EASTERN NATIONAL TITLE AGENCY, INC. – PRIVACY POLICY

Updated August 2024

This Privacy Policy, as may be amended from time to time (hereafter, “Privacy Policy”), discloses the privacy practices regarding all information gathered from or about you (“Personal Information”), including in person, via any websites, mobile applications, social media pages, written or typed questionnaires, electronic transmissions, short message services, facsimiles, telephonic communications, and all services, software functionality, or materials (collectively, the “Sources“) collected by or on behalf of Eastern National Title Agency, Inc. (“EASTERN”, “us” or “we”).

We understand the importance that our customers place on privacy—we take your privacy seriously, too Our Privacy Policy is the same for former customers, current customers and prospective customers. We have designed this Privacy Policy to describe our information-gathering and dissemination practices. You consent and agree to this Privacy Policy and our Terms and Conditions of Use of our website, which can be found here when you access or use any Sources or communicate with us. If you do not consent or agree to this Privacy Policy, please do not access or use any of our Sources or communicate with us (as a basis for processing your Personal Information is your consent to this Privacy Policy). If you wish to withdraw your consent, please follow the procedures set forth below to withdraw your consent (in whole in or part) by following our opt-out procedures.

Please note that we reserve the right to review and update this Privacy Policy from time to time. If we make any material changes to the Privacy Policy, a notification will be made by means of a general notice displayed on certain Source(s) prior to the change taking effect. If you use any Sources or communicate with us after any such update, you will be deemed to have agreed to the updated Privacy Policy.

NOTICE OF ADDITIONAL DISCLOSURES

Additional privacy policies, specifically developed and maintained for residents of certain states are found within this Privacy Policy in the section entitled “Additional Disclosures.” 

WHAT INFORMATION DO WE COLLECT ABOUT YOU AND WHY?

We do collect certain personally identifiable information or “Personal Information” about you. We may collect this in a variety of ways as described below. This can include information collected by Cookies, or “Usage Information” as described below. Some of this information, like what is collected by cookies or “Usage Information” are meant to help us improve the Sources. Some other information you provide us, like your name and number, may be used to help us follow up with or contact you, while some is only collected and used in the event you use us for your home mortgage.

In addition, we may also collect, aggregate, and share “Non-PII” which is information that is aggregated, anonymized, de-identified and is unable to be readily identified to you. This can also include some information collected by Cookies, as well as “Usage Information” as defined below.

Some Personal Information is classified as “Sensitive Personal Information” or “SPI.” This includes information like social security numbers, login information, financial information, precise geolocation information, information on your racial or ethnic origins, religious or philosophical beliefs, biometric or genetic information that can be used to identify you, or other personal information like sexual orientation. However, this does not include anything that you have posted online for the general public to see, or is otherwise publicly available.

Types of Information That We Collect about You.

When you register for an account with or on any Source(s) or purchase a home, product, or service from us, or contact us, or interact with us in any way, we may collect, or you may provide to us, the following information:

Personal Information

The types of information that EASTERN collects may include, among other things, the following categories of information (collectively, “Personal Information”):

contact information (e.g., your first name, last name, title, physical address, zip code, phone number, email address);
user name, password and security questions and answers;
demographic information, such as your date of birth and nationality, which allows us to verify your identity and comply with federal law;
social security number (SSN), driver’s license, passport, resident alien card, passport visa, and other government ID numbers and government documents;
Internet Protocol (or IP) address or device ID/UDID, protocol and sequence information;
loan account information;
bank account and credit/debit card numbers;
whether you own or rent your home;
dependent information;
divorce decree and property settlement information;
IRS transcripts; and
other Personal Information provided by you to us.

Usage Information

The types of usage information that EASTERN collects may contain generic information about you when you visit, access, or use our website or any of the Sources, which may include, among other things, the following categories of information (collectively, “Usage Information”):

browser language and type;
domain name system requests;
browsing history (such as, time spent at a domain, time and date of your visit, links clicked on, search data and terms, user names, physical location) and number of clicks;
http headers, application client and server banners, and operating system and fingerprinting data;
aggregated information, including De-identified Data (as defined herein); and
type of computer, mobile device or tablet you are using, your MAC address, your operating system and version, your IP address, and your internet service provider.

How Information Is Collected

When you access certain of our Sources, we automatically collect your computer or device’s internet protocol (IP) address and other technical information about your computer or device and website usage, including your browser type and version, geographic information, time zone setting, and operating system and platform. We do this using various automated technologies that are used for tracking and to collect information from you and about you when you visit our website or interact with us online via the Sources including cookies, information from your browser, information from our server, web beacons, pixel tags, clear GIFs and other means. In addition, during the normal course of our business, we may collect Personal Information and Usage Information about you from the following sources:

