NotaryTrue

1. Introduction and Who We Are

NotaryTrue, Inc. ("NotaryTrue," "we," "us," or "our") is a Remote Online Notarization (RON) and electronic closing platform incorporated in Delaware and headquartered in Los Angeles, California. We operate notarytrue.com and the NotaryTrue platform (collectively, the "Services"), which are designed to facilitate compliant RON closings for title companies, escrow officers, mortgage lenders, notaries, and property transaction signers.

This Privacy Policy describes how we collect, use, store, share, and protect personal information when you visit our website, request a demo, create an account, or participate in a notarization or electronic closing session through our platform.

By accessing or using the Services, you acknowledge that you have read and understood this Privacy Policy. If you do not agree, please do not use the Services.

2. Scope and Who This Policy Covers

This Privacy Policy applies to the following categories of individuals whose personal information we process:

• Title company clients and escrow officers who access the platform on behalf of their organization (B2B users)
• Property transaction signers and buyers/sellers who participate in RON or eClosing sessions (B2C users)
• Commissioned notaries who use NotaryTrue to conduct RON sessions
• Website visitors and individuals who request a demo or contact us through notarytrue.com

This policy does not apply to information processed by third-party platforms or services that you access independently, even if linked from our website.

3. Information We Collect

3.1 Information You Provide Directly

Identity & Contact Data: Contact and account information:

• Name, email address, phone number, company name, job title, and mailing address
• Username, password, and account preferences
• Demo request information including estimated monthly closing volume

Identity Verification Data: Government-Issued Identity Documents:

• Driver's license, state-issued ID, or passport used to satisfy RON identity-proofing requirements under applicable state law
• Knowledge-Based Authentication (KBA) responses — answers to dynamic identity verification questions generated from public records
• Selfie or facial image captured during liveness verification

Payment Data: Payment and billing information:

• Credit card or ACH bank account details processed through our PCI-compliant payment processor
• Billing address and transaction history

3.2 Biometric Data

IMPORTANT — BIOMETRIC DATA NOTICE: As part of the identity verification process required for RON compliance, NotaryTrue collects and processes biometric identifiers, including:

• Facial geometry data extracted during liveness detection and biometric face-matching procedures
• Liveness verification data used to confirm that the identity verification session involves a live human being

Biometric data is collected only when you participate in a notarization or identity verification session on the platform. We do not use biometric data for any purpose other than identity verification and RON compliance. Biometric data is not sold, leased, traded, or profited from. Biometric data is destroyed no later than the earlier of (a) three years after the date of collection, or (b) upon fulfillment of the purpose for which it was collected, consistent with applicable state law retention requirements.

3.3 Session Recording Data

State RON statutes require that audio-video recordings of notarization sessions be retained for a minimum period specified by the notary's commissioning state (commonly 5 to 10 years). NotaryTrue retains these recordings in a secure eVault on your behalf and in compliance with applicable law. Recordings are not used for advertising or marketing purposes.

3.4 Information Collected Automatically

When you visit our website or use the platform, we automatically collect:

• Device identifiers, IP address, browser type and version, operating system
• Usage data: pages visited, features accessed, session duration, click paths
• Cookie and tracking data as described in Section 8
• Log data: server logs, error reports, and performance data

3.5 Information from Third Parties

We may receive information about you from:

• Title production systems (such as SoftPro, ResWare, or Qualia) that transmit closing order data to NotaryTrue through API integration
• Identity verification service providers who perform KBA and credential analysis on our behalf
• Payment processors who return transaction confirmation data
• Public records databases used to generate KBA questions

4. How We Use Your Information

We use the information we collect for the following purposes:

4.1 Platform Operations and Service Delivery

• Creating and managing user accounts for title company clients, notaries, and signers
• Processing closing orders and routing transactions through the RON workflow
• Performing identity verification and KBA as required by applicable state RON statutes
• Facilitating live audio-video notarization sessions
• Applying electronic notarial seals and maintaining the electronic notary journal
• Submitting documents for electronic recording with county recorders
• Syncing completed closing packages back to title production systems

