Privacy Policy

Privacy Policy

Peninsula Escrow, Inc. Privacy Notice for California Residents

This Privacy Notice of California Residents applies to all visitors, users, and others who reside in the State of California (“consumers” or “you”). We adopt this notice to comply with the California Consumer Privacy Act of 2018 (CCPA) and any terms defined in the CCPA have the same meaning when used in this notice. As use throughout this notice, Peninsula Escrow is referred to as “we,” “us,” or “our company.”

Received or Collected Information

This table discloses information we may receive or collect, and information we do not receive or collect:

Category	We May Receive or Collect This Information	After Searching, We Are Not Aware of Collecting This Information
Identifiers	Your name, postal address, email address, online identifiers, internet protocol address, social security number, driver’s license number, financial information, bank information, tax information, citizenship status, tax ID number, passport numbers, alias, prior names, birth date, encumbrances, matters of public record, employment	Unique personal identifiers
California Customer Records statute information (Cal. Civ. Code § 1798.80(e)	Signature, address, telephone number, bank account number, sales information such as listing price and purchase price, home/title insurance policy numbers or other financial information relating to the financing of a real estate transaction (i.e. information provided to an agent by you, a lender, or mortgage broker; information related to the verification of a down payment typically required by a real estate purchase agreement; or information provided to an agent when a “net sheet” is created), social security number, driver’s license number, financial information, bank information, tax information, citizenship status, tax ID number, passport numbers, alias, prior names, birth date, encumbrances, matters of public record	Physical characteristics or description, state identification car number, other insurance policy numbers, education, employment, employment history, credit card number, debit card number, or any other financial information, medical information, or health insurance information.
Protected classification characteristics under California for federal law	Citizenship or marital status, mental capacity (as sometimes issues of capacity arise in a real estate transaction), social security number, driver’s license number, financial information, bank information, tax information, citizenship status, tax ID number, passport numbers, alias, prior names, birth date	Race, color, ancestry, national origin, religion or creed, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information).*
Commercial information	Information is received when used to facilitate a real property purchase transaction such as sales information, purchase price, listing price or contract terms, matters of public record.	Records of personal property (unless part of the sale, or encumbrance on the property), products or services purchased (unless part of the sale), obtained or considered, or other purchasing or consuming histories or tendencies.
Biometric information	We do not collect this information.	Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as fingerprints (unless required by state or federal law), face prints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, sleep, health or exercise data.
Internet or other similar network activity	Browsing history, search history, information on a consumer’s interaction with a website, application, or advertisement.
Geolocation data	General geographic physical location.	Physical movements.
Sensory data	We do not collect this information.	Audio, electronic, visual, thermal, olfactory, or similar information.
Professional or employment-related information	Your name, postal address, email address, online identifiers, internet protocol address, social security number, driver’s license number, financial information, bank information, tax information, citizenship status, tax ID number, passport numbers, alias, prior names, birth date, encumbrances, matters of public record, employment contact	Employment information other than current employer contact, current or past job history, or performance evaluations
Non-public education information (per the Family Educational Rights and Privacy Act [20 U.S.C. Section 1232g, 24 C.F.R. Part 99])	We do not collect this information.	Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records.
Inferences drawn from other personal information	Lists of potential clients (“leads lists”).	Profile reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.

Social security (tax ID), driver’s license and passport numbers, and citizenship and occupational information may be collected pursuant to Treasury Department anti-money laundering rules when the buyer is an entity and is not using a bank loan to purchase residential real property. These Treasury Department rules are designed to uncover the identity of the natural person behind the entity. This information will be required to be given to the title company when the transaction involves all of the following:

• Property within the counties of Los Angeles, San Diego, San Francisco, San Mateo or Santa Clara;
• Sales price is $300,000 or more;
• Buyer is a “Legal Entity” such as a corporation, LLC or partnership;
• Property is a 1-4 unit residential property (including condos);
• Some part of the purchase is made using ANY wired funds, cashier’s check, certified check;
• traveler’s check, personal check, business check, money order in any form, or a virtual currency; and
• Purchase is done without a bank loan or similar forms of external financing.

California law under the CCPA defines “personal information” broadly. However, there are some exceptions. Personal information does not include:

• Publicly available information from government records;
• Deidentified or aggregated consumer information; or
• Information excluded from the CCPA’s scope, like:

o   Health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and the California Confidentiality of Medical Information act (CMIA) or clinical trial data; and

o   Personal information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FRCA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver’s Privacy Protection Act of 1994.

