CloseSimple, Inc. Portal Privacy Policy

Effective Date: 03/31/2026

1. GENERAL

We know that your privacy is important to you, and we work hard to earn and keep your trust. CloseSimple, Inc. ( “Company,” “we,” “us,” and “our”) respects your privacy and is committed to protecting your privacy through our compliance with this Portal Privacy Policy (the “Policy”). The words “you” and “your” refer to you as a user of the Services (defined below).

This Policy describes:

• The types of information we collect from you or that you may provide when you use the web portal, applications, and services owned by, or operated by or on behalf of, the Company and where this Policy is linked (collectively, our “Portal”).
• Our practices for collecting, using, maintaining, protecting, and disclosing that information.

This Policy does not apply to information collected by us offline or through any other means, including on any other website or platform operated by the Company where this Policy is not linked or any third party, or information collected by any third party through any application or content (including advertising) that may link to or be accessible from the Services (for further information, see below, “Third-party Websites”).

Please read this Policy carefully to understand our practices regarding your information and how we will treat it. If you do not agree with our policies and practices, then please do not use our Services. By using our Services, you agree to the terms of this Policy. This Policy may change from time to time (see below, “Changes to this Policy”). Your continued use of our Services after we make changes is deemed to be acceptance of those changes, so please check the Policy periodically for updates.

2. TERMS OF SERVICE; OTHER AGREEMENTS

This Policy is incorporated by reference and should be read in conjunction with the Company’s Portal End User License Agreement and Terms of Service (collectively, the “Terms”).

Your use of the Portal and any information associated with the Portal may also be subject to the terms of a separate Master Subscription Agreement between Company and our Real Estate Title and Escrow business client with which you are transacting (the “Brand”). When and where applicable, this Policy may be superseded by specific terms in such agreement.

3. THE INFORMATION WE COLLECT

Personal Information. To ensure that we provide you with the best possible experience, we will store, use, and disclose personal information about you in accordance with this Policy. Personal information is 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 user, household or device (“Personal Information”). The Personal Information that we may receive and collect depends on what you do when you visit our Portal.

Information of Other Individuals. You may have the opportunity to provide information of other individuals. When providing such information, you are solely responsible for obtaining the necessary consents and authorizations from any individuals in accordance with applicable data security laws and regulations, and the Company shall not be responsible or held liable for your failure to obtain the necessary consents.

Financial Account Information. Please note that for any financial account information provided on the Portal to request or receive earnest money or closing funds, we utilize trusted third-party payment processors and escrow service providers to process all of your transactions and those third-party providers collect and maintain the necessary Personal Information needed to necessitate such transactions in accordance with their own terms and privacy policies. The Brand may also provide additional instructions and terms that may apply to such transactions. Please be sure to review any terms and privacy policies presented at the time of payment and verbally verify all wire instructions with the Brand via a trusted phone number before sending funds.

Aggregated and De-Identified Data. We may also collect, use and disclose aggregated and de-identified data such as statistical or demographic data for any purpose. Aggregated and de-identified data could be derived from your Personal Information but is not considered Personal Information under applicable law as this data will not directly or indirectly reveal your identity. However, if we combine or connect aggregated or de-identified data with your Personal Information so that it can directly or indirectly identify you, we treat the combined data as Personal Information which will be used in accordance with this Policy.

Free-Text Boxes and Upload Features. The information that you provide in each case will vary. In some cases, you may be able to provide Personal Information via email or free text boxes or through upload features, such as when contacting the Company to request further information or uploading documents requested by the Brand. When providing your Personal Information, please provide only relevant information and do not provide unnecessary sensitive information, such as Social Security numbers, credit card information or other sensitive personal data, unless required for our services.

Username and Password. We may ask you to create a username and password that should only be known to you.

Recording Use of the Portal. We partner with trusted third-party vendors to analyze the performance and traffic on our Portal. This may include things like buttons you click, mouse movements and other behavior on the Portal, date and time of access, pages visited, web beacons, and cookie, pixel, or tag information. Please see our “Cookies and Similar Technologies” section below to learn more about cookies, pixels, tags, and analytic technologies.

Online Chat Features. We may partner with a trusted third-party vendor to provide you with chat features to better assist you. When using the chat features, please only provide necessary information and do not provide sensitive information. For recordkeeping, training, and quality assurance purposes, we or our third-party vendor may record and maintain a transcript of any communications in the chat.

1. Information We May Collect on the Portal

You may have the opportunity to provide Personal Information on our Portal, including but not limited to:

We may obtain the Personal Information listed above from the following categories of sources:

• Directly from you. For example, when you:
• register with the Portal;
• submit support tickets or contact our customer support team;
• submit and/or sign forms and documents;
• upload documents or files;
• submit or receive payments; or
• otherwise communicate with us, such as contacting us for more information.
• Indirectly from you. For example, through information we collect from you in the course of providing our Portal to you.
• Directly and indirectly from activity on our Portal. For example, from usage details that are collected automatically. For more information on automatic information collection, please review the “Cookies and Similar Technologies” section below.
• Third Party Sources. We may collect information about you from third party sources, such as from the Brand or our business partners.

