Senior Market Sales LLC Privacy Notice

About SMS and Why We Collect and Process Your Personal Data

SMS is a professional services company that provides a host of business to business and certain direct to consumer professional services, including the provision of insurance brokerage services on a wide range of insurance products and policies. From time to time we may use third party service providers to perform certain of these services. This Privacy Notice outlines the personal data we may collect, receive, and process and share as a result of the following:

• Client Relationships
• Business Relationships
• Individuals Who Use or Access our Website
• Other Business Activities, as described below

How We Collect Your Personal Data

In order to provide the tools and services you request, and for the operation and/or promotion of our business, we may need to collect information from you, including personal information. We collect information from you in the following ways: 
 
Directly From You. We may collect your personal data directly from you to provide you with the information, products and services you request from us, to contact you in response to inquiries you submit, to communicate with you, to provide you with notices about your account, to provide you with support, to investigate and address your concerns and monitor and improve our responses, to notify you about changes to the websites or any products or services we offer or provide though it, or to process your consumer requests and verify your identity, as applicable.
 
From Other Third Parties and Publicly Available Sources. We may collect your personal data from other third-party sources to conduct our business. This includes personal data we may receive or collect via social media apps and websites, from our service providers or subcontractors, from our marketing partners, and from other publicly-available sources – such as the County Assessor to access certain property and asset records, State and Federal courts to access legal proceeding and criminal conviction records, and professional licensure records, including those records received by way of authorized background checks and other legally permissible screening tools.

Automatically from your devices when you visit our website. We may collect certain personal data automatically from your device(s) when you visit our websites, depending on what you do when visiting our website as more fully set forth in our Terms of Use and in the Server and Site Visit Information below, but may include certain personal data about you to perform requested services or respond to inquiries.

What Personal Data We Receive or Collect

Depending on your relationship with SMS, we may collect the following types of personal data:
 
Personal, Demographic, and Contact Information. Name, email address, phone number, physical address, as well as your date of birth, age, gender, and marital status.
 
Identifying Information. Identification numbers issued by federal or state governmental agencies such as Social Security Numbers (SSNs), driver’s license number, passport number, tax identification numbers, and professional licensure details.
 
Account Information. If you communicate with us through our website or have an account with us, your username and password and any associated profile details you provide.
 
Financial and Payment Information. Billing address, bank account information, credit card details, financial information, brokerage account information, tax and income information, investment information, property and other asset and debt information.
 
Background Check and Screening Information Including Criminal Records Information. Personal data received from authorized background checks and screening including criminal records information.
 
Special Category and Sensitive Personal Data. Data related to your health, genetic, or biometric data, including protected health information, sexual orientation, gender identity, racial or ethnic origin, religious or philosophical beliefs, and union membership.
 
Professional Disciplinary Information. Information related to professional license-related discipline or suspension, including from certain governing federal or state regulatory agencies responsible for professional licensing.
 
Marketing and Event Attendance Information. This includes details about your visits to SMS offices and your virtual or physical attendance at SMS-sponsored events, and your interest in attending certain events or meetings. It also includes your preferences for receiving marketing materials, and whether you open certain communications and clicks links provided, and whether you complete surveys and your responses to those surveys.
 
Website Usage and Related Information. Any username and password or other information collected when you visit our website, including information collected by cookies and other tracking methods, including your IP address, domain name, location data, browsing time, and social medial related information.
 
Aggregate Information. SMS may also collect, receive, or maintain certain non-personal information that does not identify you as an individual person. We may use this information for our own legitimate business purposes, such as evaluating how people use and experience our website.

How We Use Your Personal Data

Depending on your relationship with SMS, we may use your personal data for the following purposes:

To Manage Our Relationship with You.

• To provide you with the tools and services that best meet your unique needs and preferences;
• To qualify you as a licensed insurance agent;
• To facilitate your contracting and/or appointment with insurance carriers;
• To maintain accurate records about who you are and where you learned about us;
• To maintain accurate records and a personal profile for your secure access via the Web.
• To communicate with the insurance provider(s) with whom you do business and/or to process information for delivery to them;
• When you purchase a product or service, in order to process your application, your payment, and to carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collection, and to facilitate delivery of the product or service.
• For improvement of the website and our services; to provide, support, personalize, and develop our website, products, services, and systems; for testing, research, analysis, and product development and improvement.

Marketing and Communication with You.