directly from you – you may provide information to us online, or in person, for any number of reasons. For example, you may sign your home purchase agreement over the Internet, request information about our homes or communities, submit a warranty request, respond to a survey or submit a job application. In such cases, we will collect the information that you provide, which may include information regarding your home, your name, telephone number, email address, physical address, name of your present community or a EASTERN community in which you are interested, or certain demographic information, such as your age range, gender and areas of interest and, in the case of a job application, may include your resume and social security number;
service providers - we, like many businesses, sometimes hire other companies (“Service Providers“) to perform certain business-related functions. Examples include mailing information, maintaining databases, processing credit card transactions, and hosting services.
information from third parties – we may collect or purchase information from third parties, including marketing companies. If you have responded to or interacted with third parties who share your information with us, we collect the information the third party provides to us, including your email address.
social media. EASTERN maintains profiles and pages on social media platforms including, Facebook®, Twitter®, Pinterest®, YouTube®, Instagram® and others. We may collect the information that you post on social media platforms including Personal Information, pictures or other information. Information posted on any such pages is also subject to the privacy policies and terms of use of the respective social media platforms.
applications or other forms we receive from you or your authorized representative, which may include information about your assets and income and identifying information, such as name, address and SSN;
your communication to us (for example, an inquiry about a property, or a request to sign up for a mailing list or to receive updates from us);
information we receive from you through the Sources and as a result of your use of our services;
information we receive from your computer or mobile device;
information we receive from our affiliates, partners or service providers;
information we receive from bank statements, lender approvals or W-9 forms;
information from consumer or other reporting agencies and public records maintained by governmental entities that we obtain directly from those entities, from our affiliates or others, such as your creditworthiness and credit history; and
information we receive from other sources, as permitted by applicable laws, rules and regulations.

Cookies and Other Tracking Technologies That We Use

We and our Service Providers use cookies, beacons, embedded scripts and local shared objects in connection with certain of the Sources.

Cookies are small text files that are stored on your computer or device when you visit for example a website. Cookies allow a website to recognize a particular device or browser. The use of cookies is a standard practice among websites to collect information about visitors’ activities while using such website.

Beacons are small graphical images (also known as “pixel tags” or “clear GIFs”) that may be included on certain of our Sources and typically work in conjunction with cookies to identify users and user behavior.

An embedded script is programming code that is designed to collect information about your interactions with certain of the Sources, such as the links you click on. The code is temporarily downloaded onto your computer or device from our web server or a third-party service provider, is active while you are connected to the applicable Sources, and is deactivated or deleted thereafter.

These technologies are used in analyzing trends, administering certain of the Sources, services and products, tracking users’ movements around certain of the Sources, and to gather demographic information about our user base as a whole. We may receive reports based on the use of these technologies on an individual as well as aggregated basis.

We use cookies to remember users’ settings, market products and services to you, and for authentication purposes. To manage the cookies that are placed on your computer, you may configure your internet browser to refuse, accept or delete cookies from our Sources at any time. The help portion of the toolbar on most browsers will tell you how to prevent your browser from accepting new cookies, how to have the browser notify you when you receive a new cookie, or how to disable cookies altogether. Please note that if cookies are disabled or removed, not all features of certain of our Sources will operate as intended.

Do Not Track Signals

We do not monitor or identify “do not track signals” from your devices and such signals will not affect the operation of the Sources. Even if you are using a device that sends a “do not track signal,” we may collect, use and share Personal Information consistent with this Privacy Policy.

How We Use Information We Collect

EASTERN will use and disclose the information we collect for any lawful purpose we deem appropriate. This includes in connection with obtaining a loan; your purchase of a EASTERN home; to fulfill your requests; to answer your questions; to manage our business; to recruit and hire employees; to protect our interests; to comply with law enforcement; and, to support direct marketing and other opportunities of EASTERN and third parties as described in this Privacy Policy. In this regard, we may contact you by email, postal mail, text message, social media, telephone or other means regarding our products, services, promotions and employment opportunities.

The information we collect helps us to improve our website and other Sources and to deliver a better and more personalized service, including by enabling us to:

Estimate our audience size and usage patterns.
Store information about your preferences, allowing us to customize our website according to your individual interests.
Speed up your searches.
Recognize you when you return to our website.
Identify individual preferences for marketing purposes.
We may transfer your Personal Information to third parties, including our hosting partners and other trusted third parties who assist us in operating the Website. You can read more about this below in “When Information is Disclosed and to Whom.”

Unless otherwise required by law, EASTERN will treat all information shared with us online as non-confidential and non-proprietary. EASTERN will utilize such information in accordance with this Privacy Policy. If you use or visit our website, submit any content to us, or post any content on our website or our social media pages or profiles, or otherwise interact with the Sources you agree that, with respect to such content, EASTERN is granted an unlimited, non-exclusive, world-wide, non-revocable, perpetual license to reproduce, duplicate, transmit, display, publish, create derivative works, sublicense and otherwise use any such information for any lawful purpose whatsoever, including marketing and you agree to hold us harmless with respect thereto.

When Information Is Disclosed and to Whom

We may provide your Personal Information (excluding information we receive from consumer or other credit reporting agencies) and Usage Information to various individuals and companies, as permitted by law, without obtaining your prior authorization. Please see the section below titled “Choices with Your Personal Information” to learn how to limit the discretionary disclosure of your Personal Information and Usage Information.

We may allow web analytics providers and other third parties including our advertisers, email vendors, service providers, and other service companies to collect information, including Personal Information, about your online activities, over time and across different web sites, when you use tour website. These third parties may use the technologies mentioned above and other technologies to track your online behavior and to gather information about your activities on certain of the Sources and elsewhere on the internet to provide you with relevant advertising based upon your browsing activities and interests. This type of advertising is sometimes called interest-based advertising or targeted advertising. These technologies may be used to collect certain information about your visits to our website or other websites (including the types of information mentioned above).

We may also use Service Providers (such as Google Analytics), that may use cookies or other technologies to collect information about your online activities across this and other sites over time for non-advertising purposes such as those described above. To learn more about how Google Analytics collects and processes data and the choices Google may offer to control these activities, you may visit  http://www.google.com/intl/en/policies/privacy/partners/ .

