Titan Locators PRIVACY POLICY & DATA GOVERNANCE
Effective Date: January 5, 2026
Last Updated: February 19, 2026
This Privacy Policy is provided for transparency to consumers. It is not a contract, does not create third-party beneficiary rights, and does not impose obligations on any partner, provider, purchaser, or broker beyond what is required by applicable law.
2. Information Origination and Collection
2.1 Data Sources
We originate information directly from consumers who voluntarily submit information or interact with the Ecosystem. We do not purchase consumer data from secondary markets, data append vendors, or open-market aggregation sources for the purpose of creating consumer profiles.
2.2 Categories of Information We Collect
Depending on the consumer’s actions and selections, we may collect:
a) Personally Identifiable Information (PII): name, email address, phone number, mailing address, and other identifiers the consumer provides.
b) Housing and Service Intent Data (Self-Reported): housing preferences, move timeframe, household details, income ranges, credit-related self-disclosures, legal inquiry indicators, employment history, and other information the consumer voluntarily provides to request help, be contacted, or receive resources.
c) Technical and Usage Data: IP address, device identifiers, browser type, operating system, referral URLs, pages viewed, timestamps, clickstream data, and interaction metrics used for security, fraud prevention, analytics, and infrastructure optimization.
d) Communications: messages or form submissions sent to us, and records of communications (including email/SMS where permitted and where the consumer has consented or where otherwise lawful).
2.3 What We Do Not Intend to Collect
We do not request sensitive data such as Social Security numbers, government ID numbers, or full bank account numbers through standard consumer intake pathways unless explicitly required for a specific service process and presented with clear, separate notice. If such information is provided to us inadvertently, we may delete or redact it where feasible.
3. How We Use Information
We use collected information for the following business purposes:
a) Service Enablement and Matching: to present resources, route requests, and facilitate introductions between consumers and housing, legal, financial, employment, and related service providers.
b) Data Distribution and Licensing: to disclose, sell, license, or otherwise make available consumer-originated information to third parties, including our authorized distribution partner(s) and downstream commercial recipients, for housing, legal, financial stabilization, employment transition, marketing, outreach, and related services, consistent with consumer selections, notices presented at the point of collection, and applicable law.
c) Operations and Infrastructure: to maintain, secure, and improve our platforms; debug issues; conduct analytics; prevent fraud; enforce policies; and protect the integrity of our systems.
d) Compliance and Legal: to comply with legal obligations, respond to lawful requests, exercise or defend legal claims, and enforce our rights.
Titan Locators does not guarantee housing placement, lease approval, legal outcomes, credit outcomes, employment offers, or service fulfillment. Any decisions, underwriting, eligibility determinations, pricing, or outcomes are made solely by third parties.
4. Disclosures, Distribution Partners, and Data Brokerage
4.1 Authorized Distribution Partner(s)
Titan Locators may distribute consumer-originated information through an exclusive authorized distribution partner (“Authorized Distribution Partner”). The Authorized Distribution Partner may, subject to applicable law and its own policies, sell, license, or otherwise disclose such data to additional third parties (including providers, networks, platforms, advertisers, and commercial recipients).
4.2 Direct Disclosures to Third Parties
In addition to disclosures through an Authorized Distribution Partner, Titan Locators may disclose information directly to third-party recipients including property management groups, housing networks, legal service providers, financial institutions, employers, marketers, and service platforms.
4.3 No Endorsement; No Obligations to Provide Services
Disclosure of information is a commercial data transaction and/or routing function, not an endorsement of any provider, purchaser, or recipient. Titan Locators does not supervise, control, or guarantee any third party’s performance, service availability, or outcomes. The Ecosystem may facilitate community growth and provider discovery, but Titan Locators and any partners have no obligation to ensure provider participation, consumer outcomes, or fulfillment of any particular service pathway.
4.4 Advertising, Outreach, and Marketing Uses
Third-party recipients may use information for outreach, marketing, and service offers where lawful. Consumers may have the right to opt out of certain marketing and/or certain disclosures depending on state law. See Section 7.