• To market our services or the services of third party marketing partners, including via e-mail, website, text message, mail, or telephone (with your consent, where required by law).
• To provide communications on industry developments we think may interest you, including legislative and regulatory developments that impact the services we provide you, and other information we believe may interest you.
• To deliver important materials to you pertaining to insurance carriers with whom you do business and products you may offer to your clients.
• To communicate with you about your account, policy, coverage, or the services we provide you, or could potentially provide you, including responding to your inquiries.
• To conduct market research.

To Operate and Protect against Unauthorized Access, Security Incidents, Fraud, and Other Malicious or Illegal Activity

• To create, maintain, customize, and secure your account with us.
• To help maintain the safety, security, and integrity of our website, products and services, databases and other technology assets and business.

To Comply with a Legal Requirement. To respond to regulatory and administrative agency requests, as well as law enforcement requests and as required by applicable law, court order, or governmental regulations, and to respond to civil litigation matters including subpoenas or other requests required by law.

To Conduct Our Business. To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of SMS’ assets, in which personal data held by SMS about our website users is among the assets transferred, as appropriate to protect SMS’ rights or property or to protect the rights or property of you, our customers or others, and for other business and operational purposes, including litigation management.

With Your Consent. SMS and its service providers may use your personal data for any other purpose with your consent. On other occasions where we ask you for consent, we will use the information for the purposes which we explain at that time. You have the right to withdraw your consent.

Legal Basis for Processing Personal Data. Where we are required to have a legal basis to process your personal data, our legal basis will be (1) pursuant to a legitimate interest; (2) for the performance of a contract, (3) to comply with a legal obligation, (4) to prevent or detect fraud, or (5) pursuant to your consent.

SMS will not collect additional categories of personal data or use the person information we collected for materially different, unrelated, or incompatible purposes without providing you notice.

How We Share Your Personal Data

SMS may share your personal data between and among its affiliates and subsidiaries based on your interactions with us, pursuant to the provision of our services, for a legitimate business operation purpose including marketing, data analytics, and surveys, benchmarking, or to comply with a legal obligation.
 
We may share your personal data for a business purpose with the following categories of third parties:
 
Business Partners. Third parties to whom we need to disclose your information in connection with products or services we provide you such as insurance carriers and brokers, managing general agents, our affiliates and subsidiaries, and other consultant or third parties necessary to provide our services.
 
Service Providers. Third party subcontractors who support us in our capacity as in the provision of our services to you and other clients, information technology service providers responsible for our information security, telephone or internet providers, marketing agencies where authorized under law or with your consent, and background check and credit reference agencies.
 
Insurance Carriers Who Provide Our Insurance.
 
Governmental Agencies, Regulators, and Law Enforcement. Agencies responsible for relevant licensing and oversight of the various industries in which we provide services, and law enforcement with appropriate jurisdiction, judicial bodies, and quasi-governmental authorities.
 
SMS may disclose aggregated information about you without restriction. This data cannot be attributed to any specific individual. We may disclose aggregated customer data to our affiliates and to other third parties for lawful purposes.
 
If some or all of our assets are sold or transferred or used as security, or to the extent we engage in business negotiations with our business partners, the information collected on the website may be transferred or shared with third parties as part of that transaction or negotiation.

No mobile information will be shared with third parties or affiliates for marketing and/or promotional purposes. All other categories exclude text messaging originator opt-in data and consent; this information will not be shared with third parties.

How We Protect Your Personal Data

We take commercially reasonable steps to protect the privacy of your data by restricting access to our personnel on a need-to-know basis in connection with our providing services to you and by safeguarding it from unauthorized individuals by limiting access to our databases. Although access to your information is restricted by reasonable physical, technical, and organizational safeguards, it should be understood that we cannot guarantee complete security or accuracy of customer information. We ask that you assist our security efforts by maintaining the privacy of all computer passwords that you use to connect with SMS and to encrypt confidential information transmitted to us over the internet. Please also advise us immediately at the address listed below of any incident involving the loss of or unauthorized access to or disclosure of personal data that is in our custody or control.
 
When we disclose personal data for a business purpose, we take commercially reasonable steps to ensure that the service provider or other third party who receives the information protects it and maintains a comparable level of protection as set forth in this Notice. As necessary, and when required by law, we enter into a contract that requires the service provider or third party to process and retain that information only for the purposes we have shared it with them and in a manner that complies with our legal obligations to you.