4.2 Compliance and Legal Obligations

• Retaining session recordings, audit logs, and notary journal entries as required by state RON law
• Maintaining records sufficient to demonstrate MISMO data standards compliance
• Meeting ALTA Best Practices Pillar 3 data security and NPI protection obligations
• Responding to lawful requests from regulatory authorities, courts, or law enforcement
• Detecting and preventing fraud, unauthorized access, and identity theft

4.3 Business Operations

• Processing payments and managing billing relationships with title company clients
• Providing customer support and responding to inquiries
• Sending transactional communications (closing confirmations, session reminders, account notifications)
• Communicating about platform updates, new features, and service changes

4.4 Analytics and Platform Improvement

• Analyzing aggregated, de-identified usage data to improve platform performance and reliability
• Identifying and resolving technical issues
• Conducting internal research to develop new features

5. Legal Basis for Processing

We process your personal information on the following legal grounds:

• Contract performance: Processing necessary to deliver the Services you have requested or to fulfill our contractual obligations to title company clients
• Legal obligation: Processing required to comply with applicable state RON statutes, federal law (including Gramm-Leach-Bliley Act / GLBA), and regulatory requirements
• Legitimate interests: Processing for fraud prevention, platform security, and service improvement, where these interests are not overridden by your rights
• Consent: Where required by applicable law, we obtain your explicit consent before collecting biometric data or placing non-essential cookies

6. How We Share Your Information

We do not sell your personal information. We share personal information only in the following circumstances:

6.1 Service Providers

We share information with third-party vendors who process data on our behalf under written data processing agreements, including:

• Identity verification and KBA providers
• Cloud infrastructure and eVault storage providers
• Payment processors (PCI-DSS compliant)
• Electronic recording submission services
• Customer support and communication tools

All service providers are contractually prohibited from using your information for any purpose other than providing services to NotaryTrue.

6.2 Title Company Clients

If you participate in a notarization session arranged through a title company that uses NotaryTrue, we share closing data, session recordings, audit logs, and signed documents with that title company as part of the contracted service. The title company's own privacy practices govern their subsequent use of that information.

6.3 Legal and Regulatory Disclosures

We may disclose personal information when required by law, court order, subpoena, or lawful government request; to enforce our Terms of Service; or to protect the rights, safety, or property of NotaryTrue, our users, or the public.

6.4 Business Transfers

In the event of a merger, acquisition, financing, reorganization, or sale of assets, personal information may be transferred to the acquiring entity. We will provide notice before personal information is transferred and becomes subject to a different privacy policy.

7. Data Retention

We retain personal information for as long as necessary to fulfill the purposes described in this policy and to comply with applicable law:

• Session recordings and notary journal entries: retained for the period required by the notary's commissioning state RON statute (typically 5 to 10 years)
• Government-issued ID and KBA data: retained for the duration of the transaction plus any legally required retention period, then securely deleted
• Biometric data: destroyed no later than three years from the date of collection or upon completion of the purpose for which it was collected, whichever is earlier
• Account data: retained for the life of the account, plus a reasonable period after account closure to resolve disputes and comply with legal obligations
• Payment records: retained as required by tax and financial regulations (typically 7 years)
• Website analytics: retained in aggregated, de-identified form

8. Cookies and Tracking Technologies

We use cookies and similar technologies on notarytrue.com for the following purposes:

• Strictly necessary cookies: Required for platform functionality (session management, authentication, security). These cannot be disabled.
• Analytics cookies: Used to understand how visitors interact with our website (e.g., Google Analytics). These are enabled only with your consent where required.
• Marketing cookies: We do not use third-party advertising or behavioral tracking cookies on our platform.

You can manage cookie preferences through your browser settings or through any cookie consent tool presented on the website. Disabling non-essential cookies will not affect your ability to use the core platform.

