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:
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.
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.
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.
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:
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.
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.
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 firstname.lastname@example.org 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.
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:
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.
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 email@example.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.
Last Modified: 1/21/2020