How Long We Retain Your Personal Data

We retain personal data for as long as necessary to provide services to you and fulfill the transactions you have requested, or for other necessary purposes such as complying with our legal obligations and enforcing our agreements. Retention periods vary depending on the type of information and how it is used. The criteria we use to determine the appropriate retention periods include:

• How long we have a relationship with you and provide services or products to you.
• Whether there is a legal, contractual or similar obligation that requires us to keep your information for a certain period of time.
• Whether you have consented to retention of your information for a longer period of time.
• Whether the personal data is sensitive.
• When we no longer need to use or retain your personal data, we will remove it from our systems or depersonalize it so that it cannot be used to identify you.

Communications Preferences

You may receive electronic communications from SMS when you provide your email address. If you do not wish to continue receiving email communications you can opt-out by following the unsubscribe instructions provided in such communications.

Third Party Sites

Our websites may contain links to other websites. Please note that when you click on one of these links, you may leave our website and will be subject to the notices and privacy practices of the other site, which may differ significantly. You should review the notices of other sites you visit. The Company is not responsible for the content, technology, security, or practices of linked sites operated by others, or for your use of linked sites.

Server and Site Visit Information

Like every website, the SMS servers automatically and temporarily store the following information in the server log files. This information is provided by your browser, unless you have deactivated the function.

• IP address of the inquiring computer
• File query by the client
• The http response code
• The Internet page from which you visited us (referrer URL)
• The time of the server query
• The browser type and version
• The operating system used on the enquiring computer
• The server log files are not analyzed with respect to individuals. At no time can this data be attributed to specific individuals.

Cookies and Similar Technology. As is standard practice on many websites, our website may use “cookies” and other technologies to help SMS understand which parts of the website are the most popular and the preferences of the SMS’ agents and customers. SMS may also use cookies and other technologies to study traffic patterns on the websites, to improve their functionality and usability as well as to improve the effectiveness of our communications with users. SMS may also use cookies to customize your experience and provide greater convenience to you during your interactions with the website.
 
A cookie is a unique alphanumeric identifier that websites use to help identify the number of unique visitors to a website, whether or not those visitors are repeat visitors, and the source of the visits. Cookies cannot be executed as code or used to deliver a virus and thus pose no threat to you. Servers and sites other than the one placing the cookie on your hard drive cannot read the cookie, and no personal data can be gathered by other servers from the cookie. If you prefer not to enable cookies or to disable them, you may do so through your web browser’s security settings. Please note that certain features of the website may not be available once cookies have been disabled.
 
Some of our communications to you may contain a “click-through URL” which links to content on the website. When you click one of these URLs, it passes information through the SMS web server before you arrive at the destination web page. SMS tracks this click-through data to help determine interest in particular topics and measure the effectiveness of our communications. If you prefer not to be tracked, simply avoid clicking text or graphic links in emails you receive from SMS.
 
Certain features of the website may use local stored objects (“Flash cookies”) to collect and store information about your preferences and navigation to, from, and on our websites. Flash cookies are not managed by the same browser settings as are used for browser cookies.
 
Different Devices. If you use different devices (e.g., your smart phone, laptop, and/or home computer) to access the website, we may be provided with and collect device-specific information, including your hardware model, operating system version, unique device identifiers, phone number, location, and mobile network information. We may associate your device identifiers or phone number with your account information.
 
Third-Party Analytics. We may use third-party service providers (e.g., search engines) to collect and analyze information about use of the website. These service providers may utilize cookies and related technologies to collect personal data.

Children’s Privacy

The website not aimed at or intended for children. We do not knowingly collect or sell information from children under the age of sixteen through the website. If we obtain actual knowledge that we have inadvertently collected personal data from a child under the age of sixteen, we will delete that information from our records. If you believe we might have any information from a child under the age of thirteen, please contact us here. 

Applicable Law

We recognize that the website may be accessed from anywhere in the world, and that the laws of the jurisdictions in which some users are located may differ substantially from those of the United States and the State of Nebraska. Because we cannot practicably prevent users in different jurisdictions from accessing the website, you are responsible for knowing and complying with the laws of your jurisdiction. If such laws conflict with your use of the website or any of their content or functionality, the website is not intended for you, and we ask you not to use them or submit any information through them.

Cross-Border Transfers

We may transfer your personal data to other countries in compliance with applicable laws. In certain circumstances, courts, law enforcement agencies, regulatory agencies or security authorities in those countries may have access to your personal data.

