Privacy Policy

Last Update: February 2025

Title Inc. (“Title”) provides a cloud-based collection management software to manage, value, and organize collections of valuable and collectible items. Title also provides services of asset identification, inventory and documentation of collections, coordination of appraisals with expert appraisers, and generation of insights to assist with the financial management and insurance of collections.

Title’s Users include individuals who own collections (“Collectors”), as well as the professionals who support them in managing their collections and making informed decisions (“Advisors”). These Advisors include, but are not limited to, personal property appraisers (“Appraisers”), professional collection managers (“Collection Managers”), wealth managers, estate planners, insurers, insurance managing general agent, insurance brokers, and other advisors with authorized access to a Collector’s account.

Title is committed to respecting and safeguarding your personal information. Our practices are designed following multiple international data protection regulations, including but not limited to the Personal Information Protection and Electronic Documents Act (PIPEDA) of Canada, the General Data Protection Regulation (GDPR) of the European Union, and applicable U.S. data protection laws. Wherever you are accessing our services from, know that your privacy is of utmost importance to us.

This Privacy Policy explains how, and for what purposes, we use the information collected about you via (a) our websites offered on or through https://www.titlecollections.com/ (the “Website”); (b) any text, pictures, media, data, or other information, materials, or content (collectively, the “Content”) contained on or provided through the Title Website; and (c) all other Content, products or services provided by us to you (collectively, the “Services”). By using the Services, you consent to our collection and handling of personal information as described in this Privacy Policy.

Introduction

Capitalized terms shall have the meanings given to them in this Privacy Policy or the Terms of Use for the Services, as applicable.

When you use the Website or the Services, we may collect certain information about you such as your name, contact details, information about the device you use, and how you use the Website. We may also collect information about third parties where you provide information about those individuals through your use of the Website or the Services.

We collect this information about you so that we can provide the Services to you; run our business; further develop elements of the Services; personalize the Services to your preferences; contact you; and comply with the law.

Our Services are not intended for individuals under the age of 18. We do not knowingly collect personal data from minors. If we become aware that we have inadvertently collected personal information from a minor, we will take appropriate steps to delete such information.

How we collect and use data

We collect and process personal information with transparency and fairness, adhering to internationally recognized data protection principles. Regardless of where you are from, we ensure that we have a legal basis, such as your consent or a legitimate business interest, for collecting and processing your data.

Create a User Account: When you create, or are invited to create, a user account, we collect your first and last name, an email address, your preferred language, and your preferred currency. This information is used to create and administer your online account.
- User Sign-Up: If you are creating an account by yourself, you will be prompted to set your own password during the sign-up process. Please ensure your chosen password is secure and kept confidential.
- Invitation-Based Account: If you are invited to create an account, a temporary password will be sent to your email address to verify your identity and facilitate account setup. Do not disclose this temporary password to anyone. We will never ask for your temporary password in any communication, such as phone calls, text messages, or email messages.

Create an Advisor Account: When an Advisor enters an agreement to use the Website, we create an Advisor profile and will create the User Accounts requested by the administrator of the Advisor account. We will collect your business contact details (such as name, email address, phone number, mailing address), as well as employee information per the administrator's requirements for the creation of User Accounts for its employees.

Join the User Waitlist: Prior to creating a User account, you may be invited to join a waitlist by providing your first and last name and your email address. We will contact you using the email address provided when we invite you to create an account.

Generate Collection Reports: As part of the Services, Collectors and Advisors have the capability to generate report about some or all of the information of a collection. These reports may include private information about the collection, its value, the location of items, and other details. Once a report is generated, it can be downloaded as a PDF or other file format and be shared outside the platform. While Title facilitates the creation of these reports, we do not control how they are stored, transmitted, or shared after they are generated. Users are solely responsible for safeguarding any reports they download or distribute and ensuring they are shared only with authorized parties.

Request Appraisal: As part of the Services, Collectors have the capability to request an item to be appraised, using Title as an intermediary between the Collectors and Appraisers. By requesting an appraisal, the Collectors grants the sufficient rights to use the Collector’s data to facilitate the appraisal mandate. Appraisal requests may involve the use of AI-powered recommendation tools to identify suitable appraisers based on the Collector’s needs. All parties to such mandate will be bound by Title’s Privacy Policy. Title reviews appraisal-related data solely for quality assurance and compliance with the Uniform Standards of Professional Appraisal Practice (USPAP). Appraisers and Advisors receiving personal data are subject to strict confidentiality obligations and are permitted to use the data only to fulfill the appraisal or professional mandate.

Visiting our Website: You do not have to register to visit our Website. In general, you can visit our Website without telling us who you are or submitting any personal information. However, we collect the IP (Internet protocol) addresses of all visitors to our Website and other related information such as page requests, browser type, operating system and average time spent on our Website, as well as information we or our partners have stored in cookies (more on that below), such as unique identifiers assigned to your browser. We use this information to help us understand our Website activity and to monitor and improve our Website.

