Stewart Information Services Corporation and its affiliates and majority-owned subsidiary companies (collectively, “Stewart,” “our,” or “we”) respect and are committed to protecting your privacy.  Pursuant to the California Consumer Privacy Act of 2018 (“CCPA”) and the California Privacy Rights Act of 2020 (“CPRA”), we are providing this Privacy Notice (“CCPA Notice”).  This CCPA Notice explains how we collect, use, and disclose personal information, when and to whom we disclose such information, and the rights you, as a California resident have regarding your Personal Information.  This CCPA Notice supplements the information contained in Stewart’s existing privacy notice and applies solely to all visitors, users, consumers, and others who reside in the State of California or are considered California Residents as defined in the CCPA (“consumers” or “you”).  All terms defined in the CCPA & CPRA have the same meaning when used in this Notice.

Personal information that is collected, processed, sold, or disclosed pursuant to the Gramm-Leach Bliley Act (GLBA) is exempt from the California Consumer Privacy Act (CCPA). GLBA is a federal law that regulates the use and disclosure of personal information by financial institutions. Personal information obtained by AccountChek from financial institutions is regulated by GLBA. Consumers grant AccountChek authorization to collect their personal information from financial institutions and share it for specific purposes described in AccountChek’s Terms of Service Agreement, which is presented to end users in the AccountChek® application.

AccountChek has implemented and maintains data security measures designed to ensure that personal information is secure and encrypted at rest or in transit. 

Personal and Sensitive Personal Information Stewart Collects

Stewart has collected the following categories of personal and sensitive personal information from consumers within the last twelve (12) months:

1. Identifiers. A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, Social Security number, driver’s license number, passport number, or other similar identifiers.
2. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)). A name, signature, Social Security number, address, telephone number, passport number, driver’s license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information.
3. Protected classification characteristics under California or federal law. Age, race, color, ancestry, national origin, citizenship, marital status, sex (including gender, gender identity, gender expression), veteran or military status.
4. Commercial information. Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.
5. Internet or other similar network activity. Browsing history, search history, information on a consumer’s interaction with a website, application, or advertisement.
6. Geolocation data

Stewart obtains the categories of personal and sensitive information listed above from the following categories of sources:

• Directly and indirectly from customers, their designees, or their agents (For example, realtors, lenders, attorneys, brokers, etc.)
• Directly and indirectly from activity on Stewart’s website or other applications.
• From third parties that interact with Stewart in connection with the services we provide. 

Use of Personal and Sensitive Personal Information

Stewart may use or disclose the personal or sensitive information we collect for one or more of the following purposes:

1. To fulfill or meet the reason for which the information is provided.
2. To provide, support, personalize, and develop our website, products, and services.
3. To create, maintain, customize, and secure your account with Stewart.
4. To process your requests, purchases, transactions, and payments and prevent transactional fraud.
5. To prevent and/or process claims.
6. To assist third party vendors/service providers who complete transactions or perform services on Stewart’s behalf pursuant to valid service provider agreements.
7. As necessary or appropriate to protect the rights, property or safety of Stewart, our customers, or others.
8. To provide you with support and to respond to your inquiries, including to investigate and address your concerns and monitor and improve our responses.
9. To personalize your website experience 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).
10. To help maintain the safety, security, and integrity of our website, products and services, databases and other technology-based assets, and business.
11. To respond to law enforcement or regulator requests as required by applicable law, court order, or governmental regulations.
12. Auditing for compliance with federal and state laws, rules, and regulations.
13. Performing services including maintaining or servicing accounts, providing customer service, processing, or fulfilling orders and transactions, verifying customer information, processing payments, providing advertising or marketing services or other similar services.
14. To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by us is among the assets transferred.

Stewart will not collect additional categories of personal or sensitive information or use the personal or sensitive information we collected for materially different, unrelated, or incompatible purposes without providing you notice.

Disclosure of Personal Information to Affiliated Companies and Nonaffiliated Third Parties

Stewart does not sell your personal information to nonaffiliated third parties.  Stewart may share your information with those you have designated as your agent throughout the course of your transaction (for example, a realtor, broker, or a lender).

We share your personal information with the following categories of third parties:

1. Service providers and vendors we contract with to render specific services (For example, search companies, mobile notaries, and companies providing credit/debit card processing, billing, shipping, repair, customer service, auditing, marketing, etc.)
2. Affiliated Companies.
3. Parties involved in litigation and attorneys, as required by law.
4. Financial rating organizations, rating bureaus and trade associations.
5. Federal and State Regulators, law enforcement and other government entities

In the preceding twelve (12) months, Stewart has disclosed the following categories of personal information:

Category A:  Identifiers
Category B:  California Customer Records personal information categories
Category C:  Protected classification characteristics under California or federal law
Category D:  Commercial Information
Category E:  Internet or other similar network activity
Category F:   Non-public education information

• Your Consumer Rights and Choices Under CPPA and CPRA

The CCPA and CPRA provide consumers (California residents as defined in the CCPA) with specific rights regarding their personal information.  This section describes your rights and explains how to exercise those rights.