Disclosures of your Personal Information may be made to the following categories of affiliates and nonaffiliated third parties, unless prohibited by applicable law:

Subcontractors and Service Providers Providing Services to EASTERN and EASTERN homeowners. If you are a EASTERN homeowner or prospective homeowner, we share your information, which may include Personal Information, with our subcontractors, service providers and developers of communities (for example, electricians, painters, land developers and telecom providers) in connection with your purchase of a EASTERN home and in response to your warranty or customer service requests and to provide services to you and our other homeowners. We may share your information with service providers who perform services on our behalf, such as those service providers that perform technology services for us.
EASTERN Business Relationships. If you enter into a mortgage for a new home, we may share your information, including your Personal Information, with others and, unless you opt-out as described in the new home documentation, such sharing may be for direct marketing purposes.
Other Third Parties. We may share your information, including your Personal Information, with other third parties, and, unless you opt-out, such sharing may be for direct marketing purposes.
Legal Matters. We may share your information, including your Personal Information, with third parties, including law enforcement; in response to legal process; and, to investigate, prevent, or take action regarding illegal, suspicious or fraudulent activities involving this website, you, or us.
Business Transactions. We may share your information, including your Personal Information, with potential buyers in the event of the sale or a proposed sale of a business unit or property or other business transaction.
Storage. We share your information, including your Personal Information, with third parties for the purpose of helping us gather, store and maintain data.
To third parties to provide you with services you have requested, and to enable us to detect or prevent criminal activity, fraud, material misrepresentation, or nondisclosure.
To our subsidiaries and affiliates.
To our outside marketing consultant.
To nonaffiliated third-party service providers who provide or perform services on our behalf and use the disclosed information only in connection with such services.
To law enforcement or other governmental authority in connection with an investigation, or civil or criminal subpoena or court order.
To lenders, lien holders, judgment creditors, or other parties claiming an interest in title whose claim or interest must be determined, settled, paid, or released prior to closing on your new home.
To other third parties for whom you have given us written authorization to disclose your Personal Information.
To a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of EASTERN’s assets, whether as a going concern or as part of a bankruptcy, liquidation, or similar proceeding, in which person information held by EASTERN about our users is among the assets transferred.
To fulfill the purpose for which you provide it.
For any other purpose disclosed by us when you provide the information.
With your consent.

We might disclose Personal Information and/or Usage Information when required by law or in the good-faith belief that such disclosure is necessary:

To comply with a legal process or applicable laws.
To enforce this Privacy Notice.
To enforce or apply our Terms of Use and other agreements.
To take precautions against liability and respond to any claim that any information provided by you violates the rights of a third party.
To assist government enforcement agencies.
To protect our rights, property, or the safety or the rights, property, or personal safety of our visitors and the public, which includes exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction, and, if required by law, disclosing information to U.S. federal and state governmental agencies.
To investigate potential unauthorized access or misuse of the website.

We maintain reasonable safeguards to keep your Personal Information secure. When we provide Personal Information to our affiliates or third-party service providers as discussed in this Privacy Notice, we require that these parties agree to process such information in compliance with our Privacy Notice or in a manner that complies with applicable privacy laws. The use of your information by a trusted business partner may be subject to that party’s own privacy notice. Unless permitted by law, we do not disclose information we collect from consumer or credit reporting agencies with our affiliates or others without your consent.

In addition to the other rights described herein, we have the right to exploit, share, and use, for any purpose, the collected Personal Information in an aggregated, anonymized form, such that you are not individually identified (collectively, “De-identified Data”). For example, aggregate data may include De-identified Data that describes the general demographics, usage or other characteristics of certain Sources’ users. We reserve the right to transfer or keep aggregate or group data about our Sources’ users for lawful or legitimate purposes, such as for the purposes described in this section.

We may allow you to create a user profile for use in connection with the Sources (“Profile”).  When you open an account with us and create a Profile, we may obtain, verify and record information that identifies you, including Personal Information. We may be required to verify, record or share such information to help the government fight the funding of terrorism and money laundering activities.

As we develop our business, we might sell or buy businesses or assets. In the event of a corporate sale, merger, reorganization, dissolution, total or partial sale of assets in bankruptcy or similar event, Personal Information may be part of the transferred assets. You expressly agree and consent to the use and/or transfer of the foregoing information in connection with any of the above-described proceedings. We are not responsible for any breach of security or action by any of these third parties.

Some of our Sources utilize framing techniques to serve content to you from third parties while preserving the look and feel of our Sources. When you interact with content from third parties displayed on any of our Sources, please be aware that you are providing your Personal Information to these third parties and it will be governed by their respective privacy policies and terms and conditions.

We may disclose your Personal Information for any purpose disclosed by us when you provide the information. We may also disclose your Personal Information with your permission or as directed by you.

YOUR CHOICES ABOUT HOW WE USE AND DISCLOSE YOUR INFORMATION

We strive to provide you with choices regarding the personal information you provide to us. We have created mechanisms to provide you with the following control over your information:

To stop receiving newsletters or marketing communications from us or to opt out of having information, such as your email address shared with third parties, please use the “unsubscribe” mechanism provided in the communication or send an e-mail to privacy@khov.com along with the information necessary for us to process your request.
Tracking Technologies and Advertising. You can set your browser to refuse all or some browser cookies, or to alert you when cookies are being sent. To learn how you can manage your Flash cookie settings, visit the Flash player settings page on Adobe’s website. If you disable or refuse cookies, please note that some parts of this site may then be inaccessible or not function properly.
Disclosure of Your Information for Third-Party Advertising. If you do not want us to share your personal information with unaffiliated or non-agent third parties for promotional purposes, you can opt-out by checking the relevant box located on the form on which we collect your data. You can also always opt-out by sending us an email with your request to privacy@khov.com.
Promotional Offers from the Company. If you do not wish to have your contact information used by the Company to promote our own or third parties’ products or services, you can opt-out by checking the relevant box located on the form on which we collect your data or by sending us an email stating your request to privacy@khov.com. If we have sent you a promotional email, you may send us a return email asking to be omitted from future email distributions. This opt out does not apply to information provided to the Company as a result of a product purchase, warranty registration, product service experience or other transactions.

