Privacy

Policygenius Privacy Policy

Last updated February 1, 2022

This Privacy Policy describes how Policygenius (“we”, “us, or “our”) collects, uses, shares, and secures your personal information in connection with our website, mobile applications, and other digital properties that link to this Privacy Policy (collectively, the “Sites”) and how we provide the Sites, educational materials, insurance coverage estimates and quotes, insurance brokerage services, estate planning tools, and other services (the “Services”) more broadly. It applies to information collected from and about you in connection with your use of the Sites and Services, as well as from other sources, such as over the telephone with our representatives or from third parties in connection with our Services, and not to External Sites (as defined below). By using the Sites and Services, you consent to the data practices described in this Policy.

As providers of Services that involve the use of personal – and sometimes sensitive – information, protecting the confidentiality of that information is a top priority. This means we will never sell your personal information and we use industry standard technical, physical, administrative, and organizational controls, to ensure the security and confidentiality of your data! 

Our Gramm-Leach-Bliley Act (“GLBA”) Privacy Notice applies to personal information we collect, use, and share in connection with offering you financial products or services (including insurance products and services), whether that information is obtained through our Sites, over the telephone, from third parties, or by any other lawful means. Please read the GLBA Privacy Notice for information about your rights with respect to the information collected in connection with seeking, applying for, or obtaining insurance products or services from us.

We may change this Privacy Policy at any time, and we take such steps as required by applicable law to notify you of any material changes. Your continued use of the Sites or Services following the update and notification means that you consent to our updated policy.

CONTENTS

I. How and Where We Collect and Use Your Information

II. How We Share Your Information

III. How We Secure Your Information

IV. Users From Outside The U.S.

V. Children

VI. Job Applicants

VII. External Sites

VIII. How to Opt-Out

IX. Additional Information For California Residents

X. Online Tracking Opt-Out Guide

XI. Contact Us

I. How and Where We Collect and Use Your Information

You can use some of the Sites by just browsing (as a “Visitor”) or by accessing the Sites and Services after creating and maintaining an account, for example, to seek, apply for and/or purchase one or more products through the Sites (as a “Member”). 

You may also become a Member by providing us with information (as described below) when you seek, apply for and/or purchase one or more insurance products over the telephone with one of our representatives.

Each of Visitors and Members may be referred to in this Privacy Policy by the terms “user,” “you” or “your.” Some of our Services are only available to Members. 

1. Sources of Information 

The types and sources of personal information we collect depend on the Service utilized, how you interact with us and our Sites, and/or how you were referred to us. The types and sources of information may include:

• Information that you provide to us directly, for example: using our online tools; on applications or forms; during your transactions and communications with us, our representatives, or our business partners (e.g., through telephone conversations, emails, text messages, or chats).

• Information from third parties, including: consumer, credit, and/or other reporting agencies; Referral Partners (as further described below); insurance carriers; and medical or health care providers.

• Information generated through your interaction with our Sites, as well as from social networks or other third-party platforms you may use to access our Sites and Services (see “Establishing an Account” and “Social Features” below).

2. Types of Information We Collect and How We Use It:

Site Users

We collect “Usage Information” which may include: information about the technical mechanisms you used to access the Sites, such as your browser and operating system type; the link that brought you to our Sites; data points that help our analytics function and which tell us what brought you to a particular spot on our Sites; your specific type of mobile device and device ID; and your IP address.

We use Usage Information to inspect, analyze, and improve our Sites and Services and ensure they function well with the technology used by our Visitors and Members. In addition to analytics about the demographics of our Sites users, we use your IP Addresses to comply with legal rules applicable based on your location.

Newsletters

Visitors and Members may sign up for email newsletters by providing their first and last name, and email address. We collect and use information about your engagement with Newsletter communications (e.g., whether you view or click on those communications).

Marketing

In connection with our marketing campaigns, we collect and use information about your engagement with our marketing communications (e.g., whether you view or click on marketing emails) to make sure that the products and offers that we inform you of are relevant to you.

