How TrueFocus Automation collects, uses, protects, and respects personal information across our website and our Title Hunter® and Title Miner® platforms.
| Effective Date | Last Updated | Version |
| June 1, 2026 | August 6, 2026 | 1.1 |
TrueFocus Strategic Consulting, LLC dba TrueFocus Automation (“TrueFocus”, “we”, “us”, or “our”) provides intelligent automation, AI-powered digital workers, and managed services to the title, mortgage, and real-estate industry through our website at https://truefocusautomation.com and our products Title Hunter®, Title Miner®, Title Lens™ and Appraisal Hunter™ (collectively, the “Services”).
Trust is the foundation of our business. Our clients entrust us with information that sits at the heart of property transactions, and the individuals behind that information trust that it will be handled with care. TrueFocus recognizes that the collection, use, and disclosure of Personal Information carry important consequences for us as a business, for our clients,and above all for the people concerned. Careful and considerate handling of Personal Information is essential to maintaining that trust, upholding our reputation, and building strong and lasting relationships.
This Policy describes how we collect, use, disclose, retain, and protect Personal Information, the principles we hold ourselves to, and the choices and rights available to you. It is designed to comply with all data protection and privacy laws applicable to our operations, and it applies globally, wherever we do business. TrueFocus is certified to ISO/IEC 27001:2022, the international standard for information security management.
- Scope of this Policy
This Policy applies to Personal Information we collect or process when you:
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- Visit or interact with our website, marketing channels, or business chat (including WhatsApp);
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- Engage with us as a prospect, client, supplier, or business partner;
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- Are an authorized user of Title Hunter®, Title Miner®, Title Lens™, Appraisal Hunter™ and/or our Custom Bots;
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- Are named in records that our digital workers process on behalf of our clients (for example, individuals appearing in county property, lien, tax, or court records); or
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- Apply for employment with us.
Where TrueFocus processes Personal Information on behalf of a client – for example, records processed by our digital workers for a title agent or lender, the client determines the purposes of that processing, and TrueFocus acts strictly as a service provider under contract and applicable law. In those cases, the client’s own privacy notice governs, and requests concerning that information should be directed to the client. This Policy nonetheless describes the safeguards we apply to all information in our care.
- What We Mean by “Personal Information”
“Personal Information” (or “Personal Data”) means any information relating to an identified or identifiable natural person information that, either directly or indirectly, alone or in combination with other information available or likely to be available, can identify that person. It does not include information that has been irreversibly aggregated or anonymized, or information lawfully available in the public domain, except to the extent we combine it with other identifying information.
- Personal Information We Collect
3.1 Website visitors and marketing prospects
When you visit our website, submit a contact or demo-request form, subscribe to communications, or interact with us through chat, we collect:
- Identifiers – name, business email, company name, job title, telephone number;
- Inquiry content – the messages, files, or information you choose to submit;
- Technical data – IP address, browser type, device identifiers, referring URL, timestamps;
- Usage data – pages viewed, click activity, and session duration, captured via cookies and similar technologies (see Section 12).
3.2 Authorized users of our platforms
When you use Title Hunter®, Title Miner®, Title Lens™, Appraisal Hunter™ and/or our Custom Bots as an authorized user, we collect:
- Account information – name, business email, organization, role, authentication credentials, and access logs;
- Configuration data – search parameters, bot configurations, and output destinations;
- Activity data – jobs run, searches performed, files accessed, IP and device used, and audit-trail entries.
3.3 Records processed by our digital workers
On instruction from our clients, our digital workers access public records and authorized data sources including county assessor, tax, recorder, lien and judgment, court, and sanctions-screening sources and may incidentally process Personal Information about individuals named in those records, such as names, addresses, property identifiers, mortgage and lien details, and court filings. We process this information solely as a service provider, only for the purposes the client has instructed, and never for our own marketing. We do not sell it.
3.4 Job applicants
If you apply for a role with us, we collect the information contained in your application – name, contact details, CV, work history, references, and anything else you choose to share and may collect background-check information where lawful and with your consent.
3.5 Sensitive Personal Information
We do not solicit information about health, biometrics, racial or ethnic origin, religious belief, sexual orientation, trade-union membership, or precise geolocation. Where information such as financial-account details or government identifiers is treated as sensitive, we do not collect it through our website, and we process it through our platforms only to the limited extent necessary to perform a client engagement – and always under heightened safeguards.
- Our Data Protection Principles
Every activity involving Personal Information at TrueFocus is governed by the following principles. They apply to all our entities, all our staff, and all systems that touch Personal Information.
Purpose and manner of collection
- Personal Information is collected only for purposes directly related to a function or activity of TrueFocus, and only where collection is necessary for that purpose.
- Collection is always lawful, fair, and limited to adequate, relevant data – never excessive.
- Where the law requires it, consent is obtained from the individual providing the information, and individuals are informed of the purpose of collection, who is collecting it, and who will retain it.
