Date last updated: 09/09/2022
The purpose of the Platform is to receive information about individuals who are interested in insurance products (“Consumers”) and make such information available to licensed insurance agents to assist individuals with the purchase of the products (“Agents”). We may also work with “Lead Vendors” – companies that collect inquiries from Consumers and pass such inquiries to Agents. Lead Vendors must obtain appropriate consent from Consumers to be contacted regarding specific products before providing us with such Consumers’ information.
HIPAA and GLBA
Because we facilitate the sale of a diverse range of insurance products, our processing of some information on behalf of our agents may fall under another state or federal regulatory framework, like the Health Insurance Portability and Accountability Act (“HIPAA”) and related state laws, or the Gramm-Leach-Bliley Act (“GLBA”) and related state laws.
Specifically, we act as a Business Associate (as defined by HIPAA) when we receive client Protected Health Information (“PHI”) from lead vendors or on behalf of a health plan that is a Covered Entity (as defined by HIPAA). In our role as a Business Associate we collect, use, and disclose PHI to provide services for or on behalf of health plans. For more information about how PHI is used and disclosed, please review the applicable health plan’s Notice of Privacy Practices.
When we receive client information pertaining to certain insurance or financial products, we may collect non-public personal financial information, which is regulated by GLBA. For more information about how non-public personal financial information is used and disclosed, please review the GLBA Notice provided by the financial institution that issued the clients’ policies or products.
Personal Information We Collect
The table below details the categories of Personal Information that we collect or obtain through the operation of the Platform.
|Category||Examples and Sources|
|Consumers’ and Agents’ name, phone number, and email address, as well as Consumers’ postal address.
We collect this information about Consumers from Lead Vendors, the Company, Agents, data brokers, and agencies.
We collect this information about Agents from Agents or marketing organizations in the Agents’ product sale hierarchy.
|Login credentials||This includes username and password* when Agents or Consumers choose to create an account with us.|
|Identification information||Agents’ National Producer Number.
We collect this information from Agents when they register for the Platform.
|Demographic information||Consumers’ age, date of birth, marital status, language preference, ethnicity, race, and sex or gender.*
We collect this information about Consumers when Lead Vendors, the Company, Agents, data brokers, and agencies provide it to us.
|Health information*||Consumers’ health information provided in the course of discussions with an Agent or representative, which is relevant to the processing of an application for an insurance product. For example, notes about a Consumer may state that the Consumer has diabetes, as is relevant for an application for a life insurance product.|
|Sensory information||We collect audio recordings of your conversations with representatives and Agents in connection with your inquiry regarding insurance products. We also have access to video snippets of user website activity evidencing consent to be contacted. This information is collected from Lead Vendors, Agents, and agencies.|
|Commercial information||We collect information about the products in which you are or may be interested, including information entered into insurance product applications, as provided by you, a Lead Vendor, Agent, data brokers, or an agency. We also collect information regarding your purchase of insurance products, including the type of product purchased and the corresponding carrier.|
|Internet or other similar network activity||Automatically-collected information on users’ interaction with the Platform. This may include your browsing history (including the site you came from before visiting our website and the site you went to after leaving our website), duration of browsing session, device ID, and IP address.|
|Geolocation data||We collect geolocation* from users to ensure the security and integrity of the Platform.|
|Education and profession||We collect from data brokers Personal Information about Consumers’ educational background, profession, income, product preference, consumer behavior, and asset ownership. This information is used for offline marketing.|
Types of Personal Information marked with an asterisk (*) may be considered “sensitive” personal information according to some state laws.
We may also partner with financial processors or payment vendors to provide services to Agents on the Platform, but these parties do not share Personal Information with us.
We do not collect biometric information.
Your information may be provided to us by your spouse or other family member.
We intend to keep the above categories of Personal Information for as long as reasonably necessary to achieve the business purposes for which they were collected. Our general business purpose is to connect Agents with Consumers and facilitate the sale of insurance products to Consumers.
Use of Personal Information
We may use or disclose the Personal Information that we collect for one or more of the following purposes:
- Operate the Platform;
- Communicate with you regarding the Platform;
- Contact Consumers through our employed agents regarding insurance products in which the Consumer expressed interest;
- Address users’ and Consumers’ inquiries;
- Process transactions;
- Tailor the content and information that we may send or display to you;
- Analyze use of our products and services;
- Develop new products and services;
- Comply with legal obligations;
- Protect our rights, property, and safety or the rights, property, and safety of others;
From time to time, we may contact users via email and mail, for the purpose of providing announcements, promotional offers, alerts, confirmations, surveys, and/or other general communication. If you would like to stop receiving marketing or promotional communications via email or mail from us, you may opt out of such communications by contacting us at the toll-free number or email address listed below.
We may also contact users and Consumers via text messaging, but only if such individuals opt in to receive text messages and only within the scope of such consent.
Sharing Personal Information
We may disclose all categories of Personal Information described above in “Personal Information We Collect” to the third parties listed below for the purpose of facilitating the sale of insurance products to individuals who are interested in purchasing such products.