We may also send you service-related email announcements on rare occasions when it is necessary to do so. For instance, if our service is temporarily suspended for maintenance, we might send you an email. Because these emails are not promotional in nature, you do not have an option to opt out of these communications.

We do not control third parties’ collection or use of your information to serve interest-based advertising. However, these third parties may provide you with ways to choose not to have your information collected or used in this way. You can opt out of receiving targeted ads from members of the Network Advertising Initiative (“NAI”) on the NAI’s  website. If you wish to not have this information collected and used for interest-based advertising, you may opt-out by clicking  here; for third parties that participate in the TRUSTArc (formerly TRUSTe) opt-out tool. If you wish to opt-out from this type of advertising for companies that participate in the Digital Advertising Alliance (“DAA”), you can do so  here. Please note that this does not opt you out of being served with all advertisements. You will continue to receive generic ads.

California residents may have additional personal information rights and choices. Please see “FOR CALIFORNIA RESIDENTS,” found below, for more information.

Our Policy on Accessing, Correcting, Updating or Deleting Personal Information, and Deactivating Your Account

You may request to access, correct, update, or delete certain of your Personal Information or deactivate your account by emailing our Customer Support at  privacy@khov.com with information necessary for us to process your request. While reasonable efforts will be made to delete all of the Personal Information as you may request, in certain circumstances retention of certain of your Personal Information may be required, including as required by law. Please see below regarding our retention policy.

Children Under The Age Of 18

Our website is not intended for children under 18 years of age. No one under age 18 may provide any information to, or on, the website or any of the Sources. We do not knowingly collect personal information from children under 18. If you are under 18, do not use or provide any information on this website, register on the website, or provide any information about yourself to us, including your name, address, telephone number, email address, or any screen name or user name you may use. If we learn we have collected or received personal information from a child under 18 without verification of parental consent, we will delete that information. If you believe we might have any information from or about a child under the age of 18, please contact us at privacy@khov.com.

California residents under 16 years of age may have additional rights regarding the collection and sale of their personal information. Please see the section entitled FOR CALIFORNIA RESIDENTS,” found below, for more information.

YOUR PRIVACY OUTSIDE THE WEBSITE/SOURCES

Our website or Sources may now, or in the future, contain links to other websites or Sources. EASTERN is not and cannot be responsible for the privacy practices or the content of any of those other websites. Please check with those websites in order to determine their privacy policies and your rights under them.

We may use the services of third party service providers, for example to process payments and other transactions or to provide analytics services. By using our Website, you grant us all necessary rights and consents under applicable laws to disclose to the third party service providers –  and/or allow those third party service providers to collect, use, retain and disclose to us – any Personal Information for purposes of providing services to you, including data that we may collect directly from you using cookies or other similar means.

SOCIAL MEDIA WIDGETS

Our Sources may include social media features, such as the Facebook “Like” button and widgets such as the “share this” button or interactive mini-programs that run on certain of our Sources. These features may collect your IP address, which pages you are visiting on certain of our Sources, and may set a cookie to enable the feature to function properly. Social media features and widgets are either hosted by a third party or hosted directly on certain of our Sources. Your interactions with these features are governed by the privacy policy of the company providing them.

SECURITY AND RETENTION

We take commercially reasonable steps to help protect personal information from loss, misuse, unauthorized access, use, disclosure, alteration and destruction. However, no internet or electronic transmission is ever fully secure or error free. We do not and cannot guarantee or warrant that any information transmitted through the Internet is secure, or that such transmissions are free from delay, interruption, interception or error. ANY TRANSMISSION OF PERSONAL INFORMATION IS AT YOUR OWN RISK. If you believe that the security of any information or data that you have provided to us has been compromised, please immediately notify us of the problem by contacting us in accordance with the “Contacting Us” section below.

WE ARE NOT RESPONSIBLE FOR CIRCUMVENTION OF ANY  PRIVACY SETTINGS OR SECURITY MEASURES CONTAINED ON THE WEBSITE. Where we have given you (or where you have chosen) a password for access to certain parts of our Website, you are responsible for keeping this password confidential. We ask you not to share your password with anyone.

LIMITATION OF LIABILITY . TO THE MAXIMUM EXTENT ALLOWED BY APPLICABLE LAW, IN NO EVENT WILL EASTERN BE LIABLE TO YOU OR ANY OTHER PARTY FOR ANY, AND EASTERN DISCLAIMS ANY AND ALL, DAMAGES, LOSSES, CLAIMS, LIABILITIES, PENALTIES, COSTS, EXPENSES AND ATTORNEYS’ FEES, INCLUDING, WITHOUT LIMITATION, DIRECT, SPECIAL, INCIDENTAL, PUNITIVE, INDIRECT, CONSEQUENTIAL OR EXEMPLARY DAMAGES IN ANY WAY RELATING TO OR ARISING FROM THE MISUSE, DISCLOSURE (EITHER VOLUNTARY DISCLOSURE BY EASTERN, OR UNINTENTIONAL DISCLOSURE VIA A DATA OR SECURITY BREACH), ALTERATION OR DESTRUCTION OF PERSONAL INFORMATION OR ANY BREACH OF SECURITY OR FOR THE UNAUTHORIZED ACCESS OR USE OF PERSONAL INFORMATION OR FOR ANY TECHNICAL FAILURES OR PROBLEMS, ERRORS IN PERSONAL INFORMATION, INTERRUPTION IN OR TERMINATION OF THE OPERATION OF ANY SOURCES, OR ANY RESULTS OF ANY SUCH FAILURES, PROBLEMS, OR ERRORS.

