Privacy Policy Notice

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What does Vanguard Research & Title Services, Inc. do with your Personal Information?

Our Privacy Policy

Federal law requires Vanguard Research & Title Services, Inc. (Vanguard) to tell you how Vanguard collects, shares, and protects your personal information. Vanguard's privacy policy has not changed and you may review Vanguard's policy and practices with respect to your personal information at www.vgrti.com or we will mail you a free copy upon request if you call us at (315) 422-6031.

Protecting the privacy and security of our clients and customers is of utmost importance to us here at Vanguard. Federal law, specifically Title V of the Gramm-Leach-Bliley Act (GLBA) of 1999 and certain provisions of the Federal Trade Commission's (FTC) Privacy of Consumer Financial Information Rule require that Vanguard tell you how Vanguard collects, uses and shares any non-public personal information (NPPI) about you. Federal law limits how Vanguard can use any personal information it may collect. This notice provides important information about Vanguard's data security practices. Please read this notice and ensure you understand it. Should you have any questions or concerns regarding this notice please contact the corporate office at the number recited above.

Vanguard may collect or receive NPPI about you voluntarily if you call or otherwise contact Vanguard electronically to request a product or service directly. Vanguard may also collect or receive NPPI about you from our affiliates or non-affiliated third parties in the normal course of business in order to provide our products and services to you. Vanguard collects only the information necessary to provide products and services to you, to communicate with you about products and services and to help improve its services.

What types of personal information does Vanguard collect?

The types of non-public personal information Vanguard collects and processes depends on the product or service you request from Vanguard or from affiliated or non-affiliated third parties who may request products and services on your behalf. This information can include but may not be limited to any of the following:

• Contact information (such as name, phone number, address, e-mail address)
• Social security number or taxpayer identification number
• Drivers license number or other government identification number (or a full copy)
• Bank and routing information from checks or electronic payment methods
• Loan information contained on a loan or other real estate disclosure form provided by a settlement agent (such as an attorney) in a real estate transaction

Where does your information go?

Vanguard does not share non-public personal information about you to any affiliate or non-affiliated third party that is not expressly permitted by law. Even where sharing such information is permitted under the law, you may be able to opt out of such sharing by providing written notice to Vanguard. Reasons why and with whom Vanguard might share your personal information are as follows:

Internally:

• To enable Vanguard's personnel to perform everyday business purposes, including but not limited to processing orders, maintaining accounts, preparing for and responding to court orders and legal investigations and routine audits

Externally:

• To third party contractors or service providers from whom Vanguard obtains a product or service on your behalf related to the settlement process
• To law enforcement or other governmental authority in connection with investigation, or civil or criminal matters or to respond to subpoenas or court orders
• For reasons of communicating with financial service providers engaged in banking, consumer finance, securities and insurance
• Communicating with parties involved in a specific loan transaction or real estate closing such as an attorney or the bank/lender
• Communicating with non-financial companies such as direct mail companies and other fulfillment service providers
• For marketing purposes in order to offer Vanguard's product(s) and service(s) to you
• For Vanguard's affiliates to market to you
• For non-affiliates to market to you
• For Vanguard's affiliates' or non-affiliate third party providers' everyday business purposes, information about your order(s)
• To enforce this privacy notice

When does Vanguard collect personal information?

Vanguard may collect non-public personal information about you in person, over the phone, through facsimile (fax) transmission or other electronic communication, such as e-mail or through Vanguard's website or other portal, and on applications or other forms submitted to Vanguard.

Vanguard may also collect or receive personal information about you from others involved in your transaction such as the real estate agent, attorney or lender and through standard real estate settlement forms, such as state tax forms.

Vanguard may also collect or receive personal information about you from affiliates or non-affiliated service providers, consumer reporting agencies and regulators in connection with or in relation to products or services Vanguard provides to you, law enforcement action and regulatory reporting and investigation.

Can you limit our sharing?

Yes, federal law gives you the right to limit Vanguard's sharing in certain cases. You can limit Vanguard's sharing of your personal information to affiliates and non-affiliated third party service providers for reason of marketing products and services to you. Vanguard does not make a practice of providing or selling non-public personal information such as name lists to any non-affiliated third party for their own direct marketing use but may in future make joint marketing arrangements with an affiliate or non-affiliate in order to promote future products and services.

You cannot limit Vanguard's sharing of personal information with Vanguard's affiliates or non-affiliated third parties in cases wherein the information is necessary to provide our products or services to you or on behalf of a third party with whom you are engaged as a customer such as your lender. In such cases Vanguard may also be obligated to abide by the privacy practices of the financial institution with whom you are a customer which may also additionally limit our use of your personal information. In certain cases Vanguard may contact you in order to obtain your permission to share information with non-interested parties to your loan and settlement transaction, such as your real estate agent.

Reasons why Vanguard may share some personal information in the normal course of business, as allowed by law, may include but are not limited to, verifying your identity for reason of complying with state or federally-mandated forms, for reason of insurance underwriting contractual requirements or ensuring proper delivery of specific products or services.

To limit Vanguard's sharing:

• Call Vanguard's Corporate Office at (315) 422-6031
• Visit Vanguard Online at www.vgrti.com
• Mail in the form provided below

Please note: If you are a new customer, Vanguard can begin sharing your information 30 days from the date you received this notice. When you are no longer our customer, Vanguard can continue to share your information as described in this notice, however, you can contact us at any time to limit our sharing.

How does Vanguard protect your information?

Any non-public personal information which Vanguard may have to collect and process for reasons of routine business are protected by physical, electronic and procedural safeguards intended to make best efforts to comply with federal law. Vanguard limits access to non-public personal information only to those personnel who have a reasonable need to access such information for purposes of providing products and services to you. Vanguard also limits the non-public personal information provided to third party service providers or contractors to only that information necessary to provide a product or service on your behalf.

Ways in which Vanguard may protect your non-public information include but are not limited to the following:

Training our employees on privacy and data security best practices

Directing the flow of documents between personnel and between Vanguard's offices

Using document envelopes and bags to transport legal documents

Keeping paper files for storage which may contain NPPI in locking cabinets or behind locked doors

Protecting files and attachments sent via E-mail

Only communicating with persons and entities Vanguard knows and trusts in the settlement process as legitimate service providers

Protecting external hard drives which may be used to store digital NPPI

Utilizing network security access controls

Using strong passwords, user authentication steps and other security measures to limit access to NPPI stored on computers or in Vanguard's database

Properly disposing paper copies with NPPI by shredding

For Questions or Complaints Contact:

CEO: Patrick J. Corbett, 407 South Warren Street, Syracuse, New York 13126; (315) 422-6031

Definitions

Affiliates - companies related by common ownership or control. They can be financial and non-financial companies.

Non-affiliates - companies not related by common ownership or control. They can be financial and non-financial companies.

Joint marketing - a formal agreement between non-affiliated companies that together market products or services to you.

Settlement - the process of settling a transfer of ownership to real estate between parties. This may include loan origination and processing, negotiating the sale and purchase of real estate and recording the legal documents, such as a deed, which reflect the new ownership with the local County Clerk's Office.