Title V of the Gramm-Leach-Bliley Act (GLBA) generally prohibits any financial institution (including title agencies and companies) from sharing nonpublic personal information about you with a nonaffiliated third party unless the institution provides you with a notice of its privacy policies and practices. In compliance with the GLBA, we are providing you with this document, which notifies you of the privacy policies and practices of Cumberland Title Services, LLC.
Applicability
The principal role of Cumberland Title Services, LLC is to provide individual title insurance products and services to consumers, as well as to provide title insurance underwriting and loan closing services to lenders. This privacy policy governs our use of the information which you provide to us when you apply for private owners’ title insurance through us. It does not govern the manner in which we may use information we have obtained from any other third party, such as information obtained from lenders, in order for us to provide services to them. Information obtained from you by your lender, for example, is governed by the lender’s privacy policy.
Types of Information
Depending on which of our services you are utilizing, the types of nonpublic personal information that we may collect and retain include: information that identifies you such as name, address, telephone number and Social Security number; information you provide to us on applications and through other means that will help us determine if you are eligible for products you request; information we receive from a consumer reporting agency during a normal business transaction; and information from outside sources or others involved in your transaction, such as details about your property and data from public records that is not assembled or used for the purpose of determining eligibility for a product or service.
Use of Information
We request information from you for our own legitimate business purposes and not for the benefit of any nonaffiliated party except where we are providing services to a third party, such as your lender, related to a product or service you have requested. Therefore, we will not disclose any nonpublic personal information about customers’ or former customers’ accounts or other personally identifiable data to unaffiliated third parties for their independent use, unless the information is provided: 1) to assist us in providing products and services to our customers in the normal course of our business; 2) at the request or with the permission of the customer; or 3) when the disclosure is permitted by law or required by law enforcement or regulatory agencies.
We may store such information indefinitely, including the period after which any customer relationship has ceased. Our privacy policy will continue to apply to those who are no longer our customers. Information may be used for any internal purpose, such as quality control efforts or customer analysis. If we provide identifiable customer information to a third party with which we have a business relationship, we insist that the third party adhere to strict privacy guidelines that provide for keeping any such information confidential.
Maintenance of Accurate Customer Information
We have established procedures to maintain the accuracy of customer information and to keep such information current and complete. These procedures include promptly responding to requests to correct inaccurate information. We maintain physical, electronic and procedural safeguards that comply with federal regulations to guard your nonpublic personal information.
Limiting Employee Access to Information
We restrict employee access to nonpublic personal information about you to those with a business reason for knowing such information. Employees are educated on the importance of maintaining the confidentiality of customer information and our privacy policy. Because of the importance of this issue, all of our employees are responsible for maintaining the confidentiality of customer information, and employees who violate this privacy policy are subject to disciplinary measures up to and including termination.
Reservation of Right to Alter, Modify, Replace or Repeal
We reserve the right to alter, modify, replace or repeal this privacy policy. We will provide notice to the customer, as required by law, prior to or contemporaneously with any such alteration, modification, replacement or repeal.