Privacy Policy

Effective Date: July 8, 2026

Vanguard Settlement Services, LLC dba Vanguard Settlement Alliance (“Vanguard Settlements,” “we,” “us,” or “our”) is committed to protecting the privacy and security of your personal information. This Privacy Policy describes how we collect, use, disclose, and safeguard information in connection with our website, vanguardsettlements.com (the “Site”), and our settlement/title services (the “Services”).

By using our Site or Services, you agree to the terms of this Privacy Policy and our Terms & Conditions (the “Terms”) available at: https://vanguardsettlementservices.com/terms-

%26-conditions (or any successor URL).

1. Who We Are (Settlement/Title Services Provider)

Vanguard Settlements is a settlement agent and title services provider. This Privacy Policy

applies to information we collect through the Site and in connection with Services we provide, including services provided in Pennsylvania, Delaware, and New Jersey.

2. Affiliated Business Arrangement (AfBA) Disclosure (Common Ownership)

Vanguard Settlements is part of a family of companies under common ownership,

including:

Vanguard Lending, LLC (“Vanguard Lending”) (mortgage lending/financing-related services); and
Vanguard Realty Alliance, LLC d/b/a VRA Realty (“VRA Realty”) (real estate brokerage and related services).

Because of these relationships, we may refer you to these affiliates, and they may refer you to us.

RESPA Notice / No Required Use (Affiliated Business Relationship Disclosure). Vanguard Settlement Services, LLC has a business relationship with Vanguard Lending, LLC and Vanguard Realty Alliance, LLC d/b/a VRA Realty, all under common ownership. Because of this relationship, a referral of business between these entities may provide a financial or other benefit. You are NOT required to use any affiliated provider as a condition of settlement services, and you are free to shop around for similar services from other providers.

3. Gramm-Leach-Bliley Act (GLBA) and Nonpublic Personal Information (NPI)

Vanguard Settlement Services, LLC is generally considered a “financial institution” subject

to the Gramm-Leach-Bliley Act (“GLBA”) in connection with certain settlement/title

activities. In providing our Services, we may collect and handle Nonpublic Personal

Information (“NPI”), which can include (as applicable):

Government-issued identification information (e.g., driver’s license or other ID details);
Financial account information;
Wire instructions and related payment/escrow disbursement information; and
Other information obtained in connection with providing a financial product or service.

This Privacy Policy describes, at a high level, how we collect, use, share, protect, and retain Personal Information, including NPI. However, this Privacy Policy does not replace our

GLBA Privacy Notice (the “Facts” form). We may provide you a separate GLBA notice

(and any related state notices) when required or appropriate.

FCRA Affiliate Marketing Rule. The opt-out rights described in this notice regarding affiliate sharing of creditworthiness information are derived from the Fair Credit Reporting Act (FCRA) Affiliate Marketing Rule (Regulation V, 12 C.F.R. Part 1022). Any opt-out request you submit will be honored operationally, including by sharing that election with our affiliates.

3A. GLBA Privacy Notice (Model Disclosure)

Vanguard Settlement Services, LLC collects Nonpublic Personal Information (“NPI”) about you in connection with providing settlement, title, and closing services. This notice describes our practices regarding that information.

FACTS: WHAT DOES VANGUARD SETTLEMENT SERVICES, LLC DO WITH YOUR PERSONAL INFORMATION?

Why? Financial companies choose how they share your personal information. Federal law

gives consumers the right to limit some but not all sharing. Federal law also requires us to

tell you how we collect, share, and protect your personal information. Please read this

notice carefully.

What? The types of personal information we collect and share depend on the product or

service you have with us. This information can include:

Name, address, email, phone number
Social Security number and other government-issued ID information
Property address and transaction details
Account balances, wire instructions, and financial account information
Payment history and transaction records
Credit history (when applicable to the transaction)

How? All financial companies need to share customers’ personal information to run their

everyday business. In the section below, we list the reasons financial companies can share

their customers’ personal information; the reasons Vanguard Settlement Services, LLC

chooses to share; and whether you can limit this sharing.

Reasons we can share your personal information:

For our everyday business purposes — such as to process your transactions, maintain your account(s), respond to court orders and legal investigations, or report to credit bureaus. Can you limit this sharing? No.
For our marketing purposes — to offer our products and services to you. Can you limit this sharing? Yes — send us a written request using the contact information in Section 18.
For joint marketing with other financial companies. Can you limit this sharing? We do not share for this purpose.
For our affiliates’ everyday business purposes — information about your transactions and experiences. Can you limit this sharing? No.
For our affiliates’ everyday business purposes — information about your creditworthiness. Can you limit this sharing? Yes — send us a written request using the contact information in Section 18.
For our affiliates to market to you. Can you limit this sharing? Yes — send us a written request using the contact information in Section 18. See Section 12 below for additional opt-out options.
For nonaffiliates to market to you. Can you limit this sharing? We do not share for this purpose.