Email and Chat

Visitors and Members can communicate with us over email or chat on the Sites by providing their first and last name, and email address. We will use this information to provide products and services relevant to you. Members may also share additional personal information with us over chat or email when communicating about the Services. We may collect this information to provide you with the Services, such as to complete an insurance application. 

Customer Surveys and Reviews

We may ask you to participate in customer reviews and surveys. If you participate, we may request certain personal information. Participation in these surveys is completely voluntary and you therefore have a choice whether or not to disclose this information. The requested information typically includes first and last name, contact information (such as email or address), and demographic information (such as zip code).

We use this information to evaluate our level of customer service, as well as test and make improvements on our products, Sites, and Services. With your consent, we may use your first and last name, along with your responses, on our Sites, in marketing materials, or on our social media platforms. With your consent, we may pass on your information to a third-party service provider, to assist in resolving errors or make improvements relating to their services.

Establishing an Online Account

You can establish an online account on the Sites by providing your first and last name, and email address. You may be required to create a password for your account (together with your name and email address, “Login Credentials”). You may also provide your telephone number when creating your account. We may use your email address and telephone number to contact you about the Services and products you have requested. 

You may also choose to login via a social network or other third-party platform (for example, Facebook or Google). We may collect information from that platform, such as your social network alias, email address, first and last name, country of residence, language preference, and profile picture, and use it as described in this Privacy Policy. Our collection and processing of the information we obtain from third-party platforms are also governed by the requirements these platforms impose on us in their relevant terms and conditions. We encourage you to review the privacy policies of such third-party platforms to obtain information regarding their information collection, use, and disclosure policies.

Getting Insurance Estimates

If you choose to use the Sites and Services to receive an insurance estimate, you will become a Member and will be required to provide us with additional personal information we use in connection with providing the estimate. This may include (depending on the type of insurance) your age, gender, zip code, marital status, employment status, risk tolerance, living situation details, property and vehicle ownership information, family information such as number of children and number of pets, whether you are a homeowner or a renter, your income, amounts of your savings and debts, and general details about your current insurance coverage (collectively, “Estimate Information”), as well as contact information including your first and last name, email address, and telephone number (“Contact Information”). 

If you choose to access the Services, receive an insurance estimate, and become a Member over the telephone, you will need to provide the Estimate Information and Contact Information to one of our representatives over the telephone. 

We use the Estimate Information to return results to you that assess your current coverage and/or provide recommendations for insurance products. We use the Contact Information to contact you regarding insurance products and Services.

Getting Quotes & Applying for Insurance

To get an insurance quote and apply for an insurance policy, in addition to the Estimate Information described above, you may need to supply additional information, such as your date of birth, gender, occupation, social security number, address, smoking status, height and weight, family medical history, health history, driving history, and your citizenship status (collectively with Estimate Information, “Application Information”). 

“Account Information” will include your Login Credentials, together with your Estimate Information, Contact Information, and Application Information.

Banking and Credit Card Information

If you submit a credit card payment through our Services, for example to purchase insurance coverage, we do not store credit card information on our own servers or associate it with your Account Information for any purpose other than completing your purchase.

If you submit bank account information, for example purchase insurance coverage, that bank information is stored on our servers in encrypted form and is accessed and used to complete your insurance application or purchase. 

If you submit credit card or other payment information via DocuSign, it will be temporarily stored in encrypted form on DocuSign’s servers, and we will use the payment information to securely transmit your payment information to the carrier.

Policy Information

If you apply for insurance, we may collect information about your application or policy from the insurance carrier, for example your policy or application status, payment information, claim information, or Application Information provided directly to the carrier. The Policy Information is used to service your insurance application and/or policy, and to provide you with the Services and products you have requested.