Updates to this Privacy Notice

SMS may update this Privacy Notice and the website to reflect material changes in how we collect, use, share, or store your information, to satisfy legal requirements, or for other business purposes. You should review this Privacy Notice when you visit the website to understand our current practices. The date at the top of the page shows when this Privacy Notice was last updated.
 
We encourage you to refer to this Privacy Notice on an ongoing basis so that you understand our current practices. When we make changes to this privacy notice, we will post the updated notice on the Website and update the notice’s effective date. Your continued use of our website following the posting of changes constitutes your acknowledgement and acceptance of such changes.
 
SMS reserves the right to amend this privacy notice at our discretion and at any time.

Interpretation of this Privacy Notice

Any interpretation associated with this Privacy Notice will be made by SMS’ legal counsel. This Privacy Notice includes examples but is not intended to be restricted in its application to such examples, therefore where the word ‘including’ is used, it means “including without limitation.”
 
This Privacy Notice does not create or confer upon any individual any rights, or impose upon SMS any rights or obligations outside of, or in addition to, any rights or obligations imposed by applicable country, state, and other privacy laws, as applicable. Should there be, in a specific case, any inconsistency between this Privacy Notice and applicable privacy laws, this Privacy Notice shall be interpreted in that case to give effect to, and comply with, such privacy laws.

Contact Us

If you have questions or comments about this Notice, the ways in which SMS collects and uses your information, your choices and rights regarding such use, or you wish to exercise your rights under applicable law, please contact us using the information below.

• Calling Us: (800) 786-5566, extension 4567
• Emailing Us: privacy@seniormarketsales.com
• Visiting Our Website: https://seniormarketsales.com/contact-us/

Privacy Rights for California Residents

The California Consumer Privacy Act (CCPA), as amended by the California Privacy Rights Act, and applicable regulations, (collectively, the “CPRA”) require that SMS make certain disclosures that are applicable to California residents. This section specifically describes the applicable rights under the CPRA and how California residents may exercise those rights.

Legal Categories of Personal Information. We are required by the CPRA to tell you about the personal data we collect about you in a certain way; specifically in California, we need to tie it back to “legal categories” of personal information that are listed in the law. To do this, we bundled the information we provided in this Notice and matched the different types of personal data we collect about you with the legal category. To make things easier to understand, we’ve made a chart that shows you six things:

1. The legal category of personal information.
2. Examples of the types of personal information included in each legal category.
3. The source from which your personal information is collected.
4. The purpose for why we collect and use your personal information for each legal category.
5. The business purposes for which we share your personal information and with whom.
6. Whether we sell your personal information.

We’ve included this information in the Personal Information Privacy Chart at the end of this Notice.

Privacy Rights for California Residents

This section describes the privacy rights of California residents in greater detail. In certain situations where we have established a direct relationship with you, versus receiving your information from other third parties to perform services for them, you may have the right to:

• Know: You have the right to request that SMS disclose certain information to you about our collection and use of your personal information, including what information we collect, the sources, the purpose for collecting and/or selling your information, third parties with whom your information is shared or sold, and the specific pieces of personal information we have about you.
• Change or Correct: You have a right to correct personal information that we hold about you that is inaccurate or incomplete. You can review and edit your personal information by logging onto our websites and visiting your account. You may also send us an email to correct any personal information that you have provided to us.
• Delete: Under certain circumstances, you can request that we erase or delete all or some of your personal information (e.g., it is no longer necessary to provide services to you).
• Opt Out of Sale or Sharing: You have the right to ask us not to sell your personal information or share it for purposes of targeted advertising or profiling that produces significant effects about you.
• Limit Sensitive Information: Sensitive Personal Information includes your Social Security number, driver’s license number, state ID card, passport number, precise geolocation, racial or ethnic origin, union membership, and health and genetic data. You may have the right to ask us to limit our use of your Sensitive Personal Information to only what is required to accomplish the purposes we included in this privacy notice or that you reasonably expect from us. Our practice is to not process your Sensitive Personal Information except when it is necessary to accomplish the purposes disclosed in this Notice.
• Non-Retaliation for Exercising Privacy Rights: You have the right not to receive discriminatory treatment for the exercise of your privacy rights conferred by applicable law.

