Last updated November 04, 2025
This Privacy Notice for Palermo Solutions, Inc. (doing business as “Fairway”) (“we,” “us,” or “our”) describes how and why we may access, collect, store, use, and/or share (“process”) your personal information when you use our services (“Services”), including when you:
- Visit our website at http://www.getfairway.com or any website of ours that links to this Privacy Notice.
- Use Fairway Title and Registration Automation. Fairway provides an integrated suite of AI-powered tools that automate every step of the title and registration lifecycle. Its AI Title Clerk technology audits title applications for completeness and accuracy — verifying data across handwritten and digital documents, auto-filling required forms, and flagging discrepancies before submission. The system enforces authoritative DMV rules at the state and county level, resulting in faster approvals, fewer rejections, and reduced administrative cost. Across all products, Fairway’s architecture is API-first, enabling seamless white-label integration for partners and agencies. By combining automated rule enforcement, intelligent document verification, and embedded distribution, Fairway is establishing the statewide compliance standard in multiple jurisdictions — processing millions of audited transactions annually and advancing its mission to make vehicle titling and registration effortless, accurate, and trusted.
- Engage with us in other related ways, including any sales, marketing, or events.
Questions or concerns? Reading this Privacy Notice will help you understand your privacy rights and choices. We are responsible for making decisions about how your personal information is processed. If you do not agree with our policies and practices, please do not use our Services. If you still have any questions or concerns, please contact us at info@getfairway.com.
SUMMARY OF KEY POINTS
This summary provides key points from our Privacy Notice, but you can find more details about any of these topics by going to the relevant section in the table of contents below.
What personal information do we process?
When you visit, use, or navigate our Services, we may process personal information depending on how you interact with us and the Services, the choices you make, and the products and features you use. See “1. WHAT INFORMATION DO WE COLLECT?” for more details.
Do we process any sensitive personal information?
In some jurisdictions, certain information is considered “special” or “sensitive,” for example your racial or ethnic origins, sexual orientation, or religious beliefs. We may process sensitive personal information when necessary with your consent or as otherwise permitted by applicable law. See “1. WHAT INFORMATION DO WE COLLECT?” (Sensitive Information) for more details.
Do we collect any information from third parties?
We do not collect personal information from data brokers or similar third-party sources. However, our business customers may submit personal information about other individuals (such as vehicle owners, drivers, and lienholders) as part of using our Services.
How do we process your information?
We process your information to provide, improve, and administer our Services, to communicate with you, for security and fraud prevention, and to comply with law. We may also process your information for other purposes with your consent. See “2. HOW DO WE PROCESS YOUR INFORMATION?” for more details.
In what situations and with which types of parties do we share personal information?
We may share information in specific situations and with specific categories of third parties. See “3. WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?” for more details.
How do we keep your information safe?
We have organizational and technical processes and procedures in place to protect your personal information. However, no electronic transmission over the Internet or information storage technology can be guaranteed to be 100% secure, so we cannot guarantee that unauthorized third parties will not be able to defeat our security measures. See “6. HOW DO WE KEEP YOUR INFORMATION SAFE?” for more details.
What are your rights?
Depending on where you are located geographically, the applicable privacy law may grant you certain rights regarding your personal information. See “8. WHAT ARE YOUR PRIVACY RIGHTS?” for more details.
How do you exercise your rights?
The easiest way to exercise your rights is by contacting us at info@getfairway.com. We will consider and act upon any request in accordance with applicable data protection laws.
If you want to learn more about what we do with the information we collect, please review this Privacy Notice in full.
TABLE OF CONTENTS
- WHAT INFORMATION DO WE COLLECT?
- HOW DO WE PROCESS YOUR INFORMATION?
- WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?
- DO WE OFFER ARTIFICIAL INTELLIGENCE-BASED PRODUCTS?
- HOW LONG DO WE KEEP YOUR INFORMATION?
- HOW DO WE KEEP YOUR INFORMATION SAFE?
- DO WE COLLECT INFORMATION FROM MINORS?
- WHAT ARE YOUR PRIVACY RIGHTS?
- CONTROLS FOR DO-NOT-TRACK FEATURES
- DO UNITED STATES RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS?
- DO WE MAKE UPDATES TO THIS NOTICE?
- HOW CAN YOU CONTACT US ABOUT THIS NOTICE?
- HOW CAN YOU REVIEW, UPDATE, OR DELETE THE DATA WE COLLECT FROM YOU?