Using our Website: When using the Website, you are required to log-in using your User account and we collect the information described in the sections above as well as locations where items are located.

Cookies: Our Website uses a technology known as "cookies". A cookie is a tiny element of data sent from our Website to a User’s browser, which may then be stored on the User’s hard drive to facilitate subsequent interactions with our site. Some cookies are essential for certain features and functionalities of our Website. While you can configure your browser to notify you about cookies or to reject certain cookies, not accepting essential cookies may hinder your experience and the full functionality of our Website.

Analytics: We may use third parties, such as Google Analytics or others, to help us gather and analyze information about the areas visited on the Website in order to evaluate and improve the user experience and the Website. These third parties may use cookies and other tracking technologies.
We may also process personal information to improve internal operations, including troubleshooting, data analysis, testing, research, and statistical purposes.

Sign-up to receive marketing communications: If you sign up to receive email marketing communications such as newsletters, we collect your email address as well as other information on an optional basis to help us tailor our communications to you. You can unsubscribe at any time by clicking the “unsubscribe” link included at the bottom of each marketing email. Please note that you may continue to receive account-related communications from us.

Connect with us on social media: We may offer you the opportunity to engage with our content on or through third-party social networking websites, plug-ins and applications. When you engage with our content on or through third-party social networking websites, plug-ins and applications, you may allow us to have access to certain information associated with your social media account (e.g., name, username, email address, profile picture, gender) to deliver the content or as part of the operation of the website, plug-in or application.

Participate in a survey: From time to time, we may offer you the opportunity to participate in a survey. The information obtained through our surveys is used in an aggregated, de-identified form. We use this information to help us understand our Users and to enhance the Website and Services.

Contact Us: When you contact us with a comment, question or complaint, you may be asked for information that identifies you, such as your name, location, email address, or telephone number, along with additional information we need to help us promptly answer your question or respond to your comment. We may retain this information to assist you in the future and to improve our customer service and the Services.

Note that if any of your personal details change during your use of our Website, you are responsible for updating them by accessing the relevant section of our Website, or by contacting us.

When do we share your data with other parties

We do not sell or disclose your personal information to third parties without your consent, except as set forth below or as required or permitted by law.

Service Features: The Services functions as a data management tool, enhancing the process of collection and sharing details about valuable and collectible assets owned by the Collector. Depending on the features and relevant privacy settings, certain personal information related to the assets may be shared with some Users associated with other Users and their teams. As an example, an Insurance Broker employee receives a report detailing the collector's assets listed for insurance coverage, along with pertinent information like the location of these assets, to ensure policy compliance. Additionally, when a Collector requests an appraisal from the Services, Title acts as an intermediary and will share only the information necessary to obtain quotes for mandates and for the selected appraiser to perform the appraisal report. Unless requested by the Collector or mandatory for the performance of the appraisal and previously approved by the User, Title will not share any Collector's personal information with appraisers.

Service Providers: Your personal information will be transferred (or otherwise made available) to certain third parties that provide services to us. We use service providers to provide or receive services such as hosting the Website, cloud storage, payment processing, customer support and issue-tracking capabilities, and advertising, analytics, and marketing services. Our service providers may be located in the U.S., Canada or other foreign jurisdictions.

Legal and Compliance: We and our Canadian, US and other foreign service providers may provide your personal information in response to a search warrant to other legally valid inquiry or order, or to another organization for the purposes of investigating a breach of an agreement or contravention of law or detecting, suppressing or preventing fraud, or as otherwise may be required or permitted by applicable Canadian, U.S. or other law or legal process, which may include lawful access by US or foreign courts, law enforcement or other government authorities. Your personal information may also be disclosed where necessary for the establishment, exercise or defense of legal claims and to investigate or prevent actual or suspected loss or harm to persons or property.

Sale of Business: We may transfer any information we have about you as an asset in connection with a proposed or completed merger, acquisition or sale (including transfers made as part of insolvency or bankruptcy proceedings) involving all or part of Title Inc. or as part of a corporate reorganization or other change in corporate control.

Where we store your data

By using the Website, you acknowledge that in order to perform the Services, we may need to transfer your personal data outside of your country to countries where Title maintains an office, or to countries where a Supplier is tasked with fulfilling a request on your behalf. While these countries may have different data protection standards than your home country, we commit to always adhering to the higher standard of protection, whether mandated by applicable law or dictated by our own stringent policies. Regardless of where your data is transferred or processed, we assure you that it will be protected as outlined in this Privacy Policy.

Our data is hosted on Amazon Web Services (AWS) servers located in the United States and Canada.