In addition, e-mail sent to or from any of our Sources may not be secure, and you should therefore take special care in deciding what information you send to us via electronic transmission. Please keep this in mind when disclosing any Personal Information to us or to any other party via the Internet. When you enter sensitive information on our order forms or login credentials (such as username and password) on our platform login, we encrypt the transmission of that information using secure socket layer technology (SSL).

Your Personal Information will be stored in the United States and will be subject to laws applicable in the United States. Our Sources may not be available or appropriate for use in countries other than the United States. If you choose to access one of our Sources from a country other than the United States, you do so at your own risk and with the understanding that Personal Information may be collected, used, disclosed or stored in the United States. If you are accessing our Sources in a country other than the United States, you acknowledge that our Sources are operated in the United States and your Personal Information may be transferred to and processed in the United States, where the privacy laws may be different than those in the country from which you are accessing our Sources.

We may retain your Personal Information, including for as long as your account is active or as needed to provide you services, comply with our legal obligations, resolve disputes or enforce our agreements or otherwise.

Additional Disclosures

EUROPEAN UNION USERS

The website, Sources, and our products and services are hosted in the United States and are governed by United States law. If you are using the website, Sources, or our products or services from outside the United States, please be aware that your Personal Information may be transferred to, stored, and processed in the United States where our servers are located and our central database is operated. The data protection and other laws of the United States and other countries might not be as comprehensive as those in your country. By using the website or our products and services, you consent to your Personal Information being transferred to our facilities and to the facilities of those third parties with whom we share it as described in this Privacy Notice.

FOR CALIFORNIA RESIDENTS

If you are a California resident, California law may provide you with additional rights regarding our use of your personal information.To learn more about your California privacy rights, see the following portions of this privacy policy.

California’s “Shine the Light” law (Civil Code Section § 1798.83) permits users of our Website that are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please send an email to privacy@khov.com or write us at:

Eastern National Title Agency, Inc.
Attention: Corporate Legal Department
90 Matawan Rd, 5th Floor
Matawan, NJ 07747

This supplemental privacy notice  for California residents  supplements the information contained in the previous portions of this privacy policy and applies solely to all visitors, users, and others who reside in the State of California (“consumers” or “you”). We adopt this notice to comply with the California Consumer Privacy Act of 2018 (CCPA) and any terms defined in the CCPA have the same meaning when used in this notice.

Information We Collect

We collect through our Website and normal business operations information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or device (“personal information”). In particular, EASTERN has collected the following categories of personal and usage information from its consumers within the last twelve (12) months and indicated in the table below which sets forth a summary of Personal Information collected based on the categories of information we collect:

Identifiers

·          What We May Collect:

o    A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol (“IP”) address, email address, account name, Social Security number, driver’s license number..

·          How do we Collect it?:

o    We generally collect this information about you at the start of any business relationship with us, such as getting your name, alias, postal address, or email address through forms.

o    We may also collect your IP address through cookies on your device during your use of our Website.

o    Other, more sensitive information like your social security number will only be requested in certain situations, like if needed to clear judgments on title. Drivers licenses and Identification cards may also be used to verify identification as part of closing.

·          Business Purpose for Disclosure:

o    We use identifiers to determine who you are, where you are, and how to best contact you and answer any questions or concerns you may have about our services.

o    In addition, there may be some circumstances where we need specific identifiers for tax and loan documents.

o    Finally, we may use some of this information, like your name and email, to identify and alert you of any of our services that you may be interested. Finally, we may use some of this information, like your name and email, to identify and alert you of any of our services that you may be interested in using. You can always unsubscribe from these email notices.

Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e))

·          What We May Collect:

o    A name, signature, Social Security number, address, telephone number, driver’s license or state identification card number, resident alien card, passport visa, dependent information, divorce decree and property settlement, IRS transcripts, employment, employment history, bank account number, credit card number, debit card number, and other financial informationnumber..

·          How do we Collect it?:

o    We generally collect this information about you at the start of any business relationship with us, such as getting your name, alias, postal address, or email address through forms and applications. This information may also be sent to us by Third Parties (as defined below) who you have given your information to. Other, more sensitive information like your social security number will only be requested in certain situations, like if needed to clear judgments on title. Drivers licenses and Identification cards may also be used to verify identification as part of closing.

·          Business Purpose for Disclosure:

o    We use identifiers to determine who you are, where you are, and how to best contact you and answer any questions or concerns you may have about services.

o    We may also need certain identifiers, such as your social security number and financial information, to run credit checks and other validations on you and qualify you for a mortgage.

o    Finally, we may use some of this information, like your name and email, to identify and alert you of any of our services that you may be interested in using.You can always unsubscribe from these email notices by clicking here.

o    Furthermore, we may use your phone number to contact you or respond to any requests or questions you have regarding our services.

o    Finally, your signature may be collected as part of an acknowledgement in order to enter into a loan agreement.

Protected classification characteristics under California or federal law

·          What We May Collect:

o    Age (40 years or older), date of birth, race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, dependent information, genetic information (including familial genetic information).

·          How do we Collect it?:

o    We collect this kind of information directly from you under our loan application.

