ROI TITLE AGENCY ORDERS — PRIVACY POLICY

ROI Title Agency LLC | 1700 West Big Beaver Road Suite 220, Troy, MI 48084 | Phone: (248) 434-5179 Effective Date: June 10, 2026

This policy describes how ROI Title Agency LLC (“we,” “our”) collects, uses, protects, and shares information through the ROI Title Agency Orders mobile application (the “App”). The App is intended for real estate professionals and their clients who place and track title orders with us. Our federal Gramm-Leach-Bliley Act (GLBA) consumer privacy notice, prepared in accordance with the ALTA model form, separately governs nonpublic personal information collected in connection with title insurance transactions; this policy supplements — and does not replace — that notice.

INFORMATION THE APP COLLECTS

• Registration information: your name, company, professional role, mobile phone, and email address, together with a password credential managed by Google Firebase Authentication (we never see or store your password in readable form).

• Order information: transaction type, the party you represent, buyer/seller/borrower names, property address, file numbers, and notes you provide.

• Documents you attach, such as purchase agreements and lender requests, which may contain nonpublic personal information about transaction parties.

• Identity verification. To confirm the identity of the parties to a transaction and help prevent fraud, we — through our identity-verification provider (Plaid) — may collect an image of your government-issued photo identification and a self-portrait photo or short "liveness" video, together with the identifying information contained in your ID (such as your name, date of birth, address, and document number). We use this information solely to verify your identity, to document that verification in the transaction file, and to meet our underwriting, legal, and recordkeeping obligations. These images and video are retained as part of the closing record for the period required to complete the transaction and satisfy applicable legal and regulatory requirements, and are protected with encryption in transit and at rest.

• Bank account verification. To confirm that closing funds are sent to and received from the correct account and to help prevent wire fraud, we — through our account-verification provider (Plaid) — may verify your bank account information, including the account and routing numbers and the name associated with the account. If you connect an account, your online banking credentials are entered directly with the provider and are never seen or stored by ROI Title Agency LLC; we receive only the verification result and the limited account details needed to confirm ownership and set up the transfer.


HOW WE USE INFORMATION

• To verify and approve your registration (every account is individually reviewed by ROI Title Agency LLC staff).

• To open and process title orders, respond to closing-date and update requests, and communicate with you about your transactions.

• To tell you about ROI Title Agency LLC products and services, consistent with our GLBA notice. You may opt out of marketing communications at any time by calling (248) 434-5179 or emailing orders@roititle.com.

HOW INFORMATION IS PROTECTED

All data moves between your device and our systems over encrypted connections (TLS) and is encrypted at rest in Google Cloud (Firebase) data centers located in the United States. Access controls restrict every record to the account that created it; attached documents are readable only by our secured order-processing systems and authorized personnel. Documents are never stored on your device by the App, and uploads are automatically purged from App storage within 30 days of delivery into our title production systems. These safeguards comply with federal law, including GLBA and its implementing regulations.

SHARING

We do not sell your information. We do not share it with nonaffiliated companies for their marketing. We share information only:

• With service providers that host our infrastructure (Google Cloud / Firebase / Plaid) under confidentiality obligations;

•Verification providers. We use Plaid Inc. to perform identity and bank account verification. Information collected during these steps is also handled under the provider's own privacy policy, in addition to this policy. The App does not collect your location, contacts, photo library (other than files you deliberately attach), or any advertising identifier. The App contains no analytics or advertising frameworks and does not track you across other companies’ apps or websites.

• With parties necessary to perform your title transaction — such as underwriters, lenders, and counsel — consistent with our GLBA notice;

• With our affiliates, Midwest Insurance Associates and Birmingham Peninsula Insurance Agency, as permitted by GLBA and the Michigan Insurance Code; you may limit affiliate marketing by contacting us;

• As required by law, court order, or regulatory authority.

RETENTION AND DELETION

Registration information is retained while your account is active. You may delete your account at any time from within the App (menu → Account → Delete Account) or by contacting us; deletion removes your login credential and registration profile. Records of title orders and transactions are business records of ROI Title Agency LLC and are retained as required by Michigan title insurance regulations, our underwriting agreements, and applicable law, even after account deletion.

YOUR CHOICES

• Opt out of marketing or limit affiliate sharing: call (248) 434-5179 or email orders@roititle.com.

• Delete your account: in-App, or by written request to the address above.

• Questions or privacy complaints: contact us at the address, phone, or email above.

STATE DISCLOSURES

Michigan: We may share information with the affiliates named above to the extent permitted by GLBA and the Michigan Insurance Code; Michigan law may give you additional rights to limit certain uses. California and Vermont: we will not share information we collect about you with companies outside ROI Title Agency LLC except as permitted by law, such as to process your transactions or maintain your account. Information subject to GLBA is exempt from certain state consumer-privacy statutes.

CHILDREN

The App is intended for use by licensed real estate professionals and adult consumers and is not directed to anyone under 18.

CHANGES

We may update this policy and will post the current version at this address, with notice as required by law for material changes. Former users remain covered by the practices described here.