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Privacy Policy

Effective Date: June 8, 2026 | Last Updated: June 8, 2026

www.escrowofthewest.com

CCPA NOTICE

If you are a California resident, you have specific rights under the California Consumer Privacy Act (CCPA) as amended by the California Privacy Rights Act (CPRA). See Section 11 for your full rights and how to exercise them.

1. Introduction

Escrow of the West, Inc. (“us”, “we”, or “our”) operates www.escrowofthewest.com (the “Service”). We are committed to protecting your personal information and your right to privacy. This Privacy Policy explains how we collect, use, disclose, and safeguard your information, and it describes your rights and our obligations under applicable law, including:

  • The California Consumer Privacy Act (CCPA), as amended by the California Privacy Rights Act (CPRA)
  • Regulations of the California Department of Financial Protection and Innovation (DFPI)
  • The Organization for Economic Co-operation and Development (OECD) Privacy Framework and Fair Information Practice Principles (FIPPs)

By using the Service, you agree to the collection and use of information in accordance with this Policy. Unless otherwise defined here, terms used in this Policy have the same meanings as in our Terms and Conditions.

2. Information We Collect

2.1 Information You Provide Directly

When you use our Service, you may provide us with personally identifiable information (“Personal Information”), including but not limited to:

  • Full legal name
  • Email address
  • Phone number
  • Postal address
  • Financial information necessary to complete escrow transactions
  • Government-issued identification (where legally required for identity verification)
  • Other information you choose to provide in connection with the Service

2.2 Information Collected Automatically (Log Data)

When you visit our Service, we automatically collect certain information that your browser or device sends, which may include:

  • Internet Protocol (IP) address
  • Browser type and version
  • Pages of our Service that you visit and time spent on those pages
  • Date and time of your visit
  • Referring website addresses
  • Device identifiers and operating system information

This data is collected for security, fraud prevention, and analytics purposes. We use third-party services, including Google Analytics, that collect and process this information under their own privacy policies.

2.3 Sensitive Personal Information

As a licensed escrow company subject to DFPI oversight, we may collect categories of information that qualify as “sensitive personal information” under the CPRA, including government identification numbers and financial account details. We collect this information only as strictly necessary to perform escrow services and comply with our legal obligations. We do not use sensitive personal information for purposes beyond those disclosed in this Policy.

2.4 Information We Do Not Collect

We do not sell your Personal Information to third parties. We do not knowingly collect Personal Information from individuals under the age of 18.

3. How We Use Your Information

We process your Personal Information based on one or more of the following lawful purposes, consistent with OECD Purpose Specification and Use Limitation principles:

  • Performance of contract: To process and complete escrow transactions you initiate
  • Legal obligation: To comply with applicable federal and California laws, DFPI regulations, anti-money laundering (AML) requirements, and other regulatory obligations
  • Legitimate interests: To operate, maintain, and improve our Service; to detect and prevent fraud, security incidents, or other illegal activity
  • Consent: To send you newsletters, marketing, or promotional communications (you may opt out at any time)
  • Vital interests / public interest: To protect the security and integrity of escrow transactions and the financial system

We will not use your Personal Information for any purpose that is incompatible with those disclosed in this Policy without providing you with prior notice and, where required, obtaining your consent.

4. Disclosure of Your Information

4.1 Service Providers

We may share your Personal Information with trusted third-party companies and individuals who assist us in operating the Service (“Service Providers”). These parties have access to your information only to perform specific tasks on our behalf and are contractually obligated not to disclose or use your information for any other purpose.

4.2 Legal and Regulatory Disclosures

As a DFPI-licensed escrow company, we may be required to disclose your Personal Information to:

  • The California Department of Financial Protection and Innovation (DFPI) during examinations or investigations
  • Law enforcement agencies pursuant to lawful court order, subpoena, or other legal process
  • Federal and state regulators as required under anti-money laundering (AML), Bank Secrecy Act (BSA), and related financial regulations
  • Other parties where disclosure is necessary to protect the rights, property, or safety of Escrow of the West, our customers, or others

4.3 Business Transfers

If Escrow of the West is involved in a merger, acquisition, or asset sale, your Personal Information may be transferred. We will provide notice before your information is transferred and becomes subject to a different privacy policy.