Questions? Contact us using the information in Section 18.

Who We Are. Who is providing this notice? Vanguard Settlement Services, LLC d/b/a Vanguard Settlement Alliance (a Pennsylvania-registered DBA), and its affiliates as described below.

What We Do. How does Vanguard Settlement Services, LLC protect my personal information? To protect your personal information from unauthorized access and use, we use security measures that comply with federal law. These measures include computer safeguards and secured files and buildings, and controls over access to NPI.

How does Vanguard Settlement Services, LLC collect my personal information? We collect

your personal information, for example, when you:

Request title or settlement services
Provide information related to a real estate transaction
Submit documents or wire instructions
Communicate with us about your transaction
Use our website or fill out forms

Why can’t I limit all sharing? Federal law gives you the right to limit only:

Sharing for affiliates’ everyday business purposes — information about your creditworthiness
Affiliates from using your information to market to you
Sharing for nonaffiliates to market to you

State laws and individual companies may give you additional rights to limit sharing. See Section 15 below.

What happens when I limit sharing for an account I hold jointly with someone else? Your

choices will apply to everyone on your account.

Definitions.

Affiliates: Companies related by common ownership or control. They can be financial and nonfinancial companies. Our affiliates include Vanguard Lending, LLC (legal name; no DBA) and Vanguard Realty Alliance, LLC d/b/a VRA Realty.
Nonaffiliates: Companies not related by common ownership or control. They can be financial and nonfinancial companies. We do not share with nonaffiliates for them to market to you.
Joint Marketing: A formal agreement between nonaffiliated financial companies that together market financial products or services to you. We do not engage in joint marketing.

This GLBA disclosure supplements our Privacy Policy and is provided as required by the Gramm-Leach-Bliley Act (15 U.S.C. §§ 6801-6809) and Regulation P (12 C.F.R. Part 1016).

Reconciling This Notice with Our Opt-In Process. The “Facts” form above describes your right to opt out of certain affiliate sharing and marketing under federal law. Separately, the checkbox opt-in at Section 7 of this Policy governs whether you consent to receive marketing communications from our affiliates. These are distinct mechanisms: the opt-out rights in this notice apply to sharing that is permitted by default under GLBA and the FCRA Affiliate Marketing Rule (Regulation V), while the checkbox opt-in under Section 7 requires your affirmative consent before we or our affiliates may send you marketing messages. You may exercise both rights — opt out of certain sharing under this notice, and choose whether to opt in to marketing communications under Section 7 — independently.

Delivery of GLBA Notice. This GLBA Privacy Notice is available via a link on our Site. We will provide you with a copy of this notice at the time we establish a customer relationship and annually thereafter, either by directing you to the link on our Site or by providing a copy upon request, in accordance with Regulation P (12 C.F.R. Part 1016).

4. Information We Collect

We collect information that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked with you (“Personal Information”). Depending on how you use our Site or Services, we may collect:

Identifiers & Contact Information: Name, email address, phone number, mailing address.
Property & Transaction Information: Property address, purchase/sale details, closing date, settlement-related documentation and instructions.
Loan / Financing Information: Loan type, amount, term, rate, lender, and other financing details you provide or that are necessary to coordinate settlement/title services.
Communications & Preferences: Records of your inquiries, communications, and marketing/communication preferences, including records of your opt-in consent.
Internet / Device Information: IP address, device identifiers, browser type, pages viewed, links clicked, and related usage data collected via cookies and similar technologies.
Sensitive Information: If you provide sensitive information as part of a transaction (for example, government ID numbers, wire instructions, or financial account information), we will use and disclose it only as needed to provide Services, comply with law, prevent fraud, and secure transactions.

5. How We Collect Information

We collect Personal Information through the following methods:

Directly from You: When you fill out forms on our Site, request information, submit documents, engage us for settlement/title services, or otherwise communicate with us.
From Transaction Participants: Such as real estate agents, lenders, borrowers, sellers, buyers, attorneys, notaries, title underwriters, and other parties involved in a transaction, as needed to provide Services.
Post-Closing Entry: Following a closing, certain transaction or loan data (such as rate and term) may be entered into our systems (including our CRM such as GoHighLevel) for recordkeeping, compliance, customer support, and (where permitted) to evaluate eligibility for future real estate-related opportunities.
Affiliates: We may receive information from Vanguard Lending or VRA Realty consistent with this Privacy Policy, your preferences/consent, and applicable law.
Automatically Through Technology: Via cookies, pixels, tags, logs, and similar technologies when you interact with our Site.