- You may decline to provide Personal Information, or withdraw consent previously given, by written communication to us; in that case, we may be unable to provide the services for which the information was sought.
Accuracy and duration of retention
- All practicable steps are taken to keep Personal Information accurate and up to date.
- You may review the information you have provided at any time and ask us to correct or complete anything inaccurate or deficient.
- Personal Information is not retained longer than is necessary for the purposes for which it may lawfully be used, or as otherwise required by law (see Section 7 for indicative periods).
Use limitation
- Unless you have given prior consent, Personal Information is used only for the purpose for which it was originally collected, or a directly related purpose.
Security
- All practicable steps are taken to protect Personal Information against unauthorized or accidental access, processing, erasure, loss, damage, or destruction.
- Security controls are implemented in accordance with our documented, independently certified information security program. (see Section 8).
Openness and redress
- Any discrepancy or grievance concerning the processing of your information is addressed in a time-bound manner through a designated Grievance Officer (see Section 11).
Disclosure
- Personal Information is disclosed only with your prior consent, where necessary to perform a lawful contract, or where required to comply with a legal obligation, court order, or the lawful direction of a competent authority.
- Third parties receiving Personal Information from us are bound by contract not to disclose it further or use it for their own purposes.
- TrueFocus will under no circumstances publish Personal Information collected during its business.
- How We Use Personal Information
| Purpose | Categories Used |
| Operate and secure our website | Identifiers, technical data, usage data |
| Respond to inquiries and demo requests | Identifiers, inquiry content |
| Provide, support, and administer the Services | Account data, configuration data, activity data |
| Process records on client instruction | Records data (Section 3.3) |
| Account management and billing | Identifiers, account data |
| Marketing communications (with opt-out at any time) | Identifiers |
| Security, fraud prevention, and audit | All categories, as needed |
| Improve and develop the Services | Account data, activity data, aggregated data |
| Comply with law and establish or defend legal rights | All categories, as needed |
- Disclosure and Sub-Processors
We do not sell Personal Information, and we do not disclose it for cross-context behavioral advertising. We disclose Personal Information only as follows:
- Our clients – processed outputs and audit trails are returned to the client that instructed the work;
- Sub-processors – trusted vendors who process Personal Information on our behalf, under written contracts imposing confidentiality and security obligations consistent with this Policy;
- Affiliates and corporate transactions – within the TrueFocus group, or in a merger, acquisition, or financing, subject to confidentiality;
- Legal and regulatory – to comply with law, court orders, or lawful requests of government agencies and regulators, or to protect rights, safety, or property;
- At your direction – any other disclosure you request or consent to.
Current sub-processor categories:
| Category | Purpose | Location |
| Cloud infrastructure | Hosting and storage of website, platforms, and backups | United States (primary); India (secondary support region) |
| Identity and email | Authentication, business email, collaboration | United States / India |
| Source control and code | Engineering and build automation | United States |
| Endpoint and email security | Anti-malware and threat protection | United States / United Kingdom |
| Analytics | Website usage analytics (aggregated) | United States |
| Customer support and chat | Inquiry handling, including WhatsApp business chat | United States / Global |
| Engineering support partner | Application development and security operations | India |
A current named list of sub-processors is available on request from privacy@truefocusautomation.com.
- How Long We Keep Personal Information
We retain Personal Information only for as long as necessary for the purposes for which it was collected, to comply with legal obligations, resolve disputes, and enforce agreements. Indicative periods:
| Data Category | Retention Period |
| Website contact / demo form submissions | 24 months from last interaction |
| Marketing contact lists | Until you unsubscribe, or 24 months of inactivity |
| Platform account data (Title Hunter®, Title Miner®, Appraisal Hunter™, Title Lens™) | Lifetime of the contract + 12 months |
| Records processed for clients | As instructed by the client; default 90 days post-job unless retention is contractually extended |
| Security and audit logs | 12 months (longer where required by law) |
| Job applicant data | 12 months after the recruitment decision (longer with your consent) |
| Contractual and financial records | As required by applicable tax, commercial, and statutory law (typically 7 years) |
- How We Protect Personal Information
TrueFocus operates an Information Security Management System certified to ISO/IEC 27001:2022. We apply administrative, technical, and organizational measures proportionate to risk, including encryption in transit and at rest, multi-factor authentication for privileged access, segmented network architecture, monitored logging, vulnerability management, secure development practices, vendor risk management, security awareness training for all staff, and a documented and tested incident-response program.
Where we handle non-public financial information of consumers on behalf of financial-institution clients, we maintain a written information security program aligned with the regulatory standards applicable to those clients, and we assist them in meeting their own notification obligations.
No method of transmission or storage is completely secure. If we become aware of a breach affecting Personal Information, we will promptly investigate and contain it, and notify affected individuals, clients, and competent authorities where and when required by law and by our client contracts.