Other Uses of Personal Information on our Sites and Services

In addition to the above, we may use your personal information to:

• Otherwise provide, improve, maintain, or optimize the Services;

• Help underwrite and provide accurate insurance premium rate quotes;

• Provide insurers with the required information for applications;

• Provide or offer other financial and consumer products and services from partners with whom we have entered into a joint marketing agreement;

• Provide, maintain and improve customer service;

• Tailor your experience with the Services to your interests;

• Develop and improve the Sites and the Services;

• Respond to your inquiries;

• Communicate with you regarding the insurance products that you purchased through the Sites as well as other products and services that may be of interest to you; and

• In addition, we may aggregate your personal information with our other users’ personal information and use that information for benchmarking and analysis purposes.

Use of Personal Information for Compliance and Protection

We may use your personal information to:

• Comply with applicable laws, lawful requests, and legal process, such as to respond to subpoenas or requests from government authorities;

• Protect our, your or others’ rights, privacy, safety or property (including by making and defending legal claims);

• Audit our internal processes for compliance with legal and contractual requirements and internal policies;

• Enforce the terms and conditions that govern the Services; and

• Prevent, identify, investigate and deter fraudulent, harmful, unauthorized, unethical or illegal activity, including cyberattacks and identity theft.

Cookies and Online Tracking Technologies

Our Sites use technologies such as cookies, beacons, tags, and scripts, to analyze trends, administer our Sites, track users’ movements around our Sites, and gather demographic information about our user base.

Cookies are a small piece of software or text placed on your computer when you visit a website. They are used to store information on web browsers and to store and receive identifiers and other information on computers, telephones, and other devices. They may include data we store on your web browser or device, identifiers associated with your device, and other software. In this Privacy Policy, we refer to all these technologies that store or reference data on your device as “cookies.” If you visit from a mobile device, we may reference your device identifier or other information about where your visit originated. Certain cookies used on our Sites last for ninety or more days. 

We use cookies to:

• Recognize you on return visits and, if you have an account - expedite the login process, help verify and authenticate your account, and help detect fraud; 

• Show ads and to make recommendations for products and services; 

• Measure the performance of ad campaigns;

• Serve and measure ads across different browsers and devices; and

• Conduct web analytics on usage of our Sites and Services.

Web beacons (also sometimes called “clear GIFs,” Pixel tags or action tags) are small files stored and/or served on a website, app, advertisement, or in an email which collect, track, or transmit a data point back to us or to a third party. For example, we use a web beacon to assess whether an email message has been opened.

We use web beacons to facilitate advertising and functionality on our Sites, as well as:

• Associate our users with the reports they provide about satisfaction with our Sites and Services;

• Administer and monitor email campaigns;

• Analyze the portions of our Sites that are used most often by our Visitors, as well as how Visitors interact with our Sites;

• Perform testing on our Sites;

• Optimize interaction with our data stores;

• Improve the functionality and usefulness of our support and support chat functions;

• Analyze the efficacy of our own advertising campaigns;

• Customize the content displayed to you on our Sites and Services;

• Organize and administer other web beacons and cookies on our Sites;

• Conduct web analytics on usage of our Sites and Services; and

• Enable, improve, and effect targeted and re-targeted advertising for our advertising partners on both our Sites and their third-party sites such as Facebook.

In some cases, the above web beacons’ functions may be performed by custom HTML in our Sites’ code.

We may use cookies and/or web beacons to track if, and when, a user abandons a purchase before it is complete and attempt to re-engage that user for the same or a similar purchase, as well as making offers for related purchases to that user.

To learn more about how to opt-out of certain cookies and tracking technologies, see the Online Tracking Opt-Out Guide section below.

Web browser do not track (DNT) - Some web browsers may transmit “do-not-track” signals to websites with which the browser communicates. We do not currently have the ability to recognize Do Not Track signals. You can learn more about Do Not Track signals at https://allaboutdnt.com/ 

II. How We Share Your Information

1. When We Share Specific Information 

We may share your information with:

• Insurance Carriers – We may share personal information, including Application Information, to obtain quotes and submit and process insurance applications. 

• Service Providers and Contractors – We may share your personal information with service providers for the purpose of providing you the Services. Additionally, we may partner with other companies to process, analyze, and/or store data, including, but not limited to, analytical data. These companies may access your personal information for the purposes of providing services for us.