Opting Out of the Sale or Sharing of Personal Information

California residents have the right to opt-out of the sale of their Personal Information, or the sharing of their Personal Information to a third party for cross-context behavioral advertising (i.e., targeted advertising), whether or not for monetary or other valuable consideration. Nevada residents have the right to opt-out of the sale of certain covered personally identifiable information we have collected about them through our websites and online services, as those terms are defined under applicable Nevada law. California and Nevada residents may exercise these rights by clicking on the “Do Not Sell or Share My Information” link on our homepage, or by: 

• Calling Us: (800) 786-5566, extension 4567
• Emailing Us: privacy@seniormarketsales.com
• Visiting Our Website: https://seniormarketsales.com/contact-us/

To disable sharing through cookies set by third-parties that may be considered “sales” or “sharing” under the CPRA, click here.

Subject to applicable law, opting out through this mechanism will not prevent your personal information from being shared with third parties for non-marketing purposes (for example, to process one of your transactions). Further, this opt out mechanism will not prevent the transfer of personal information in connection with a merger, acquisition, bankruptcy or other sale of all or a portion of our assets.

How to Make a Request

To exercise any of the privacy rights described above, please submit a request by:

• Calling Us: (800) 786-5566, extension 4567
• Emailing Us: privacy@seniormarketsales.com
• Visiting Our Website: https://seniormarketsales.com/contact-us/

In your request, please include your name, email address, home address, zip code, and the type of request you would like to make. To the extent you have established an account with our system, you can review and change your personal information by logging into the website and visiting your account. You may also send us an email to correct or delete any personal information that you have provided to us. If you request that your account information be deleted or if you unsubscribe from communications, we may maintain information about your transactions or inquiries for future service and recordkeeping purposes. In some circumstances, a change in or withdrawal of consent may severely limit our ability to provide you information, products, or services. We may not accommodate a request to change information if we believe the change would violate any law or legal requirement or cause the information to be incorrect.
 
Verifying your Identity. For your protection, we may need to verify your identity before fulfilling your request. To do this, we may ask for at least two data points that match the data points we maintain about you to compare the information and verify your identity. We will only use personal information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request, and will request your contact information (name, address, email address, employer name and address, phone number), and as necessary, may request your account information, date of birth, partial social security number, geolocation, and/or professional details including professional licensure and professional credentials. Please note that we may need to retain certain information for recordkeeping purposes or to complete transactions that occurred prior your request. We will also retain your personal information if reasonably necessary to comply with our legal obligations, meet regulatory requirements, resolve disputes, maintain security, prevent fraud and abuse, or enforce the Terms and Conditions.

Only you, or a representative that you authorize to act on your behalf, may make a verifiable consumer request related to your personal information. The verifiable consumer request must:

• Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative.
• Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you. Making a verifiable consumer request does not require you to create an account with us.

Requests by Authorized Agents. You may have the right to designate an authorized agent to make a request on your behalf. You may authorize an agent to make a request by providing the agent with written permission to act on your behalf. We will ask the agent to provide proof of that written permission by providing their professional licensure information and letter of representation. If permitted by law, we will also require that you and/or your agent to verify your own identity in response to a request, even if you chose to submit a request using an agent.

Your request will be evaluated to determine whether the requested change meets legal regulatory requirements and whether we have a legal obligation that prohibits us from fulfilling your request. If we aren’t able to honor any part of your request, we will tell you that in our response, as well as the reason(s) we cannot do so.

To learn more about how to make these requests, please contact us here.

Response Timing and Format

We endeavor to respond to a verifiable consumer request within forty-five (45) days of receipt. If we require more time, we will inform you of the reason and extension period in writing.
 
We will deliver our written response by mail or electronically at your option. Any disclosures we provide will only cover the twelve (12) month period preceding the verifiable consumer request’s receipt. The response we provide will also explain the reasons we cannot comply with a request, if applicable.
 
We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.

California’s “Shine the Light” Law

California’s “Shine the Light” law (Civil Code Section 1798.83) permits users of our website that are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. If applicable, this information would include a list of the categories of personal information that was shared and the names and addresses of all third parties with which the Company shared information in the immediately preceding calendar year. To make such a request, please send an email.

“Do Not Track” Signals

“Do Not Track” is a privacy setting that you may set in your web browsers. If turned on, this setting requests that websites not track information about users. At this time, we do not respond to “Do Not Track” browser settings or signals.

