Privacy Policy

June 27, 2006

At First American Title Holding Company, we recognize that privacy is important. This Policy applies to all websites offered by First American Title Holding Company. First American Title Holding Company adheres to the US safe harbor privacy principles of Notice, Choice, Onward Transfer, Security, Data Integrity, Access and Enforcement.

Information we collect and how we use it

We offer a number of services that do not require you to register for an account or provide any personal information to us. However, in order to provide our full range of services, we may collect the following types of information:

Information you provide - When you sign up for a First American Title Holding Company service or promotion that requires registration, we ask you for personal information (such as your name, email address, and address information). For certain services, we may give you the opportunity to opt out of combining such information.

Log information - When you use First American Title Holding Company services, our servers automatically record information that your browser sends whenever you visit a website. These server logs may include information such as your web request, Internet Protocol address, browser type, browser language, the date and time of your request and one or more cookies that may uniquely identify your browser.

User communications - When you send email or other communication to First American Title Holding Company, we may retain those communications in order to process your inquiries, respond to your requests and improve our services.

Other sites - This Privacy Policy applies to web sites and services that are owned and operated by First American Title Holding Company. We do not exercise control over the sites displayed as search results or links from within our various services. These other sites may place their own cookies or other files on your computer, collect data or solicit personal information from you.

First American Title Holding Company only processes personal information for the purposes described in the applicable Privacy Policy and/or privacy notice for specific services. In addition to the above, such purposes include:

• Providing our products and services to users, including the display of customized content and advertising
• Auditing, research and analysis in order to maintain, protect and improve our services
• Ensuring the technical functioning of our network
• Developing new services

Choices for personal information

When you sign up for a particular service that requires registration, we ask you to provide personal information. If we use this information in a manner different than the purpose for which it was collected, then we will ask for your consent prior to such use.

If we propose to use personal information for any purposes other than those described in this Policy and/or in the specific service notices, we will offer you an effective way to opt out of the use of personal information for those other purposes. We will not collect or use sensitive information for purposes other than those described in this Policy and/or in the specific service notices, unless we have obtained your prior consent.

You can decline to submit personal information to any of our services, in which case First American Title Holding Company may not be able to provide those services to you.

Information sharing

First American Title Holding Company only shares personal information with other companies or individuals outside of First American Title Holding Company in the following limited circumstances:

• We have your consent. We require opt-in consent for the sharing of any sensitive personal information.
• We provide such information to our subsidiaries, affiliated companies or other trusted businesses or persons for the purpose of processing personal information on our behalf. We require that these parties agree to process such information based on our instructions and in compliance with this Policy and any other appropriate confidentiality and security measures
• We have a good faith belief that access, use, preservation or disclosure of such information is reasonably necessary to (a) satisfy any applicable law, regulation, legal process or enforceable governmental request, (b) enforce applicable Terms of Service, including investigation of potential violations thereof, (c) detect, prevent, or otherwise address fraud, security or technical issues, or (d) protect against imminent harm to the rights, property or safety of First American Title Holding Company, its users or the public as required or permitted by law.

If First American Title Holding Company becomes involved in a merger, acquisition, or any form of sale of some or all of its assets, we will provide notice before personal information is transferred and becomes subject to a different privacy policy.

Information security

We take appropriate security measures to protect against unauthorized access to or unauthorized alteration, disclosure or destruction of data. These include internal reviews of our data collection, storage and processing practices and security measures, as well as physical security measures to guard against unauthorized access to systems where we store personal data.

We restrict access to personal information to First American Title Holding Company employees, contractors and agents who need to know that information in order to operate, develop or improve our services. These individuals are bound by confidentiality obligations and may be subject to discipline, including termination and criminal prosecution, if they fail to meet these obligations.

Data integrity

First American Title Holding Company processes personal information only for the purposes for which it was collected and in accordance with this Policy or any applicable service-specific privacy notice. We review our data collection, storage and processing practices to ensure that we only collect, store and process the personal information needed to provide or improve our services. We take reasonable steps to ensure that the personal information we process is accurate, complete, and current, but we depend on our users to update or correct their personal information whenever necessary.

Accessing and updating personal information

When you use First American Title Holding Company services, we make good faith efforts to provide you with access to your personal information and either to correct this data if it is inaccurate or to delete such data at your request if it is not otherwise required to be retained by law or for legitimate business purposes. We ask individual users to identify themselves and the information requested to be accessed, corrected or removed before processing such requests, and we may decline to process requests that are unreasonably repetitive or systematic, require disproportionate technical effort, jeopardize the privacy of others, or would be extremely impractical (for instance, requests concerning information residing on backup tapes), or for which access is not otherwise required. In any case where we provide information access and correction, we perform this service free of charge, except if doing so would require a disproportionate effort. Some of our services have different procedures to access, correct or delete users' personal information. We provide the details for these procedures in the specific privacy notices or FAQs for these services.

Enforcement

First American Title Holding Company regularly reviews its compliance with this Policy. Please feel free to direct any questions or concerns regarding this Policy or First American Title Holding Company's treatment of personal information by contacting us through this web site or by writing to us at Privacy Matters, c/o First American Title Holding Company Inc., 168 West Pacific, P.O. Box 868, Blackfoot, ID, 83221, USA. When we receive formal written complaints at this address, it is First American Title Holding Company's policy to contact the complaining user regarding his or her concerns. We will cooperate with the appropriate regulatory authorities, including local data protection authorities, to resolve any complaints regarding the transfer of personal data that cannot be resolved between First American Title Holding Company and an individual.

Changes to this policy

Please note that this Privacy Policy may change from time to time. We will not reduce your rights under this Policy without your explicit consent, and we expect most such changes will be minor. Regardless, we will post any Policy changes on this page and, if the changes are significant, we will provide a more prominent notice (including, for certain services, email notification of Policy changes). Each version of this Policy will be identified at the top of the page by its effective date, and we will also keep prior versions of this Privacy Policy in an archive for your review.

If you have any additional questions or concerns about this Policy, please feel free to contact us any time through this web site or at Privacy Matters, c/o First American Title Holding Company Inc., 168 West Pacific, P.O. Box 868, Blackfoot, ID, 83221, USA.