• Referral Partners –  If you were referred to us by a business partner (such as another financial services company or another insurance agent or broker), or submitted a request for quotes or an application for insurance through a business partner, we will share your information, including Application Information, with that business partner as necessary to honor the terms of our agreement with that business partner and to provide you the requested products and services.  For example, if you were referred to us by a mortgage provider because you need homeowners insurance in connection with a mortgage application, we may, under the terms of our agreement with that partner, share information about the status of your application, your policy number when issued, and other information about your policy. 

2. When We Share Information Generally

We share the information we collect generally:

• For Marketing purposes pursuant to joint marketing arrangements. You may opt out of receiving our marketing communications at any time by contacting us at privacy@policygenius.com or by using the unsubscribe link in any of our communications. If you wish to opt out of receiving marketing communications from our joint marketing partners, you will need to opt out of those communications directly with those partners. 

• With certain third-party vendors that help us administer the Sites and/or Services, including by:

• • Storing and hosting our content or your data;

  • Performing analytics on our Sites and Services; and

  • Providing operations and marketing assistance to us.

• When you request us to share certain information with third parties, such as through your use of social media widgets or login integrations.

• With marketing-related business partners to gather insights about your interactions with our products and Services so that we may better advertise to you and customize our products and services.

• With corporate affiliates including any of our parent companies, subsidiaries, joint ventures, or other companies under common control with us.

• With counterparties in the course of a corporate sale, merger, reorganization, sale of assets, dissolution, or similar event, some or all of the personal information may be part of the transferred assets.

• To the extent permitted by law, when required by law, in connection with a court order, or other government or law enforcement authority or regulatory agency, or whenever we believe that disclosing such information is necessary or advisable, for example, to protect the rights, property, or safety of us or others.

Social Features

Certain features of the Services permit you to initiate interactions between the Services and third-party services or platforms, such as social networks (“Social Features”). Social Features include features that allow you to click and access our pages on certain third-party platforms, such as Facebook and Twitter, and from there to “like” or “share” our content on those platforms. Use of Social Features may entail a third party’s collection and/or use of information about you, which will be subject to the privacy policies of those platforms. If you use Social Features or similar third-party services, information you post or otherwise make accessible may be publicly displayed by the third-party service you are using. Both us and the third party may have access to information about you and your use of both the Services and the third-party service.

III. How We Secure Your Information

We maintain commercially reasonable administrative, physical and technical safeguards designed to prevent any unauthorized use, access, destruction, loss, alteration, or disclosure of your data. 

While we take commercially reasonable steps to protect your data we cannot guarantee perfect security – no internet-based service can. No security system is impenetrable. Despite our security measures, we cannot guarantee the security of our databases, nor can we guarantee that the information you supply will not be intercepted while being transmitted to and from us over the Internet. 

IV. Users From Outside The U.S.

Policygenius provides its Sites and Services for use by U.S. residents, and U.S. law, and not the laws of other countries, govern these Sites and Services. If you are visiting the Sites or any of the Services, your information will be maintained in the U.S. and in other locations where we may process data. 

By default, we disable the submission of personal information to our Sites from users using European Union and United Kingdom IP addresses, regardless of whether the user is an E.U. or U.K. citizen or using a VPN device. If you need access to your account and are using an E.U. or U.K. IP address, please email privacy@policygenius.com with (i) a description of the access and/or help you need, and (ii) an express consent to use any personal information in our possession to respond to your request.

V. Children

We do not knowingly collect personal information from children under the age of 13. If you are under 13, please do not give us any personal information and do not use the Sites or Services. If you have reason to believe that a child under the age of 13 has provided personal information to us, please contact us immediately, and we will delete that information from our databases.

VI. Job Applicants

When you visit the careers portion of our Sites, we collect information that you provide to us in connection with your job application. This includes business and personal contact information, professional credentials and skills, educational and work history, and other information of the type that may be included in a resume. This may also include diversity information that you voluntarily provide. We use this information to facilitate our recruitment activities and process employment applications, such as by evaluating a job candidate for an employment activity, and monitoring recruitment statistics. We may also use this information to operate and improve the Services, and as otherwise necessary for compliance, fraud prevention, and safety purposes.

