June 29, 2022

In this Privacy Policy (“Policy”), we describe how Kai Group Holding, Inc. and its subsidiaries and affiliates, including AccuTitle LLC and Millennium Software Developers, Inc. (“we,” “us,” “our”) collects, uses, and discloses information that we obtain about users of our website, our software and myTitleVault, our Service allows title agents to collaborate with buyers and sellers as well as other transaction professionals. Our services automate and streamline the title production and closing process. While we keep certain information confidential, please understand that real estate transactions and title transfers are public information and that for a particular transaction, users of a particular Service may include buyers, sellers, and Transaction Professionals.

By using our Service, you agree that your personal information will be handled as described in this Policy. Your use of our Service, and any dispute over privacy, is subject to this Policy and our Terms of Service, including its applicable limitations on damages and the resolution of disputes. The Terms of Service are incorporated by reference into this Policy.

The Information We Collect About You

We collect information about you directly from you and from third parties, and automatically through your use of the Services.

Information We Collect Directly From You. The information we collect from you depends on how you use our Service and your role in the transaction. To create an account, you may provide your name, email and physical address, telephone number and/or company name depending on the Service. Once you log in, you will be able to review the information previously provided by the Transaction Professionals that may include contact information about the buyer and seller, information about the property, details about the transaction, title insurance information and other pertinent data and provide your own information such as wire instructions and bank account information used to transfer the funds. We also collect contact information from buyers and sellers such as name, email and physical address (“Contact Information”).

Information From Other Entities. Buyers and sellers and Transaction Professionals (such as realtors) upload information into the Service and also access the Service to support the transaction.  This information may include Contact Information about the buyer and seller, information about the property, details about the transaction, title insurance information and other pertinent data.

Information We Collect Automatically. We automatically collect information about your use of our Service through cookies, web beacons, and other technologies. This includes:

• your browser type and operating system;
• information about your devices;
• pages you view on the Service;
• links you click on the Service;
• your IP address;
• the length of time you visit our Service and/or use its features;
• the referring URL, or the webpage that led you to a given page of our Service.

 To the extent permitted by applicable law, we combine this information with other information we collect about you, including your personal information. Please see the section “Our Use of Cookies and Other Tracking Mechanisms” below for more information.

How We Use Your Information

We use your information, including your personal information, for the following purposes:

• To enable the use of the Service,
• To communicate with you about your use of our Service, to respond to your inquiries, and for other customer service purposes,
• To tailor the content and information that we may send or display to you and to personalize your experiences while using the Service,
• To send you marketing about our and our affiliates’ products and Services,
• To assist third parties in sending you marketing about their products and services,
• To send you email marketing about products and services of other entities that we think may be of interest to you,
• To assist us in advertising and to evaluate the success of our adverting campaigns through third-party channels (including our online targeted advertising and offline promotional campaigns),
• To better understand how users access and use our Service, both on an aggregated and individualized basis. For example, we will evaluate which features of our Service are used by users,
• To administer surveys and questionnaires, such as for market research or member satisfaction purposes,
• To comply with legal obligations, as part of our general business operations, and for other business administration purposes,
• As otherwise communicated to you or with your consent, and
• Where we believe necessary to investigate, prevent or take action regarding illegal activities, suspected fraud, situations involving potential threats to the safety of any person or violations of our Terms of Service or this Privacy Policy.

 How We Share Your Information

We may share your information, including personal information, as follows:

• Service Providers. We disclose the information we collect from or about you to service providers, contractors or agents who perform functions on our behalf. These service providers include IT hosting and other services, email and analytics providers, payment processors, and others.
• Affiliates. We may disclose the information we collect from or about you to our affiliates or subsidiaries.
• Third Parties. Unless you opt-out, we may share property and Contact Information with third parties such as value-added services for homeowners. If you wish to opt out, please email optout@accutitle.com. We will not share information with third parties that has not been, is not or will not become public information.
• Transaction Professionals. Some of our Services facilitate the sharing of information between buyers, sellers and Transaction Professionals. Information that you or others share on the portal, for example, may be available to others involved in the transaction.
• Third Party Ad Networks. We also share your information with third party ad networks and analytics providers as described below.

 We also disclose information in the following circumstances:

• Business Transfers. If (i) we or our affiliates are or may be acquired by, merged with, or invested in by another company, or (ii) if any of our assets are or may be transferred to another company, whether as part of a bankruptcy or insolvency proceeding or otherwise, we may transfer the information we have collected from you to the other company. As part of the business transfer process, we may share certain of your personal information with lenders, auditors, and third-party advisors, including attorneys and consultants.
• In Response to Legal Process. We disclose your information to comply with the law, a judicial proceeding, court order, or other legal process, such as in response to a court order or a subpoena.
• To Protect Us and Others. We disclose your information when we believe it is appropriate to do so to investigate, prevent, or take action regarding illegal activities, suspected fraud, situations involving potential threats to the safety of any person, violations of our Terms of Service or this Policy, or as evidence in litigation in which we are involved.
• Aggregate and De-Identified Information. We share aggregate or de-identified information about users with third parties for marketing, advertising, research or other purposes.

 Our Use of Cookies and Other Tracking Mechanisms

We and our service providers use cookies and other tracking mechanisms to track information about your use of our Service. We may combine this information with other personal information we collect from you (and our service providers may do so on our behalf).