4.4 No Sale of Personal Information

We do not sell, rent, or trade your Personal Information to third parties for monetary or other valuable consideration. This applies to all California residents under the CCPA/CPRA and to all users of our Service globally.

4.5 No Sharing for Cross-Context Behavioral Advertising

We do not share your Personal Information for cross-context behavioral advertising without your explicit opt-in consent.

5. Cookies and Tracking Technologies

5.1 What Are Cookies?

Cookies are small text files stored on your device when you visit a website. They help the site function properly, enhance your experience, and provide usage analytics. We use both first-party cookies (set by us) and third-party cookies (set by our service partners).

5.2 Consent and Cookie Preferences

When you first visit our Service, you will be presented with a cookie consent banner allowing you to accept, reject, or customize non-essential cookies. You may update your preferences at any time by clicking the “Consent Preferences” button on our website. Your choice will be respected on all subsequent visits.

5.3 Types of Cookies We Use

Necessary Cookies

Required for the website to function. These cannot be disabled without affecting Service functionality.

Cookie Duration Description
wpEmojiSettingsSupports Session Determines if the browser can display emojis properly.
li_gc 6 months LinkedIn cookie storing visitor consent for non-essential cookies.
cookieyes-consent 1 year Remembers users’ cookie consent preferences across visits.

Functional Cookies

Enable features such as social media sharing and third-party integrations.

Cookie Duration Description
fnct.escrowofthewest.com Session Functional test cookie for Service features.

Analytics Cookies

Help us understand how visitors interact with our Service. All analytics data is anonymized.

Cookie Duration Description
_ga 1 year, 1 month Google Analytics: tracks unique visitors and session data anonymously.
_gid 2 hours Google Analytics: stores visit and page performance data.
_ga_* 1 year, 1 month Google Analytics: stores and counts page views.

Performance Cookies

Cookie Duration Description
_gat 2 hours Google Analytics: limits request rate on high-traffic sites.

Advertisement Cookies

Used to deliver relevant advertisements and measure ad campaign effectiveness. These require your consent.

Cookie Duration Description
bcookie 1 year LinkedIn: recognizes browser IDs for ad tags and share buttons.
lidc 1 day LinkedIn: facilitates data center selection.

5.4 Third-Party Advertising Services

Google (AdWords & DoubleClick)

Google, as a third-party vendor, uses cookies to serve and measure ads on our Service. You may opt out of interest-based advertising at: http://www.google.com/ads/preferences/

You may also install the Google Analytics Opt-out Browser Add-on at: https://tools.google.com/dlpage/gaoptout

Facebook

Facebook remarketing services may be used on our Service. You may opt out at: https://www.facebook.com/about/ads/

Facebook adheres to Self-Regulatory Principles established by the Digital Advertising Alliance. You may also opt out through: http://www.aboutads.info/choices/ (USA), http://youradchoices.ca/ (Canada), or http://www.youronlinechoices.eu/ (Europe).

5.5 Do Not Track

We support the Do Not Track (“DNT”) browser preference. When DNT is enabled, we will not engage in cross-site tracking for advertising purposes. You can enable DNT in your browser’s Preferences or Settings.

5.6 Managing Cookies

You may block or delete cookies through your browser settings:

  • Chrome: https://support.google.com/accounts/answer/32050
  • Safari: https://support.apple.com/en-in/guide/safari/sfri11471/mac
  • Firefox: https://support.mozilla.org/en-US/kb/clear-cookies-and-site-data-firefox
  • Internet Explorer: https://support.microsoft.com/en-us/topic/how-to-delete-cookie-files-in-internet-explorer-bca9446f-d873-78de-77ba-d42645fa52fc

Please note that disabling certain cookies may affect the functionality of our Service.