9. Data Security

NotaryTrue implements administrative, technical, and physical safeguards designed to protect your personal information against unauthorized access, disclosure, alteration, or destruction. Our security program includes:

• Encryption of data in transit (TLS 1.2 or higher) and at rest (AES-256)
• Multi-factor authentication (MFA) for all administrative and platform access
• Role-based access controls limiting employee access to personal data
• Regular vulnerability assessments and security monitoring
• Incident response procedures consistent with applicable breach notification laws
• Written Information Security Plan (WISP) aligned with ALTA Best Practices Pillar 3

While we take reasonable measures to protect your information, no security system is impenetrable. In the event of a data breach affecting your personal information, we will notify you as required by applicable law.

10. Additional Rights for California Residents (CCPA/CPRA)

If you are a California resident, you have the following rights under the California Consumer Privacy Act (CCPA) as amended by the California Privacy Rights Act (CPRA):

10.1 Right to Know

You have the right to request that we disclose what personal information we have collected about you, the categories of sources, the purposes for collection, and the categories of third parties with whom we share it.

10.2 Right to Delete

You have the right to request deletion of personal information we have collected about you, subject to certain exceptions (including our obligation to retain records required by RON statutes and other applicable law).

10.3 Right to Correct

You have the right to request correction of inaccurate personal information we maintain about you.

10.4 Right to Opt Out of Sale or Sharing

NotaryTrue does not sell your personal information and does not share personal information for cross-context behavioral advertising. You therefore have no need to opt out, but you may contact us to confirm.

10.5 Right to Limit Use of Sensitive Personal Information

You have the right to limit our use of sensitive personal information — including government-issued ID, biometric data, and precise geolocation — to purposes reasonably necessary and proportionate to the service. We use sensitive personal information only for the purposes described in this policy and do not use it for inferring characteristics or for advertising.

10.6 Right to Non-Discrimination

We will not discriminate against you for exercising your CCPA/CPRA rights.

10.7 Categories of Personal Information Collected (CCPA Categories)

In the past 12 months, we have collected the following categories of personal information:

• Identifiers (name, email address, IP address, device identifiers)
• Categories of personal information listed in Cal. Civ. Code § 1798.80(e) (name, signature, address, telephone number, employment information)
• Characteristics of protected classifications (not collected, except as may be incidentally captured in identity documents)
• Commercial information (transaction and payment records)
• Internet or other electronic network activity information (usage data, log data)
• Biometric information (facial geometry, liveness data)
• Audio, electronic, visual, or similar information (session recordings)
• Professional or employment-related information (company name, job title for B2B users)
• Sensitive personal information: government-issued ID, biometric identifiers

10.8 How to Submit a California Privacy Request

To exercise your CCPA/CPRA rights, contact us at:

Email: privacy@notarytrue.com
Mail: NotaryTrue, Inc., Attn: Privacy, 18960 Ventura Blvd. #490, Tarzana, Ca 91356

We will respond to verified requests within 45 days. We may extend this period by an additional 45 days when reasonably necessary and will provide notice of the extension. We will verify your identity before processing requests relating to sensitive or biometric data.

11. Children's Privacy

The NotaryTrue platform is not directed to individuals under the age of 18. We do not knowingly collect personal information from minors. If you believe we have inadvertently collected information from a minor, please contact us immediately at privacy@notarytrue.com and we will take prompt steps to delete that information.

12. Third-Party Links and Integrations

Our website and platform may contain links to third-party websites or integrate with third-party title production systems. This Privacy Policy does not apply to those third parties. We encourage you to review the privacy policies of any third-party services you use in connection with your NotaryTrue account.

13. Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our practices, technology, legal requirements, or for other operational reasons. When we make material changes, we will provide notice by posting the updated policy on notarytrue.com with a new effective date and, where appropriate, sending an email notification to account holders. Your continued use of the Services after any update constitutes acceptance of the revised policy.

14. Contact Us

If you have questions, concerns, or requests regarding this Privacy Policy or our data practices, please contact us:

NotaryTrue, Inc.
Attn: Privacy Compliance
Los Angeles, California
Email: privacy@notarytrue.com
Website: notarytrue.com

For California-specific inquiries, you may also contact our designated California Privacy Contact at the email address above, referencing "CCPA Request" in the subject line.