Effective Date: June 1, 2022
Introduction
In this privacy policy, the words “we,” “us,” and “our” mean Investors United Title Corp., doing business as IRA Title Pro. The words “you” and “your” mean any visitor or user of a website or social media site (a “Site” or the “Sites”) that we administer and provide for your online interactions with us. The Sites covered by this policy include iratitlepro.com and other websites and social media sites that we administer and provide for your use in interacting with us.
We offer a broad spectrum of services that focus on all stages of the home lifecycle: buying, selling, closing. We carefully evaluate how to use data from and about you, to make sure we use that information to provide value for you. If you have any questions we haven’t answered by this policy, you can always contact us using any of the options shown in the Contact Information section.
When you use our services to find, buy, or sell your home, get a mortgage, or connect to a Closing Agent, we know that we have a responsibility to respect your privacy and we are committed to protecting it through our compliance with this policy. This policy describes the information we collect, why we use it, who we share it with, and how we protect it.
This policy generally applies to the:
- Information we collect when you visit and use our Site;
- Information we collect when you submit and exchange electronic messages with us through our Site; and
- Information we collect when you interact with our advertising and applications on third-party websites and services, if those applications or advertising include links to this policy.
This policy 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 this Site.
Additional privacy rights and notices will apply if you are a California resident. See the section below called Your California Privacy Rights for more information about your rights under California law.
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 to not use our Site. By accessing or using this Site, you agree to this privacy policy. This policy may change from time to time (see the section below called Changes To Our Privacy Policy), so please check this policy periodically for updates. If we change the policy on this Site and you continue to use it, you agree that your continued use of the Site after the effective date shown at the top of this policy will mean you have accepted all changes in the updated policy.
Changes To Our Privacy Policy
We are always reviewing our privacy practices to make sure they comply with this policy. Sometimes, we’ll need to update the policy to reflect changes in our products, technology, and other uses of data. We won’t change the policy in a way that reduces your rights or significantly changes the way we use or share data without disclosing ahead of time and giving you a chance to stop using our services.
Children Under the Age of 18
Our Site is not intended for children under 18 years of age. No one under age 18 is allowed to provide personal information on this Site. 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 Site 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 use any of the options in the Contact Information section below to notify us.
Information Collected by Investors United Title Corp.
While using our services, we collect a variety of information about you and your devices. Some of this is personal information that identifies you directly (such as your name and contact information), while some of it is merely associated with you through your account, profile, or device (such as the devices you use to access our Site, the dates and times you use our Site, IP addresses, location data, and the homes you choose to save). We may collect this information directly from you when you provide it to us through the Site. We may also collect it automatically as you navigate through the Site or from third parties, such as our business partners and others that provide services associated with the ones we provide on your behalf.
The type of data we collect about you depends on how you request and obtain our services. If you only use our services to generate closing cost estimates, we’ll receive less information about you than if we help sell your home or if you use any of our other transaction services. Even if you don’t specifically have an account with us, we may still collect some data about you, such as an email address and phone number.
Information Provided or Created Using Our Services
When you request or obtain our services, we often ask you for information about yourself. This usually includes basic things, such as your name, email address, and phone number.
Information from Public Sources and Third Parties
We collect information from integrated Closing Agents and other real property sources, such as county and state tax and property records, government agencies, and multiple listing services (or MLS). Most of this information relates to properties, not people. But some information we collect, such as the identity of a property’s owner or real estate license information, may relate to individuals.
We also collect information about you from various third parties to ensure better service for you or as part of the employment application process. This may include demographic information and other attributes about you.
Information Collect as You Use Our Services
Along with the information you give us directly, we automatically collect a variety of information as you visit our Site and use our services.
Activity Information
We collect information about how you use our Site and services. This includes aspects like a desire to sell and information entered into our Site, including but not limited to list prices, addresses, closing costs, and tax proration amounts. When you call or text us or our integrated Closing Agents, we receive information about your call or text, including its date and time, your phone number, and the content of the call or text.