Exemptions under the California Privacy Rights Act (CPRA) 

Certain types of data are exempt from the requirements of the CPRA. This includes but is not limited to: protected health information collected by a covered entity or business associate and governed by the Health Insurance Portability and Accountability Act of 1996 (HIPAA); medical information governed by the California Confidentiality of Medical Information Act (CMIA); personal information collected, processed, sold, or disclosed pursuant to certain sector-specific privacy laws, including the Fair Credit Reporting Act (FCRA), the Gramm-Leach-Bliley Act (GLBA), or California Financial Information Privacy Act (FIPA), and the Driver’s Privacy Protection Act of 1994 (DPPA).

Use of Sensitive Personal Information

We do not use, receive, collect, or disclose sensitive personal information for purposes other than those authorized under the CPRA. At times, SMS may need to receive, collect, or disclose your sensitive personal information as necessary for provision of insurance services, our operations in furtherance of a substantial public interest, and/or where you have given us your explicit consent, or where a third party is responsible for obtaining your explicit consent to enable us to collect and use your data for the purposes described in this Privacy Notice, or to establish, exercise or defend legal claims; only. If SMS wishes to use your personal information beyond what is needed for or expected by you in the context of your relationship with SMS, SMS will request your affirmative consent before using your sensitive personal information for these new purposes. 