4. COOKIES AND SIMILAR TECHNOLOGIES

In addition to the information that you provide to us, we may also collect information about you during your visit to our Portal. We collect this information using automated tools that are detailed below. These tools may collect information about your behavior and your computer system, such as your Internet Protocol (“IP”) address, device identifier, browser type and language, operating system, date and time stamp, session ID, internet service provider, data regarding network-connected hardware, the pages you have viewed, and the actions you have taken while using the Portal.

We may use this automatically collected information to: (i) conduct analyses about our Portal; (ii) associate the different devices you use; (iii) remember your browser or device; (iv) remember your preferences and interactions; (v) collect information about our Portal; and (vi) log activity on our Portal.

Some of the tools we use to automatically collect information about you may include:

1. Cookies. A “cookie” is a small data file transmitted from a website to your device’s hard drive. Cookies are usually defined in one of two ways, and we may use either (or both) of them: (1) session cookies, which do not stay on your device after you close your browser, and (2) persistent cookies, which remain on your device until you delete them or they expire.
   
2. Analytics Services. Our Portal may use Google Analytics, TrackJS, and others for audience measurement and analytics purposes. These analytics services may use cookies or similar technologies to collect information to help us analyze users and how they use our Portal. The information collected by these technologies is used to assess how often you visit our Portal, what pages you view when you visit our Portal, and what other websites you visited before coming to our Portal. Information generated by these services may be transmitted to and stored by these providers and they may use this information for purposes such as evaluating your use of our Portal, compiling statistics reports on the Portal’s activity, and providing other services relating to activity and other internet usage for our Portal. You may review Google’s data privacy practices for Google Analytics and data privacy practices for Google Tag Manager. To opt out of being tracked by Google Analytics, you may download and install the Google Analytics Opt-out Browser Add-on.
3. Web Beacons. A Web Beacon is an electronic image. Web Beacons can track certain things from your computer and can report activity back to a web server allowing us to understand some of your behavior. If you choose to receive emails from us, we may use Web Beacons to track your reaction to our emails. We may also use them to track if you click on the links and at what time and date you do so. Some of the third-party marketers we engage with may use Web Beacons to track your interaction with online advertising banners on our Portal. This information is only collected in aggregate form and will not be linked to your Personal Information. Please note that any image file on a webpage can act as a Web Beacon.
4. Embedded Web Links. Links provided in our emails and, in some cases, on third-party websites may include tracking technology embedded in the link. The tracking is accomplished through a redirection system. The redirection system allows us to understand how the link is being used by email recipients. Some of these links will enable us to identify that you have personally clicked on the link and this may be attached to the Personal Information that we hold about you. This data is used to improve our service to you and to help us understand the performance of our marketing campaigns.

Of course, if you do not wish to have cookies on your device, you may turn them off at any time by modifying your internet browser’s or device’s settings. Please refer to the help section of your browser or mobile device for additional information. Your browser or mobile device may also offer add-ons, plugins, or extensions to manage cookies, local storage objects, scripts, or similar technologies mentioned in this Policy. Apple and Android mobile devices each generate an advertising identifier that can be accessed by apps and used by advertisers in much the same way that cookies are used on websites. Each operating system provides options to limit tracking and/or reset the advertising ID. However, by disabling cookies on your browser or device, you may be prohibited from full use of the Portal’ features or lose access to some functionality.

5. HOW WE USE YOUR INFORMATION

The information we gather and that you provide is collected to provide you information and the services you request, in addition to various other purposes, including, but not limited to:

• Security or fraud prevention purposes;
• identity verification;
• providing you with effective customer service;
• providing you with a personalized experience when you use the Portal;
• developing new products and services;
• contacting you with special offers and other information we believe will be of interest to you (in accordance with any privacy preferences you have expressed to us);
• contacting you with information and notices related to your use of the Portal;
• better understanding your needs and interests;
• improving the content, functionality and usability of the Portal;
• improving our products and services;
• de-identifying information we collect about you and using it for any purpose in accordance with applicable law; and
• any other purpose identified at the point of data collection, in an applicable privacy notice, in a click-through agreement or in any other agreement between you and us.

Duration. The length of time Company intends to retain Personal Information, including sensitive personal information, if any, is for as long as reasonably necessary to carry out Company’s intended business purpose for such information.

