Privacy Policy

Terrio AI, Inc. provides a title and closing workflow platform to real estate law firms, title agencies, and settlement companies. This Policy explains how we handle information across our website and platform.

1. Introduction and scope

This Privacy Policy ("Policy") describes how Terrio AI, Inc., a Delaware corporation ("Terrio," "we," "us," or "our"), collects, uses, discloses, retains, and safeguards information in connection with (a) our websites that link to this Policy (the "Sites") and (b) our software platform and related services provided to our business customers (the "Platform," and together with the Sites, the "Services").

Our business customers are real estate law firms, title agencies, and settlement service providers (each, a "Firm"). This Policy applies to information we process both as a business/controller and, separately, in our capacity as a service provider/processor acting on behalf of a Firm. Section 3 explains this distinction, which determines your rights and the appropriate point of contact.

2. Definitions

• "Personal Information" means information that identifies, relates to, describes, or is reasonably capable of being associated with a particular individual or household, as defined under applicable law.
• "Sensitive Personal Information" or "Nonpublic Personal Information" ("NPI") means Personal Information warranting heightened protection, including government identifiers (such as Social Security and taxpayer identification numbers), financial-account and payment information, government-issued identification, and date of birth.
• "Transaction Data" means the documents, records, and data comprising a Firm's real estate closing file that a Firm submits to, or authorizes Terrio to receive for, processing through the Platform, which may include Personal Information and NPI of the Firm's clients and transaction counterparties.
• "Process" (and "Processing") means any operation performed on information, including collection, use, storage, disclosure, and deletion.

3. Our role: controller and service provider

Terrio as service provider / processor. The substantial majority of Personal Information Terrio handles is Transaction Data that a Firm provides or authorizes us to receive so that we may process that Firm's closings. With respect to Transaction Data, the Firm is the business/controller and Terrio acts as its service provider/processor. We Process Transaction Data solely to perform the Services pursuant to our written agreement with the Firm and in accordance with the Firm's documented instructions. We do not "sell" or "share" Transaction Data (as those terms are defined under applicable law), and we do not use Transaction Data for our own commercial purposes, including advertising.

If you are an individual party to a real estate transaction (for example, a buyer, seller, or borrower) and you wish to exercise rights with respect to your Personal Information, please contact the Firm handling your transaction, which is the controller of that information. We will provide reasonable assistance to the Firm in responding to your request.

Terrio as business / controller. With respect to the Sites and to information about Firm personnel, account administrators, and prospective customers, Terrio acts as the business/controller and Processes such information as described in this Policy.

4. Categories of information we collect

We do not intentionally collect Personal Information from children under 16, and the Services are not directed to children.

5. Sources of information

We collect information (a) directly from Firms and Firm personnel; (b) from individuals who interact with the Sites or submit forms; (c) from third-party systems and service providers that a Firm authorizes us to access; and (d) automatically through cookies and similar technologies on the Sites, as described in Section 11.

6. How we use information

• to provide, operate, maintain, secure, and improve the Services;
• to open and administer closing files, coordinate third-party orders, identify and flag compliance matters, and prepare work product, on behalf of and at the direction of the applicable Firm;
• to authenticate users and administer Firm accounts;
• to communicate regarding the Services, including support, security, and administrative notices, and to market the Services to Firms and other business audiences;
• to detect, investigate, and prevent fraud, security incidents, and misuse; and
• to comply with applicable legal obligations and to establish, exercise, or defend legal claims.

We do not use Transaction Data to create advertising or marketing profiles, and we do not sell Personal Information.

7. Data minimization and handling of sensitive information

• No NPI by unsecured channels. NPI is Processed within the secured Platform or transmitted through approved secure-transfer channels; Terrio does not transmit NPI through ordinary electronic mail.
• No role in the movement of funds. Terrio does not send, receive, hold, disburse, or reconcile closing funds, and does not compose or transmit wire instructions. Terrio is not a trust-accounting service, escrow agent, or tax-filing or withholding agent; those functions remain with the Firm and its selected providers.
• Need-to-know limitation. We limit the Personal Information included in notifications and communications to that which is necessary for the applicable task.