·          Business Purpose for Disclosure:

o    We are required to comply with the Equal Credit Opportunity Act and the Home Mortgage Disclosure Act. The demographic information we collect about you is so we can fulfil our obligations to report and disclose information about the mortgages that we originate, to help regulators determine if lenders as a whole are serving the housing needs of their communities, identify discrimination, and assist public officials in making housing investment decisions.

o    None of this information is used or considered when determining whether or not you qualify for a loan.

Commercial information

·          What We May Collect:

o    Records of personal property, products or services purchased, obtained, or considered, divorce decree and property settlements, IRS transcripts, or other purchasing or consuming histories or tendencies.

·          How do we Collect it?:

o    We collect this information from you as part of the loan application process, either through the form, or your consent to our order of your credit history.

o    We may also collect and retain information as it pertains to your use of services.

·          Business Purpose for Disclosure:

o    We collect and maintain this information about you in order to determine if you qualify for a loan, what kind of loan you qualify for, and how much do you qualify for.

o    In addition, we may anonymize and aggregate some of this information to better inform us about our marketing and marketing team.

Internet or other similar network activity. 

·          What We May Collect:

o    Browsing history, search history, information on a consumer’s interaction with a website, application, or advertisement.

·          How do we Collect it?:

o  We may also collect your IP address through cookies on your device during your use of our Website. Similarly, we may collect other information through cookies, such as the type of device, what directed you to our Website, and whether or not you clicked on one of our advertisements.

·          Business Purpose for Disclosure:

o  We collect, aggregate and anonymize this information to better inform us about our marketing and marketing team.

Sensitive Personal Identifiers

·          What We May Collect:

o    Anything that reveals your social security, driver’s license, state identification card, or passport number.

·          How do we Collect it?:

o    We receive this information from you through the website, in-person, written in a completed form, application or other written correspondence, e-mail and/or by telephone.  This may also be collected from other sources you provide that information to, such as our agents, vendors and service providers and from publicly available sources. For example, sometimes we receive updated address information from third parties that we may use to update our records.

·          Business Purpose for Disclosure:

o    This information is only collected and utilized to the extent it is needed in order to complete a transaction with you.

Sensitive Personal Account Information:

·          What We May Collect:

o    This includes things that reveals your account log-In, or financial account in combination with any required security or access code, password, or credentials allowing access to an account.

·          How do we Collect it?:

·          Business Purpose for Disclosure: 

o    This information is only collected and utilized to the extent it is needed in order to complete a transaction with you.

Disclosing Personal Information

EASTERN may disclose your personal information to a third party for a business purpose. When we disclose personal information for a business purpose, we enter a contract that describes the purpose and requires the recipient to both keep that personal information confidential and not use it for any purpose except performing the contract.

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

Service providers.
Outside marketing consultants.
Third party vendors.

Below you will find a table summarizing how your Personal Information is disclosed:

Identifiers

What we may disclose:
- A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol (“IP”) address, email address, account name, Social Security number, driver’s license number.
What Kind of Third Parties Do We Disclose Your Information to?:
- We disclose this information to escrow agents, third party lien holders, service providers; document processing companies, consumer verification services, and any other third party involved in your loan process.

Business Purpose for Disclosure:

We disclose this information so these parties know who you are, and how to reach you for the purposes of a transaction between you and EASTERN. We may also disclose this information to comply with our legal obligations.

Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e))

What we may disclose:

A name, signature, Social Security number, address, telephone number, driver’s license or state identification card number, resident alien card, passport visa, dependent information, divorce decree and property settlement, IRS transcripts, employment, employment history, bank account number, credit card number, debit card number, and other financial information.

What Kind of Third Parties Do We Disclose Your Information to?:

We disclose this information to escrow agents, third party lien holders, service providers; document processing companies, consumer verification services, and any other third party involved in your loan process

Business Purpose for Disclosure:

Protected classification characteristics under California or federal law

What we may disclose:

Age (40 years or older), date of birth, race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, dependent information, genetic information (including familial genetic information).

What Kind of Third Parties Do We Disclose Your Information to?:

Business Purpose for Disclosure:

Commercial information

What we may disclose:

Records of personal property, products or services purchased, obtained, or considered, divorce decree and property settlements, IRS transcripts, or other purchasing or consuming histories or tendencies.

What Kind of Third Parties Do We Disclose Your Information to?:

Business Purpose for Disclosure:

We disclose this information for the purposes of reporting your creditworthiness, and to confirm and allow for the verification of information that you provide to EASTERN.

Internet or other similar network activity.

What we may disclose:

Browsing history, search history, information on a consumer’s interaction with a website, application, or advertisement.

What Kind of Third Parties Do We Disclose Your Information to?:

We disclose this information to marketing partners, service providers; and any other third party involved in your loan process. Furthermore, this information may be shared with external information technology experts to determine and assess the nature of a data breach.

Business Purpose for Disclosure:

We share some of this information, after it has been de-identified pursuant to the Terms of use information to better tailor our service to your brokers.

Sales of Personal Information

In the preceding twelve (12) months, EASTERN has not sold any personal information. It is EASTERN’s policy that we do not sell personal information.

Your Rights and Choices

The CCPA provides consumers (California residents) with specific rights regarding their    personal information. This section describes your CCPA rights and explains how to exercise those rights.

Access to Specific Information and Data Portability Rights

You have the right to request that EASTERN 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, we will disclose to you:

·         The categories of personal information we collected about you.

·         The categories of sources for the personal information we collected about you.

·         Our business or commercial purpose for collecting or selling that personal information.

·         The categories of third parties with whom we share that personal information.