Personal information Privacy Chart

Categories of Sources from which the Information was Collected	Business or Commercial Purpose(s) for which Information is Collected	Categories of Third Parties to whom this type of Personal Information is Disclosed for a Business Purpose	Categories of Third Parties to Whom this Type of Personal Information is Sold or Shared (for Cross Contextual Behavioral Advertising)
Category of Personal Information Collected: Identifiers This category includes real name; alias; contact information (such as postal address, phone number, and email address); unique personal identifier; online identifier; device identifier; Internet Protocol address; account name; birth day and month; or other similar identifiers.
We may collect this type of information from: Consumer (i.e., you);	This information is collected: To provide you with the tools and services that best meet your unique needs and preferences; When you purchase a product or service, in order to process your application; To qualify you as a licensed insurance agent, or facilitate your appointment with insurance carriers; To communicate with the insurance provider(s) with whom you do business and/or to process information for delivery to them;   To maintain accurate records about who you are and where you learned about us; To maintain accurate records and a personal profile for your secure access via the Web; To create, maintain, customize, and secure your account with us; To market our services or the services of third party business partners, including via e-mail, website, text message, mail, or telephone (with your consent, where required by law); To provide communications on industry developments we think may interest you, including legislative and regulatory developments that impact the services we provide you, and other information we believe may interest you; To deliver important materials to you pertaining to insurance carriers with whom you do business and products you may offer to your clients; To communicate with you about your account, policy, coverage, or the services we provide you, or could potentially provide you, including responding to your inquiries; For legal, regulatory and internal business purposes; To help maintain the safety, security and integrity of our website, products and services, databases and other technology assets and business; For other purposes disclosed to you at the time of collection or undertaken with your consent.	We may disclose this type of information to: Third parties (including insurance carriers) to whom we need to disclose your information in connection with products or services we provide you; Service providers, such as those described in the “HOW WE SHARE YOUR PERSONAL DATA” section of our Privacy Policy, above; Third parties or affiliated companies when you agree to or request that we share your information with them; Third parties who may acquire your information as a result of a merger, acquisition or other ownership transition; Governmental agencies, regulators, and law enforcement agencies responsible for relevant licensing and oversight of the various industries in which we provide services, and law enforcement with appropriate jurisdiction, judicial bodies, and quasi-governmental authorities.	We may sell or share this type of personal information to/with: Our affiliates and third party business partners for their own marketing purposes. Third-party advertising, analytics, and similar marketing business partners may have access to this data and this may be considered a “sale” or “share” under the CCPA and CPRA under certain circumstances.
Category of Personal Information Collected: Customer Records This category includes name, signature, social security number, address, telephone number, passport number, driver’s license or state identification card number, insurance policy number, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information.
We may collect this type of information from: Consumer (i.e., you);	This information is collected: To provide you with the tools and services that best meet your unique needs and preferences; When you purchase a product or service, in order to process your application, your payment, and to carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collection, and to facilitate delivery of the product or service; To qualify you as a licensed insurance agent, or facilitate your appointment with insurance carriers; To communicate with the insurance provider(s) with whom you do business and/or to process information for delivery to them;   To maintain accurate records about who you are and where you learned about us; To maintain accurate records and a personal profile for your secure access via the Web; To create, maintain, customize, and secure your account with us; To market our services or the services of third party business partners, including via e-mail, website, text message, mail, or telephone (with your consent, where required by law); To provide communications on industry developments we think may interest you, including legislative and regulatory developments that impact the services we provide you, and other information we believe may interest you; To deliver important materials to you pertaining to insurance carriers with whom you do business and products you may offer to your clients; To communicate with you about your account, policy, coverage, or the services we provide you, or could potentially provide you, including responding to your inquiries; For legal, regulatory and internal business purposes; To help maintain the safety, security and integrity of our website, products and services, databases and other technology assets and business; For other purposes disclosed to you at the time of collection or undertaken with your consent.	We may disclose this type of information to: Third parties (including insurance carriers) to whom we need to disclose your information in connection with products or services we provide you; Service providers, such as those described in the “HOW WE SHARE YOUR PERSONAL DATA” section of our Privacy Policy, above; Third parties or affiliated companies when you agree to or request that we share your information with them; Third parties who may acquire your information as a result of a merger, acquisition or other ownership transition; Governmental agencies, regulators, and law enforcement agencies responsible for relevant licensing and oversight of the various industries in which we provide services, and law enforcement with appropriate jurisdiction, judicial bodies, and quasi-governmental authorities. Other third parties to comply with law, regulation, or legal request (such as pursuant to subpoenas or court orders), or to protect or defend our or any third party’s legal rights.	We do not sell or share this category of information.
Category of Personal Information Collected: Professional or employment-related information Information related to professional license-related discipline or suspension, including from certain governing federal or state regulatory agencies responsible for professional licensing.
We may collect this type of information from: Consumer (i.e., you);	This information is collected: To qualify you as a licensed insurance agent, or facilitate your appointment with insurance carriers; To communicate with the insurance provider(s) with whom you do business and/or to process information for delivery to them;   For legal, regulatory and internal business purposes; For other purposes disclosed to you at the time of collection or undertaken with your consent.	We may disclose this type of information to: Third parties (including insurance carriers) to whom we need to disclose your information in connection with products or services we provide you; Service providers, such as those described in the “HOW WE SHARE YOUR PERSONAL DATA” section of our Privacy Policy, above; Third parties or affiliated companies when you agree to or request that we share your information with them; Third parties who may acquire your information as a result of a merger, acquisition or other ownership transition; Governmental agencies, regulators, and law enforcement agencies responsible for relevant licensing and oversight of the various industries in which we provide services, and law enforcement with appropriate jurisdiction, judicial bodies, and quasi-governmental authorities. Other third parties to comply with law, regulation, or legal request (such as pursuant to subpoenas or court orders), or to protect or defend our or any third party’s legal rights.	We do not sell or share this category of information.