Device Information
Similar to other websites and apps, we also collect information about the browsers and devices you use when you visit and use our Site. The information we gather includes browser or device model and settings, operating system, unique identifiers, and the version of the app you’re using. We also collect information about how your browsers and devices interact with our services, including IP address, crash reports, system activity, and the date, time, and the URL of the site you visited before visiting our Site.
You manage our collection of certain data, such as your mobile device model or the language your mobile device uses by adjusting the privacy and security settings on your mobile device.
Location Information
If you enable location services on your mobile device, we then collect the location of your device. We use that information to provide you with location-based information and ads, such as homes in your area, and to also offer location-based services, such as allowing you to unlock and tour our homes on your own schedule and claim your home through us and our Site. If you don’t want to use these specific features, you can simply turn off location services on your device.
We also collect location information for similar purposes from your browser, if enabled. You can also disable access any time through your browser settings.
Cookies, Pixel Tags, and Other Tracking Technologies
We and our partners use various tools to collect data when you visit our Sites, including cookies, pixel tags, and other similar technologies. Cookies are specs of electronic data that can be transferred to your computer or other device to identify your browser.
When you visit and use our Site, we and our partners may use cookies and other tools to collect information about how you view and use our services and Site content and to connect your activity with other information we store about you. The use of cookies helps us serve you better by understanding what you’re interested in, by tracking trends, measuring the effectiveness of ads, saving your preferences, and storing information you may want to retrieve on a regular basis, such as your favorite homes.
Social Networks
If you use social media logins (like Google and Facebook) to log in to our Site, we may also access your public social media profile information. You can always limit this sharing by modifying your social media service settings.
Inferences
To improve our services by making them more useful to you, we also use data about your activity to understand and infer your preferences. For example, if you usually search for homes for rent rather than homes to buy, we may assume that you are not looking to buy a home, so you’ll be shown more information that’s helpful for renters.
Commercial Information
We collect information about the products and services you purchase or consider purchasing from us. This includes products for professionals, such as our advertising products as well as consumer services.
Completing Transactions
When you use our services to complete real estate transactions, such as buying or selling your home, we use your personal information to verify your identity and complete the transaction.
Personal Communication and Connection with Others
We use the contact information you provide, such as your phone number and email address, to communicate with you about our services. This includes responding to comments, questions, and requests you send us. It also includes notifying you of transaction or service updates and changes. We may also inform you about our services, offers, promotions, news, and other updates we believe may be of interest to you.
If you ask us, we can also use your information to connect you to a Closing Agent for when you want to finish and proceed to close on a sale.
Personalizing Your Experience
We use the information collected about you and your activity on our Site to personalize the services we offer, such as advertising, content, or features that we think you might like. This includes customized search results that match your preferences and prior search criteria. Also, if you ask us, we can connect you with a real estate professional that’s best suited to accommodate your needs.
Other Uses of Your Info
We also use your data to detect, investigate, and prevent fraudulent transactions and other illegal activities in order to protect the rights and property of Investors United Title Corp., its customers, and others.
Occasionally, there may be a reason we’d like to use your information in a way that is not disclosed on this page, but if that happens, we’ll let you know so you can decide if you’re comfortable with us doing so.
Information You Ask Us to Share.
We share information when you ask us to share it. For example, if you choose to contact a Closing Agent through our platform, we will forward your name and contact information to the Closing Agent.
Service Providers and Business Partners
When we integrate with a Closing Agent provider to help operate our business and close real estate transactions, we may need to disclose certain personal information about you to the Closing Agent that it needs to provide the services you request. We allow the use of information only to perform the service you’ve asked us or the Closing Agent to perform. We vet all service providers carefully, and Investors United Title Corp. always accepts responsibility for the privacy of your information that is shared with our service providers.
When we work directly with other businesses to offer products and services to you, we may share information with those partners only as needed to optimize products and services, which is also subject to the terms of this privacy policy.
Legal and Compliance Transfers
When we need to disclose personal information about you to comply with a legal or regulatory requirement, including responding to a subpoena or other lawful government request for data, we will share information that’s only necessary to comply with that requirement. We’ll disclose before sharing your information in these situations unless we’re prohibited from doing so.