6. HOW WE DISCLOSE YOUR INFORMATION

We do not sell your Personal Information to any third party. We may disclose your Personal Information to a third party for a business purpose, including the following categories of third parties:

• Our Affiliates. We may disclose the information collected through the Portal with our affiliates, subsidiaries, and other related entities in order to provide our products, services and effective customer support.
• Third-party Service Providers. We disclose Personal Information collected through the Portal with third-party Service Providers who act for or on behalf of the Company. These third parties may need information about you to perform their functions. “Service Providers” may include companies and consultants that provide cloud hosting, software development, identity verification, website and data analytics, information technology and related infrastructure support, customer service, email delivery, and auditing.
• Brands. If you use our Portal in connection with a Brand, we may disclose your Personal Information with the Brand. Without limiting the generality of the foregoing, your Personal Information may be synced with the Brand’s internal production software. The Company is not responsible or liable for any uses of your information or your content by the Brand.

Except as described in this Policy, we will not disclose your information with other third parties without your notice and consent or the consent of the Brand, unless it is under one of the following circumstances:

• Legal Reasons.
• We believe that disclosure is reasonably necessary to comply with any applicable law, regulation, subpoena, or court order;
• To respond to duly authorized information requests from law enforcement or other governmental authorities;
• To enforce our agreements or policies;
• To investigate and prevent security threats, fraud, or other malicious activity; or
• To respond to an emergency that we believe in good faith requires us to disclose such information to assist in preventing the death or serious bodily injury of any person or Company employee.
• Sale of Business or Merger. There are circumstances where the Company may decide to buy, sell, or reorganize its business. Under these circumstances, it may be necessary to disclose or receive Personal Information with prospective or actual purchasers, acquisition targets, partners or affiliates. In such circumstances, the Company will ensure your information is used in accordance with this Policy.
• In Aggregate or De-Identified Form. We may aggregate or otherwise anonymize the data we collect for purposes of analytics, research, marketing and other business interests of the Company. Such use shall not include Personal Information or information that can identify you as an individual or reasonably be used to identify you.

7. COMMUNICATION PREFERENCES

We want to provide you with relevant information that you have requested. When possible, we will always provide options as to what information we collect and how you can manage any preferences that pertain to such information.

If we provide subscription-based services, such as email newsletters, we will allow you to make choices about what information you provide at the point of information collection or at any time after you have received a communication from us while you are subscribed. Transactional or service-oriented messages, such as confirmation messages, are usually excluded from such preferences, as such messages are required to respond to your requests or to provide goods and services, and are not intended for the purposes of marketing.

From time to time, we may send you email newsletters and marketing emails. You may opt out of them at any time by selecting the “unsubscribe” link at the bottom of each email. Please note that by opting out or unsubscribing you may affect other services you have requested we provide to you, in which email communication is a requirement of the service provided. Even if you opt-out of receiving marketing material, we may still need to contact you with important information about your account or responding to your requests or questions.

8. TEXT MESSAGING

You may have the opportunity to receive SMS or “text” messages, pre-recorded voice messages or auto-dialed phone calls from the Company, its affiliates and related entities as well as third parties. Any such communications you receive from us will be administered in accordance with your preferences and our SMS Privacy Policy and SMS Terms and Conditions (collectively, “SMS Terms”).

Except as otherwise provided in the SMS Terms, in providing your mobile device number or cell phone number to the Company, you knowingly consent to such communications from the Company or for the Company to use your cell phone number and mobile device number. In providing your number, you represent that you have the authority to agree to receive text messages at the telephone number that you provide to the Company, or from which you sent the text message request to us. You further acknowledge that: (a) no purchase is required to opt into this service; (b) you may opt out at any time by following the instructions provided in the SMS Terms; and (c) your receipt of text messages may result in separate charges from your mobile provider.

9. INFORMATION OF MINORS

We do not knowingly collect or use information from individuals under the age of eighteen (18) without parental or guardian consent. We do not target the Portal to minors, and would not expect them to be engaging with the Portal. We encourage parents and guardians to provide adequate protection measures to prevent minors from providing information unwillingly on the internet. If we are aware of any Personal Information that we have collected about minors, we will take steps to securely remove it from our systems.

10. FEEDBACK

We welcome inquiries or feedback on the services or products you might use or like to use. Any inquiries, feedback, suggestions, or ideas you provide to us (collectively, “Feedback”) will be treated as non-proprietary and non-confidential. Your Feedback on or through the Portal may be available to others who use the Portal. In addition, we may use your Feedback in advertising campaigns and other promotions. We may or may not use your name in connection with such use, and we may or may not seek your consent before using the Feedback for such purposes. Therefore, you should have no expectation of privacy with respect to your Feedback on or through the Portal. You should not submit any Feedback you do not wish to make available to the general public, and you must take special care to make sure your Feedback complies with our Terms or other applicable agreements. All terms and conditions of our Terms apply to Feedback on or through the Portal. In particular, your Feedback must not violate the privacy or other rights of others. You may not use false identifying information or contact information, impersonate any person or entity, or otherwise mislead us as to the origin of any Feedback.

