1. INTRODUCTION

Schedule Ventures Inc ("Schedule Ventures," "we," "our," or "us") is committed to protecting your privacy. This Privacy Policy describes how we collect, use, disclose, and safeguard your personal information when you:

• Visit our website at www.scheduleclosings.com (the "Website")

• Use our Schedule Closings marketplace platform (the "Platform")

• Interact with Affiliated Title Ventures, LLC d/b/a Venture Title ("ATV Title"), our sister company

• Contact us or use our services

This Privacy Policy applies to all users, including:

• Consumers searching for and booking closing services

• Attorneys listed on the Platform

• Real Estate Agents and Lenders using the Platform

• Licensees (title insurance companies licensing the Platform)

• JV Partners (joint venture partners with ATV Title)

• Website Visitors

Legal Basis for Processing (GDPR)

We process personal information under the following legal bases:

Legal Bases:

• Contract Performance:To provide services you've requested

• Legitimate Interests: To operate, improve, and secure our platform

• Legal Obligations: To comply with applicable laws

• Consent: Where you have provided explicit consent (which you may withdraw at any time)

2. DEFINITIONS

3. INFORMATION WE COLLECT

3.1 Information You Provide Directly

Website Visitors:

• Contact information (name, email, phone) when you contact us or subscribe to newsletters

• Attorney/firm information when applying to join the Platform (firm name, location, credentials, service areas)

• Any information you include in correspondence with us

Consumer Users:

• Account information (name, email, phone, address, username, password)

• Transaction details (property address, transaction type, closing date/time preferences)

• Payment information (processed by our payment processor Stripe)

• Communications preferences and text message consent

• Third-party authentication tokens (if using Google/Facebook login)

Platform Users (Attorneys, Agents, Lenders):

• Professional profile information (credentials, license numbers, firm details, service areas)

• Availability and scheduling preferences

• Calendar integration data (via Cronofy)

• Fee structures and service offerings

• Communications with other Platform users

• Performance metrics and reviews

Licensees and JV Partners:

• Business entity information (company name, EIN, address)

• Contact information for authorized representatives

• Billing and payment information

• Territory and routing preferences

• Order volume and transaction data

3.2 Information Collected Automatically

Usage Data:

• IP address and device identifiers

• Browser type and version

• Pages visited, time spent, referring URLs

• Operating system and device type

• Click patterns and navigation paths

• Platform feature usage and interaction data

Cookies and Tracking Technologies:

• Essential Cookies: Required for platform functionality (authentication, session management, security)

• Analytics Cookies: To understand usage patterns and improve services (Google Analytics)

• Preference Cookies: To remember your settings and preferences

You can manage cookies through your browser settings. Disabling essential cookies may limit platform functionality.

3.3 Information from Third-Party Sources

From Transaction Parties:

• Information shared by other parties to your transaction

• Documents uploaded to facilitate closings (deeds, affidavits, loan documents, title commitments)

• Nonpublic personal information governed by the Gramm-Leach-Bliley Act (see Section 10)

From Service Providers:

• Calendar data from Cronofy (for scheduling)

• Communication data from Twilio (for SMS notifications)

• Email delivery data from SendGrid

• Payment processing data from Stripe

• Authentication data from Google/Facebook (if applicable)

From Business Partners:

• Information from title underwriters (First American, Fidelity, Stewart, WFG, CATIC)

• Attorney network referrals and recommendations

3.4 Sensitive Personal Information

Under California law and GDPR, certain information receives heightened protection:

Sensitive Information Types:

• Social Security numbers (for identity verification and financing)

• Driver's license numbers (for identity verification)

• Financial account information (bank account/routing numbers)

• Precise geolocation data (if enabled for location-based services)

• Racial or ethnic origin, religious beliefs (only if voluntarily provided in Equal Housing forms)

We collect sensitive information only when necessary for transaction processing and subject to additional safeguards.

4. HOW WE USE YOUR INFORMATION

4.1 Primary Uses

To Provide Services:

• Create and manage your account

• Facilitate booking and scheduling of closing services

• Route orders to appropriate Licensees and attorneys

• Process payments and manage billing

• Send transaction notifications and updates

• Provide customer support

To Improve Our Platform:

• Analyze usage patterns and user behavior

• Develop new features and functionality

• Conduct quality assurance and testing

• Create aggregated, de-identified statistical data

To Communicate:

• Respond to inquiries and requests

• Send administrative messages and service updates

• Deliver marketing communications via email only (with consent - you may opt-out at any time)

• Conduct surveys and collect feedback

For Legal and Safety Purposes:

• Comply with legal obligations

• Enforce our Terms of Service

• Prevent fraud and unauthorized access

• Protect rights, property, and safety of users

• Resolve disputes and investigate complaints

4.2 Marketing Communications

We may send you marketing communications via email only:

Marketing Communications Include:

• Platform updates and feature announcements

• Educational content about real estate closings

• Promotional offers and special programs

• Newsletter (if subscribed)

You may opt-out of email marketing at any time by:

Opt-Out Methods:

• Clicking "unsubscribe" in any email

• Updating your account communication preferences

• Contacting privacy@scheduleclosings.com

We will continue to send essential service communications (transaction notifications, security alerts, legal notices) even if you opt-out of marketing.

4.3 Automated Decision-Making and Profiling

We use automated systems to:

Automated System Functions:

• Match consumers with appropriate attorneys based on location, availability, and preferences

• Route orders to Licensees based on territory assignments

• Detect and prevent fraudulent activity

• Personalize platform recommendations

These automated processes do not produce legal effects or similarly significantly affect you. You have the right to request human review of automated decisions under GDPR.