Cookies.  Cookies are alphanumeric identifiers that we transfer to your device’s hard drive through your web browser for record-keeping purposes. Some cookies allow us to make it easier for you to navigate our Service, while others are used to enable a faster log-in process or to allow us to track your activities at our Service. There are two types of cookies: session and persistent cookies.

• Session Cookies. Session cookies exist only during an online session. They disappear from your device when you close your browser or turn off your device. We use session cookies to allow our systems to uniquely identify you during a session or while you are logged into the Service. This allows us to process your online requests and verify your identity, after you have logged in, as you move through our Service.
• Persistent Cookies. Persistent cookies remain on your device after you have closed your browser or turned off your device. We use persistent cookies to track aggregate and statistical information about user activity.

 Disabling Cookies. Most web browsers automatically accept cookies, but if you prefer, you can edit your browser options to block them in the future. The Help portion of the toolbar on most browsers will tell you how to prevent your computer from accepting new cookies, how to have the browser notify you when you receive a new cookie, or how to disable cookies altogether. Visitors to our Service who disable cookies will be able to browse certain areas of the Service, but some features may not function.

Third-Party Analytics. We use automated devices and applications, such as Google Analytics, to evaluate usage of our Service, and to the extent permitted. We also may use other analytic means to evaluate our Service. We use these tools to help us improve our Service’s performance and user experiences. These entities may use cookies and other tracking technologies, such as web beacons or local storage objects (LSOs), to perform their services. To learn more about Google’s privacy practices, please review the Google Privacy Policy at https://www.google.com/policies/privacy/. You can also download the Google Analytics Opt-out Browser Add-on to prevent their data from being used by Google Analytics at https://tools.google.com/dlpage/gaoptout.

Do-Not-Track. Currently, our systems do not recognize browser “do-not-track” requests. You may, however, disable certain tracking as discussed in this section (e.g., by disabling cookies); you also may opt-out of targeted advertising by following the instructions in the Third-party Ad Network section.

Third-Party Ad Networks

We use third parties such as network advertisers to serve advertisements on third-party websites or other media (e.g., social networking platforms). This enables us and these third parties to target advertisements to you for products and services in which you might be interested. Third-party ad network providers, advertisers, sponsors and/or traffic measurement services may use cookies, JavaScript, web beacons (including clear GIFs), Flash LSOs and other tracking technologies to measure the effectiveness of their ads and to personalize advertising content to you. These third-party cookies and other technologies are governed by each third-party’s specific privacy policy, not this one. We may provide these third-party advertisers with information, including personal information, about you.

Users in the United States may opt out of many third-party ad networks. For example, you may go to the Digital Advertising Alliance (“DAA”) Consumer Choice Page for information about opting out of interest-based advertising and their choices regarding having information used by DAA companies. You may also go to the Network Advertising Initiative (“NAI”) Consumer Opt-Out Page for information about opting out of interest-based advertising and their choices regarding having information used by NAI members.

Opting out from one or more companies listed on the DAA Consumer Choice Page or the NAI Consumer Opt-Out Page will opt you out from those companies’ delivery of interest-based content or ads to you, but it does not mean you will no longer receive any advertising through our Service, or on other websites. You may continue to receive advertisements, for example, based on the particular website that you are viewing (i.e., contextually based ads). Also, if your browsers are configured to reject cookies when you opt out on the DAA or NAI websites, your opt out may not be effective. Additional information is available on the DAA’s website at www.aboutads.info or the NAI’s website at www.networkadvertising.org.

Third-Party Links

Our Service may contain links to third-party websites. Any access to and use of such linked websites is not governed by this Policy, but instead is governed by the privacy policies of those third-party websites. We are not responsible for the information practices of such third-party websites.

Security of My Personal Information

We have implemented reasonable precautions to protect the information we collect from loss, misuse, and unauthorized access, disclosure, alteration, and destruction. Please be aware that despite our best efforts, no data security measures can guarantee security.

You should take steps to protect against unauthorized access to your password, phone, and computer by, among other things, signing off after using a shared computer, choosing a robust password that nobody else knows or can easily guess, and keeping your log-in and password private. We are not responsible for any lost, stolen, or compromised passwords or for any activity on your account via unauthorized password activity.

Access to My Personal Information

Depending on the Service, you may modify personal information that you have submitted by logging into your account and updating your profile information or by contacting us directly. Please note that copies of information that you have updated, modified or deleted may remain viewable in cached and archived pages of the Service for a period of time.

What Choices Do I Have Regarding Use of My Personal Information?

We may send periodic promotional emails to you. You may opt-out of promotional emails by following the opt-out instructions contained in the email. If you opt-out of receiving promotional emails, we may still send you emails about your account or any services you have requested or received from us.

If you wish to opt out of our sale of your personal information, please email support@accutitle.com.

Children

Our Service is not designed for children. If we discover that a child has provided us with personal information, we will delete such information from our systems.

Special Information for California Consumers Under the California Shine the Light Law

California residents may request a list of certain third parties to which we have disclosed personally identifiable information about you for their own direct marketing purposes. You may make one request per calendar year. In your request, please attest to the fact that you are a California resident and provide a current California address for your response. You may request this information in writing by contacting us at support@accutitle.com.

Contact Us

If you have questions about the privacy aspects of our Service or would like to make a complaint, please contact us at (877) 354-1170 ext. 1 or support@accutitle.com. You may also write to us at 1518 Long Beach Blvd., Ship Bottom, NJ 08008.

Changes to this Policy

This Policy is current as of the Effective Date set forth above. We may change this Policy from time to time, so please be sure to check back periodically.