of this privacy policy and applies solely to all visitors, users, and others who reside in the State of California ("consumers" or "you"). We adopt this notice to comply with the California Consumer Privacy Act of 2018 (CCPA) along with any amendments and regulations thereto (including the California Privacy Rights Act (CPRA)), and any terms defined in the CCPA have the same meaning when used in this notice.

Your Rights And Choices - California Residents

The CCPA provides consumers (California residents) with specific rights regarding their personal information. This section describes your CCPA rights and explains how to exercise those rights.

The following table provides a summary of the categories of personal information collected, specific types of personal information that may be collected, how the personal information is collected and the business reason for such collection.

Information We Collect (CA)

We collect through our Website and normal business operations information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or device ("personal information"). In particular, IHL has collected the following categories of personal and usage information from its consumers within the last twelve (12) months:

Personal Information: The types of information that IHL collects may include, among other things, the following categories of information (collectively, “Personal Information”) For California employees, please see the Century Privacy Policy:

contact information (e.g., your first name, last name, title, physical address, zip code, phone number, email address);
user name, password and security questions and answers;
demographic information, such as your date of birth and nationality, which allows us to verify your identity and comply with federal law;
social security number (SSN), driver’s license, passport, and other government ID numbers and government documents;
Internet Protocol (or IP) address or device ID/UDID, protocol and sequence information;
commercial information; and
other personal information needed to provide title related services to you.

You are not required to provide any of this information, but if you choose not to provide certain information, we may not be able to provide you the requested service or complete your transaction.

Usage Information: The types of usage information that IHL collects may contain generic information about you when you visit the Website, which may include, among other things, the following categories of information (collectively, “Usage 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 server banners, and operating system and fingerprinting data; and
aggregated information, including De-identified Data (as defined herein).

Personal information does not include:

Publicly available information from government records.
Deidentified or aggregated consumer information.
Information excluded from the CCPA'sscope, like:
- Health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and the California Confidentiality of Medical Information Act (CMIA) or clinical trial data;
- Personal information covered by certain sector-specific privacylaws, including the Fair Credit Reporting Act (FRCA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver's Privacy Protection Act of 1994.

IHL obtains the categories of personal information listed above from the following categories of sources:

Applications or other forms we receive from you or your authorized representative, which may include information about your assets and income and identifying information, such as name, address and SSN;
Your communication to us (for example, an inquiry about a property, or a request to sign up for a mailing list or to receive updates from us);
Information we receive from you through the Website and as a result of your use of our services;
Information we receive from your computer or mobile device;
Information collected automatically as you navigate through the site. Information collected automatically may include usage details, IP addresses, and information collected through cookies and other tracking technologies;
Information we receive from our affiliates, partners or service providers;
Information from consumer or other reporting agencies and public records maintained by governmental entities that we obtain directly from those entities, from our affiliates or others, such as your creditworthiness and credit history; and
Information we receive from other sources, as permitted by applicable laws, rules and regulations.

Use of Personal Information for a Business Purpose (CA)

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

To provide products and services to you or any affiliate or third party who is obtaining services on your behalf or in connection with a transaction involving you.
To improve our products and services.
To conduct sales and marketing analysis.
To personalize your experience on the Website.
To communicate with you.
To inform you about IHL’s, our affiliates’ and third parties’ products and services, jointly or independently.
To fulfill any other purpose for which you provide it.
To notify you about changes to our Website or any products or services we offer to provide through it.
In any other way we may describe when you provide the information.
For any other purpose with your consent.

Sharing Personal Information (CA)

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

Service providers.
Outside marketing consultant.
Third party vendors.

Disclosures of Personal Information for a Business Purpose (CA)

In the preceding twelve (12) months, IHL has disclosed the following categories of personal information for a business purpose:

Financial information.
Name, address, zip code, e-mail address and phone number.

Sales of Personal Information (CA)

In the preceding twelve (12) months, IHL has not sold personal information.

