PRIVACY POLICY

We understand there is certain information you do not want to share with everyone. And we are just as concerned about safeguarding the information you provide to us. That is why Independence Title and Escrow and our affiliated companies have adopted these privacy principles and guidelines. We value the trust you have placed in us and are committed to earning and maintaining your confidence.

Introduction

This privacy policy describes the kinds of information we collect from our customers, how we use that information, and the limited circumstances under which we will share it with third parties.

Information Collection

Independence Title and Escrow will only collect information about you that we reasonably believe will be necessary or useful in processing or administering products or services that you have requested from us. We will also collect information in order to notify you about products; services and other opportunities we think will be of interest to you.

This information may be collected from a variety of sources, such as the following: (1) information provided by you in connection with obtaining financial products and services such as mortgage loans, deposit accounts and investment products and services, (2) information obtained from non-affiliated third parties such as a credit bureau which provides your credit history or employment verification, and (3) information about your transactions with us, our affiliates or others.

Maintenance of Accurate Information

We work hard to ensure your information is as accurate, current and complete as possible. If you ever find that our records are inaccurate or not current, please contact us at the telephone number on your account statement. If the record is within our control, we will correct any inaccurate or incomplete information.

Security Procedures to Protect Customer Information Access

to our systems containing nonpublic personal information is only to those employees who need it for the purpose of providing products or services to our customers. In addition, we maintain physical, electronic, and procedural safeguards that are designed to comply with federal guidelines concerning the security of nonpublic personal information.

Information Sharing Within Our Affiliated Family of Companies

There are times where we will need to share a portion of your Independence Title and Escrow account information with certain affiliated companies that either currently exist or that we may create in the future. However, we will only do so in order to provide you with superior service, inform you of product and service opportunities that may be of interest to you, improve and develop our products and services, or perform other business functions. Affiliated companies may be financial services providers, including, life and casualty insurance companies, insurance agencies, securities brokerage firms, trust companies, and companies that provide settlement services, such as title agencies, escrow companies and appraisal firms. An "affiliated company" or "affiliate" is a company that we own or control. The information we may provide to these affiliates includes (i) identifying information, such as your name, address and social security number, and (ii) information about the financial product or service you obtain from us, such as your deposit balance, investment history, loan balance and/or payment history, as applicable. Under the federal Fair Credit Reporting Act, we are permitted to share this information within our affiliated family of companies.

Information Sharing With Unaffiliated Third Parties

Unlike some other mortgage brokers, Independence Title and Escrow does not sell customer lists or other information about our customers to unaffiliated parties. Moreover, we do not in any manner share customer information with unaffiliated third parties except as described below or as otherwise expressly permitted by law.

In order to efficiently and cost-effectively market our own products, we contract with companies providing marketing and solicitation services, such as printers, marketing fulfillment firms and other companies. As part of these activities, we may provide limited information about our customers to such parties. In addition, we may occasionally engage in joint marketing with unaffiliated financial institutions for various financial products and services (such as credit life and disability insurance) that Independence Title and Escrow does not offer on its own, but we think will be of interest to our customers. In such cases, Independence Title and Escrow will always be identified in the joint marketing materials or solicitation. We may disclose all of the information we collect (described in "Information Collection" above) to the companies that perform marketing services on our behalf or to other financial institutions that have joint marketing agreements with us. Our agreements with these companies are subject to confidentiality provisions and restrictions that prohibit using the information beyond the performance of the specified services or in connection with the jointly marketed product or service.

Our Former Customers

Rest assured that even if you are no longer a customer of Independence Title and Escrow, we will continue to treat the information we have with the same level of confidentiality.

We appreciate your business and want you to understand our commitment to maintaining the privacy of your personal information, as expressed in this Privacy Policy. This Privacy Policy applies to individual consumers. We reserve the right to amend the policy at any time.

Protecting Your Financial Privacy

Independence Title and Escrow will protect the privacy of your personal and financial information. To guard your nonpublic personal information, we maintain physical, electronic, and procedural safeguards that comply with federal regulations.

Specifically, we have designed our systems to ensure that your Personal Identification Number (PIN), password and other access codes are always private and confidential. For your protection, only you know your access codes - our employees cannot gain access to them and they will not ask you to reveal them.

The length of time we retain information varies depending on the product or service and the nature of the information. This period may extend beyond the end of your relationship with us but only for so long as it is legally necessary for us to have sufficient information to respond to any issue that may arise at a later date or as required by other regulatory agencies. When your information is no longer needed for the purposes explained to you, we have procedures to destroy, delete, erase or convert it to an anonymous form.

We update and test our technology regularly to ensure we maintain commercially reasonable standards in securing your financial privacy.

Regarding Cookies

To provide better service and a more effective Web site, we use "cookies" as part of our interaction with your browsers. A "cookie" is a small text file placed on your hard drive by our Web Page Server. Our cookies cannot retrieve any other data from your hard drive, pass on computer viruses, or capture your e-mail address. Cookies are commonly used on Web sites and do not harm your system.

We may use cookies to record information about

- Visitors preferences User sessions on our web sites

- What pages users access or visit on our web sites

- Pastactivity at a site in order to provide better service when visitors return to our site, or to accomplish the following purposes

- Alert visitors to new areas that we think might be of interest to them when they return to our site

- Customize Web page content based on visitors' browser type or other information that the visitor sends

We use cookies in places where you need to register, or where you are able to customize the information you see. Recording a cookie at such points makes your online experience easier and more personalized.

Our cookies do not collect personally identifiable information and we do not combine information collected through cookies with other personal information to determine who you are or your e-mail address. By configuring your preferences or options in your browser, you determine if and how a cookie will be accepted. However, if you configure your web browser so that "cookies" are turned off, our website will not be able to process your transaction. If this happens, please turn your cookies back on and log onto our site again.

Encryption

Your password as well as all information relating to your accounts and your enrollment are scrambled using some of the strongest forms of encryption commercially available for use over the World Wide Web.