6. Data Retention

We retain your Personal Information for as long as necessary to fulfill the purposes described in this Policy, including to:

  • Complete escrow transactions and maintain required transactional records
  • Comply with California and federal legal retention requirements applicable to licensed escrow companies, which may mandate retention of records for a period of up to seven (7) years or longer as prescribed by law
  • Resolve disputes and enforce our agreements
  • Comply with DFPI examination and recordkeeping requirements

When Personal Information is no longer required for these purposes, we will securely delete or anonymize it in accordance with our data retention schedule and applicable law. The OECD principle of data minimization guides our retention practices — we keep only what is necessary for as long as necessary.

7. Data Security

We implement commercially reasonable administrative, technical, and physical safeguards designed to protect your Personal Information from unauthorized access, use, modification, disclosure, or destruction. Our security measures are consistent with applicable DFPI standards and include:

  • Encryption of sensitive data in transit and at rest
  • Access controls and role-based permissions limiting access to Personal Information
  • Regular security assessments and monitoring
  • Employee training on data security and privacy obligations

Notwithstanding these measures, no method of transmission over the internet or method of electronic storage is 100% secure. We cannot guarantee the absolute security of your Personal Information.

DATA BREACH

In the event of a data breach involving your Personal Information, we will notify affected individuals and the appropriate regulatory authorities as required by California law (Cal. Civ. Code § 1798.82) and DFPI regulations, within the timeframes prescribed by law.

8. International Data Transfers

Your Personal Information is primarily processed and stored in the United States. If you access our Service from outside the United States, your information may be transferred to and processed in the U.S., where data protection laws may differ from those in your jurisdiction.

In accordance with OECD accountability principles, where we transfer data internationally, we take steps to ensure that appropriate safeguards are in place and that the information receives a level of protection consistent with this Policy.

9. Links to Third-Party Sites

Our Service may contain links to third-party websites not operated by us. If you click a third-party link, you will be directed to that site. We strongly advise you to review the Privacy Policy of every site you visit. We have no control over and assume no responsibility for the content, privacy policies, or practices of any third-party sites or services.

10. Children’s Privacy

Our Service is intended for use by persons age 18 or older. We do not knowingly collect Personal Information from individuals under 13. If you are a parent or guardian and believe your child has provided us with Personal Information, please contact us immediately. Upon verification, we will promptly delete such information from our records.

11. California Consumer Privacy Rights (CCPA/CPRA)

If you are a California resident, you have the following rights under the CCPA as amended by the CPRA:

11.1 Right to Know

You have the right to request that we disclose to you the categories and specific pieces of Personal Information we have collected about you, the categories of sources from which the information was collected, the business purposes for collection, and the categories of third parties with whom we have shared your information.

11.2 Right to Delete

You have the right to request deletion of your Personal Information that we have collected, subject to certain exceptions (e.g., where retention is required to complete a transaction, comply with a legal obligation, or for other permitted purposes under the CCPA/CPRA).

11.3 Right to Correct

You have the right to request that we correct inaccurate Personal Information we maintain about you.

11.4 Right to Opt-Out of Sale or Sharing

We do not sell or share Personal Information for cross-context behavioral advertising. If this practice changes, we will update this Policy and provide a “Do Not Sell or Share My Personal Information” link on our homepage.

11.5 Right to Limit Use of Sensitive Personal Information

You have the right to direct us to limit our use and disclosure of your sensitive personal information to uses that are necessary to perform the services you have requested, or as otherwise permitted by the CPRA.

11.6 Right to Non-Discrimination

We will not discriminate against you for exercising any of your privacy rights. We will not deny you goods or services, charge you different prices, or provide a different level of quality for exercising your rights under the CCPA/CPRA.