Category of Personal Information Collected: Characteristics of Protected Classifications under California or Federal Law This category includes age; marital status; and sex (including gender)
We may collect this type of information from: Consumer (i.e., you);	This information is collected: When you purchase a product or service, in order to process your application; For legal, regulatory and internal business purposes; For other purposes disclosed to you at the time of collection or undertaken with your consent.	We may disclose this type of information to: Third parties (including insurance carriers) to whom we need to disclose your information in connection with products or services we provide you; Service providers, such as those described in the “HOW WE SHARE YOUR PERSONAL DATA” section of our Privacy Policy, above; Third parties or affiliated companies when you agree to or request that we share your information with them; Third parties who may acquire your information as a result of a merger, acquisition or other ownership transition; Governmental agencies, regulators and law enforcement agencies responsible for relevant licensing and oversight of the various industries in which we provide services, and law enforcement with appropriate jurisdiction, judicial bodies, and quasi-governmental authorities. Other third parties to comply with law, regulation, or legal request (such as pursuant to subpoenas or court orders), or to protect or defend our or any third party’s legal rights.	We do not sell or share this category of information.
Category of Personal Information Collected: Commercial Information This category includes information about your transactions with us, including records of products and services you purchase or use; information about your contact history with our company (such as when you interact with our team over the phone or through our website or if you respond to our text messages, including transcriptions of conversations and IVR recordings); and information about your participation in marketing and special events.
We may collect this type of information from: Consumer (i.e., you);	This information is collected: To provide you with the tools and services that best meet your unique needs and preferences; To communicate with the insurance provider(s) with whom you do business and/or to process information for delivery to them;   To maintain accurate records about who you are and where you learned about us; To maintain accurate records and a personal profile for your secure access via the Web; To create, maintain, customize, and secure your account with us; To market our services or the services of third party business partners, including via e-mail, website, text message, mail, or telephone (with your consent, where required by law); To communicate with you about your account, policy, coverage, or the services we provide you, or could potentially provide you, including responding to your inquiries; For legal, regulatory and internal business purposes; To help maintain the safety, security and integrity of our website, products and services, databases and other technology assets and business; For other purposes disclosed to you at the time of collection or undertaken with your consent.	We may disclose this type of information to: Third parties (including insurance carriers) to whom we need to disclose your information in connection with products or services we provide you; Service providers, such as those described in the “HOW WE SHARE YOUR PERSONAL DATA” section of our Privacy Policy, above; Third parties or affiliated companies when you agree to or request that we share your information with them; Third parties who may acquire your information as a result of a merger, acquisition or other ownership transition; Governmental agencies, regulators, and law enforcement agencies responsible for relevant licensing and oversight of the various industries in which we provide services, and law enforcement with appropriate jurisdiction, judicial bodies, and quasi-governmental authorities. Other third parties (including government agencies) to comply with law, regulation, or legal request (such as pursuant to subpoenas or court orders), or to protect or defend our or any third party’s legal rights.	We may sell or share or share this type of personal information to/with: Our affiliates and third party business partners for their own marketing purposes. Third-party advertising, analytics, and similar marketing business partners may have access to this data and this may be considered a “sale” or “share” under the CCPA and CPRA under certain circumstances.
Category of Personal Information Collected: Internet or Other Electronic Network Activity This category includes: the hardware model, browser, and operating system you are using; the URL or advertisement that referred you to the website you are visiting; all of the areas within the websites that you visit; devices you have used to access the website; login information (such as your last login); your time zone; location information based off your IP address; mobile network (if applicable); and session recordings.
We may collect this type of information from: Cookies and tracking technologies.	This information is collected: To allow you to use our websites, applications, or features or activities we offer; To protect against misuse of our websites or applications, fraud, or any criminal activity; To help us serve you better, including personalizing your interactions with us through our websites and applications, and tailoring content and recommendations we make to you; To improve our websites and applications, or our products and services; For legal, regulatory and internal business purposes; and To detect and troubleshoot problems, resolve disputes, and enforce applicable agreements and policies for our websites and applications.	We may disclose this type of information to: Our affiliates; Service providers, such as those described in the “HOW WE SHARE YOUR PERSONAL DATA” section of our Privacy Policy, above; Third parties when you agree to or request that we share your information with them; Third parties who may acquire your information as a result of a merger, acquisition or other ownership transition; Other third parties (including government agencies) to comply with law, regulation, or legal request (such as pursuant to subpoenas or court orders), or to protect or defend our or any third party’s legal rights.	We may sell or share this type of personal information to/with: Our affiliates and third party business partners for their own marketing purposes. In addition, third-party advertising, analytics, and similar marketing business partners may have access to this data and this may be considered a “sale” or “share” under the CCPA and CPRA under certain circumstances.
Category of Personal Information Collected: Inferences Drawn from Any of the Information Identified Above to Create a Profile about a Consumer We may draw inferences from any of the information we have collected or may receive inferences drawn by a third party. These inferences may relate to your perceived interests, preferences, characteristics, or behavior.
We may collect this type of information from: We may draw these inferences ourselves or acquire them from third-party data resellers.	This information is collected: To help us serve you better, including personalizing your interactions with us in person, on the phone, or through our website, and tailoring content and recommendations we make to you; To improve our websites, applications or our products and services.	We may disclose this type of information to: Our affiliates; Service providers, such as those described in the “HOW WE SHARE YOUR PERSONAL DATA” section of our Privacy Policy, above; Third parties when you agree to or request that we share your information with them; Third parties who may acquire your information as a result of a merger, acquisition or other ownership transition; Other third parties (including government agencies) to comply with law, regulation, or legal request (such as pursuant to subpoenas or court orders), or to protect or defend our or any third party’s legal rights.	We may sell or share this type of personal information to/with: Our affiliates and third party business partners for their own marketing purposes. In addition, third-party advertising, analytics, and similar marketing business partners may have access to this data, including to better serve you more relevant and sometimes location-based advertisements, and this may be considered a “sale” or “share” under the CCPA and CPRA under certain circumstances.