Your Rights and Choices (CA)

The CCPA provides consumers (California residents) with specific rights regarding their personal information. This section describes your CCPA rights and explains how to exercise those rights.

Right to Opt-Out Of The Sale Or Sharing Of Personal Information (CA)

IHL does not sell your personal information. You have the right to opt-out of the sale or sharing of your personal information.

You have the right to direct to limit the use and disclosure of your sensitive personal information at any time (the "right to opt-out"). To exercise the right to limit the use and disclosure, you (or your authorized representative) may submit a request to us by visiting the following Internet Web page link: Exercise My Rights

You do not need to create an account with us to exercise your limit use and disclosure rights. We will only use personal information provided in a limit use request to review and comply with the request.

Please note that IHL can use sensitive personal information for the following purposes, and you do not have the right to limit the use and disclosure of sensitive personal information being used in the following ways:

To perform the services or provide the goods reasonably expected by an average consumer who requests those goods or services.
To detect security incidents that compromise the availability, authenticity, integrity, and confidentiality of stored or transmitted personal information, provided that the use of the consumer’s personal information is reasonably necessary and proportionate for this
To resist malicious, deceptive, fraudulent, or illegal actions directed at the business and to prosecute those responsible for those actions, provided that the use of the consumer’s personal information is reasonably necessary and proportionate for this purpose.
To ensure the physical safety of natural persons, provided that the use of the consumer’s personal information is reasonably necessary and proportionate for this purpose.
For short-term, transient use, including, but not limited to, nonpersonalized advertising shown as part of a consumer’s current interaction with the business, provided that the personal information is not disclosed to another third party and is not used to build a profile about the consumer or otherwise alter the consumer’s experience outside the current interaction with the business.
To perform services on behalf of the business, such as maintaining or servicing accounts, providing customer service, processing or fulfilling orders and transactions, verifying customer information, processing payments, providing financing, providing analytic services, providing storage, or providing similar services on behalf of the business.
To verify or maintain the quality or safety of a service or device that is owned, manufactured, manufactured for, or controlled by the business, and to improve, upgrade, or enhance the service or device that is owned, manufactured by, manufactured for, or controlled by the business.

Right To Deletion

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

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, 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.
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 free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et. seq.).
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.
Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
Comply with a legal obligation.
Make other internal and lawful uses of that information that are compatible with the context in which you provided it.

Right to Correction (CA)

You have the right to request correction of inaccurate personal information maintained by us about you. Upon receipt of a verifiable request from you, we will use commercially reasonable efforts to correct the inaccurate personal information.

Response Timing and Format (CA) We endeavor to respond to a verifiable consumer request for access, correction or deletion within forty-five (45) days of its receipt, and a verifiable opt-out or limit use request within fifteen (15) days from receipt. If we require more time (up to 90 days), we will inform you of the reason and extension period in writing.

Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request's receipt, or after January 1, 2022 – as directed by you. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your personal information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance.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.

Personal Information Sales Opt-Out and Opt-In Rights for Younger Customers (CA) If you are 16 years of age or older, you have the right to direct us to not sell your personal information at any time (the "right to opt-out"). We do not sell the personal information of consumers we actually know are less than 16 years of age, unless we receive affirmative authorization (the "right to opt-in") from either the consumer who is between 13 and 16 years of age, or the parent or guardian of a consumer less than 13 years of age. Consumers who opt-in to personal information sales may opt-out of future sales at any time.

How to Exercise Your Rights – California Residents

If you would like to exercise any of your rights as described in this Privacy Policy, please do so by one (or more) of the following methods:

Visiting IHLEscrow.com and going to the following link: Exercise My Rights
Calling us at (844) 775-7758
E-mailing us at contact@IHLescrow.com
Sending us mail at IHL Escrow, Attn: Privacy Officer, 4695 MacArthur Court, Suite 350, Newport Beach, CA 92660

Please note that you may only make a data access or data portability disclosure request twice within a 12-month period.