• Access to Specific Information and Data Portability Rights

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

1. The categories of personal information Stewart collected about you.
2. The categories of sources for the personal information Stewart collected about you.
3. Stewart’s business or commercial purpose for collecting that personal information.
4. The categories of third parties with whom Stewart shares that personal information.
5. The specific pieces of personal information Stewart collected about you (also called a data portability request).
6. If Stewart disclosed your personal data for a business purpose, a listing identifying the personal information categories that each category of recipient obtained.

• Deletion Request Rights

You have the right to request that Stewart delete any personal information we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request, Stewart will delete (and direct our service providers to delete) your personal information from our records, unless an exception applies.

Stewart may deny your deletion request if retaining the information is necessary for us or our service providers to:

1. Complete the transaction for which we collected the personal information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you.
2. Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
3. Debug products to identify and repair errors that impair existing intended functionality.
4. Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
5. Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 ).
6. 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 the information’s deletion may likely render impossible or seriously impair the research’s achievement, if you previously provided informed consent.
7. Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
8. Comply with a legal obligation.
9. Make other internal and lawful uses of that information that are compatible with the context in which you provided it.

• Opt-Out of Information Sharing and Selling

Stewart does not share or sell information to third parties, as the terms are defined under the CCPA and CPRA.  Stewart only shares your personal information as commercially necessary and in accordance with this CCPA Notice.

The CCPA provides consumers with the right, at any time, to opt-out of a business’s sale of a consumer’s personal information to third parties. Businesses that sell personal information to third parties are required to provide notice that personal information may be sold and that consumers have the right to opt-out. IR does not send marketing communications directly to consumers nor do we sell consumer information to other third parties. If you would like to opt-out of credit offers and stop Trigger leads generated by the bureaus, please take the following steps:

1. Register for Opt-Out Prescreen at optoutprescreen.com. This will stop all credit bureaus (Equifax, Experian, and TransUnion) from selling their name as a trigger lead for at least a 5-year period. Once requested, it takes approximately 5 days to become effective.
2. Register name and phone number to reduce telemarketing efforts on the National Do Not Call Registry at donotcall.gov or call 1-888-382-1222 from each phone number they wish to register. Once requested, it takes approximately 31 days to become effective.

Register with the Direct Marketing Association’s Mail Preference Service to opt out of commercial mailings for 5 years with a $1 processing fee at dmachoice.org. DMA distributes its lists quarterly, so effective date can vary upon when your request is submitted.

• Correction of Inaccurate Information

You have the right to request that Stewart correct any inaccurate information maintained about.

• Limit the Use of Sensitive Personal Information

You have the right to limit how your sensitive personal information, as defined in the CCPA and CPRA is disclosed or shared with third parties.

Exercising Your Rights Under CCPA and CPRA

If you have questions or comments about this notice, the ways in which Stewart collects and uses your information described herein, your choices and rights regarding such use, or wish to exercise your rights under California law, please submit a verifiable consumer request to us by the available means provided below:

1. Emailing us at OptOut@stewart.com; or ComplianceDepartment@InformativeResearch.com

2. Visiting http://stewart.com/ccpa or https://www.informativeresearch.com/privacy-policy/

3. By Mail:
   Informative Research
   Compliance Department
   California Privacy Rights Request
   PO Box 2379
   Garden Grove, CA 92842

 Only you, or someone legally authorized to act on your behalf, may make a verifiable consumer request related to your personal information.  You may also make a verifiable consumer request on behalf of your minor child, if applicable.

To designate an authorized agent, please contact Stewart through one of the methods mentioned above.

You may only make a verifiable consumer request for access or data portability twice within a 12-month period. The verifiable consumer 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.
• Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

Stewart cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you.

Making a verifiable consumer request does not require you to create an account with Stewart.

Response Timing and Format

We endeavor to respond to a verifiable consumer request within forty-five (45) days of its receipt.  If we require more time (up to an additional 45 days), we will inform you of the reason and extension period in writing.
A written response will be delivered by mail or electronically, at your option.
Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request’s receipt.  The response we provide will also explain the reasons we cannot comply with a request, if applicable.
Stewart does not charge a fee to process or respond to your verifiable consumer 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.

Non-Discrimination

Stewart 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 a different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.
• Provide you a different level or quality of goods or services.
• Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.

Record Retention

Your personal information will not be kept for longer than is necessary for the business purpose for which it is collected and processed.  We will retain your personal information and records based on established record retention policies pursuant to California law and in compliance with all federal and state retention obligations.  Additionally, we will retain your personal information to comply with applicable laws, regulations, and legal processes (such as responding to subpoenas or court orders), and to respond to legal claims, resolve disputes, and comply with legal or regulatory recordkeeping requirements.

Changes to This CCPA Notice
Stewart reserves the right to amend this CCPA Notice at our discretion and at any time.  When we make changes to this CCPA Notice, we will post the updated Notice on Stewart’s website and update the Notice’s effective date.

Link to Privacy Notice
Stewarts Privacy Notice can be found on our website at https://www.stewart.com/en/privacy.html.

Contact Information
Stewart Information Services Corporation
Attn:  Mary Thomas, Chief Compliance and Regulatory Officer
1360 Post Oak Blvd., Ste. 100, MC #14-1
Houston, TX  77056