1. Where Does Peninsula Escrow, Inc. Receive Information From?

Peninsula Escrow, Inc. receives personal information primarily directly from you for the purpose of providing settlement services. Our company receives some information indirectly as well. Nearly all of the information we directly collect about you is received from the physical or electronic documents that constitute transaction underlying the need for settlement services. For example, a real property purchase agreement will contain your name, signature, purchase price and other personal information. Once these documents come into our possession, by law, we must maintain such records.

Cookies and Other Technologies. Our website and some of our online products and services, email messages, and advertisements may use cookies, log files, and other technologies to collect information about your use of our website, products and services and third-party websites that have a business relationship with our service providers. A cookie is a delicious treat, but this purpose, it is a small data file that is sent to your browser from a website’s servers and stored on your computer’s hard drive, and is used to store information such as the name of your Internet service provider, your Internet Protocol (IP) address, the website that referred you, your general geographic location, the pages you request, and the dates and times of those requests.

Title, Mortgage and Real Estate Companies. These service providers are essential to certain settlement transactions and sometimes provide or receive your personal information to facilitate a transaction.

Lenders and Mortgage Brokers. We will typically be in contact with the lender or lender’s representative throughout certain transactions to keep informed on the progress of the lending process. During this process, we may receive personal information relating to the loan, the loan application, the qualifications for the loan, documents requested by the lender, or reasons why a loan is being denied, approved or delayed.

City, County, State and Other Agencies of Government. Many aspects of transaction rely on information received from a variety of government sources. For example, the assessor will typically provide their estimate of the square footage, permits, and composition of the house, among various other types of data concerning the property.

Reporting Companies. Reporting companies will access public records for information concerning the property and then provide a summary of the information. This information is not typically considered “personal information.”

Other Sources of Information. Brokers, agents, lenders, buyers, sellers, neighborhood advertising information, real property portals such as Realtor.com, homeowner’s association documents, appraisers and appraisals, investigators, inspectors, contractors, and disclosures are other sources of information from which personal information may be collected or received.

1. Use, Sharing, and Sale of Personal Information

Use of Personal Information

Providing Settlement Services. The primary use of your personal information is to provide settlement services for your transaction. For example, if you are seeking to buy or sell a house, the personal information we collect will facilitate the close of escrow for you.

Web Technologies. We use cookies and other technologies to verify user information, to make your use of our website, products and services more convenient and to assist in understanding your use of our website products and services. We also use cookies to measure website activity and generate statistics that allow us to improve the services we provide online.

Additional Uses. We may use the personal information we collect for the following additional business purposes:

• To create, maintain, customize, and secure the communications between you and us.
• To assist in preventing transaction fraud.
• To provide, support, personalize, and develop our website, products, and services.
• To personalize your online experience with us and to deliver content and product and service offerings relevant to your interests, including targeted offers and ads through our website, third-party sites, and via email or text message (with your consent, where required by law).
• For testing, research, analysis, and product development, including to develop and improve our website, products, and services.
• To respond to law enforcement requests and as required by applicable law, court order, subpoena, or governmental regulations.
• As described to you when collecting your personal information or as otherwise set forth in the CCPA.
• To evaluate or conduct a merger, divestiture, restricting, reorganization, dissolution, refinance, purchase, sale, or transfer of some or all of our company’s assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by our company is among the assets.
• To comply with regulations set forth by the California Department of Business Oversight and any other local, state or federal governmental agencies regarding settlement services.

Sharing of Personal Information and Chart

Sharing Information. We do not share your personal information unless required by us to facilitate your transaction, or to comply with local, state, or federal law.

This table discloses which types of information our company has and has not disclosed for a business purpose within the last 12 months.

