Doma Academy

Privacy Policy

Last Updated: August 11, 2022

This privacy policy describes how Doma Holdings, Inc. and its subsidiaries and affiliates (together referred to as “Doma,” “we,” “us,” or the “Company”) collects, aggregates, stores, safeguards and uses the data and information (including non-public personal information, or “NPI”) provided by users through our websites www.doma.com,  www.natic.com, and www.naticu.com (collectively, the “Site”), as well as personal information collected by us through other means, including by email, over the phone, in offline communications, and from third parties (“Policy”). The Site is operated by the Company and has been created to provide information about our company, products, and services (together, the “Services”). 

We take your privacy and the security of your information seriously.

This policy explains:

  • What information we collect, and how we use it
  • Choices you can make about the way your information is collected and used
  • How we protect your information

This Policy applies to all your personal information that we process when you use our products and services, visit our Site, use our customer support, or otherwise interact with Doma.  Individuals who reside in certain jurisdictions may have additional rights under applicable privacy laws, as explained below.  This Privacy Policy does not address our privacy practices with respect to the personal information of our employees, job applicants, contractors, or service providers.

This Policy is incorporated into and a material term of your registration and/or use of Doma’s products and services, including the Site. By using the Site or the Services, you consent to the practices set forth in this Policy.

Information We Collect

We collect personal and/or business information to operate effectively and provide you with the best experiences with our Sites and services. As described in further detail below, you provide some of this information directly, such as when you contact us. We also collect some of your information, such as your IP address, automatically when you visit and use our Sites and services. We also may receive information about you from third parties.

Information About You

Doma collects information from and about you when you choose to provide it to us through the Site or through any other means. The most common of these circumstances where you would provide personal information include the following:

  • when we create an account for you on the Site and services
  • when you register for or request products or services
  • when you apply for and receive Doma products or services.  We may collect your personal information, for example, when you apply for insurance, apply for financing, give us your contact information, provide your mortgage information, or show your government-issued ID.  We also collect your personal information from others, such as credit bureaus, lenders, affiliates or other companies.
  • when you sign up for newsletters or our email lists
  • when you request information from us, use our Site, or otherwise contact us  

The information we collect may include your name, address, email address, telephone or mobile phone number, job title, employer name, social security number, income, transaction history, payment history, purchase history, account balances, and our communications with you.

Information We Automatically Collect

We may use cookies or other technologies to automatically collect certain information when you visit our Site or interact with our emails. For example, if you are responding to an offer, promotional email or other email from us, we may automatically populate your personal information into our system once you enter your offer code or similar identifying device or otherwise accept your offer or promotion. Additionally, we may automatically collect certain non-personal information from you such as your browser type, operating system, software version, and Internet Protocol (“IP”) address. We also may collect information about your use of the Site, including the date and time of access, the areas or pages that you visit, the amount of time you spend using the Site, the number of times you return, whether you open, forward, or click-through emails, and other Site usage data.  We use Google Analytics to collect information.  You can learn about how Google Analytics collects and processes data here.

You may adjust your browser or operating system settings to limit this tracking or to decline cookies, but by doing so, you may not be able to use certain features on the Site or take full advantage of all of our offerings. Check the “Help” menu of your browser or operating system to learn how to adjust your tracking settings or cookie preferences. Please note that our system may not respond to Do Not Track requests or headers from some or all browsers.

Sensitive Information

Unless we specifically request or invite it, we ask that you not send or otherwise disclose to us your racial or ethnic origin, political opinions, religion or other beliefs, health, criminal background, or trade union membership.  In those cases where we may request or invite you to provide the foregoing information, we will only do so with your express consent, in accordance with applicable data protection law requirements.  Where you provide us with such information without request from Doma, we reserve the right (but do not have any obligation) to erase any such information at our discretion.

How We Use Information We Collect

Doma uses the data and information about you in a manner that is consistent with this Policy, our Terms of Service, and applicable law. We may process your personal information for the following purposes:

  • Performing and managing the contract we have with you or the company you are associated with; 
  • Managing our relationship with you;
  • Communicating with you;
  • Sending you marketing and promotional materials about our products or services or promotions; and
  • Complying with our legal obligations. 

Furthermore, if you provide personal information for a certain reason, we may use the personal information in connection with the reason for which it was provided. For instance, if you contact us by email, we will use the personal information you provide to answer your question or resolve your problem. Also, if you provide personal information in order to obtain access to the Site or the Services, we will use your personal information to provide you with access to such services and to monitor your use of such services. 

