Williston Financial Group Privacy Notice

Revised 12/20/2022

Williston Financial Group LLC, WFG National Title Insurance Company, and each of the affiliates listed below (collectively “WFG” or the “WFG Family”) believe it is important to protect your privacy and confidences. We recognize and respect the privacy expectations of our customers. We believe that making you aware of how we collect information about you, how we use that information, and with whom we share that information will form the basis for a relationship of trust between us. This Privacy Notice provides that explanation. We reserve the right to change this Privacy Notice from time to time.

WFG’s primary business is providing appraisal, title insurance, and escrow services for the sale or refinance of real property. This can be a complicated process involving multiple parties, many of whom have been selected by our customers, each filling a specialized role. In part, you have hired WFG to coordinate and smooth the passage of the information necessary for an efficient settlement or closing.

In the course of this process, WFG collects a significant amount of personal and identifying information about the parties to a transaction, including sensitive items that include but are not limited to: your contact information, including email addresses, Social Security numbers, driver’s license, and other identification numbers and information; financial, bank and insurance information; information about past and proposed mortgages and loans; information about properties you currently or previously owned; your mortgage application package; and the cookie, IP address, and other information captured automatically by computer systems.

Much of this information is gathered from searches of public land, tax, court and credit records to make certain that any liens, challenges or title defects are addressed properly. Some of the information that is collected is provided by you or the computer systems you use. We also may receive information from real estate brokers and agents, mortgage brokers and lenders, and others working to facilitate your transaction, as well as information from public, private or governmental databases including credit bureaus, ‘no-fly’ lists, and terrorist ‘watch lists’.

What Information is Shared?

WFG DOES NOT SELL any of your information to non-affiliated companies for marketing or any other purpose.

However, some of the same information does get shared with persons inside and outside the WFG Family in order to facilitate and complete current and future transactions.

For example:

  • Information, draft documents, and closing costs will pass back and forth between WFG and your mortgage broker and lender to facilitate your transaction.
  • Information, including purchase agreements and amendments, will pass back and forth between WFG and the real estate agents and brokers, the mortgage brokers and lenders, the lawyers and accountants, and others involved in facilitating the transaction.
  • WFG may order property searches and examinations from title searchers, abstractors and title plants.
  • WFG may use third parties to obtain tax information, lien information, payoff information, and condominium or homeowners’ association information.
  • Third parties may be engaged to prepare documents in connection with your transaction.
  • Surveys, appraisals, and inspections may be ordered.
  • Within the WFG Family of companies, we may divide up the work to handle each closing in the most efficient manner possible and to meet specific legal and licensing requirements. Certain parts of your closing (for example a search or disbursement) may be handled by another division or company within the WFG Family.
  • When it is time for signatures, your complete closing package may be sent to a notary, remote online notary, or notary service company who will arrange to meet with you to sign documents. The notary will, in turn, send signed copies back to us along with copies of your driver’s license or other identity documents, usually by mail, UPS, Federal Express or another courier service.
  • Your deed, mortgage and other documents required to perfect title will be recorded with the local recorder of deeds.
  • In some cases, we use an outside service to coordinate the recording or electronic-recording of those instruments, and they will receive copies of your deeds, mortgages and other recordable documents to process, scan and send on to the recording office.
  • Information within your title policy may be shared with WFG National Title Insurance Company title policy issuing agents to facilitate future financial transactions involving your property.
  • Various government agencies get involved. The law requires us to provide certain information to the IRS, the U.S. Department of the Treasury, local and state tax authorities, and other regulatory and governmental agencies.
  • WFG title policy issuing agents only: personal information provided by you may be shared with a third party for the purposes of facilitating training to obtain CE/CLE credits.

You have a choice in the selection of a mortgage broker, lender, real estate broker or agent and others that make up your ‘transaction team.’ Information flows to and from the members of the transaction team you have selected to facilitate an efficient transaction for you.

When WFG selects and engages a third party provider, we limit the scope of the information shared with that third party to the information reasonably necessary for that service provider to provide the requested services. With most, we have entered into agreements in which they expressly commit to maintain a WFG customer’s information in strict confidence and use the information only for purposes of providing the requested services, clearing title, preventing fraud and addressing claims under our title insurance policies.

How Does WFG Use Your Information?

We may use your personal information in a variety of ways, including but not limited to:

  • Provide the products, services and title insurance you have requested, and to close and facilitate your transaction.
  • Provide and use historic transaction information to facilitate future financial transactions.
  • Coordinate and manage the appraisal process.
  • Handle a claim or provide other services relating to your title insurance policies.
  • Create, manage, and maintain your account.
  • Operate and improve WFG’s applications and websites, including WFG MyHome®, WFG’s secure communication and transaction portal. Your information is used for access management, payment processing, site administration, internal operations, troubleshooting, data analysis, testing, research, and for statistical purposes.
  • Respond to your requests, feedback or inquiries.
  • Comply with laws, regulations, and other legal requirements.
  • Comply with relevant industry standards and our policies, including managing WFG’s risk profile through reinsurance.
  • Protect and enforce your rights and the rights of other users against unlawful activity, including identity theft and fraud.
  • Protect and enforce our collective rights arising under any agreements entered into between WFG and you or any other third party.
  • Protect the integrity and maintain security of our applications, websites, and products.
  • Operate, evaluate, and improve our business.
  • Provide you with information about products, services, and promotions from WFG or third parties that may interest you.
  • WFG title policy issuing agents only: Provide you with a training platform to obtain CE/CLE credits.