Category	We May Disclose for a Business Purpose within the last 12 Months	After Searching, We Are Not Aware of Disclosing for a Business Purpose within the last 12 Months
Identifiers	Your name, postal address, email address, online identifiers, internet protocol address, social security number, driver’s license number, financial information, bank information, tax information, citizenship status, tax ID number, passport numbers, alias, prior names, birth date, encumbrances, matters of public record, employment	Alias, unique personal identifier, account name.
California Customer Records statute information (Cal. Civ. Code § 1798.80(e)	Signature, address, telephone number, bank account number, sales information such as listing price and purchase price, home/title insurance policy numbers or other financial information relating to the financing of a real estate transaction (i.e. information provided to an agent by you, a lender, or mortgage broker; information related to the verification of a down payment typically required by a real estate purchase agreement; or information provided to an agent when a “net sheet” is created), social security number, driver’s license number, financial information, bank information, tax information, citizenship status, tax ID number, passport numbers, alias, prior names, birth date, encumbrances, matters of public record	Physical characteristics or description, state identification car number, other insurance policy numbers, education, employment (other than current if required), employment history, medical information, or health insurance information.
Protected classification characteristics under California for federal law	Citizenship or marital status, mental capacity (as sometimes issues of capacity arise in a real estate transaction), social security number, driver’s license number, financial information, bank information, tax information, citizenship status, tax ID number, passport numbers, alias, prior names, birth date	Race, color, ancestry, national origin, religion or creed, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information).*
Commercial information	Information is received when used to facilitate a property purchase transaction such as sales information, purchase price, listing price or contract terms.	Records of personal property (unless part of the sale), products or services purchased (unless part of the sale), obtained or considered, or other purchasing or consuming histories or tendencies.
Biometric information	We do not collect or share this information.	Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as fingerprints, face prints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, sleep, health or exercise data.
Internet or other similar network activity	We do not share this information.	Browsing history, search history, information on a consumer’s interaction with a website, application, or advertisement.
Geolocation data	We do not share this information.	General geographic physical location.
Sensory data	We do not collect or share this information this information.	Audio, electronic, visual, thermal, olfactory, or similar information.
Your name, postal address, email address, online identifiers, internet protocol address, social security number, driver’s license number, financial information, bank information, tax information, citizenship status, tax ID number, passport numbers, alias, prior names, birth date, encumbrances, matters of public record, employment contact	Employment information other than current employer contact, current or past job history, or performance evaluations	Your name, postal address, email address, online identifiers, internet protocol address, social security number, driver’s license number, financial information, bank information, tax information, citizenship status, tax ID number, passport numbers, alias, prior names, birth date, encumbrances, matters of public record, employment contact
Non-public education information (per the Family Educational Rights and Privacy Act [20 U.S.C. Section 1232g, 24 C.F.R. Part 99])	We do not collect or share this information.	Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records.
Inferences drawn from other personal information	Lists of potential buyers or sellers (“leads lists”) may be placed on third party websites to aggregate data and manage client services.	Profile reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.

Sale of Personal Information

We do not sell your Personal Information.

This table discloses which types of information our company has and has not sold within the last 12 months.

Category	We May Sell this Information	After Searching, We Are Not Aware of Selling This Information
Identifiers	We do not sell this information
California Customer Records statute information (Cal. Civ. Code § 1798.80(e)	We do not sell this information.
Protected classification characteristics under California for federal law	We do not sell this information.	Race, color, ancestry, national origin, religion or creed, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information).*
Commercial information	We do not sell this information.	Records of personal property (unless part of the transaction), products or services purchased (unless part of the transaction), obtained or considered, or other purchasing or consuming histories or tendencies.
Biometric information	We do not sell this information.	Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as fingerprints (unless part of the transaction), face prints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, sleep, health or exercise data.
Internet or other similar network activity	We do not sell this information.	Browsing history, search history, information on a consumer’s interaction with a website, application, or advertisement.
Geolocation data	We do not sell this information.	General geographic physical location.
Sensory data	We do not sell this information.	Audio, electronic, visual, thermal, olfactory, or similar information.
Professional or employment-related information	We do not sell this information.	Employment information other than current employment, past job history, or performance evaluations.
Non-public education information (per the Family Educational Rights and Privacy Act [20 U.S.C. Section 1232g, 24 C.F.R. Part 99])	We do not sell this information.	Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records.
Inferences drawn from other personal information	We do not sell this information.	Profile reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.

III.                Your Rights and Choices

If you are a California resident, you have certain rights regarding your personal information under the CCPA. This section describes your CCPA rights and explains how to exercise those rights.

Access to Specific Information

You have the right to request that we disclose certain information to you about our collection and use of your personal information over the past 12 months. You must make a verifiable consumer request as described below. Once we receive and confirm your verifiable consumer request, we will disclose to you:

• The categories of personal information we collected about you;
• The categories of sources from which we collected your personal information;
• Our business or commercial purpose for collecting or selling your personal information;
• The categories of third parties with whom we share your personal information;
• The specific pieces of personal information we collected about you; and
• If we sold or disclosed your personal information for a business purpose, we will provide two separate lists disclosing the following:

o   The categories of personal information that we disclosed about you for a business purpose; and

o   The categories of personal information that we sold about you and the categories of third parties to whom the personal information was sold, by category of personal information for each third party to whom the personal information was sold.

Deletion Request Rights

You have the right to request that we delete any of your personal information that we collected from you and retained, subject to certain exceptions. You must make a verifiable consumer request as described below. Once we receive and confirm your verifiable consumer request, we will delete (and direct our service providers to delete) your personal information from our records, unless an exception applies. However, we will not direct the MLS to delete your personal information. For that, you must contact the MLS directly because we have no control over their data.

