Privacy Policy

Last Updated: January 5, 2025

The privacy and security of your personal information are important to us, and we are committed to safeguarding it. CloseWise, Inc. and its affiliates (collectively, “CloseWise“, “we”, “us”, or “our”) have prepared this Privacy Policy to describe to you our practices regarding the Personal Information we collect from users of our website (https://www.closewise.com/), or any other websites of CloseWise (collectively, the “Website“), in any way, including using services or resources available or enabled via, or that interact with, the Website (collectively, the “Services“), unless otherwise indicated. All capitalized terms not defined in this Privacy Policy have the definitions assigned in the Terms of Service.

Applicability Of This Privacy Policy

By using our Website or Services, you agree to this Privacy Policy. This is our entire and exclusive Privacy Policy, and it supersedes any earlier version. In conjunction with this Privacy Policy, you should also review our Terms of Service, available here (https://www.closewise.com/terms-and-conditions/), for a more complete understanding of the rules governing the Services.

You should also understand, in reading our Privacy Policy, that while we typically handle Personal Information relating to four categories of User (Companies, Notaries, Borrowers, and Participants), our processing of Borrower and Participant personal information is solely in our role as a service provider to a Company. So, if you are a Borrower or a Participant representative, we may not have the authority to act on your privacy questions or requests, in which case we will direct you to the Company for whom we provided the Services. If you are a User from a Company or Notary, CloseWise has a direct relationship with you and as such we can respond directly to you on your Personal Information questions or requests.

Types of Data We Collect

“Personal Information” means information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular person or even a household.

Information You Provide to Us

We require certain Personal Information from you, such as your first and last name, e-mail and mailing addresses, company name, and password, when you create an account to log in to our Website (“Account“). Additional information may include governmental identification, date of birth, professional history, or payment information depending on your use of our Services.

Information Collected via Technology

To make the Services more useful to you, our servers collect information when you visit the Website and use the Services, including your browser type, operating system, Internet Protocol (“IP“) address, and session details. We also use Cookies and Pixel Tags to enhance your experience.

Google APIs

We use Google Maps APIs, Google Calendar APIs, and other Google services. This privacy policy incorporates the Google Privacy Policy (http://www.google.com/privacy.html) as amended by Google from time to time. CloseWise’s use and transfer to any other app of information received from Google APIs will adhere to the Google API Services User Data Policy, including the Limited Use requirements.

How We Use Your Information

• To operate our business and provide you with our Services.
• To verify your identity and confirm transactions.
• To improve and tailor our Website and Services to your needs.
• To comply with legal obligations and resolve disputes.

Sharing and Disclosure of Google User Data

We do not sell or rent your personal data to third parties. However, we may share Google user data in the following circumstances:

• Service Providers: We may share data with trusted service providers who assist in delivering our services, such as cloud hosting providers, analytics platforms, or customer support tools. These providers are contractually obligated to maintain the confidentiality of the data and to use it solely for providing the services to us.
• Legal Obligations: We may disclose your information to comply with applicable legal requirements, such as responding to a subpoena, court order, or legal process.
• Business Transfers: In the event of a merger, acquisition, or sale of all or a portion of our business, user data, including Google user data, may be transferred as part of that transaction.
• With Your Consent: We will share your information with third parties if you explicitly authorize us to do so.

Data Protection Mechanisms

At CloseWise, we prioritize the security and privacy of your sensitive data. Here are the measures we take to protect your information:

• Encryption: All sensitive information, including data received from Google APIs, is encrypted both in transit and at rest using industry-standard encryption protocols.
• Access Control: Access to sensitive data is restricted to authorized personnel only, and access is monitored and audited regularly to prevent unauthorized activity.
• Compliance: We adhere to industry security standards, including the Payment Card Industry Data Security Standards (PCI DSS), and comply with applicable privacy laws, such as GDPR and CCPA, where applicable.
• Monitoring and Auditing: We utilize advanced monitoring tools to detect and respond to any suspicious activity, ensuring your data remains secure.

OAuth Scope Details

To provide you with our services, CloseWise requests access to certain Google API scopes. Below is a detailed list of the scopes requested and their purposes:

• https://www.googleapis.com/auth/calendar: To access and manage your Google Calendar for scheduling purposes.
• https://www.googleapis.com/auth/calendar.events To access and manage your Google Calendar events for scheduling purposes.

• https://www.googleapis.com/auth/maps: To provide accurate location-based services using Google Maps.

We use these scopes strictly to deliver the functionality described, in compliance with Google’s API Services User Data Policy and the Limited Use requirements.

Your Choices and Rights About Your Personal Information

• Email Communications: You can opt out of receiving promotional emails by following the unsubscribe instructions provided in those emails.
• Accessing, Changing, or Deleting Information: You may review, update, or delete your information through your account settings or by contacting us directly.
• Cookie Management: You may adjust your browser settings to block cookies.

Changes to This Privacy Policy

We may update this Privacy Policy from time to time. When we do, we will post the updated version on our Website with a new “Last Updated” date. Your continued use of the Website and Services constitutes your acceptance of the updated Privacy Policy.

Contact Us

If you have any questions or concerns regarding this Privacy Policy, please contact us at support@CloseWise.com.