How Do We Store and Protect Your Personal Information?

Although no system can guarantee the complete security of your personal information, we will use our best efforts to maintain commercially reasonable technical, organizational, and physical safeguards, consistent with applicable law, to protect your personal information and our systems and sites from malicious intrusions or hacking.

How Long Do We Keep Your Personal Information?

We keep your personal information for as long as necessary to comply with the purpose for which it was collected, our business needs, and our legal and regulatory obligations. We may store some personal information indefinitely. If we dispose of your personal information, we will do so in a way that is secure and appropriate to the nature of the information subject to disposal.

Computer Information

When you access a WFG website, communicate with us by email, or close your transaction on an eClosing platform, we may automatically collect and store more information than you are expressly providing.This may include:

  • Your IP address.
  • Your email address, your alias, and social media handles.
  • The type of browser and operating system you use.
  • The time of your visit.
  • The pages of our website you visit.
  • Cookies.

In order to provide you with customized service, we make use of Web browser cookies. Cookies are files that help us identify your computer and personalize your online experience. You may disable cookies on your computer, but you may not be able to download online documents or access certain websites unless cookies are enabled.

The technical information we collect is used for administrative and technical purposes and to prevent fraud and provide identity verification. For instance, we may use it to count the number of visitors to our website and determine the most popular pages. We may also use it to review types of technology you are using, determine which link brought you to our website, assess how our advertisements on other websites are working, help with maintenance, and improve our customers’ experience.

We may compare information gathered on previous visits to verify that we are interacting with the same parties and not a potential imposter.

If we ask you to fill out any forms or surveys, we will use the information we receive only for the specific purposes indicated in those forms or surveys.

The information you and your transaction team send us in emails or attached to an email, or provide through any of our online tools, is used for purposes of providing title, escrow and appraisal management services and used for the purposes described above.

In addition to the above, if you use an eClosing platform to sign your real estate transaction additional information may be collected. This may include:

  • Your IP address.
  • Your location.
  • Your email address and your alias.
  • The type of browser and operating system you use.
  • The time of your visit.
  • Your biometrics.
  • Your image.
  • Video recording of your transaction signing.
  • Transaction metadata.
  • Cookies.

Links to Third Party Websites

Our applications and websites may contain links to third party websites and services. Please note that these links are provided for your convenience and information, and the websites and services may operate independently from us and have their own privacy policies or notices, which we strongly suggest you review. This Privacy Notice applies to WFG’s applications and websites only.

Do Not Track

Because there is not an industry-standard process or defined criteria to permit a user to opt-out of tracking their online activities (“Do Not Track”), our websites do not currently change the way they operate based upon detection of a Do Not Track or similar signal. Likewise, we cannot assure that third parties are not able to collect information about your online activities on WFG websites or applications.

Social Media Integration

Our applications, websites, and products contain links to and from social media platforms. You may choose to connect to us through a social media platform, such as Facebook, Twitter, Google, etc. When you do, we may collect from the social media platform additional information from or about you, such as your screen names, profile picture, contact information, contact list, and the profile pictures of your contacts. The social media platforms may also collect information from you.

When you click on a social plug-in, such as Facebook’s “Like” button, Twitter’s “tweet” button, or the Google+, that particular social network’s plug-in will be activated and your browser will directly connect to that provider’s servers. Your action in clicking on the social plug-in causes information to be passed to the social media platform.

We do not have control over the collection, use and sharing practices of social media platforms. We therefore encourage you to review their usage and disclosure policies and practices, including their data security practices, before using social media platforms.

How Can You “Opt-Out?”

We do not sell your information; therefore there is no need to opt-out of such reselling. Under various laws, you can opt-out of the sharing of your information for more narrow purposes. For additional detail, consult the links under the Legal Notices below.

Legal Notices

To comply with various federal and state laws, we are required to provide more complete legal notices and disclosures – see links below. The state-specific statutes referenced therein may also give residents of those states additional rights and remedies.

Additional Forms

Privacy Notice for California Residents – https://wfgtitle.com/privacy-notice-california

Privacy Notice for Oregon Residents – https://wfgtitle.com/privacy-notice-oregon

GLB Model Form – https://wfgtitle.com/glb-model-form

How to Contact Us

If you have any questions about WFG’s Privacy Notice or how we protect your information, please contact WFG:

• By email: Consumerprivacy@willistonfinancial.com

• By telephone: 833-451-5718

• By fax: 503-974-9596

• By mail: 12909 SW 68th Pkwy, Suite 350, Portland, OR 97223