6. How We Use Your Information

We use Personal Information to:

Provide, operate, maintain, and improve the Site and Services (including title, escrow, and settlement services).
Communicate with you about your transaction, requests, documents, appointment scheduling, and closing logistics.
Respond to inquiries, provide customer support, and send administrative information.
Affiliated real estate-related communications (with consent where required):

Share and use your information with Vanguard Lending and/or VRA Realty for

communications about settlement services, mortgage financing, and related real

estate services.

Market our Services and (where applicable) our affiliates’ services in a compliant manner and consistent with your preferences.
Detect and prevent fraud, unauthorized activity, and security incidents.
Comply with legal and regulatory obligations (including RESPA and applicable state insurance/title regulations) and enforce our agreements.

7. Consent, Opt-In Mechanism, and Affiliated Sharing

We do not sell your Personal Information. We may share Personal Information as

described below.

Opt-in checkbox required for affiliate contact. When a form includes an opt-in, we use a

clear checkbox where you confirm that you:

have read and agree to the Terms & Conditions (https://vanguardsettlementservices.com/terms-%26-conditions or any successor URL); and
consent to be contacted by Vanguard Settlements and its affiliated entities (Vanguard Lending and VRA Realty) regarding settlement services, mortgage financing, and related real estate services (which may include emails, calls, and texts, as permitted by law).

Text-message-only consent is not sufficient. Per our policy, consent provided only by text message, voicemail, or verbal statement is not sufficient for affiliate marketing/solicitation. A form submission with an explicit checkbox opt-in is required to authorize outreach by Vanguard Settlements and/or its affiliated entities for these purposes (subject to applicable law, including TCPA and similar state laws).

You may withdraw consent at any time as described in Section 12 (Your Rights and

Choices).

8. How We Share Information (Third Parties and Affiliates)

We may share Personal Information in the following circumstances:

Affiliates (Common Ownership): We may share Personal Information among Vanguard Settlements, Vanguard Lending, and VRA Realty for operational purposes and to provide you with real estate-related communications consistent with your preferences and any required consent.
Service Providers / Vendors: With companies that provide services on our behalf (for example: CRM providers such as GoHighLevel, hosting providers, analytics providers, document management tools, customer support tools). These vendors are contractually required to protect the information and use it only for the services they provide to us.
Transaction Participants: Such as title underwriters, lenders, real estate brokers/agents, attorneys, notaries, escrow partners, and other parties as necessary to complete your transaction and provide settlement/title services.
Compliance, Law, and Safety: If required by law, subpoena, court order, regulatory request, or to protect rights, safety, and security; to prevent fraud; or to enforce our agreements.
With Your Consent: We may share information for other purposes when you direct us to do so or provide consent.

9. Cookies, Analytics, reCAPTCHA, and Tracking Technologies

We use cookies and similar technologies to operate our Site, personalize content, and

understand how the Site is used.

Cookies and Similar Technologies: Cookies may be session-based or persistent and may include first-party and third-party cookies.
Analytics: We may use analytics services (including Google Analytics or similar tools) to measure traffic, usage trends, and improve the Site.
Google reCAPTCHA: We may use Google reCAPTCHA to help prevent spam and abuse. reCAPTCHA may collect information about you and your device and is subject to Google’s privacy policy and terms.
Do Not Track: Some browsers offer a “Do Not Track” setting; the Site may not respond to all such signals.

You can control cookies through your browser settings and, where available, through cookie preference tools. Blocking certain cookies may impact functionality.

10. Data Retention

We retain Personal Information for as long as reasonably necessary to provide Services, maintain business records, meet legal and regulatory obligations (including settlement/title recordkeeping requirements), resolve disputes, prevent fraud, and enforce agreements. Retention periods vary depending on the type of information and the context in which it was collected.

11. Data Security

We implement administrative, technical, and physical safeguards designed to protect Personal Information, such as access controls, encryption where appropriate, and secure systems and vendor management practices. However, no method of transmission over the internet or electronic storage is 100% secure, and we cannot guarantee absolute security.

12. Your Rights and Choices (Access, Correction, Deletion, Opt-Out)

Depending on your jurisdiction and subject to applicable exceptions, you may have the

right to:

Access: Request access to the Personal Information we hold about you.
Correction: Request correction of inaccurate or incomplete Personal Information.
Deletion: Request deletion of your information, subject to legal and regulatory retention requirements and other lawful exceptions.
Opt-Out of Certain Sharing/Marketing: Opt out of marketing emails (unsubscribe link), marketing texts (reply “STOP”), and certain affiliate-sharing/affiliate communications where applicable. You may also request that we limit sharing with our affiliates for marketing/solicitation purposes, subject to transactional necessities and legal obligations.