Doma may also use your personal information and other personally non-identifiable information to help us improve the content and functionality of the Site or the Services, to better understand our users and to improve the Site and the Services. 

Doma and its affiliates may use your information to contact you in the future to tell you about services we believe will be of interest to you. If at any time you wish not to receive any future marketing communications or you wish to have your name deleted from our mailing lists, please contact us as indicated below.

Sharing Of Information We Collect

Doma does not sell your information.  There are, however, certain circumstances in which we may share your personal information with certain third parties without further notice to you, as set forth below:

Agents, Consultants and Third-Party Service Providers:

Doma, like many businesses, sometimes hires other companies to perform certain business-related functions. Examples of such functions include mailing information, website hosting, maintaining databases and processing payments. When we employ another entity to perform a function of this nature, we only provide them with the information that they need to perform their specific function.

Business Transfers:

As we develop our business, we might sell or buy businesses or assets. In the event of a corporate sale, merger, reorganization, dissolution or similar event, personal information may be part of the transferred assets.

Related Companies:

We may also share your personal information with our corporate affiliates and subsidiaries, if any, for purposes consistent with this Policy.

Legal Requirements:

Doma may disclose your personal information if required to do so by law or in the good faith belief that such action is necessary to (i) comply with a legal obligation, (ii) protect and defend the rights or property of Doma, (iii) act in urgent circumstances to protect the personal safety of users of the Site, the Services or the public, or (iv) protect against legal liability.

Aggregated and Non-personal Information:

We may share aggregated and non-personal information we collect under any of the circumstances set forth in this Policy. We may combine non-personal information we collect with additional non-personal information collected from other sources. We also may share aggregated information with third parties.

Privacy Notice:

Please see our Privacy Notice, which is incorporated by reference into this Privacy Policy.

Links To Other Websites

The Site may have links to third-party websites that do not operate under this Policy.  We encourage you to review the privacy policies of all third-party websites you visit to understand their privacy practices. We are not responsible for the practices of such sites, nor does any such link imply that Doma endorses or has reviewed the third-party site subject to such link. We suggest contacting those sites directly for information on their privacy policies.

Data Security

We have taken certain physical, administrative, and technical steps to safeguard the information we collect from and about our customers and Site visitors. While we make reasonable efforts to help ensure the integrity and security of our network and systems, we cannot guarantee our security measures.  Therefore, you should take special care in deciding what information you send to us via email. Please keep this in mind when disclosing any personal information to the Company via the Internet.

Data Retention

We will retain your personal information for the period necessary to fulfill the purposes outlined in this Policy and as long as you are an active member unless a longer retention period is required or permitted by law or defined in an agreement. We may retain personal information for longer where required by our regulatory obligations or professional indemnity obligations, or where we believe it is necessary to establish, defend or protect our legal rights and interests or those of others.

We will also retain usage data for internal analysis, to strengthen the security, or to improve the functionality of our Sites and services.

Access To Your Personal Information

You may request to access, review, update, amend, have deleted, or otherwise exercise your rights under applicable privacy laws over your personal information that we collected or otherwise maintain subject to certain limitations under applicable privacy laws. You may submit a request to us by using the contact information provided at the end of this Policy.

To keep your personal information accurate, current, and complete, please contact us as specified below. We will take reasonable steps to update or correct personal information in our possession that you have previously submitted via the Services or the Services.

Opt-Out

You may be given a choice as to whether you want to receive marketing or promotional e-mails or newsletters from us. At any time you can choose to no longer receive marketing or promotional emails or newsletters from us by modifying your email preferences by selecting the “Opt-Out” link found in the footer of the communication. You may modify your choice at any time by using the “Opt-Out” link as described above. It may take up to 10 business days for us to process an opt-out request. Please note that opting out of receipt of promotional email communications will only affect future activities or communications from us. If we have already provided your information to a third party before you have changed your preferences or updated your information, you may have to change your preferences directly with that third party.

Even if you opt-out of receiving marketing or promotional communications, you may continue to receive other types of transactional and relationship e-mail communications, such as sending you a survey you have elected to participant in.

Children And Minors

Doma does not knowingly collect personal information from minors under the age of 18. If you are under the age of 18, please do not submit any personal information through the Site or the Services. We encourage parents and legal guardians to monitor their children’s Internet usage and to help enforce our Policy by instructing their children never to provide personal information without their permission. If you have reason to believe that a minor under the age of 18 has provided personal information to Doma through the Site or the Services, please contact us, and we will endeavor to delete that information from our databases.

