Closing Party


Privacy Policy

This Privacy Policy (“Privacy Policy”) describes how Qualia Labs, Inc., on behalf of itself and its affiliates (collectively, “Qualia”, “we”, “us”, or “our”), collects, uses and discloses certain information, including non-public personal information (“Personal Information”), in connection with the proprietary web-based platform, and associated sites, applications and services, located at www.qualia.io and provided by Qualia (collectively, the “Service”). Your access to and use of the Service are subject to our Terms of Service and any Platform License Agreement or other written agreement between you, or the entity on whose behalf you are accessing the Service, and Qualia (collectively, the “Terms”). This Privacy Policy is incorporated into and made part of the Terms. All capitalized terms used but not defined herein have the meanings given to them in the Terms.

By accessing or using the Service, you consent to the collection, use and disclosure of your information, including Personal Information, in accordance with this Privacy Policy.

What Types of Personal Information Does Qualia Collect?

Qualia may collect any information provided by you or authorized by you to be provided by a title company or other third party in connection with the Service, which information may include:

  • Identifiers collected to verify your identity and provide services to you such as your name, postal address, email address, account name, social security number, driver’s license number or other identifiers.
  • Information needed in connection with financing, including scanned copies of passport, driver’s license, employment verification and related information, and bank account number for disbursements/payments.
  • Characteristics such as sex/gender, date of birth (age), and marital status, needed in connection with your financing, and reporting obligations.
  • Commercial information regarding property records used in connection with closing.
  • Internet and electronic network activity, including IP address, related to your interactions with the Service.
  • Professional or employment-related information in connection with loan applications.

We or your title company collect information from you when you use the Service, fill out a form, submit an application, upload information, create or use an account, or otherwise supply information to us. When you send email or other communications to us, we may retain and use those communications in order to process your inquiries, respond to your requests, and improve the Service. We also collect information from you and authorized third parties in connection with user-related transactions.

If you decide to register through or a title company acting on your behalf otherwise grants access to a third party integrated service (each, an "Integrated Service"), such as Google, we may collect Personal Information that is associated with your Integrated Service account. You may also have the option of sharing additional information with Qualia through an Integrated Service, as controlled through your account settings on such Integrated Service. If you or your title company choose to provide such information, during registration or otherwise, we will treat the information as Personal Information and will use it in the ways described in this Privacy Policy. You may revoke our access to your account on any Integrated Service at any time by updating the appropriate settings in the account preferences of the respective Integrated Service. Please review the terms of use and privacy policy, and your privacy settings, for each Integrated Service carefully before using its services and before authorizing any integration between such Integrated Service and the Service.

We may also automatically collect information regarding your interaction with, and use of, the Service. We may use a variety of methods to collect this information, including cookies, pixel tags, web beacons, embedded web links and other commonly used information gathering tools (“Automatic Data Collection Tools”). These Automatic Data Collection Tools collect certain standard information that your web browser or device sends to us, as applicable, such as your access times, IP address and clickstream behavior. You may have the ability, through your browser settings, to receive notices regarding or turn off certain Automatic Data Collection Tools; however, please note that turning off Automatic Data Collection Tools may negatively impact the functionality or performance of the Service.

Information may be collected by us or by our vendors who provide hosting for the Service. We may combine information we collect with other information that is publicly available or received from transactions or third parties.

Because there is not yet a common understanding of how to interpret web browser-based “Do Not Track” (“DNT”) signals other than cookies, we do not currently respond to undefined DNT signals to the Service.

How Does Qualia Use Your Personal Information?

We use Personal Information to facilitate your use and receipt of the Service, and any products or services related thereto, and as further described in this Privacy Policy. We may use Personal Information to:

  • enable you to participate in the Service;
  • provide the Service, which may require us to share some Personal Information with a third party or contractor that we use to provide the Service or that you have authorized to provide a related product or service; and
  • provide you with important information about Qualia or the Service, including critical updates and notifications.

Facilitate Your Use of the Service. We may use your Personal Information to communicate with you regarding the Service, your account information or other customer service matters; to respond to your questions and instructions; and to enhance, customize and personalize your experiences and communications with us.

Operate and Improve the Service. We may use your Personal Information to operate, provide, improve and maintain the Service, including analyzing user behavior and trends; to send you administrative messages and other information about Qualia and the Service; to investigate or take action regarding violations or suspected violations of applicable law or the Terms; and to maintain the integrity of the Service and our network and otherwise address security issues.

Special Circumstances. We may also access, use, copy or disclose Personal Information in the event of any Special Circumstances (as described below).

Aggregated Data. Information collected from any source may be combined to provide or improve the Service, including by facilitating more targeted, tailored communications. We may aggregate de-identified data and information collected about you and other users of the Service to create anonymous aggregated data (“Aggregated Data”). Qualia may use Aggregated Data consistent with the direction of its title company clients and/or the services Qualia provides to you and title companies, including research and analysis, ascertaining trends and patterns, and internal record keeping and reporting.

With Whom Does Qualia Share Your Personal Information?

We do not sell or rent your Personal Information to any third party. We may, however, share your Personal Information with the following parties: Qualia’s affiliates for purposes related to the Service; service providers that you have authorized to provide title-related, closing related or other real-property-related services; our hosting partners; or other parties who assist us with the administration of the Service, conducting our business, or servicing you, so long as those parties agree to maintain reasonable security measures to safeguard the confidentiality, security and integrity of your Personal Information.