A. Personal information you disclose to us
In short: We collect personal information that you provide to us.
We collect personal information that you voluntarily provide to us when you register on the Services, express an interest in obtaining information about us or our products and Services, participate in activities on the Services, or otherwise contact us.
Personal Information Provided by You
The personal information that we collect depends on the context of your interactions with us and the Services, the choices you make, and the products and features you use. The personal information we collect may include:
- Names
- Phone numbers
- Email addresses
- Usernames
- Passwords
Sensitive Information
When necessary, with your consent or as otherwise permitted by applicable law, we process the following categories of sensitive information:
- Social security numbers or other government identifiers
- Information revealing race or ethnic origin
- Financial data
- Credit worthiness data
- User-submitted case files and documents containing personal information about other individuals, such as vehicle owners, drivers, and lienholders (including names, contact details, government identifiers like driver’s license numbers, license plate numbers, VINs, title information, signatures, and related documentation)
All personal information that you provide to us must be true, complete, and accurate, and you must notify us of any changes to such personal information.
B. Information automatically collected
In short: Some information — such as your IP address and/or browser and device characteristics — is collected automatically when you visit our Services.
We automatically collect certain information when you visit, use, or navigate the Services. This information does not reveal your specific identity (like your name or contact information) but may include device and usage information, such as:
- IP address
- Browser and device characteristics
- Operating system
- Language preferences
- Referring URLs
- Device name
- Country and approximate location
- Information about how and when you use our Services
- Other technical information
This information is primarily needed to maintain the security and operation of our Services and for our internal analytics and reporting purposes.
The information we collect includes:
Log and Usage Data
Log and usage data is service-related, diagnostic, usage, and performance information our servers automatically collect when you access or use our Services, and which we record in log files. Depending on how you interact with us, this log data may include your IP address, device information, browser type and settings, and information about your activity in the Services (such as date/time stamps, pages and files viewed, searches you perform, and other actions you take, such as which features you use), device event information (such as system activity, error reports or “crash dumps”), and hardware settings.
C. Google API
Our use of information received from Google APIs will adhere to the Google API Services User Data Policy, including its Limited Use requirements. You can review these policies at:
- https://developers.google.com/terms/api-services-user-data-policy
- https://developers.google.com/terms/api-services-user-data-policy#limited-use
- HOW DO WE PROCESS YOUR INFORMATION?
In short: We process your information to provide, improve, and administer our Services, communicate with you, for security and fraud prevention, and to comply with law. We may also process your information for other purposes with your consent.
We process your personal information for a variety of reasons, depending on how you interact with our Services, including:
- To facilitate account creation and authentication and otherwise manage user accounts.
We may process your information so you can create and log in to your account, as well as keep your account in working order. - To deliver and facilitate delivery of services to the user.
We may process your information to provide you with the requested service. - To respond to user inquiries and offer support.
We may process your information to respond to your inquiries and solve any issues you might have with the requested services. - To send administrative information to you.
We may process your information to send you details about our products and services, changes to our terms and policies, and other similar information. - To fulfill and manage your orders.
We may process your information to fulfill and manage your orders, payments, returns, and exchanges made through the Services. - To request feedback.
We may process your information to request feedback and to contact you about your use of our Services. - To send you marketing and promotional communications.
We may process the personal information you send to us for our marketing purposes, if this is in accordance with your marketing preferences. You can opt out of marketing emails at any time. For more information, see “8. WHAT ARE YOUR PRIVACY RIGHTS?” - To post testimonials.
We may post testimonials on our Services that may contain personal information. - To protect our Services.
We may process your information as part of our efforts to keep our Services safe and secure, including fraud monitoring and prevention. - To evaluate and improve our Services, products, marketing, and your experience.
We may process your information when we believe it is necessary to identify usage trends, determine the effectiveness of our promotional campaigns, and to evaluate and improve our Services, products, marketing, and your experience. - To identify usage trends.
We may process information about how you use our Services to better understand how they are being used so we can improve them. - To comply with our legal obligations.
We may process your information to comply with our legal obligations, respond to legal requests, and exercise, establish, or defend our legal rights. - To provide automated audit, validation, and form-completion services for title and registration transactions on behalf of our business customers.
We may process user-submitted case data and documents in order to automatically check for completeness, enforce rules, ensure consistency across documents, and generate or pre-fill required forms for use in title and registration processes.
- WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?