8. Automated processing and artificial intelligence

The Platform uses automated processing, including artificial-intelligence technologies, to assist in extracting, organizing, drafting, and reviewing Transaction Data. Where we engage third-party artificial-intelligence providers, we do so under contractual terms that prohibit the use of Terrio's or a Firm's data to train the provider's models, and we do not use Firm Transaction Data to train artificial-intelligence models. Automated output is subject to review within the Firm's workflow, and the certifying attorney or licensed professional retains responsibility for the resulting work product.

9. How we disclose information

We disclose information only as necessary to provide the Services and as described below. We do not sell Personal Information, and we do not share Personal Information for cross-context behavioral advertising.

• Subprocessors and service providers. We engage service providers to host and support the Platform under written contracts that require appropriate confidentiality and security protections and that restrict their use of information to the provision of services to us. Our subprocessors currently include Microsoft Azure (cloud infrastructure, United States), Anthropic (artificial-intelligence processing), and Microsoft (electronic-mail delivery). A current list of subprocessors is made available to Firms upon request.
• At a Firm's direction. We disclose Transaction Data to third parties designated by the Firm, such as secure-transfer, electronic-recording, and title-service vendors.
• Legal, compliance, and safety. We may disclose information where we believe in good faith that disclosure is required by law or legal process, or is necessary to protect the rights, property, or safety of Terrio, our Firms, or others.
• Corporate transactions. We may disclose information in connection with a merger, acquisition, financing, or sale of assets, subject to the recipient's continued protection of the information consistent with this Policy.

10. Information security

We maintain administrative, technical, and physical safeguards designed to protect information against unauthorized access, use, alteration, and destruction, including tenant isolation (each Firm's data logically segregated with database-level access controls), encryption in transit and at rest with additional field-level encryption for designated sensitive data, access controls and logging (including logging of access to sensitive information and a tamper-evident audit record of activity on a matter), malware and content scanning of ingested files, and centralized secrets management using a managed key vault. No system of transmission or storage can be guaranteed to be perfectly secure. We will notify affected parties of a security incident to the extent required by applicable law.

11. Cookies and analytics

The Sites use cookies and similar technologies to enable core functionality, to remember your preferences, and to measure and improve the performance of the Sites and of our marketing. Our marketing is directed to Firms and other business audiences, not to individual consumers, and we do not use cookies to engage in cross-context behavioral advertising directed to individual consumers. You can control cookies through your browser settings. Where required by applicable law, we will present a cookie notice and obtain consent for non-essential cookies.

12. Data retention

We retain Transaction Data for the period necessary to provide the Services and as instructed by the applicable Firm, and thereafter as required to satisfy legal, regulatory, and records-retention obligations applicable to real estate and title records. Retention periods are configurable at the Firm level and are set by default to a multi-year period consistent with applicable statutory requirements. We delete or de-identify information when it is no longer required for these purposes.

13. International data transfers

The Services are operated in the United States. If you access the Services from outside the United States, you understand and agree that your information will be transferred to, and Processed in, the United States, which may have data-protection laws that differ from those of your jurisdiction.

14. Your rights and choices

Depending on your jurisdiction, you may have rights with respect to your Personal Information, including the rights to access, correct, delete, obtain a copy of, or restrict or object to certain Processing, and to be free from unlawful discrimination for exercising these rights.

• Individuals party to a transaction. Because we Process your Personal Information as a service provider/processor on behalf of the Firm handling your transaction, please direct rights requests to that Firm. We will provide reasonable assistance to the Firm in fulfilling verified requests.
• Firm personnel and Site users. You may submit a request using the contact information below. We will verify and respond to your request as required by applicable law. You may use an authorized agent where permitted by law.

We do not sell Personal Information or share it for cross-context behavioral advertising, and therefore do not offer an opt-out of such activities.

15. Changes to this Policy

We may update this Policy from time to time. If we make material changes, we will post the revised Policy with an updated "Last updated" date and, where appropriate, provide notice to Firms. Your continued use of the Services following the effective date of a revised Policy constitutes acceptance.

16. Contact us