We may disclose Personal Information when we reasonably believe disclosure is appropriate (collectively, “Special Circumstances”), including as we reasonably deem appropriate to:

  • comply with applicable law;
  • enforce or apply this Privacy Policy or other agreements to which we are a party or that otherwise relate to the Service;
  • facilitate fraud protection or credit risk reduction; or
  • protect the rights, property or safety of Qualia, our users or others.

If our company is acquired by or merged with or into another entity, or if our assets or business is sold or transferred to another entity, your Personal Information may be transferred to such entity as part of the transaction, and that entity and its affiliates may use your Personal Information consistent with applicable law and the provisions of this Privacy Policy.

Information Security

Information security is important to Qualia. We follow generally accepted industry security standards to safeguard and help prevent unauthorized access to or use of your Personal Information. However, like other companies, Qualia cannot guarantee the 100% security or confidentiality of your Personal Information. Consequently, while we endeavor to safeguard your Personal Information against unauthorized access and disclosure, we do not warrant or guarantee the absolute security of any Personal Information you transmit to, from or through the Service. In the event that we become aware of a security breach involving your Personal Information stored by or for us, we may notify you of certain details of the breach via posting to the Service, email or other commercially reasonable means. Qualia does not have control over the security of other sites or applications, even if a link to any such third party site or application appears on the Service.

Some of the content we deliver to or receive from you through the Service, specifically that of emails and text messages, may be unencrypted, and transmissions may be unknowingly or unintentionally intercepted by third parties. We do not maintain or have access to devices, servers or networks outside of our domain and control, and we bear no liability or responsibility for the security or control of content or communications, once delivered to you.

Third Party Privacy Policies

This Privacy Policy applies solely to your interactions with, and information collected through, the Service. Once you leave the Service, whether independently or via links, the privacy policies of the sites or applications to which you migrate will apply. We have no responsibility or liability for the content or activities of any linked sites or applications.

International Users—Cross-Border Transfer

The Service is operated in the United States and is not directed to residents of countries outside of the United States. If you are located outside of the United States, please note that any information you provide to us will be transferred to the United States, which may have laws that are different than the data protection or consumer protection laws in your home country. Your information may be available to government authorities under lawful orders and law applicable in such jurisdictions. By using the Service or providing us with your information, you consent to this transfer. The Service is not intended or authorized for use by a person in any country or other region where such use would be contrary to any applicable laws or regulations.

Children’s Privacy

The privacy of children is important to Qualia. The Service is not directed at children, and we do not knowingly collect Personal Information from children under the age of 13 through the Service. All information provided to Qualia will be treated as if provided by an adult. If a child has provided us with Personal Information, a parent or guardian of that child may send an e-mail to privacy@qualia.com with “Request for Child Information Removal” on the subject line and the name and age of the child in the body of the message. We will then use commercially reasonable efforts to remove the child’s Personal Information from our applicable databases.


We may update this Privacy Policy from time to time without prior notice. Any changes to our Privacy Policy will become effective upon posting of the updated Privacy Policy on www.qualia.com (or via other commercially reasonable means). If we change this Privacy Policy, we will revise the “last modified” date below, and the changes will apply to information collected after such date. For material changes to this Privacy Policy, we may notify you of such changes via posting on www.qualia.com, email or other commercially reasonable means. We encourage you to periodically review this Privacy Policy.

Your California Privacy Rights

Qualia is a service provider to title companies or other third parties, many of whom are subject to the federal Gramm-Leach Bliley Act (GLBA). Thus, much of the Personal Information processed by Qualia is exempt from the California Consumer Protection Law (CCPA). If you are a consumer, please direct any questions regarding your privacy rights to your title company. 

To the extent you have provided us Personal Information directly and that is not covered by GLBA, if you are a California resident, California law provides you with the following rights with respect to your Personal Information:

  • The right to know what Personal Information we have collected, used, disclosed and sold about you. To submit a request to know, you may email us at privacy@qualia.com. You also may designate an authorized agent to make a request for access on your behalf.
  • The right to request that we delete any Personal Information we have collected about you.  To submit a request for deletion, you may email us at privacy@qualia.com. You also may designate an authorized agent to make a request for deletion on your behalf.

When you exercise these rights and submit a proper request to us, we will verify your identity by asking you for your email address, telephone number, and/or information about your account with Qualia. We also may use a third party verification provider to verify your identity. Qualia will endeavor to honor requests unless they are properly directed at one of our title company clients or a lawful exemption under the CCPA applies. Please note that Qualia is only required to honor such requests twice in a 12-month period.

Your exercise of these rights will have no adverse effect on the price and quality of our goods or services.

For the 12-month period prior to the date of this Privacy Policy, Qualia has not sold any Personal Information about its clients; nor does it have any plans to do so in the future.  

Reporting Procedure

In performing their job duties, Qualia employees should always act lawfully, ethically, and in the best interests of Qualia in accordance with this Code of Conduct which sets out basic guiding principles for all employees. All employees are expected to review the Code of Conduct and comply with its provisions.

Employees who a) have a question about the application of the Code of Conduct, b) believe that a violation of the Code of Conduct has or is about to occur, or c) are in doubt about how to properly act in a particular situation should promptly discuss the issue with their manager, anyone in their management chain, Human Resources, or the Legal Department.

In situations where you wish to remain anonymous, subject to local laws, you may also report issues directly to people@qualia.com using an anonymous email address. The information you provide will be sent to us on a confidential and anonymous basis if you should choose. You have our guarantee that your comments will be heard.

Contact Us

If you have any questions, comments or requests regarding this Privacy Policy, please contact us at privacy@qualia.com.

Last Modified: 1/21/2020

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