In short: We may share information in specific situations described in this section and/or with the following categories of third parties.
Vendors, Consultants, and Other Third-Party Service Providers
We may share your data with third-party vendors, service providers, contractors, or agents (“third parties”) who perform services for us or on our behalf and who require access to such information to do that work. We have contracts in place with our third parties, designed to help safeguard your personal information. They may not use your personal information for their own purposes and may not share it with other organizations, except as instructed or permitted by us. They are required to protect the data they hold on our behalf and retain it only for the period we instruct.
The categories of third parties we may share personal information with include:
- AI Platforms
- Cloud Computing Services
- Data Analytics Services
- Performance Monitoring Tools
Other Sharing Situations
We may also share your personal information in the following situations:
- Business Transfers
We may share or transfer your information in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company. - Business Partners
We may share your information with our business partners to offer you certain products, services, or promotions.
- DO WE OFFER ARTIFICIAL INTELLIGENCE-BASED PRODUCTS?
In short: We offer products, features, or tools powered by artificial intelligence, machine learning, or similar technologies.
As part of our Services, we offer products, features, or tools powered by artificial intelligence, machine learning, or similar technologies (collectively, “AI Products”). These tools are designed to enhance your experience and provide you with innovative solutions. This Privacy Notice governs your use of the AI Products within our Services.
Use of AI Technologies
We provide AI Products through third-party service providers (“AI Service Providers”), including:
- Anthropic
- OpenAI
- Google Cloud AI
- xAI
Your input, output, and personal information may be shared with and processed by these AI Service Providers in order to enable your use of our AI Products, for purposes outlined in this Privacy Notice and in the section “3. WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?”. You must not use the AI Products in any way that violates the terms or policies of any AI Service Provider.
Our AI Products
Our AI Products are designed for the following functions:
- AI automation
- AI document generation
- Image analysis
- Text analysis
- Machine learning models
- AI insights
How We Process Your Data Using AI
All personal information processed using our AI Products is handled in accordance with this Privacy Notice and our agreements with relevant third parties. We implement safeguards to help ensure secure processing and to protect your information throughout the AI workflow.
- HOW LONG DO WE KEEP YOUR INFORMATION?
In short: We keep your information for as long as necessary to fulfill the purposes outlined in this Privacy Notice unless otherwise required by law.
We will only keep your personal information for as long as it is necessary for the purposes set out in this Privacy Notice, unless a longer retention period is required or permitted by law (for example, for tax, accounting, or other legal requirements). No purpose in this notice requires us to keep your personal information for longer than three (3) months past the termination of the user’s account, unless otherwise required by law or justified by a legitimate business need.
When we have no ongoing legitimate business need to process your personal information, we will delete or anonymize it. If deletion or anonymization is not possible (for example, because the personal information is in backup archives), then we will securely store your personal information and isolate it from further processing until deletion is possible.
- HOW DO WE KEEP YOUR INFORMATION SAFE?
In short: We aim to protect your personal information through a system of organizational and technical security measures.
We have implemented appropriate and reasonable technical and organizational security measures designed to protect the security of any personal information we process. However, despite our safeguards and efforts, no electronic transmission over the Internet or information storage technology can be guaranteed to be 100% secure. We therefore cannot promise or guarantee that unauthorized third parties (for example, hackers or cybercriminals) will not be able to defeat our security measures and improperly access, steal, or modify your information.
Although we will do our best to protect your personal information, transmission of personal information to and from our Services is at your own risk. You should only access the Services within a secure environment.
- DO WE COLLECT INFORMATION FROM MINORS?
In short: We do not knowingly collect data from or market to children under 18 years of age.
We do not knowingly collect, solicit data from, or market to children under 18 years of age, nor do we knowingly sell such personal information. By using the Services, you represent that you are at least 18, or that you are the parent or guardian of such a minor and consent to such minor dependent’s use of the Services.
If we learn that personal information from users less than 18 years of age has been collected, we will deactivate the account and take reasonable measures to promptly delete such data from our records. If you become aware of any data we may have collected from children under the age of 18, please contact us at info@getfairway.com.
- WHAT ARE YOUR PRIVACY RIGHTS?
In short: You may review, change, or terminate your account at any time, and depending on your jurisdiction, you may have additional rights.
