Spruce Holdings Inc
Privacy Policy

1. Introduction

At Spruce, we work hard to protect your personal information and ensure your information is kept private and secure. The following privacy policy outlines the types of personal information that Spruce Holdings Inc. and all of its subsidiaries or affiliates (collectively referred to as “Spruce Holdings Inc.” or “Spruce”) collect, including through our website (www.spruce.co) or when using our services. It also explains how we use that information.
Privacy is important to Spruce. If you have any questions or if you believe that Spruce has not adhered to this privacy policy, please send us a note at support@spruce.co or give us a call at 888-665-7535.

2. Summary

Information we collect from you:
We collect device-related information, server log information, and other types of anonymous information when you visit Spruce.co and when you become a customer of Spruce.
Additionally, we collect personal information and financial information when you register and use your Spruce account.

Why we collect your information:
We serve as title insurance agent and real estate closing agent for our customers. In order to produce a title insurance policy and close a real estate transaction, we are required to collect certain information under US and state laws.
We use your personal information to maintain your account, provide Spruce services, and enhance your customer experience.
We also use aggregated personal information and non-personal information to improve Spruce and monitor and protect the security of our service.

Who we share your personal information with:
We do not sell, rent, or trade your personal information with any third parties except as provided in this privacy policy, with your consent, or as required by law.

Your choices as the consumer:
In order to operate Spruce, produce a title insurance policy, and close a real estate transaction, we require certain personal information.
If you are not comfortable providing personal information to Spruce, then our service won’t be useful to you and you will not be allowed to open an account.

Information from Third Parties:
We may also receive information about you from third parties, pursuant to that third party’s privacy policy.
Information provided to us from Third Parties about you will be treated in the same manner as information we collect from you.

3. How You Accept This Policy

By using and continuing to use the Spruce website and/or services, or otherwise providing us with personal information (such as an email address) you agree to the terms and conditions of this privacy policy and any updates thereto. This is our entire and exclusive privacy policy and it supersedes any earlier version.

4. Information We Collect and Why

In order to provide high quality service, produce and sell title insurance, and close real estate transactions, Spruce collects various types of information when you visit our website or open an account as a customer.

4a. Visitor Information
We collect various types of anonymous information when you visit our website such as device-related information (browser type, IP address, etc.) and server log information (date and time of day of your visit). We use this information to better understand our visitors and our business and to enhance the services we offer.

4b. Cookies
Cookies are small pieces of data that are stored on your computer, mobile phone or other device. We store anonymous information in cookies to improve accessibility and help you navigate services provided through our website. Cookies and similar technology are not required for site functionality. You are not required to accept any cookies to use our website. However, refusing to accept cookies will make use of our website more cumbersome and less accessible.

4c. Analytics Services
We use analytics tools such as “Google Analytics” (collectively referred to as “Analytics Services”) to collect information about the usage of our website. These analytics services collect information such as how often users visit our website, what pages they visit when they do so, and what other sites they used prior to coming to this site. We only use the information we get from these Analytics Services to improve our website. These Analytics Services only collect the device related information on the date you visit our website, not your name or other identifying information. We do not combine the information collected through the use of these Analytics Services with personally identifiable information. The Analytics Services ability to use and share information about your visits to this site is restricted by their terms of use and privacy policies. If you choose, you can prevent your data from being used by Google Analytics on websites by installing the Google Analytics opt-out browser add-on here.

4d. Customer Information
When you choose to create an account with Spruce, we will also collect certain personal information, including, but not limited to, your full legal name, email address, permanent address, date of birth, and relevant property information. In order to produce and sell a title insurance policy and close a real estate transaction, we also are required to collect certain additional information, including, but not limited to, your social security number. Sometimes we might collect this nonpublic information from other parties in your transaction, such as the real estate agents, lenders, settlement service providers, or other parties necessary to complete your transaction. You may choose not to provide this information, but you cannot become a Spruce customer without providing it. If you use the Plaid service when signing up for a Spruce account, you acknowledge and agree that the information you provide to Spruce through Plaid will be treated in accordance with Plaid’s privacy policy, located at https://plaid.com/legal/#privacy-policy.

