July 16, 2018

Pietrangelo Smith PLC (the "Firm") respects the privacy and security of your non-public personal information ("Personal Information") and protecting your Personal Information is one of our top priorities. This Privacy Statement explains the Firm's privacy practices, including how we use the Personal Information we receive from you and from other specified sources, and to whom it may be disclosed. The Firm follows the privacy practices described in this Privacy Statement and, depending on the business performed, the Firm may share information as described herein.

Personal Information Collected:
We may collect Personal Information about you from the following sources: - Information we receive from you on applications or other forms, such as your name, address, social security number, tax identification number, asset information, and income information; - Information we receive from you through our internet websites, such as your name, address, e-mail address, internet protocol address, the website links you used to get to our websites, and your activity while using or reviewing our websites; - Information about your transactions with or services performed by us, our affiliates, or others, such as information concerning your title insurance policy, premiums, payment history, information about your home or other property, information from lenders and other third parties involved in the transaction, account balances, and credit card information; and - Information we received from consumer or other reporting agencies and publicly recorded documents.

Disclosure of Personal Information:
We may provide your Personal Information (excluding information we receive from consumer or other credit reporting agencies) to various individuals and companies, as permitted by law, without obtaining your prior authorization. Such laws do not allow consumers to restrict these disclosures. Disclosures may include, without limitation, the following: - To insurance agents, brokers, representatives, support organizations, lenders, or others to provide you with services you have requested, and to enable us to detect and prevent criminal activity, fraud, material misrepresentations, or nondisclosure in connection with an insurance or other transaction; - To third-party contractors or service providers for the purpose of determining your eligibility for an insurance benefit or payment and/or providing you with services you have requested; - To an insurance regulatory authority, or a law enforcement or other governmental authority, in a civil action, in connection with a subpoena or a governmental investigation; - To companies that perform marketing services on our behalf or to other financial institutions which we have joint marketing agreements and/or; - To lenders, lien holders, judgment creditors, or other parties claiming an encumbrance or an interest in title whose claim or interest must be determined, settled, paid or released prior to a title or escrow closing.

We may also disclose your Personal Information to others when we believe, in good faith, that such disclosure is reasonably necessary to comply with the law or to protect the safety of our customers, clients, employees, or property and/or to comply with a judicial proceeding, court order or legal process.

Disclosure to Affiliated Companies:
We are permitted by law to share your name, address and facts about your transaction with other companies, such as insurance companies, agents, lenders, and other real estate service providers to provide you with the services you have requested, for marketing or product development research, or to market products or services to you. We do not, however, disclose information we collect from consumer or credit reporting agencies with our affiliates or others without your consent, in conformity with applicable law, unless such disclosures is otherwise permitted by law.

Disclosure to Title Insurance Underwriters.
If we are called upon it issue or cause to be issued a policy of title insurance on your property, including owner's title insurance policies or mortgagee's title insurance policies insuring you lenders, we may disclosure information about you and your transaction to the title insurance company underwriting those title insurance policies. We are issuing agents for Chicago Title Insurance Company and Fidelity National Title Insurance Company, and the disclosures may be made to Chicago Title Insurance Company, Fidelity National Title Insurance Company, or their affiliates, including without limitation Fidelity National Financial and Fidelity National Title Group. In order to underwrite a title insurance policy or to process claims filed on title insurance policies, the title insurance company may require access to all of your Personal Information and the entirety of our file regarding the insured transaction. By asking us to insure title through the title insurance company, you acknowledge that we are authorized to share your Personal Information and all of the information contained in our file about you or your transaction, and acknowledge that such information is not subject to the attorney-client privilege as to the disclosure to the title insurance company.

Disclosure to Non-Affiliated Third Parties:
We do not disclose Personal Information about our clients or former clients to nonaffiliated third parties, except as outlined herein or as otherwise permitted by law.

Confidentiality and Security of Personal Information:
We restrict access to Personal Information about you to those employees who need to know that information to provide products or services to you. We maintain physical, electronic and procedural safeguards that comply with federal regulations to guard Personal Information.

Access to Personal Information / Requests for Correction, Amendment or Deletion of Personal Information:
As required by applicable law, we will afford you the right to access your Personal Information, under certain circumstances to find out to whom your Personal Information has been disclosed, and request correction or deletion of your Personal Information. However, the Firm's current policy is to maintain clients' Personal Information for no less than three (3) years or such minimum time required by the State in which the transaction occurs or in which the property to be insured is located may require for the purpose of handling future coverage claims under any title insurance policies that we procure for you or cause to be issued on your behalf.

For your protection, all requests made under this section must be in writing and must include your notarized signature to establish your identity. Where permitted by law, we may charge a reasonable fee to cover the costs incurred in responding to such requests. Please send requests to:

Bryan K. Smith
Pietrangelo Smith PLC
International Place, Tower II
6410 Poplar Avenue, Suite 190
Memphis, TN 38119

Changes to this Privacy Statement:
This Privacy Statement may be amended from time to time consistent with applicable privacy laws. When we amend this Privacy Statement, we will post a notice of such changes on our website. The effective date of this Privacy Statement, as stated above, indicates the last time this Privacy Statement was revised or materially changed.
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