Depending on your country, province, or state of residence, you may have certain rights regarding your personal information. These may include the right to:
- Request access to the personal information that we hold about you
- Request correction of inaccurate personal information
- Request deletion of your personal information
- Object to or restrict certain types of processing
- Withdraw consent where processing is based on consent
Withdrawing your consent
If we are relying on your consent to process your personal information, you have the right to withdraw your consent at any time. You can withdraw your consent by contacting us using the contact details provided in the section “12. HOW CAN YOU CONTACT US ABOUT THIS NOTICE?”.
Please note that withdrawing consent will not affect the lawfulness of processing before withdrawal, nor, when applicable law allows, will it affect processing based on other lawful grounds.
Account Information
If you would at any time like to review or change the information in your account or terminate your account, you can:
- Contact us using the contact information provided below.
Upon your request to terminate your account, we will deactivate or delete your account and information from our active databases. We may, however, retain some information in our files to prevent fraud, troubleshoot problems, assist with investigations, enforce legal terms, or comply with applicable legal requirements.
If you have questions or comments about your privacy rights, you may email us at info@getfairway.com.
- CONTROLS FOR DO-NOT-TRACK FEATURES
Most web browsers and some mobile operating systems and mobile applications include a Do-Not-Track (“DNT”) feature or setting you can activate to signal your preference that your online browsing activities not be monitored and collected. At this time, no uniform technology standard for recognizing and implementing DNT signals has been finalized. Therefore, we do not currently respond to DNT browser signals or any other mechanism that automatically communicates your choice not to be tracked online.
If a standard for online tracking is adopted that we must follow in the future, we will inform you in a revised version of this Privacy Notice.
California law requires us to let you know how we respond to DNT signals. Because there is currently no industry or legal standard for recognizing or honoring DNT signals, we do not respond to them at this time.
- DO UNITED STATES RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS?
In short: If you are a resident of certain U.S. states (including but not limited to California, Colorado, Connecticut, Delaware, Florida, Indiana, Iowa, Kentucky, Maryland, Minnesota, Montana, Nebraska, New Hampshire, New Jersey, Oregon, Rhode Island, Tennessee, Texas, Utah, or Virginia), you may have additional privacy rights.
Depending on your state of residence, you may have the right to:
- Request access to and receive details about the personal information we maintain about you and how we have processed it
- Correct inaccuracies in your personal information
- Obtain a copy of your personal information in a portable format
- Request deletion of your personal information
- Withdraw consent to certain processing activities
- Opt out of certain types of processing, such as targeted advertising, “selling” of personal information as defined by law, or profiling in furtherance of decisions that produce legal or similarly significant effects
- Not be discriminated against for exercising your privacy rights
Categories of Personal Information We Collect
In the last twelve (12) months, we have collected the categories of personal information set out below. The examples provided are illustrative and do not represent an exhaustive list.
A. Identifiers
Examples: Real name, alias, postal address, telephone number, unique personal identifier, online identifier, IP address, email address, account name.
Collected: YES
B. Personal information as defined in the California Customer Records statute
Examples: Name, contact information, education, employment, employment history, financial information.
Collected: YES
C. Protected classification characteristics under state or federal law
Examples: Gender, age, date of birth, race and ethnicity, national origin, marital status, and other demographic data.
Collected: YES
D. Commercial information
Examples: Transaction information, purchase history, financial details, payment information.
Collected: YES
E. Biometric information
Examples: Fingerprints, voiceprints.
Collected: NO
F. Internet or other similar network activity
Examples: Browsing history, search history, interactions with websites, applications, or advertisements.
Collected: YES
G. Geolocation data
Examples: Device location.
Collected: YES
H. Audio, electronic, sensory, or similar information
Examples: Images and audio, video, or call recordings created in connection with our business activities.
Collected: NO
I. Professional or employment-related information
Examples: Job title, work history, professional qualifications (e.g., if you apply for a job with us).
Collected: NO
J. Education information
Examples: Student records and directory information.
Collected: NO
K. Inferences drawn from other personal information
Examples: Profile or summary about a person’s preferences and characteristics.
Collected: NO
L. Sensitive personal information
Examples: Social security numbers, account login information, citizenship or immigration status, driver’s licenses, financial information including account access details, national origin, racial or ethnic origin, religious or philosophical beliefs, state ID card numbers, status as transgender or nonbinary, and similar data.
Collected: YES
We only use sensitive personal information as permitted by law or with your consent, and we do not use it to infer characteristics about you beyond what is necessary for lawful business or legal purposes.