5. HOW WE SHARE YOUR INFORMATION

We share information with transaction parties, service providers, and as required by law. Your mobile phone number is NEVER shared with third parties for marketing purposes.

5.1 Within Our Organization

We share information between Schedule Ventures Inc and ATV Title as needed to provide coordinated services, process orders, improve platform functionality, and maintain legal compliance.

5.2 With Transaction Parties

We share relevant information with other parties to your transaction as necessary to facilitate closings. Important: Your mobile phone number is NEVER shared with transaction parties for marketing purposes.

5.3 With Service Providers

We share information with third-party vendors who perform services on our behalf, including Twilio (SMS), SendGrid (email), Stripe (payments), and AWS (hosting). All service providers are contractually prohibited from using your mobile phone number for marketing purposes.

5.4 For Legal and Business Purposes

We may share information to comply with legal requirements, enforce our Terms of Service, prevent fraud, and in connection with business transfers. We do NOT sell, rent, or share your mobile phone number with third parties for their marketing purposes.

6. YOUR PRIVACY RIGHTS

6.1 Rights Under GDPR (European Users)

If you are in the European Economic Area (EEA), UK, or Switzerland, you have rights including: access, rectification, erasure, restriction of processing, data portability, objection, withdrawal of consent, and the right to lodge a complaint with your local data protection authority.

6.2 Rights Under CCPA/CPRA (California Users)

California residents have rights including: right to know, right to delete, right to correct, right to opt-out of sale/sharing, right to limit use of sensitive personal information, and right to non-discrimination. We do not sell personal information.

6.3 Account Management

All users can access and update account information through platform settings, correct profile information, download transaction history, and deactivate accounts.

To exercise your privacy rights, contact: privacy@scheduleclosings.com

7. DATA RETENTION

We retain personal information for as long as necessary to provide services, comply with legal obligations, resolve disputes, and maintain business records.

Specific Retention Periods:

• Account Information: Duration of account plus 7 years after closure

• Transaction Data: 7 years after closing date

• Financial Records: 7 years (IRS and tax compliance)

• Marketing Data: Until you opt-out or 2 years of inactivity

8. DATA SECURITY

We implement industry-standard security measures including encryption, multi-factor authentication, secure password hashing, regular security audits, and access controls.

In the event of a data breach affecting your personal information, we will notify affected users without unreasonable delay and report to applicable regulatory authorities as required by law.

9. INTERNATIONAL DATA TRANSFERS

Schedule Ventures operates primarily in the United States. Your information may be transferred to, stored, and processed in the United States or other countries where our service providers operate.

For transfers from the EEA/UK/Switzerland, we use Standard Contractual Clauses (SCCs) and other appropriate safeguards.

10. SPECIAL PRIVACY CONSIDERATIONS

10.1 Gramm-Leach-Bliley Act (GLBA) Compliance

When ATV Title provides title insurance services, we collect and process nonpublic personal information regulated by GLBA. We do not share nonpublic personal information with non-affiliated third parties for marketing purposes.

10.2 Children's Privacy

Our services are not directed to individuals under 18 years of age. We do not knowingly collect personal information from children.

11. BUSINESS-SPECIFIC DISCLOSURES

This section contains specific disclosures for Consumers, Attorneys, Licensees, and JV Partners regarding how their information is used and shared in the context of their relationship with Schedule Closings.

12. CHANGES TO THIS PRIVACY POLICY

We may update this Privacy Policy from time to time. Material changes will be prominently posted on the platform, and we will email registered users about significant changes. The "Last Updated" date at the top indicates when changes were made.

13. CONTACT INFORMATION

Privacy Inquiries: privacy@scheduleclosings.com

Technical Support: support@scheduleclosings.com

Data Protection Officer (GDPR): dpo@scheduleclosings.com

We aim to respond to privacy rights requests within 45 days (may extend by 45 days if needed).

14. CALIFORNIA-SPECIFIC DISCLOSURES

14.1 Categories of Personal Information (Last 12 Months)

As required by CCPA/CPRA, we collected the following categories:

14.2 Retention Summary

We retain personal information for the periods described in Section 7, generally:

Retention Periods:

• Account data: Duration of account + 7 years

• Transaction data: 7 years

• Marketing data: Until opt-out or 2 years inactivity

14.3 Sale and Sharing

14.4 Sensitive Personal Information Use

We use sensitive personal information only for purposes permitted under CCPA/CPRA:

Permitted Purposes:

• Performing services requested

• Preventing fraud and ensuring security

• Complying with legal obligations

• Short-term, transient use

You have the right to limit use of sensitive personal information, though this may limit our ability to provide certain services.

15. EUROPEAN-SPECIFIC DISCLOSURES

15.1 Data Controller

Schedule Ventures Inc is the data controller for personal information collected through the Website and Platform.

For GLBA-regulated information, ATV Title is the data controller.

15.2 Legal Bases for Processing

15.3 Data Subject Rights

See Section 6.1 for complete GDPR rights information.

15.4 Supervisory Authority

If you are in the EEA, you have the right to lodge a complaint with your local data protection authority. Find your authority at: https://edpb.europa.eu/about-edpb/board/members_en

15.5 International Transfers

Data transfers from the EEA/UK/Switzerland are protected by Standard Contractual Clauses. Contact dpo@scheduleclosings.com for more information.

16. ADDITIONAL STATE DISCLOSURES

16.1 Virginia, Colorado, Connecticut, Utah

Residents of these states have rights similar to California residents under CCPA. Exercise your rights by contacting privacy@scheduleclosings.com.

16.2 Other States

As additional states enact comprehensive privacy laws, we will update this policy and provide required disclosures. Current information available at www.scheduleclosings.com/privacy.