11.7 How to Submit a Rights Request

To exercise any of your California privacy rights, please submit a verifiable consumer request by:

  • Emailing us at: privacy@escrowofthewest.com
  • Contacting us via our website contact form at: www.escrowofthewest.com/contact

We will respond to verifiable requests within 45 days. If we need additional time (up to 90 days total), we will notify you of the extension in writing. We may need to verify your identity before processing your request. You may designate an authorized agent to make a request on your behalf; we will require written proof of authorization.

11.8 Shine the Light

California Civil Code § 1798.83 (“Shine the Light”) entitles California residents to request information about whether we have disclosed Personal Information to third parties for their direct marketing purposes in the preceding calendar year. We do not disclose Personal Information to third parties for their direct marketing purposes.

12. DFPI Regulatory Compliance

As a licensed escrow company regulated by the California Department of Financial Protection and Innovation (DFPI), we are subject to the California Escrow Law (Financial Code § 17000 et seq.) and applicable DFPI regulations. Our collection and use of certain Personal Information is mandated by law for:

  • Identity verification and customer due diligence (CDD) under anti-money laundering (AML) requirements
  • Suspicious activity reporting (SAR) obligations under the Bank Secrecy Act (BSA)
  • Maintenance of transaction records as required by DFPI examination standards
  • Compliance with DFPI orders, directives, and examinations

Any Personal Information collected for these regulatory purposes is processed solely for compliance and is subject to applicable legal retention and disclosure requirements. Where law requires us to retain or disclose information, such requirements supersede consumer deletion or restriction requests.

13. OECD Privacy Framework — Our Commitments

Our privacy practices are guided by the OECD Guidelines on the Protection of Privacy and Transborder Flows of Personal Data. The following summarizes how we implement each principle:

OECD Principle Our Implementation
Collection Limitation We collect only the Personal Information that is necessary for the stated purposes. We do not collect data in excess of what is required for escrow services and legal compliance.
Data Quality We maintain procedures to ensure Personal Information is accurate, complete, and kept up to date. You have the right to request correction of inaccurate information.
Purpose Specification The purposes for collecting Personal Information are clearly stated in this Policy before or at the time of collection. We do not repurpose data without additional notice and, where required, consent.
Use Limitation Personal Information is not used for purposes other than those specified in this Policy, except with your consent or as required by law.
Security Safeguards We apply commercially reasonable technical, administrative, and physical safeguards appropriate to the sensitivity of the data we hold.
Openness / Transparency We maintain this publicly accessible Privacy Policy and provide clear information about our practices, the types of data we hold, and our contact information.
Individual Participation You have the right to request access to, correction of, and deletion of your Personal Information, subject to applicable legal exceptions.
Accountability Escrow of the West takes responsibility for compliance with this Policy and applicable privacy laws. We require our service providers to adhere to equivalent data protection standards through contractual obligations.

14. Communications

We may use your Personal Information to contact you with newsletters, marketing materials, or other information that may be of interest to you. You may opt out of receiving any or all such communications by clicking the unsubscribe link in any email we send, or by contacting us directly. Opting out of marketing communications will not affect communications necessary to complete a transaction or comply with a legal obligation.

15. Changes to This Privacy Policy

We reserve the right to update or modify this Privacy Policy at any time. We will post the revised Policy on this page with an updated “Last Updated” date. If we make material changes, we will notify you by email (to the address on file) or by placing a prominent notice on our website at least 30 days prior to the changes taking effect. Your continued use of the Service after the effective date of the revised Policy constitutes your acknowledgment of the changes.

16. Contact Us

For questions, concerns, or to exercise your privacy rights, please contact our Operations Manager:

Company Escrow of the West, Inc.
Website www.escrowofthewest.com
Email info@escrowofthewest.com
Mail 9200 W. Olympic Blvd., Beverly Hills, CA 90212
Phone 310-402-5555

We will respond to privacy inquiries within 45 days of receipt.

© 2026 Escrow of the West, Inc. All rights reserved.

This document is for informational purposes. Please consult legal counsel for advice specific to your circumstances.

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