Retention
We retain personal information as needed to provide our Services or for other stated purposes. For example, for categories A, B, C, D, and L, customer accounts and data are generally deleted within ninety (90) days of contract termination and after the data is no longer needed for business purposes, using manual data deletion processes, unless a longer period is required or permitted by law.
Sources of Personal Information
We collect personal information from you directly (for example, from forms you submit, documents you upload, or communications with us) and automatically (for example, through your use of the Services). For more detail, see “1. WHAT INFORMATION DO WE COLLECT?”.
How We Use and Share Personal Information
We use and share your personal information as described in “2. HOW DO WE PROCESS YOUR INFORMATION?” and “3. WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?”.
We have not sold or “shared” (as defined under certain state laws) any personal information to third parties for monetary or cross-context behavioral advertising purposes in the preceding twelve (12) months.
We have disclosed the following category to third parties for a business or commercial purpose in the preceding twelve (12) months:
- Category L: Sensitive personal information (for example, to service providers that help us process title and registration transactions, subject to contractual protections).
Your Rights
Depending on your state of residence, you may have the following rights:
- Right to know whether we are processing your personal data
- Right to access your personal data
- Right to correct inaccuracies in your personal data
- Right to request deletion of your personal data
- Right to obtain a copy of the personal data you previously shared with us in a portable format
- Right to non-discrimination for exercising your rights
- Right to opt out of:
- Targeted advertising (or “sharing” as defined by California law)
- Sale of personal data (where applicable)
- Profiling in furtherance of decisions that produce legal or similarly significant effects
- Targeted advertising (or “sharing” as defined by California law)
Depending on your state, you may also have the right to:
- Obtain information about the categories or specific third parties to whom we have disclosed personal data
- Review, understand, and (in some states) correct how personal data has been profiled
- Limit the use and disclosure of sensitive personal data
- Opt out of the collection of certain sensitive data or of data via specific technologies (e.g., voice or facial recognition), where such rights are provided by law (such as in Florida or California)
How to Exercise Your Rights
You can exercise your rights by:
- Emailing us at info@getfairway.com
- Using any other contact method provided in this Privacy Notice
If permitted under your local law, you may also designate an authorized agent to make certain requests on your behalf. We may require proof that the agent has been properly authorized in accordance with applicable law, and we may need to verify your identity directly.
Request Verification
We may need to verify your identity to process your request. We will only use the personal information you provide in connection with the request to verify your identity or authority and to process the request.
Appeals
If we decline to take action on your request, you may have the right to appeal our decision by emailing us at info@getfairway.com. We will then inform you in writing of any action taken or not taken in response to your appeal, including reasons for our decision. If your appeal is denied, you may be able to submit a complaint to your state attorney general or similar regulatory authority.
California “Shine the Light” Law
California Civil Code Section 1798.83 (the “Shine the Light” law) permits California residents to request and obtain, once per year and free of charge, information about categories of personal information (if any) we disclosed to third parties for direct marketing purposes and the names and addresses of all such third parties during the preceding calendar year. If you are a California resident and wish to make such a request, please submit it in writing using the contact details in the section “12. HOW CAN YOU CONTACT US ABOUT THIS NOTICE?”.
- DO WE MAKE UPDATES TO THIS NOTICE?
In short: Yes. We will update this notice as necessary to remain compliant with relevant laws.
We may update this Privacy Notice from time to time. The updated version will be indicated by a “Last updated” date at the top of this Notice. If we make material changes, we may notify you by prominently posting a notice on our Services or by sending you an email or other communication. We encourage you to review this Privacy Notice frequently to stay informed about how we are protecting your information.
- HOW CAN YOU CONTACT US ABOUT THIS NOTICE?
If you have questions or comments about this Notice, you may contact us:
By email:
- info@getfairway.com
By postal mail:
Palermo Solutions, Inc.
1710 Keller Pkwy #2041
Keller, TX 76248
United States
- HOW CAN YOU REVIEW, UPDATE, OR DELETE THE DATA WE COLLECT FROM YOU?
Depending on the laws of your country or your state of residence in the US, you may have the right to request access to the personal information we collect from you, obtain details about how we have processed it, correct inaccuracies, or delete your personal information. You may also have the right to withdraw your consent to certain processing activities, where applicable.
To request to review, update, or delete your personal information, or to exercise any other privacy right available to you, please contact us at:
- info@getfairway.com
We will respond to your request in accordance with applicable data protection laws.