- With Our Service Providers.We may share Personal Information about Consumers and Agents with third parties who perform services for us or on our behalf. For example, this may include payment processors and companies that send emails on our behalf or other operating systems or platforms that help us run our services.
- With Our Business Partners.This includes our affiliates in the insurance industry, insurance carriers, and any other entities that are involved in the sale of insurance products such as marketing organizations that specialize in the insurance industry.
- With Law Enforcement, Government Agencies, or Parties to a Legal Proceeding. We may share Personal Information with such entities to comply with the law or assist in law enforcement.
- With Our Independent Agents and Advisors. Agents and advisors have access to the Personal Information about Consumers that is provided by the Consumers when requesting information regarding insurance products.
We partner with these third parties to tailor and customize our advertising to Users. The practice of targeted advertising may be considered a “sale” of Personal Information under some state laws. For more information about your choices related to this practice, please see “Rights Regarding Personal Information,” below.
Children Under The Age of 16
The Platform is not intended for children under 16 years of age. We do not collect information about individuals under the age of 16. No one under age 16 may provide any information through the Platform. We do not knowingly collect Personal Information from children under 16. If you are under 16, do not use or provide any information through the Platform. If we learn we have collected or received Personal Information from a child under 16 without verification of parental consent, we will delete that information. If you believe we might have any information from or about a child under 16, please contact us.
Rights Regarding Personal Information
You may have the following rights (“Data Subject Rights”) with respect to the Personal Information that we collect or process about you. These rights differ depending on where you live (including specifically in California, Virginia, Colorado, Connecticut, Nevada, and Utah), but we will endeavor to respect these rights regardless of your place of residence. Please note that we reserve the right to honor your Data Subject Rights as required by applicable law.
- Right to Access and Obtain a Copy: If you ask us, we will confirm whether we are processing your Personal Information and, if so, provide you with a copy of all Personal information you are lawfully entitled to receive along with certain other details. In addition, you may request to know the types of third parties with whom we share your Personal Information, and the categories of Personal Information we share with them.
- Right to Amend: If you believe your Personal Information is inaccurate or incomplete, you are entitled to request that we correct or complete it. If you ask us, and where possible and lawful to do so, we will also tell you with whom we shared your Personal Information so you can contact them directly.
- Right to Delete: You may request that we delete or remove your Personal Information. If we shared your Personal Information with others, we will tell them about the erasure as directed by law.
- Right to Restrict Processing: You may ask us to restrict or ‘block’ the processing of your Personal Information in certain circumstances, such as if we process Personal Information that is considered “sensitive” under applicable state laws or engage in automated decision-making.
- Right to Opt Out of Targeted Advertising: Targeted advertising is the practice of serving you tailored advertisements based your Personal Information gathered across other businesses, websites, applications, or services. You have the right to opt out of this practice.
- Right to Opt Out of Sales: Some states consider targeted advertising a “sale” of Personal Information. You may request that we not “sell” your Personal Information.
- Right to Non-discrimination: We will not discriminate against you for exercising these rights, but we may charge a reasonable fee as permitted by law in fulfilling these rights, such as if you request multiple copies of your Personal Information.
If you or your authorized agent wish to exercise any of these Data Subject Rights, please contact us by following the steps below in ‘Contact Information.’ Before responding to your request to exercise Data Subject Rights, we may require additional information from you to verify your identity or clarify your specific request. We will try to comply with your request as soon as reasonably practicable and in compliance with applicable law. Where appropriate, we will work with third parties in order to fulfil your request.
If we deny any of the above rights, you may have the right to appeal the decision with us. If you would like to appeal a prior decision, please include ‘Appeal’ in your subject line, along with the prior request and related communications. Please send this to us following the instructions located below, in Contact Information. Additionally, you may have the ability to contact your state’s attorney general (see information listed below) if you have concerns about the results of the appeal, by using the links below:
Additional Notice to California Residents
The following disclosures are made in compliance with the California Consumer Privacy Act (CCPA), as amended. In the past 12 months, we have collected the Personal Information described above, and disclosed it to the third parties listed under the section “Sharing Personal Information.” This information falls into the following categories of Personal Information under the CCPA:
- Categories of Personal Information described in section 1798.80(e) of the California civil code
- Characteristics of protected classifications under California or federal law
- Commercial information
- Geolocation information
- Audio, electronic, or visual information
- Internet or electronic network activity information
- Professional or employment-related information
Because we engage in targeted advertising, we may “sell” Users’ Personal Information as defined under some state laws, including California. If you wish to opt out of this use of your information, please contact us by following the steps below in ‘Contact Information.’
We do not use or disclose sensitive Personal Information (indicated in the section “Personal Information We Collect” with an asterisk (*)) for purposes other than those specified in Cal. Code Regs. tit. 11, § 7027(l).
Additional Notice to Nevada Residents
Nevada law permits Nevada residents to request that we not sell their personal information. We do not sell personal information as defined by Nevada law. If you are a resident of Nevada and would like to request that we not sell your information in the future, please contact us by following the steps below in ‘Contact Information.’
If you have any questions or comments about this notice, or the ways in which we collect and use your personal information, please do not hesitate to contact us at:
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