·         The specific pieces of personal information we collected about you (also called a data portability request).

·         If we sold or disclosed your personal information for a business purpose, two separate lists disclosing:

·         sales, identifying the personal information categories that each category of recipient purchased; and

·         disclosures for a business purpose, identifying the personal information categories that each category of recipient obtained.

 Deletion Request Rights

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

We may deny your deletion request if retaining the information is necessary for us or our service provider(s) 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 et. seq.).

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.

California Opt-Out Rights

If you are 16 years of age or older, you have the right to direct us to not sell your Personal Information at any time (the “right to opt-out”).  We do not sell the Personal Information of consumers we actually know are less than 16 years of age, unless we receive affirmative authorization (the “right to opt-in”) from either the consumer who is between 13 and 16 years of age, or the parent or guardian of a consumer less than 13 years of age.  Consumers who opt-in to Personal Information sales may opt-out of future sales at any time.

It is Hovnanian’s policy that we do not sell Personal Information to any entity outside of our affiliated companies. However, You have the right to direct us to not sell or share your Personal Information we have collected or will collect at any time (the “right to opt-out).  To exercise the right to opt-out, you (or your authorized representative) may submit a request to us by visiting the following Internet Web page link: https://www.khov.com/personal-information-dns-form.

Do Not Sell My Personal Information

Once you make an opt-out request, you may change your mind and opt back in to Personal Information sales at any time by e-mailing Hovnanian at privacy@khov.com or by visiting our “Do Not Sell or Share My Personal Information” page here.

You do not need to create an account with us to exercise your opt-out rights.  We will only use Personal Information provided in an opt-out request to review and comply with the request.

Exercising Access, Data Portability and Deletion Rights

To exercise the access, data portability, and deletion rights described above, please submit a verifiable consumer request to us by either:

Calling us at 1-833-678-0423
Visiting www.khov.com
E-mailing us as privacy@khov.com
Sending mail to us at:

Eastern National Title Agency, Inc.
Attention: Corporate Legal Department
90 Matawan Rd, 5th Floor
Matawan, NJ 07747

Only you, or a person registered with the California Secretary of State that you authorize 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.

You may only make a verifiable consumer request for access or data portability twice within a 12-month period.

To be considered a verifiable consumer request, the 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.

We 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 us. We will only use Personal Information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request. For instructions on exercising sale opt-out rights, see Personal Information Sales Opt-Out and Opt-In Rights, above.

Non-Discrimination

We 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 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.

However, we may offer you certain financial incentives permitted by the CCPA that can result in different prices, rates, or quality levels. Any CCPA-permitted financial incentive we offer will reasonably relate to your Personal Information’s value and contain written terms that describe the program’s material aspects. Participation in a financial incentive program requires your prior opt in consent, which you may revoke at any time.

Additional California Notice

Under California Civil Code Section 1789.3, California residents who use the website are entitled to the following consumer rights notice: If you have a question or complaint regarding the services or products provided through the Website, please send an email to privacy@khov.com. You may also contact us by writing to Eastern National Title Agency, Inc., Attention: Corporate Legal Department, 90 Matawan Rd, 5th Floor, Matawan, NJ 07747, or by calling us at 1-833-678-0423. California residents may reach the Complaint Assistance Unit of the Division of Consumer Services of the California Department of Consumer Affairs by mail at 1625 North Market Blvd., Suite N 112, Sacramento, CA 95834, or by telephone at (916) 445-1254 or (800) 952-5210.

For Colorado Residents

If you are a Colorado resident, Colorado law may provide you with additional rights regarding our use of your Personal Information.  To learn more about your Colorado privacy rights, see the following portions of this Privacy Policy.

Colorado Rights

If you are a Colorado resident, you have the following rights:

(a) The Right of Access to confirm whether processing of Personal Information is occurring and access to the Personal Information belonging to the consumer.  If the consumer requests this information, we will provide it to you in a readily usable format that will allow transfer.  Such request may be made no more than twice per calendar year.

(b) The Right of Correction of any entries of Personal Information that we currently have about you.

(c) The Right to Delete the information we have collected about you.  Please note that even though we will delete your information, we will have to retain some information about you to catalogue that your request was received, and complied with.

(d) The Right to Authorize a third party to act on the consumer’s behalf to exercise the consumer’s opt-out rights described below.

To exercise the rights described above, please submit a verifiable consumer request to us by either:

Calling us at 1-833-678-0423
Visiting www.khov.com
E-mailing us as privacy@khov.com
Sending mail to us at:

Eastern National Title Agency, Inc.
Attention: Corporate Legal Department
90 Matawan Rd, 5th Floor
Matawan, NJ 07747

To be considered a verifiable consumer request, the 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.

Colorado Opt-Out Rights

If you are a Colorado resident, you also have the right to opt out of the sale of Personal Information, collection and use of Personal Information, targeted advertising, or profiling.

If you want to indicate to us that you do not want us to sell or exchange your personal information, please visit our “Do Not Sell or Share My Personal Information” page here.

If you want to indicate to us that you do not want us to use your information for targeted advertising, or profiling, please visit our “Limit the Use of My Personal Information” page here.

FOR UTAH RESIDENTS

Utah Rights

If you are a Utah resident, you have the following rights:

(a) The Right of Access to confirm whether processing of Personal Information is occurring and access to the Personal Information belonging to the consumer. If the consumer requests this information, we will provide it to you in a readily usable format that will allow transfer. Such request may be made no more than twice per calendar year.

(b) The Right to Delete the information we have collected about you. Please note that even though we will delete your information, we will have to retain some information about you to catalogue that your request was received, and complied with.