5. Data Security and Governance
Titan Locators maintains commercially reasonable technical and organizational safeguards designed to protect information from unauthorized access, acquisition, disclosure, alteration, or destruction. Measures may include encryption in transit and/or at rest, access controls, credential management, monitoring, and secure hosting practices.
No system can be guaranteed 100% secure. We encourage consumers to use caution when submitting information online and to avoid sharing sensitive credentials through intake forms.
6. Data Retention
We retain information for as long as reasonably necessary to operate the Ecosystem, fulfill the purposes described in this policy, comply with legal obligations, resolve disputes, enforce agreements, and maintain business records. Retention periods may vary depending on data type, consumer activity, legal requirements, and operational needs.
7. Nationwide Consumer Privacy Rights and Choices
Depending on your state of residence, you may have rights regarding your personal information. These may include rights under state privacy laws such as the CCPA/CPRA (California), VCDPA (Virginia), CPA (Colorado), and similar statutes, as applicable.
7.1 Right to Know / Access
You may request that we disclose the categories of personal information we have collected and, where required by law, the specific pieces of personal information we hold about you.
7.2 Right to Delete
You may request deletion of personal information we hold. If verified and required by law, we will delete personal information from Titan Locators systems and cease further disclosures from Titan Locators systems, subject to legal exceptions.
Important: Where information has already been disclosed, sold, or licensed to third parties (including any Authorized Distribution Partner and its downstream recipients), Titan Locators may not be able to delete that information from third-party systems. Where required by law or where reasonably feasible, we may take reasonable steps to notify applicable distribution partner(s) of a verified deletion request, but we do not control third parties’ independent data retention practices.
7.3 Right to Opt Out of Sale/Sharing or Targeted Advertising (Where Applicable)
Where provided by law, you may direct us to opt you out of the “sale” or “sharing” of your personal information (as those terms are defined by applicable law) and/or certain targeted advertising activities. Opt-out rights vary by state and by data context. If you opt out, we will honor the request to the extent required by law and technically feasible for Titan Locators systems going forward.
7.4 Right to Correct (Where Applicable)
In certain states, you may request correction of inaccurate personal information we maintain about you.
7.5 How to Exercise Your Rights
To exercise these rights, please use our Opt-Out / Privacy Request Portal (if available within the Ecosystem) or contact us using the information in Section 9. We may need to verify your request (for example, by confirming access to an email address or phone number associated with the request) to protect consumers from unauthorized actions.
7.6 How to Exercise Your Rights
To exercise these rights, please use our Opt-Out / Privacy Request Portal (if available within the Ecosystem) or contact us using the information in Section 9. We may need to verify your request (for example, by confirming access to an email address or phone number associated with the request) to protect consumers from unauthorized actions.
8. Children’s Privacy
The Ecosystem is not directed to children under 13 (or under 16 where applicable under certain laws), and we do not knowingly collect personal information from children. If you believe a child has provided us personal information, contact us and we will take appropriate action consistent with applicable law.
9. Contact Information
For privacy requests, compliance inquiries, or questions regarding this Privacy Policy, contact: blarocca@titanlocators.com
Titan Locators
Attn: Data Governance Officer
Pearland, Texas, United States
If an Opt-Out / Privacy Request Portal is available within the Ecosystem, it may provide the fastest method to submit a verified request.
10. Policy Updates
We may update this Privacy Policy from time to time. The “Last Updated” date above reflects the most recent revision. If we make material changes, we may provide additional notice through the Ecosystem or other lawful means.
11. Interpretation and Limitations
This Privacy Policy is intended to describe Titan Locators’ consumer data practices. It does not create an obligation to originate, distribute, or maintain any specific volume of data, nor does it require Titan Locators, any Authorized Distribution Partner, or any third-party recipient to provide any service, outcome, or placement to any consumer. Any third-party services are independent and governed by the third party’s own terms and policies.
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