VII. External Sites

The Sites may contain links to third-party websites, including, without limitation, the websites of the insurance carriers offering the third-party insurance products made available to you through the Services (“External Sites”), but we do not endorse, and we are not responsible for the content of any linked External Sites or for the privacy practices of the third parties that own and operate such sites. Before using any External Site, please refer to the terms of use and privacy policies of the External Sites for more information, as those terms and policies govern your use of such External Sites.

VIII. How to Opt-Out 

If you wish to opt-out of the use of your personal information by our Services, we are happy to assist you. Please email us at privacy@policygenius.com and let us know what you wish to opt-out of. Please be advised that certain uses and sharing of your information may be required to continue providing certain Services to you, and that you will not be entitled to any refund if your removal of personal information will make certain prepaid Services unavailable to you.

Please note that under certain federal regulations, including the GLBA, you may not be able to opt out of the use and sharing of your personal information, in connection with seeking, applying for, or obtaining insurance products or services from us. For more information on such financial products, and our data practices, please review our GLBA Privacy Notice. 

IX. Additional Information For California Residents

If you are a California resident, California law requires us to provide you with some additional information regarding how we collect, use, and share your “personal information” (as defined in the California Consumer Privacy Act of 2018, as amended (the “CCPA”)). 

Certain federal and state financial regulations, including the GLBA, the California Financial Information Privacy Act (“FIPA”), and certain federal and California health privacy laws govern the information you have provided in seeking, applying for, and/or obtaining insurance products or services, and that information is therefore not subject to the CCPA. Because of this, in this section of our Privacy Policy, we provide disclosures and information for California residents regarding the limited personal information we collect that is subject to the CCPA.

California residents who have established business relationships with us may choose to opt out of us sharing their personal information with third parties for direct marketing purposes. If you are a California resident and (1) you wish to opt out; or (2) you wish to request certain information regarding our disclosure of your personal information to third parties for their direct marketing purposes, please send an email to privacy@policygenius.com.

In the preceding twelve (12) months, we collected and disclosed the following categories of personal information about Visitors or Members who are California residents:

Category	Examples	Collected?	Categories of Recipients Disclosed for a Business Purpose
Identifiers	First and last name, postal address, email address, IP address, mobile device ID, driver’s license number, social security number, date of birth.	Yes	• Service providers who process information on our behalf • Third-party advertising partners • Third-party partners, such as social media networks (name, email, zip code, and date of birth only) • Insurance Carriers - Referral Partners
Personal information categories listed in the California Customer Records statute	First and last name; signature, social security number, physical characteristics or description, address, telephone number, passport number, driver’s license or state identification card number, employment history, medical information, insurance policy number, bank account number	Yes	• Service providers who process information on our behalf • Third-party advertising partners • Insurance Carriers • Referral Partners
Protected classification characteristics under California or federal law	Race, gender, age, marital status, disability	Yes	• Service providers who process information on our behalf • Insurance Carriers • Referral Partners
Commercial information	Personal property information	Yes	• Service providers who process information on our behalf • Insurance Carriers • Referral Partners
Biometric information	Voice recordings	Yes	• Service providers who process information on our behalf • Insurance Carriers
Internet or other similar network activity	Cookies and information on a users interaction with the Site, device ID, other device information.	Yes	• Service providers who process information on our behalf • Third-party advertising partners • Third-party partners, such as social media networks
Geolocation data	IP address and mobile device ID	Yes	No
Sensory data	Telephone communications, voice recordings.	Yes	• Service Providers who process information on our behalf • Insurance Carriers
Professional or employment-related information	Title of profession, employer, income, employment history	Yes	• Service providers who process information on our behalf • Third-party advertising partners • Insurance Carriers • Referral Partners

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Purposes for Collection, Use, and Sharing. We use and disclose the personal information we collect for our commercial purposes, as further described in this Privacy Policy, including for our business purposes:

• Auditing related to our interactions with you;

• Legal compliance;

• Detecting security incidents, protecting against malicious, deceptive, fraudulent, or illegal activity, and necessary prosecution;

• Debugging;

• Performing services (for us or our service provider);

• Internal research for technological improvement;

• Internal operations;

• Activities to maintain and improve our services; and 

• Other one-time or short-term uses.