11. THIRD-PARTY WEBSITES

This Policy does not apply to websites or other domains that are maintained or operated by third parties or our affiliates. Our Portal may link to third-party websites and services. For example, if you click on an advertisement on the Portal, you may be taken to another website that we do not control. These links are not endorsements of these websites, and this Policy does not extend to them. Because this Policy is not enforced on these third-party websites, we encourage you to read any posted privacy policy of the third-party website before using the service or website and providing any information.

12. YOUR RIGHTS UNDER STATE LAW

Some state laws in the United States provide consumers with additional rights with respect to their Personal Information (also known as “personal data”), as those terms are defined under those applicable state laws. Such state laws may include, but are not limited to, the California Consumer Privacy Act of 2018, as amended by the California Privacy Rights Act of 2020, the Colorado Privacy Act, the Connecticut Data Privacy Act, the Delaware Personal Data Privacy Act, the Indiana Consumer Data Protection Act, the Iowa Consumer Data Protection Act, the Kentucky Consumer Data Protection Act, the Maryland Online Data Privacy Act, the Minnesota Consumer Data Privacy Act, the Montana Consumer Data Privacy Act, the Nebraska Data Privacy Act, the New Hampshire Data Privacy Act, the New Jersey Data Privacy Act, the Oregon Consumer Privacy Act, the Rhode Island Data Transparency and Privacy Protection Act, the Tennessee Information Protection Act, the Texas Data Privacy and Security Act, the Utah Consumer Privacy Act, and the Virginia Consumer Data Protection Act (collectively, the “U.S. State Privacy Laws"). Any Personal Information we collect is collected for the commercial purpose of effectively providing our services to you, as well as enabling you to learn more about, and benefit from, our services.

Company is a “Service Provider” or “Processor” as defined by the U.S. State Privacy Laws where Company processes your information on behalf of the Brand. To the extent U.S. State Privacy Laws allow you to make certain requests, including requests to access, correct, limit or delete personal information or sensitive personal information, or a list of third party disclosures, you must make these requests directly to the Brand. If you submit a request to the Company regarding your rights under applicable U.S. State Privacy Laws, we may redirect you to the Brand.

13. LOCATION OF OUR SERVICES

We do not warrant or represent that this Policy or the Portal’s use of your Personal Information complies with the laws of every jurisdiction. Furthermore, to provide you with our services, we may store, process, and transmit information in the United States and other locations around the world, including countries that may not have the same privacy and security laws as yours. Regardless of the country in which such information is stored, we will process your Personal Information in accordance with this Policy.

14. FOR USERS OUTSIDE THE UNITED STATES

Under the (i) General Data Protection Regulation (Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016, or “GDPR”), (ii) Data Protection Act 2018, (iii) the GDPR as it forms part of the law of England and Wales, Scotland and Northern Ireland (i.e., “UK GDPR”) as provided in the Data Protection Act 2018, and (iv) any other applicable data protection legislation of any country or other jurisdiction (collectively “International Data Protection Laws”) individuals have specific rights with respect to their Personal Information, or “personal data” as defined under the International Data Protection Laws. Any personal data we collect from you is processed in the United States, under the terms of this Policy, and in the legitimate interest of our business and providing our services to you as the lawful means of such processing.

The Data Controller is the Brand. Company is a “Service Provider” or “Processor” as defined by the International Data Protection Laws. To the extent International Data Protection Laws allow you to make certain requests, including requests to access, correct, erase personal information, or withdraw consent, you must make these requests directly to the Brand. If you submit a request to the Company regarding your rights under applicable International Data Protection Laws, we may redirect you to the Brand.

15. SAFEGUARDING THE INFORMATION WE COLLECT

We use reasonable technical, administrative, and physical safeguards in order to protect your Personal Information against accidental loss and from unauthorized access, use, alteration, and disclosure. However, we can never promise 100% security. Please notify us immediately of any actual or suspected unauthorized use of the Portal or your information.

16. CHANGES TO THIS POLICY

This Policy describes our current policies and practices with regard to the information we collect through the Portal. We are continually improving and adding to the features and functionality of the Portal along with the products and services we offer through the Portal. If we make any changes to this Policy, a revised Policy will be posted on this webpage and the date of the change will be reported in the “Last Revised” block above. You can get to this page from any of our webpages by clicking on the “Privacy Policy” link (usually at the bottom of the screen). We may also contact you by email using the email that you have provided to us.

17. HOW TO CONTACT US

We value your opinions and welcome your feedback. To contact us about this Policy or your Personal Information, please contact us at support@closesimple.com.