If Investors United Title Corp. is involved in a merger, acquisition, or any transfer or sale of to some capacity, whether it’s a matter of concern or as part of bankruptcy, liquidation, or similar proceeding, we may share your information in connection with that transaction.
Public and De-identified Data
We may share information that is collected from public sources or that you choose to share publicly (such as public reviews and home facts) with third parties. We may also share aggregated and/or de-identified information that cannot reasonably be used to identify you.
Sale of Personal Information
Investors United Title Corp. allows certain companies like Google and Facebook to place tracking technologies such as cookies and pixels on our sites, which allow companies to receive information about your activity on Investors United Title Corp. that is associated with your browser or device. The companies may use that data to serve you more relevant ads on our sites or others. Under some state laws, sharing data for online advertising like this may be considered a “sale” of information. Except for this kind of sharing, Investors United Title Corp. doesn’t sell any of your information.
Do Not Track Signals
Our Site currently does not respond to “Do Not Track” signals. Our Site operates as described in this Privacy Policy, regardless of whether a “Do Not Track” signal is received. If we respond to “Do Not Track” signals in the future, we will describe that process in our Privacy Policy.
Calls and Texts
Some of our services allow you to share your phone number. If you do share your phone number with us, we may call or text you: for example, we may provide updates throughout the Closing process. We will contact you through these methods only in accordance with applicable legal requirements, and you always can opt out of further calls or texts.
Protecting Your Information
We understand that no matter how we collect your information, we have a responsibility to protect it; we take that responsibility seriously. We integrate fortified security into our products and features to help protect data from unauthorized access, disclosure, alteration, and destruction.
Applicability of this Policy
This policy applies to every service of Investors United Title Corp. that’s linked.
Our apps and services may link to other companies’ websites. Some features may also involve the sharing of your information with third-party websites. These third-party websites may collect information about users on those websites. Investors United Title Corp. doesn’t control those sites, and this privacy policy does not apply to external websites and third-parties.
Your California Privacy Rights
Effective Date: June 1, 2022
Last Reviewed: June 1, 2022
This Privacy Policy for California residents (“California Privacy Policy”) supplements the information described in our general Privacy Policy. Our California Privacy Policy applies only to Site visitors and others who reside in the State of California (“consumers,” “you” and “your). We adopt this California Privacy Policy in part to comply with the California Consumer Privacy Act of 2018 (“CCPA”). Any terms defined by the CCPA have the same meaning when used in this California Privacy Policy.
Information We Collect
We collect information that identifies, relates to, describes, references, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer, household, or device (“personal information”).
Personal information does not include:
- Publicly available information from government records;
- Deidentified or aggregated consumer information; and
- Information excluded from the CCPA’s scope, such as personal information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FCRA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver’s Privacy Protection Act of 1994.
In particular, we have collected the following categories of personal information from consumers within the last twelve (12) months:
| Category | Examples | Collected |
| A. Identifiers. | A name, postal address, Internet Protocol address, and email address. | YES |
| B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)). | A name, postal address, Internet Protocol address, and email address. Some personal information included in this category may overlap with other categories. | YES |
| C. Commercial information. | Records of property, products or services purchased, obtained, or considered with us. | YES |
| D. Internet or other similar network activity. | Browsing history, search history, information on a consumer’s interaction with a website, application, or advertisement. | YES |
| E. Geolocation data | Persons who allow us to collect their location data when using our Site or requesting our services. | YES |
| F. Audio Information | Persons who allow us to record our telephone calls. | YES |
We obtain the categories of personal information listed above from the following categories of sources:
- Directly from you. For example, from forms you complete or products and services you purchase.
- Indirectly from you. For example, from observing your actions on our Site.
Use and Disclosure of Personal Information
We may use or disclose the personal information we collect for one or more of the following purposes:
- To fulfill or meet the reason you provided the information. For example, if you share your name and contact information to request a price quote or ask a question about our products or services, we will use that personal information to respond to your inquiry. If you provide your personal information to purchase a product or service, we will use that information to process your payment and facilitate delivery. We may also save your information to facilitate new orders or process transactions.