Whenever we transfer your personal data outside of the country in which you reside, or when your data is stored on servers located in another country, we adhere to rigorous safety standards to ensure your data's integrity and security, including:

Encryption: All data transfers are encrypted, ensuring that your information remains secure and unreadable during transit.
Minimal Data Sharing: We only share the absolute minimum necessary data required to fulfill a specific request or service.
Standard Contractual Clauses & Legal Safeguards: When transferring personal data from the European Economic Area (“EEA”) or other jurisdictions with data transfer requirements, we rely on appropriate safeguards, including Standard Contractual Clauses approved by the European Commission, adequacy decisions (e.g., for transfers to Canada), or other lawful transfer mechanisms.
Third-Party Accountability: Service providers and partners processing your data on our behalf are contractually required to comply with equivalent data protection safeguards.
Compliance with Local Laws: In cases where local data protection laws offer higher standards, we comply with these laws to ensure maximum protection for your data.
Regular Audits: Our data transfer processes undergo periodic reviews and audits to detect vulnerabilities and make necessary enhancements.
Government Access Requests: In the event that a government or law enforcement authority requests access to your data, we assess the validity of such requests and only disclose personal data where legally required to do so.

We are committed to ensuring that your personal data is protected to a high standard, regardless of where it is transferred or stored.

Safeguards and data retention

Our security and data retention practices are in line with international standards to ensure the utmost protection for your personal data. We use industry-leading measures to prevent unauthorized access and ensure the confidentiality, integrity, and availability of the information we handle.

We have implemented reasonable administrative, technical and physical measures in an effort to safeguard the personal information in our custody or control against theft, loss and unauthorized access, use, modification and disclosure. Measures include:

Restrict access to personal information on a need-to-know basis to employees and authorized service providers who require access to fulfill their job requirements.
Provide a role-based permission system within Advisor accounts to restrict what different people can do and see. An Advisor account may designate different roles for team members, including administrative access, standard access, and read-only access. These roles determine the level of access granted to personal data and collection information.
Follow strict guidelines in the storage and disclosure of personal data and communications that you have given us to prevent unauthorized access to it.
Have record retention processes designed to retain personal information for no longer than necessary for the purposes set out herein or as otherwise required to meet legal, regulatory or business requirements.

You can delete your User account at any time by contacting us at support@titlecollections.com. If you delete your account, information submitted to your Advisors, Collectors, or other service providers, detailing the items in your collection will continue to be accessible to Title and to the Users associated with that information. However, any attribution of such information to you will be removed from public view. Further, we may retain certain information to meet our legal or regulatory obligations.

Finally, all employees with access to private information pass a background check validation. Please contact us if you require details on our background check process.

Access to your data and your rights

As a result of our collecting and processing your information, you may have the following legal rights, subject to the data protection laws in your country:

to access personal data held about you;
to request us to make any changes to your personal data if it is inaccurate or incomplete;
to request your personal data is erased where we do not have a compelling reason to continue to process such data in certain circumstances;
to receive your personal data provided to us as a data controller in a usable way in certain circumstances;
to object to, or restrict, our processing of your personal data in certain circumstances;
to object to, and not be subject to, a decision which is based solely on, automated processing (including profiling), which produces legal effects or could significantly affect you;
where our processing of your personal data is based on your consent you have the right to withdraw consent at any time by contacting us; and
to lodge a complaint with a data protection supervisory authority. If you need the details of the data protection supervisory authority in your country, if any, please contact Title and we will be able to provide this information.

Depending on your jurisdiction, you may have additional rights under local data protection laws. For instance, residents of Canada may exercise their rights under PIPEDA, while residents of the European Union may rely on rights under the GDPR. We are committed to upholding all applicable rights under the relevant data protection frameworks.

To exercise any of your rights as set out above, please contact Title’s Privacy Officer at the email address given below in the Contact Us section.

Links

Our Website may contain links to other websites that Title does not own or operate. We provide links to third-party websites as a convenience to the Users. These links are not intended as an endorsement of or referral to the linked websites. The linked websites have separate and independent privacy policies, notices and terms of use. We do not have any control over such websites, and therefore we have no responsibility or liability for the manner in which the organizations that operate such linked websites may collect, use or disclose, secure and otherwise treat personal information. We encourage you to read the privacy policy of every website you visit.

Updates to the privacy policy

From time to time, we may update this privacy policy to reflect changes to our privacy practices. Before any significant updates go live, we will place a banner on our Website or communicate with you via email to inform users about the upcoming changes. We encourage you to periodically review this page to ensure you are familiar with those changes. We will indicate at the top of this privacy policy when it was most recently updated.

Contact us

For questions or concerns about how we handle personal data, or to understand more about our practices in relation to specific data protection regulations, or to request access to or correction of your personal information, please reach out to our Privacy Officer at the provided email address.

Privacy Officer

privacy@titlecollections.com