We may deny your deletion request if retaining the information is necessary for us or our service provider(s) to:

• Retain transaction files or comply with any other legal obligation. Brokers are required to hold all transaction files for a period of at least three years under California law. Our company holds files for approximately five years.
• Complete the transaction for which the personal information was collected, provided a good or service requested by you, or reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you. For example, we will not delete your personal information while we are representing you in your real estate transaction.
• Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity; or prosecute those responsible for that activity.
• Debug to identify and repair errors that impair existing intended functionality.
• Exercise free speech, ensure the right of another consumer to exercise his or her right of free speech, or exercise another right provided by law.
• Comply with the California Electronic Communications Privacy Act pursuant to Chapter 3.6 (commencing with Section 1546) of Title 12 Part 2 of the Penal Code.
• Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when lack of our information is likely to render impossible or seriously impair the achievement of such research, so long as you have provided informed consent.
• Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
• Otherwise use your personal information, internally, in a lawful manner that is compatible with the context in which you provided it.

How to Exercise Your Access and Deletion Rights

To exercise the access and deletion rights described above, please submit a verifiable consumer request to us by either:

• Calling us at: (800 )414-4576
• Emailing us at: privacy@penescrow.com

You may also make a request on behalf of your minor child. You may only make a request for access to or disclosure of your personal information twice within a 12-month period. The request must:

• Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative; and
• Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

We cannot respond to your request or provide you with personal information if we are unable to verify your identity or authority to make the request and confirm the personal information relates to you. You do not need to create a user account with us to make a request. However, we do consider requests made through your password protected account sufficiently verified when the request relates to personal information associated with that specific account. If you provide us with personal information in your request, we will only use it to verify the requestor’s identity or authority to make the request.

Response Timing and Format

We will try to respond to your request within 45 days of its receipt. If we require more time, we will inform you of the reason and extension period in writing. But the extension period will be no more than an additional 45 days.

If you have an account with us, we will deliver our written response to that account. If you do not have an account with us, we will deliver our written response by mail or electronically, at your option. Any disclosures we provide will only cover the 12-month period preceding our receipt of your request. The response we provide will also explain the reasons we cannot comply with a request, if applicable.

If we deliver the information to you electronically, then the information will be portable and to the extent technically feasible, in a readily useable format that allows you to transmit it from another entity without hindrance.

We do not charge a fee to process or respond to your request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.

Personal Information Sales Opt-Out and Opt-In Rights

If you are 16 years of age or older, you have the right to direct us to not sell your personal information at any time (the “right to opt-out”). We do not sell the personal information of consumers we actually know are less than 16 years of age, unless we receive affirmative authorization (the “right to opt-in”) from either the consumer who is between 13-16 years of age, or the parent or guardian of a consumer less than 13 years of age. Consumers who opt-in to personal information sales may opt-out of future sales at any time.

To exercise the right to opt-out, you or your authorized representative may submit a request to us by:

• Calling us at: (800 )414-4576
• Emailing us at: privacy@penescrow.com

Once you make an opt-out request, we will wait at least twelve months before asking you to reauthorize personal information sales. However, you may change your mind and opt back in to personal information sales at any time by visiting the following link:

http://www.penescrow.com/privacy-policy/

You do not need to create an account with us to exercise your opt-out rights. We will only use personal information provided in an opt-out request to review and comply with the request.

Non-Discrimination

We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not:

• Deny you goods or services.
• Charge you different prices or rates for goods or services, deny discounts or other benefits, or impose penalties.
• Provide a different level or quality of goods or services to you.
• Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.

However, we may offer you certain financial incentives permitted by the CCPA that can result in different prices, rates, or quality levels. Any CCPA permitted financial incentive we offer will reasonably related to your personal information’s value and contain written terms that describe the program’s material aspects. Participation in a financial incentive program requires your prior opt in consent, which you may revoke at any time. We currently do not provide any financial incentive programs, but reserve the right to change that at a later date.

Changes to Our Privacy Notice

We reserve the right to amend this privacy notice at our discretion and at any time. When we make changes to this privacy notice, we will post the updated notice on our website and update the notice’s effective date. Your continued use of our website following the posting of changes constitutes your acceptance of such changes.

Contact Us

If you have any questions about this notice, the ways in which we collect and use your information, or if you wish to exercise your rights under California law, please do not hesitate to contact us at:

Phone:: (800 )414-4576
Website: http://www.penescrow.com/privacy-policy/
Email: privacy@penescrow.com
Postal Address:
Peninsula Escrow, Inc.
Attn: IT Department
63 Malaga Cove Plaza
Palos Verdes Estates, CA 90274