To exercise the access, data portability, and deletion rights described above, please submit a verifiable consumer request to us by either:

Calling us at 1-833-678-0423
Visiting www.khov.com
E-mailing us as privacy@khov.com
Sending mail to us at:

Eastern National Title Agency, Inc.
Attention: Corporate Legal Department
90 Matawan Rd, 5th Floor
Matawan, NJ 07747

To be considered a verifiable consumer request, the 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.

Utah Opt-Out Rights

If you are a Utah resident, you also have the right to opt out of the sale of Personal Information, collection and use of Personal Information, targeted advertising, or profiling.

If you want to indicate to us that you do not want us to sell or exchange your personal information, please visit our “Do Not Sell or Share My Personal Information” page here.

If you want to indicate to us that you do not want us to use your information for targeted advertising, or profiling, please visit our “Limit the Use of My Personal Information” page here.

FOR TEXAS RESIDENTS

Texas Rights

If you are a Texas resident, you have the following rights:

(b) The Right of Correction of any entries of Personal Information that we currently have about you.

To exercise the rights described above, please submit a verifiable consumer request to us by either:

Calling us at 1-833-678-0423
Visiting www.khov.com
E-mailing us as privacy@khov.com
Sending mail to us at:

Eastern National Title Agency, Inc.
Attention: Corporate Legal Department
90 Matawan Rd, 5th Floor
Matawan, NJ 07747

To be considered a verifiable consumer request, the 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.

Texas Opt-Out Rights

If you are a Texas resident, you also have the right to opt out of the sale of Personal Information, collection and use of Personal Information, targeted advertising, or profiling.

If you want to indicate to us that you do not want us to sell or exchange your personal information, please visit our “Do Not Sell or Share My Personal Information” page here.
If you want to indicate to us that you do not want us to use your information for targeted advertising, or profiling, please visit our “Limit the Use of My Personal Information” page here.

FOR CONNECTICUT RESIDENTS

If you are a Connecticut resident, Connecticut law may provide you with additional rights regarding our use of your Personal Information. To learn more about your Connecticut privacy rights, see the following portions of this Privacy Policy.

Connecticut Resident Rights

If you are a Connecticut resident, you have the following rights:

(a) The Right of Access to confirm whether processing of Personal Information is occurring and access to the Personal Information belonging to the consumer. If the consumer requests this information, we will provide it to you in a readily usable format that will allow transfer. Such request may be made no more than twice per calendar year.

(b) The Right of Correction of any entries of Personal Information that we currently have about you.

(c) The Right to Delete the information we have collected about you. Please note that even though we will delete your information, we will have to retain some information about you to catalogue that your request was received, and complied with.

(d) The Right to Authorize a third party to act on the consumer’s behalf to exercise the consumer’s opt-out rights described below.

To exercise the rights described above, please submit a verifiable consumer request to us by either:

Calling us at 1-833-678-0423
Visiting www.khov.com
E-mailing us as privacy@khov.com
Sending mail to us at:

Eastern National Title Agency, Inc.
Attention: Corporate Legal Department
90 Matawan Rd, 5th Floor
Matawan, NJ 07747

To be considered a verifiable consumer request, the 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.

Connecticut Opt-Out Rights

If you are a Connecticut resident, you also have the right to opt out of the sale of Personal Information, collection and use of Personal Information, targeted advertising, or profiling.

If you want to indicate to us that you do not want us to sell or exchange your personal information, please visit our “Do Not Sell or Share My Personal Information” page here.

If you want to indicate to us that you do not want us to use your information for targeted advertising, or profiling, please visit our “Limit the Use of My Personal Information” page here.

FOR VIRGINIA RESIDENTS     

If you are a Virginia resident, Virginia law may provide you with additional rights regarding our use of your Personal Information. To learn more about your Virginia privacy rights, see the following portions of this Privacy Policy.

Virginia Rights

If you are a Virginia resident, you have the following rights:

(a) The Right of Access to confirm whether processing of Personal Information is occurring and access to the Personal Information belonging to the consumer. If the consumer requests this information, we will provide it to you in a readily usable format that will allow transfer. Such request may be made no more than twice per year.

(b) The Right of Correction of any entries of Personal Information that we currently have about you.

(c) The Right to Delete the information we have collected about you. Please note that even though we will delete your information, we will have to retain some information about you to catalogue that your request was received, and complied with.

To exercise the rights described above, please submit a verifiable consumer request to us by either:

Calling us at 1-833-678-0423
Visiting www.khov.com
E-mailing us as privacy@khov.com
Sending mail to us at:

Eastern National Title Agency, Inc.
Attention: Corporate Legal Department
90 Matawan Rd, 5th Floor
Matawan, NJ 07747

To be considered a verifiable consumer request, the 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.

Virginia Opt-Out Rights

If you are a Virginia resident, you also have the right to opt out of the sale of Personal Information, collection and use of Personal Information, targeted advertising, or profiling.

If you want to indicate to us that you do not want us to sell or exchange your personal information, please visit our “Do Not Sell or Share My Personal Information” page here.

If you want to indicate to us that you do not want us to use your information for targeted advertising, or profiling, please visit our “Limit the Use of My Personal Information” page here.

CONTACTING US

Our “contact us” page contains e-mail links that allow you to contact us directly with any questions or comments that you may have. If you have any questions about this Privacy Policy or our privacy practices, please feel free to contact us at privacy@khov.com or at:

Eastern National Title Agency, Inc.
Attention: Corporate Legal Department
90 Matawan Rd, 5th Floor
Matawan, NJ 07747