If you choose to contact us directly, you will need to provide us with:

Enough information to identify you (e.g., your full name, address and customer or matter reference number)); and
A description of what right you want to exercise and the information to which your request relates.

We are not obligated to make a data access, correction, deletion or data portability disclosure if we cannot verify that the person making the request is the person about whom we collected information or is someone authorized to act on such person’s behalf.

Any personal information we collect from you to verify your identity in connection with your request will be used solely for the purposes of verification. The verification we may request will reflect personal information that you have previously provided to us. 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.

You may only make a verifiable consumer request for access or data portability twice.

Non-Discrimination (CA)

We 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 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.

However, we may offer you certain financial incentives permitted by the CCPA that can result in different prices, rates, or quality levels. Any CCPA-permitted financial incentive we offer will reasonably relate to your personal information's value and contain written terms that describe the program's material aspects. Participation in a financial incentive program requires your prior opt in consent, which you may revoke at any time.

For Nevada Residents: Nevada consumers have the right to opt-out of having their personal information sold. A Nevada resident may, at any time, submit a verified request directing IHL not to make any sale of any personal information that IHL has collected or will collect about the consumer. Contact information to make such an opt-out request can be found near the end of this Privacy Notice. You may also be placed on our internal Do Not Call List by calling ((833) 256-4448) or by contacting us via the information set forth at the end of this Privacy Notice.

For Oregon Residents: We will not share your Personal Information with nonaffiliated third parties for marketing purposes, except after you have been informed by us of such sharing and had an opportunity to indicate that you do not want a disclosure made for marketing purposes.

For Vermont Residents: We will not share your Personal Information with nonaffiliated third parties, except as permitted by Vermont law, such as to process your transactions or to maintain your account. In addition, we will not share information about your creditworthiness with our affiliates except with your authorization.

Not Financial Advice

You acknowledge and agree that by providing you with access to and use of the Website, we are not providing financial opinions or advice on any of the matters discussed or included on the Website, and we will not be liable to any party for any act or failure to act relating to any information included on the Website. You further acknowledge that none of the information contained on the Website constitutes a solicitation, offer, opinion, or recommendation by IHL to buy or sell any security, or to provide legal, tax, accounting, or investment advice or services regarding the profitability or suitability of any security or investment.

Your Consent to This Privacy Notice

By using the Website, you consent to the collection and use of your information (including Personal Information) by us as specified above or as we otherwise see fit, in compliance with this Privacy Notice, unless you inform us otherwise by means of the procedure identified below. If we decide to change this Privacy Notice or some part of it, we will make an effort to post those changes on this web page so that you will always be able to understand what information we collect, how we use that information and under what circumstances we may disclose that information to others. Your use of the Website following our publication of any amendment of this Privacy Notice will signify your assent to and acceptance of its revised terms for all previously collected information and information collected from you in the future. We may use comments, information or feedback that you may submit in any manner that we may choose without notice or compensation to you.

Contact Information

If you have any questions or comments about this notice, the ways in which IHL collects and uses your information described herein, your choices and rights regarding such use, or wish to exercise your rights under California law, please do not hesitate to contact us at:

Phone: +1 (844) 775-7758

Website: www.ihlescrow.com

Email: contact@IHLescrow.com

Postal Address:

IHL Escrow

Attn: Privacy Officer

4695 MacArthur Court, Suite 350

Newport Beach, CA

Changes To Our Privacy Policy

IHL reserves the right to amend this privacy notice at our discretion and at any time. It is our policy to post any changes we make to our privacy policy on this page. If we make material changes to how we treat our users' personal information, we will notify you through a notice on the Website home page. The date the privacy policy was last revised is identified at the top of the privacy policy and below. You are responsible for ensuring we have an up-to-date active and deliverable email address for you, and for periodically visiting our Website and this privacy policy to check for any changes. Your continued use of our Website following the posting of changes constitutes your acceptance of such changes.