Information For California Residents

In this section, we provide information for California residents as required under California privacy laws, including the California Consumer Privacy Act (the “CCPA”), which requires that we provide California residents certain specific information about how we handle their personal information.

Categories of personal information that we collect and disclose. Our collection, use and disclosure of personal information about a California resident will vary depending upon the circumstances and nature of our interactions or relationship with such resident. The Section above entitled “Information We Collect” sets out generally the categories of personal information (as defined by the CCPA) about California residents that we collect and disclose to others for a business purpose. We collect these categories of personal information from the sources described in the Section above entitled “Information We Collect,” and for the purposes described in the Section above entitled “How We Use Information We Collect.”

If you are a California resident, the CCPA grants you certain rights and imposes restrictions on particular business practices as set forth below:

  • Do-Not-Sell: California residents have the right to opt-out of the sale of their personal information. 
  • Initial Notice: We are required to notify California residents, at or before the point of collection of their personal information, the categories of personal information collected and the purposes for which such information is used.
  • Request to Delete: California residents have the right to request deletion of their personal information that we have collected about them and to have such personal information deleted, except where an exemption applies. We will respond to verifiable requests received from California residents as required by law. The instructions for submitting a verifiable Request to Delete are described below.
  • Request to Know: California residents have the right to request and, subject to certain exemptions, receive a copy of the specific pieces of personal information that we have collected, used, disclosed and sold about them in the prior 12 months and to have this delivered, free of charge, either (a) by mail or (b) electronically in a portable and, to the extent technically feasible, readily useable format that allows the individual to transmit this information to another entity without hindrance. California residents also have the right to request that we provide them certain information about how we have handled their personal information in the prior 12 months, including the:
    • categories of personal information collected;
    • categories of sources of personal information;
    • business and/or commercial purposes for collecting and selling their personal information;
    • categories of third parties with whom we have shared their personal information;
    • categories of personal information that we have sold in the preceding 12 months, and for each category identified, the categories of third parties to which we sold that particular category of information; and
    • categories of personal information disclosed for a business purpose in the preceding 12 months, and for each category identified, the categories of third parties to which we disclosed that particular category of personal information.
  • Right to non-discrimination: The CCPA prohibits discrimination against California residents for exercising their rights under the CCPA. Discrimination may exist where a business denies or provides a different level or quality of goods or services, or charges (or suggests that it will charge) different prices, rates, or penalties on residents who exercise their CCPA rights, unless doing so is reasonably related to the value provided to the business by the residents’ data.

If you are a California resident and would like to make a request to exercise your rights under the CCPA, please contact us as set forth in the Section below entitled “Contact Us.” Please allow forty-five days for a response.

An authorized agent can make a request on a California residents’ behalf by providing a power of attorney valid under California law, or providing: (1) proof that the consumer authorized the agent to do so; (2) verification of their own identity with respect to a right to know categories, right to know specific pieces of personal information, or requests to delete which are outlined above; and (3) direct confirmation that the consumer provided the authorized agent permission to submit the request.

We will respond to verifiable requests received from California residents as required by law. For more information about our privacy practices, you may contact us as set forth in the Section below entitled “Contact Us.”

Do Not Track Disclosure

We do not support Do Not Track browser settings and does not currently participate in any “Do Not Track” frameworks that would allow us to respond to signals or other mechanisms from you regarding the collection of your personal information.

We do not support Do Not Track browser settings and does not currently participate in any “Do Not Track” frameworks that would allow us to respond to signals or other mechanisms from you regarding the collection of your personal information.

Nondiscrimination

Please see our Privacy Notice, which is incorporated by reference into this Privacy Policy.

Sale of Information

We have not sold the personal information of California residents to any third party in the twelve months preceding the date this Policy was last updated, and we do not intend to sell such information in the future.

 

If you have questions

If you have any questions about this Policy or the practices described herein, you may contact us at: [email protected] or 1-866-929-7437.

Changes to this policy

Doma reserves the right to revise this Policy at any time. When we do, we will post the change(s) on the Site. This Policy was last updated on the date indicated above. You should regularly check this page for any changes to this Policy. Your continued use of the Site and the Services after any changes or revisions to this Policy shall indicate your agreement with the terms of such revised Policy.