California Residents’ Privacy Rights. Except as excluded above or limited below, the CCPA grants California residents the following rights to Request:

• Information. You can request information about how we have collected, used and shared your Personal Information during the past 12 months. We have made this information available to California residents without having to request it by including it in this Privacy Policy.

• Access. You can request a copy of the personal information that we maintain about you.

• Deletion. You can ask us to delete the personal information that we collected or maintain about you. 

Please note that there are various lawful reasons why we may not be able to delete your data or may be required to hold certain personal information — for instance, (i) where we must comply with legal, regulatory, or other requirements, (ii) in case of exercising or defending legal claims, and/or (iii) where regulatory or contractual retention periods apply. 

Please note that the CCPA limits these rights by, for example, prohibiting us from providing certain sensitive information in response to an access request and limiting the circumstances in which we must comply with a deletion request. If we deny your request, we will communicate our decision to you.

Timing. We will respond to Requests within 45 days of receiving your request, unless we need more time, in which case we will notify you and may take up to 90 days total to respond to your request.

We will not discriminate against you for exercising these rights. 

How to Submit a Request. To request access to or deletion of personal information:

• call 1-855-695-2255; or

• email privacy@policygenius.com.

Identity verification. The CCPA requires us to verify the identity of the individual submitting a request to access or delete personal information before providing a substantive response to the request.

Authorized agents. California residents can empower an “authorized agent” to submit requests on their behalf. We will require the authorized agent to have a written authorization confirming that authority and are required to verify their identity. 

We do not sell personal information.

As we explain in this Privacy Policy, we use cookies and other tracking technologies to analyze traffic on our Sites and facilitate advertising. If you would like to learn how you may opt out of our (and our third party advertising partners’) use of cookies and other tracking technologies, please review the instructions provided in the Online Tracking Opt-out Guide.

X. Online Tracking Opt-Out Guide

Like many companies online, we use services provided by Google, Facebook and other companies that use tracking technology. These services rely on tracking technologies – such as cookies and web beacons – to collect directly from your device, information about your browsing activities, your interactions with websites, and the device you are using to connect to the Internet. There are a number of ways to opt-out of having your online activity and device data collected through these services, which we have summarized below:

• Blocking cookies in your browser. Most browsers let you remove or reject cookies, including cookies used for interest-based advertising. To do this, follow the instructions in your browser settings. Many browsers accept cookies by default until you change your settings. For more information about cookies, including how to see what cookies have been set on your device and how to manage and delete them, visit www.allaboutcookies.org.

• Blocking advertising ID use in your mobile settings. Your mobile device settings may provide functionality to limit use of the advertising ID associated with your mobile device for interest-based advertising purposes.

• Using privacy plug-ins or browsers. You can block our Sites from setting cookies used for interest-based ads by using a browser with privacy features, like Brave, or installing browser plugins like Privacy Badger, Ghostery or uBlock Origin, and configuring them to block third party cookies/trackers.

• Platform opt-outs. The following advertising partners offer opt-out features that let you opt-out of use of your information for interest-based advertising:

• • Google: https://adssettings.google.com

  • Facebook: https://www.facebook.com/about/ads

  • Twitter: https://twitter.com/personalization

• Advertising industry opt-out tools. You can also use these opt-out options to limit use of your information for interest-based advertising by participating companies:

  • Digital Advertising Alliance: http://optout.aboutads.info

  • Network Advertising Initiative: http://optout.networkadvertising.org/?c=1

• To opt out of tracking by Google Analytics, click here.

XI. Contact Us

If you have additional questions or would like more information regarding our information collection, use of information, or disclosure practices, please feel free to contact us at privacy@policygenius.com.

Previous GLBA Consumer Privacy Notice can be viewed here.