GLBA Note. Certain requests may be limited where information is collected, used, or

retained pursuant to GLBA, other financial services laws, or settlement/title recordkeeping

requirements.

To exercise these rights, contact us using the information in Section 18.

13. SMS, Email, and Electronic Communications

If you opt in, you may receive emails, phone calls, or text messages from Vanguard

Settlements and, if you provided the checkbox consent described in Section 7, from

Vanguard Lending and/or VRA Realty regarding settlement services, mortgage financing,

and related real estate services.

Opt-Out: You may opt out at any time by replying “STOP” to any marketing text message, using unsubscribe links in emails, or contacting us directly.
Transactional Messages: Even if you opt out of marketing messages, we may still send non-marketing, transactional, or administrative communications (for example, about your closing, documents, or appointments) as permitted by law.

14. Children’s Privacy

Our Site is not intended for children under 13, and we do not knowingly collect Personal Information from children under 13. If you believe a child has provided us Personal Information, contact us and we will take appropriate steps to delete it, subject to legal requirements.

COPPA and Age Gates. The under-13 limitation in this section is intentional and is meant to address children’s privacy obligations (including the Children’s Online Privacy Protection Act, “COPPA”). It is separate from and in addition to any age-related requirements in our Terms & Conditions (which may require you to be 18+ to use certain features or submit certain requests).

15. State-Specific Privacy Rights (PA, DE, and NJ) (Where Applicable)

If you live in Pennsylvania, Delaware, or New Jersey, you may have certain privacy rights

under applicable state laws and regulations, which can vary depending on the context and

the type of information at issue. Where applicable and subject to legal exceptions, you can

request to:

Access the Personal Information we maintain about you;
Correct inaccurate Personal Information;
Delete certain Personal Information (subject to settlement/title recordkeeping, legal, and regulatory requirements);
Opt out of certain marketing communications and request that we limit certain information sharing with our affiliates for marketing/solicitation purposes (where applicable).

DE/NJ Comprehensive Privacy Law Note. Delaware and New Jersey have enacted comprehensive consumer privacy laws. Depending on the final regulations, effective dates, and your specific activities, entities and data subject to GLBA (and/or other financial-services exemptions) may be exempt in whole or in part.

Delaware and New Jersey Status. Vanguard Settlement Services, LLC does not currently process the personal data of 35,000 or more Delaware residents or 100,000 or more New Jersey residents, nor does it derive significant revenue from the sale of personal data. Accordingly, the Delaware Personal Data Privacy Act (DPDPA, effective January 1, 2025) and the New Jersey Data Protection Act (NJDPA, effective January 15, 2025) do not currently apply to us as comprehensive privacy law obligations. However, we monitor these laws for changes in applicability.

HB 380 Watch Item (Delaware, Effective January 1, 2027). HB 380 passed the Delaware General Assembly in June 2026. If enacted, it will narrow Delaware’s entity-level GLBA exemption to banks, insurers, credit unions, securities firms, and their affiliates. As a title company, Vanguard Settlements may lose the entity-level exemption and retain only the data-level GLBA exemption. HB 380 also lowers the applicability threshold to 15,000 Delaware consumers. Whether this becomes a current obligation depends on the final enactment and Vanguard Settlements’ Delaware consumer population at that time. To exercise these rights, contact us using the information in Section 18. We may need to verify your identity before processing your request.

16. California Privacy Rights (If Applicable)

If you are a California resident who may interact with the Site or Services, you may have additional rights under applicable California privacy laws (including the California Consumer Privacy Act as amended by the CPRA), subject to exceptions. These may include the right to know/access, delete, correct, and opt out of certain “sharing” for cross-context behavioral advertising (if applicable), and the right not to be discriminated against for exercising privacy rights.

We do not sell Personal Information as that term is defined under California law. If we engage in “sharing” for cross-context behavioral advertising, you may have the right to opt out; you can submit a request using the contact information in Section 18.

You may also designate an authorized agent to make requests on your behalf, subject to

verification requirements.

17. Changes to This Policy

We may update this Privacy Policy from time to time. The “Effective Date” at the top of this

page indicates when the latest changes were made. Your continued use of the Site or Services after changes become effective constitutes acceptance of the revised policy to the extent permitted by law.

18. Contact Information

For questions, requests, or concerns regarding this Privacy Policy, contact us:

Vanguard Settlement Services, LLC d/b/a Vanguard Settlement Alliance 1244 West Chester

Pike, Suite 401 West Chester, PA 19382 Email: info@vanguardsettlements.com

Phone: (484) 206-7553 Website: https://vanguardsettlements.com

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