- Automated Processing and Artificial Intelligence
Our digital workers automate data collection, retrieval, classification, and assembly. They do not, on their own, make legal or similarly significant decisions about individuals. The client that instructs us remains responsible for the underlying lending, insurance, or business decisions made using our outputs, including any required human review.
Where we use machine learning or AI features – for example, to improve output accuracy or extract structured data from documents – we apply governance controls including human oversight, data minimization, vendor due diligence, and strict limits on the use of customer data for model training. We do not use customer data to train third-party foundation models unless the relevant contract expressly permits it. If automated processing ever produces a legal or similarly significant effect on you, you may request human review of the outcome as described in Section 10.
- Your Rights and Choices
Subject to applicable law and verification of your identity, you may:
- Access – obtain confirmation of whether we process your Personal Information, and a copy of it;
- Correction – ask us to correct inaccurate or incomplete information;
- Deletion – ask us to delete your information, subject to legal retention requirements;
- Objection / restriction – object to or restrict certain processing, including direct marketing at any time;
- Portability – where applicable, receive certain information in a structured, machine-readable format;
- Withdraw consent – where processing relies on consent, withdraw it at any time without affecting prior processing;
- Human review – where applicable, request review of automated decisions with legal or similarly significant effects;
- Complain – lodge a complaint with the data protection or supervisory authority in your jurisdiction.
To exercise any right, write to privacy@truefocusautomation.com (or to the postal address in Section 14) and tell us which right you wish to exercise. We will acknowledge your request promptly, verify your identity using information already on file, and respond within 30 days (or any shorter period required by the law applicable to you), extendable once where reasonably necessary with notice to you. Our response is free of charge except for manifestly unfounded or excessive requests. If we decline a request, we will give reasons and explain how to appeal or complain.
If your information is processed by us on behalf of a client (Section 3.3), please direct your request to that client; we will support them in responding.
- Grievance Redressal
TrueFocus has designated a Grievance Officer to address, in a time-bound manner, any discrepancy or grievance concerning the processing of your Personal Information. The Grievance Officer will acknowledge your grievance and redress it as expeditiously as possible, and in any event within one month of receipt. You can reach the Grievance Officer at privacy@truefocusautomation.com, marked “Attention: Grievance Officer”.
- Cookies and Similar Technologies
Our website uses cookies and similar technologies for the following purposes:
| Category | Purpose | Consent Required |
| Strictly necessary | Authentication, security, basic functionality | No |
| Preferences | Remember your settings (language, region) | Yes (where required) |
| Analytics | Aggregate usage statistics to improve the site | Yes (where required) |
| Marketing | Measure engagement with our marketing content | Yes (where required) |
Where consent is required by the law applicable to you, we will request it through a cookie banner. You can withdraw consent or change your choices at any time through the cookie settings on the website or through your browser. Disabling some cookies may affect site functionality.
- Children’s Privacy
Our website and Services are intended for business users and are not directed to children. We do not knowingly collect Personal Information from anyone under 16 years of age (or any higher age of majority required by applicable law). If we learn that we have collected such information without appropriate parental or guardian consent, we will delete it.
- Governance and Accountability
Protecting Personal Information at TrueFocus is not left to chance – it is governed, resourced, and audited:
- Privacy by design – data protection is considered at the design and development stage of every new system, bot, and workflow;
- Designated accountability – a designated privacy lead administers this Policy, serves as the single point of contact for our data protection framework, manages and reports incidents of loss or leakage of Personal Information, and advises the business on applicable privacy requirements;
- Staff awareness – all staff receive regular training on Personal Information privacy and protection, and observe our professional code of conduct;
- Discipline – unauthorized access to, disclosure of, or misuse of Personal Information is treated as a disciplinary matter, up to and including dismissal; individuals may also be personally liable under laws designed to protect Personal Information;
- Continuous assurance – regular reviews, self-assessments, and independent audits confirm that TrueFocus complies with the requirements of all applicable data protection and privacy laws;
- Processor obligations – everyone who performs any operation on Personal Information for TrueFocus – collection, recording, storage, retrieval, use, disclosure, erasure, or destruction – must ensure their actions do not breach this Policy or our information security policies.
When Personal Information is transferred across borders – for example, between our United States operations and our engineering support partner in India – we do so only under appropriate contractual, technical, and organizational safeguards ensuring a level of protection consistent with this Policy. Copies of the safeguards are available on request.
- Changes to this Policy
We may update this Policy from time to time. When we make a material change, we will update the Effective Date above and notify you by reasonable means – for example, by posting a notice on our website or by email to registered users. We encourage you to review this Policy periodically.
- How to Contact Us
| Channel | Details |
| Privacy email | privacy@truefocusautomation.com |
| General contact | info@truefocusautomation.com |
| Postal address | TrueFocus Strategic Consulting, LLC, 6009 W. Parker Rd, Suite 149-883, Plano, TX 75093, United States |
| Grievance Officer | privacy@truefocusautomation.com – marked “Attention: Grievance Officer” |