5. How We Use Your Personal Information

Spruce uses personally identifiable and other collected information in a manner that is consistent with this privacy policy. We use your personal and nonpersonal information for various purposes, including but not limited to the following:

Operate and maintain your account in accordance with US law
Provide the services you request, including the processing of your title order, acquiring title insurance, and/or performing a title search on your behalf
Enhance your customer experience
Provide updates and keep you informed of the status of your transaction
Investigate and understand how our website and services are used
Monitor and protect the security and integrity of SpruceBetter market and advertise Spruce’s services.

6. When We Share Your Information

We do not sell, rent, or trade your personal information with any third parties without your consent or as required by law.

We may disclose your personal information in your account with our affiliates and nonaffiliated third parties, as permitted by law, who require such information to complete your transaction.
We also may disclose some of the personal information we collect to service providers, companies that perform marketing and analytics services on our behalf, or to other financial institutions
We may disclose personal information in response to service of legal process, such as a court order, summons, subpoenas, or as permitted or required by law when we reasonably believe it is necessary or appropriate to investigate, prevent, or take action regarding illegal activities, suspected fraud, situations involving potential threats to the physical safety of any person, or violations of our customer agreements.

Information about our customers, including personal information, may be disclosed or transferred to entities now or in the future affiliated with Spruce or as part of any merger, acquisition, change of control, debt financing, insolvency, bankruptcy or sale of our assets. Such information may be used in the businesses of any entity so receiving it.

Last, we may disclose personal information in specific other cases with your consent
Your information may be transferred to another country for processing. Consistent with our policy, we will seek consent for the transfer or rely on another lawful basis if that is required under applicable law with respect to that transfer. Those other bases may include: where the relevant regulator has determined that the country to which the data will be transferred provides an adequate level or legal protection for personal data, where an approved legal mechanism is in place to affect such transfers, or where you have provided your consent.

7. Protection Of Personal Information

Spruce works diligently to protect your personal information. We employ safeguards to keep your information safe. We use our best efforts to use the strongest available browser encryption, store all of our data on servers in secure facilities, and implement systematic processes and procedures for securing and storing data. We limit access to your personal and financial information to only those employees with authorized access. Furthermore, if you choose to terminate your account or your account is terminated with us, we will continue to adhere to the privacy policies and practices outlined here. If you maintain a Spruce account that you access through our website, you are responsible for protecting and maintaining the confidentiality of your account and password and restricting access to your computer.

8. Children

Our service is not directed towards anyone under the age of 18. We do not knowingly collect Personal Information from individuals under the age of 18. If we become aware at any point that a child under the age of 18 is using our service, we will terminate his or her account.

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9. International Visitors

Our website and services are hosted in the United States. If you are an international visitor, you should note that by providing your personal information, you are: (i) permitting the transfer of your personal information to the United States which may not have the same data protection laws as the country in which you reside; and (ii) permitting the use of your personal information in accordance with this privacy policy.

10. California Privacy Rights

Spruce does not share your email address with any third parties for third party marketing purposes. However, should the company choose to do so, residents of California have the right to request from us certain information with respect to the types of personal information we share with third parties for those third parties’ direct marketing purposes and the identities of the third parties with whom the business has shared such information during the immediately preceding calendar year. To exercise your rights, you may make one request each year by emailing us at support@spruce.co. Your request should specify your full name and the email address you used when submitting personal information to us. Please allow up to thirty (30) days for a response.

11. Vermont Privacy Rights

Spruce does not share nonpublic personal financial information information we collect about Vermont residents to non-affiliated third parties except for our everyday business purposes or as otherwise permitted by law. If you wish to revoke any authorization to share your nonpublic personal financial information, which you have provided to us by entering into our Customer Agreement, please contact us at support@spruce.co. Please note, however, that we will not be able to provide you with services through Spruce without the ability to share this financial information.

12. Changes To The Policy

We may modify this privacy policy over time by posting a new version of this privacy policy, which is your responsibility to review. Any changes to the privacy policy will be reflected on this page and will become effective immediately upon posting. We encourage you to periodically review this privacy policy to stay informed about how we are protecting the personal information we collect. Please check the effective date above to determine if there have been any changes since you have last reviewed the Spruce privacy policy.
This Privacy Policy was last updated on January 29, 2020.