Privacy Policy

Title Collections 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 or whose assets are being managed or appraised (“Collectors and End-Clients”), professionals who support them in managing their collections and making informed decisions (“Advisors”), and appraisers, shippers, insurers, and other professionals who provide services through the Platform (“Service Providers”).

Title is committed to respecting and safeguarding your personal information. Our practices comply with applicable privacy legislation, including Quebec’s Act respecting the protection of personal information in the private sector(Loi 25), the Personal Information Protection and Electronic Documents Act(PIPEDA) of Canada, the General Data Protection Regulation (GDPR) of the European Union where applicable, and relevant U.S. state privacy laws.

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.

We do not use your personal information for automated decision-making or profiling that produces legal effects. Where our Platform uses recommendation tools (such as appraiser matching), these rely on professional criteria (specialty, location, certifications) and do not profile individuals.

Create a User Account

When you create an account or are invited to join the Platform, we collect your full name, email address, preferred language, preferred currency, and organization name and role (for advisor accounts). Authentication is managed by our identity provider; we do not store passwords.

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 reports 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 Collector 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 and Analytics

We use essential cookies required for authentication and session management. We use PostHog, a product analytics tool, to understand how visitors interact with our Website and Platform and to improve our services. PostHog sets analytics cookies and stores a unique identifier in your browser to recognize returning visits across our titlecollections.com sites. It collects usage data such as pages visited and actions taken. This includes session recordings, which reconstruct how visitors move through and interact with our pages so we can find and fix usability problems. Session recordings mask the text you type into form fields. We do not use advertising cookies or retargeting pixels. This data is used solely for product improvement. It is not shared with advertisers or sold to third parties. These analytics are sent through our own domain, titlecollections.com, so ad blockers and tracker blockers may not block them.

You can turn these analytics off, session recordings included, with the switch below. It is also linked from the cookie banner and the site footer. When analytics are off, PostHog does not run in your browser. Turning them off here also deletes its identifier. We remember your choice in a cookie named title_analytics for one year. If your browser sends a Global Privacy Control or Do Not Track signal, analytics start off, and stay off unless you turn them on here. You can also object to this processing, as described in Access to Your Data and Your Rights.

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.

Digital Showrooms

Title hosts digital showrooms for collection owners at showroom.titlecollections.com. A showroom presents works from a collection and is either public or private; a private showroom asks for a password. You do not need an account to visit one, and we do not ask who you are. When you visit a showroom, this section describes what we collect, in place of Visiting Our Website and Cookies and Analytics above.

What a Showroom Records When You Visit

When you open a page of a published showroom, including the password page of a private showroom, our server keeps a short record of that page request:

• the showroom and the page you opened;
• the date and time;
• your network, not your full IP address (see below);
• your country, as a two-letter code;
• your browser’s identification string (user agent), which tells us the browser, its version, the operating system and the type of device;
• the code of the tracked link or QR code you came through, if any.

This record does not include your name, your email address, your exact location, cookies, or anything you type into a page. Our server makes it when the page is requested, so it is kept even if you block analytics.

Your IP Address Is Shortened Before It Is Stored

We remove the end of your IP address before the visit record is written. For an IPv4 address, we keep the first three numbers: 203.0.113.42 becomes 203.0.113.0. For an IPv6 address, we keep the first three groups. What remains identifies a network, such as an office or a home internet connection, not a single device. Your full IP address is never written to the visit record.

Visit Records Are Deleted After 365 Days

A daily process deletes showroom visit records older than 365 days.

Analytics You Can Block

Showroom pages also load PostHog, a product analytics tool, directly from PostHog’s servers in the United States. It records the pages you view and the links and buttons you click, the time you spend on a work, and whether you zoom into an image, share a work or click a contact link. The showroom’s own events carry the showroom, the work, the page language and the link code, if any. PostHog stores a random identifier in your browser and receives your IP address, browser, device type, screen size and the site you came from. The showroom does not send PostHog your name or any account, and PostHog does not build a profile of you. PostHog keeps this analytics data for one year.

Your ad blocker, tracker blocker or browser privacy settings can block PostHog entirely. The showroom works the same without it.

The showroom also keeps the link code and an entry marker for your browsing session; both are cleared when you close the tab. On a private showroom, a cookie remembers that you entered the password.

Who Sees Showroom Visit Data

Only Title staff can see showroom visit data, in the showroom’s administration area. Staff can see individual visit records (time, page, network, country and link code) and individual browsing sessions recorded by PostHog, each under a random identifier. Staff can label a network or an identifier, for example our own office, to leave our team’s visits out of the figures.

Collection owners do not have access to this data. The reports we prepare for them contain totals only, such as visits per work, per day, per country or per device type. They never list individual visits or visitors.

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 function 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 Collections 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.

Platform data is hosted on Cloudflare’s global infrastructure, with primary database storage in North America. Files are stored in Cloudflare R2 (object storage). Authentication data is managed by Clerk (United States). Payment data is managed by Stripe (United States).

We use the following third-party service providers to operate the Platform:

Each provider processes data only as necessary to provide their service and is bound by contractual data protection obligations.

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 according to the schedule below or as otherwise required to meet legal, regulatory or business requirements.

We retain personal information according to the following schedule:

When the retention period expires, data is either deleted or irreversibly anonymized.

You can delete your User account at any time by contacting us at [email protected]. If you delete your account, your personal profile data is deleted within 30 days. Mandate records and associated data are retained for the applicable retention period above, then deleted. Data already shared with third parties (assigned appraisers, firms) as part of completed mandates cannot be recalled, but those parties remain bound by their confidentiality 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

Depending on your jurisdiction, you have the following rights regarding your personal information:

• Access: request a copy of the personal information we hold about you.
• Correction: request correction of inaccurate or incomplete information.
• Deletion: request deletion of your personal information, subject to our legal retention obligations.
• Portability: receive your personal data in a structured, machine-readable format.
• Withdrawal of consent: withdraw consent for processing where consent is the legal basis (this does not affect the lawfulness of prior processing).
• Objection: object to processing based on legitimate interests.
• De-indexing: request that your information be de-indexed from search or recommendation features.

To exercise any of these rights, contact our Privacy Officer at [email protected]. We will respond within thirty (30) days. If we cannot fulfill a request, we will explain why.

Breach Notification

In the event of a security breach involving your personal information that presents a serious risk of harm, we will:

• Notify the Commission d’accès à l’information du Québec (CAI) promptly, as required by Loi 25.
• Notify affected individuals as soon as feasible, describing the nature of the breach, the information involved, and the measures taken.
• Where applicable, notify the Office of the Privacy Commissioner of Canada and any other relevant authority.

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

We may update this Privacy Policy from time to time. When we make changes we consider material, we will notify you by email or through a notice on the Platform. The “Last Updated” date at the top of this page indicates the most recent revision.

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
[email protected]