- To provide, support, personalize, and develop our Site, products, and services.
- To create, maintain, customize, and secure your account with us.
- To process your requests, purchases, transactions, and payments and prevent transactional fraud.
- To provide you with support and to respond to your inquiries, including to investigate and address your concerns and monitor and improve our responses.
- To personalize your Site experience and to deliver content and product and service offerings relevant to your interests, including targeted offers and ads through our Site and via email or text message (with your consent, where required by law).
- To help maintain the safety, security, and integrity of our Site, products and services, databases and other technology assets, and business.
- For testing, research, analysis, and product development, including to develop and improve our Site, products, and services.
- 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 our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by us about our Site users and consumers are among the assets transferred.
We 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.
Sharing Personal Information
We may share your personal information by disclosing it to a third party for a business purpose. We make these business purpose disclosures only under written contracts that describe the purposes, require the recipient to keep the personal information confidential, and prohibit using the disclosed information for any purpose except performing the contract.
In the preceding twelve (12) months, we have disclosed personal information for a business purpose to the categories of third parties indicated in the chart below.
| Personal Information Category | Business Purpose Disclosures to Third-Party Recipients |
| A: Identifiers. | Yes, to our service providers. |
| B: California Customer Records personal information categories. | Yes, to our service providers. |
| C: Commercial information. | Yes, to our service providers. |
| D: Internet or other similar network activity. | Yes, to our service providers. |
| E. Geolocation Data | Yes, to our service providers. |
| F. Audio, Electronic or Visual Information | Yes, to our service providers. |
We do not sell personal information and have not sold personal information to third parties in the preceding twelve (12) months.
Your Rights and Choices
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 Know and Data Portability
You have the right to request that we disclose certain information to you about our collection and use of your personal information over the past 12 months (the “right to know”). Once we receive your request and confirm your identity (see Exercising Your Rights to Know or Delete), we will disclose to you:
- The categories of personal information we collected about you;
- The categories of sources for the personal information we collected about you;
- Our business or commercial purpose for collecting that personal information;
- The categories of third parties with whom we share that personal information;
- If we disclosed your personal information for a business purpose, a list that describes the disclosures we made for a business purpose, identifying the personal information categories that each category of recipient obtained; and
- The specific pieces of personal information we collected about you (also called a data portability request).
Right to Delete
You have the right to request that we delete any of your personal information that we collected from you and retained, subject to certain exceptions (the “right to delete”). Once we receive your request and confirm your identity (see Exercising Your Rights to Know or Delete), we will review your request to see if an exception allowing us to retain the information 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, fulfill the terms of a written warranty or product recall conducted in accordance with federal law, 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.).
- 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.
We will delete or deidentify personal information not subject to one of these exceptions from our records and will direct our service providers to take similar action.
Exercising Your Rights to Know or Delete
To exercise your rights to know or delete described above, please submit a request by either:
- Emailing us at: Licensing@ERES-Equity.com; or
- Calling us at: (833) 488-4853
Only you, or someone legally authorized to act on your behalf, may make a request to know or delete related to your personal information.
You may only submit a request to know twice within a 12-month period. Your request to know or delete must:
- Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative.
- Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.
We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you.
You do not need to create an account with us to submit a request to know or delete.
We will only use personal information provided in the request to verify the requestor’s identity or authority to make it.
Response Timing and Format
We will confirm receipt of your request within ten (10) business days. If you do not receive confirmation within the 10-day timeframe, please contact us using the contact information included in the section above called Exercising Your Rights to Know or Delete.
We endeavor to substantively respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time (up to another 45 days), we will inform you of the reason and extension period in writing.
If you have an account with us, we will deliver our written response to that account. If you do not have an account with us, we will deliver our written response by mail or electronically, at your option.
Any disclosures we provide will only cover the 12-month period preceding our receipt of your request. 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.
Non-Discrimination
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.
Contact Information
If you have any questions about this privacy policy or the privacy practices of Investors United Title Corp., email us at Licensing@eres-equity.com or you can write to us at:
Investors United Title Corp.
100 Carr 165, STE 606
Guaynabo, PR 00968
