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Insurance Marketing Hub Privacy Policy

Effective January 1, 2020

We Respect Your Privacy

Insurance Marketing Hub and its affiliates (collectively “IMH,” “we,” and/or “our”) provide this privacy policy (the “Privacy Policy”) to inform consumers and clients of who we are and our practices regarding how we collect, obtain, use, and share consumer personal information. IMH is a third-party mail processor that receives and processes business reply mail and maintains a Do Not Mail list for its clients. IMH provides a number of marketing services to insurance marketing organizations in order to send targeted and data driven direct mail, email, and digital ad campaigns, by targeting them to specific consumer demographics. We do not sell or endorse any of the products or services offered in the mailers.  IMH respects your privacy and takes the privacy of your information seriously.

Information We Receive AND COLLECT

We obtain consumer personal information from third-party providers who gather information from sources including public records, real property data, transactional data, and more. This data may include what we refer to as Personally Identifiable Information (“PII”) and information tied to PII regarding a consumer’s demographics or purchase data.  Please note that we are not responsible for the content or accuracy of the lists provided by our clients or these data compilers. We may collect the following PII from third-party sources. Please note that we may not collect all categories of information for every individual:

  • Name
  • Address
  • Gender
  • Marital status
  • Age band
  • Individual and/or household income band
  • Home ownership status (including market value of the home and year the home was built)
  • Mortgage information.

We may also collect information from you that you voluntarily provide to us in response to a marketing mailing.

How We Use Collected Data  

We may use the information that we obtain from a third-party in order to directly market insurance products to targeted consumers on behalf of our clients. Specifically, IMH may use PII to tailor direct mailing and email campaigns to recipients more likely to be interested in those campaigns. We may use this information, alone or in combination with other PII we collect to enhance our ability to provide relevant marketing and content to you and to develop and provide you with more relevant products, features, and service.

We may also use consumer PII for internal business purposes, such as analyzing and managing our business and/or measuring the effectiveness of campaigns. 

Sharing of Data

Please note that we do not sell your information.

We may share consumer information such as name, address, and any additional information you provide to us in response to receiving a marketing mailing with our marketing partners, service providers, vendors, and/or our clients. These partners may include but are not limited to insurance marketing organizations that provide sales support, marketing support, and lead generation services for insurance agents to market insurance products.

If IMH or its subsidiaries or affiliates are acquired by or merged into another entity, the PII will be transferred to that entity. We may also disclose PII if we believe, in good faith, that such disclosure is necessary to comply with relevant laws or to respond to subpoenas, warrants, or law enforcement and government agency requests or to otherwise protect and/or defend our rights.

OPT-OUT OF COMMUNICATIONS        

You may choose to opt-out of receiving communications and mailings from IMH and may do so by completing our online form here. All information provided by you in order to opt-out will only be used to add you to a Do Not Mail list and opt you out of our clients’ future mailings. We do not rent or sell the information collected from you on this site to any other parties.

It is important to note that when you opt-out of our clients’ mailings, you will still likely receive similar mailings from other companies and marketing organizations that are not related to our clients or IMH. Our Resources page provides information on how to put your name on national Do Not Mail lists so compilers do not sell your information to marketing companies.

SECURITY AND RETENTION

We use reasonable security measures that are designed to protect your information from accidental loss, disclosure, misuse, and destruction.  Please be advised that no data security measures can be guaranteed to be completely effective.  Consequently, we cannot guarantee security of any information that you provide to us.  You transmit information to us at your own risk. 

By responding to a marketing campaign, you agree that IMH is not responsible for any electronic communication and/or any of your PII which may be lost, altered, intercepted, or stored without authorization during the transmission of any data whatsoever across networks not owned and/or operated by IMH.  IMH will not have any liability to you for any such misuse or disclosure.

We may retain and use your information as we deem necessary to comply with our business purposes or legal obligations, to resolve disputes and enforce our agreements, or where we reasonably believe that we have a legitimate reason to do so.

INTENDED AUDIENCE

We do not knowingly collect, receive, or disclose any personal information concerning anyone under the age of 18. IMH reserves the right to delete from its records any such information provided to us.

CHANGES TO THIS PRIVACY POLICY

This Privacy Policy is reviewed and updated as needed to accurately reflect our practices and procedures.  When we do make changes to this Privacy Policy, we will revise the “last updated” date at the beginning of the Privacy Policy.  We encourage you to periodically review this Policy to stay informed about how we collect, use, and disclose personal information.  Your continued use of the Services after any changes to this Privacy Policy are in effect constitutes your acceptance of the revised Privacy Policy in connection with the new usage.

Additional Disclosures for Residents of California

The California Consumer Privacy Act (“CCPA”) provides additional rights to individuals who are residents of California. To learn more about California privacy rights and disclosures, view our Privacy Policy Addendum for California Residents.

Additional Disclosures for Residents of NEVADA

IMH does not own or operate a website or online service for a commercial purpose. Likewise, IMH does not sell your information.

CONTACT US

If you have any questions or comments about this Privacy Policy, please contact us:

Insurance Marketing Hub
Richmond, VA  23220
(833) 426-3282
[email protected]

Privacy Policy: California Addendum

Effective Date: January 1, 2020 

This Privacy Policy for California Residents supplements the information contained in IMH’s Privacy Policy and by law applies solely to customers and others who are residents of the State of California (“consumers” or “you”). We are providing you with this notice as part of our efforts to comply with the California Consumer Privacy Act of 2018 (“CCPA”).  Any bolded terms used in this Privacy Policy are defined by the CCPA and have the same meaning when used in this notice.  Information concerning the CCPA may be found here: https://oag.ca.gov/privacy/ccpa.

The Categories and Sources of Personal Information We Collect

We obtain consumer personal information from third-party providers who gather information from sources including public records, real property data, transactional data, and more. This personal information may include information regarding persons’ demographics and interests or purchase data.  Please note that we are not responsible for the content or accuracy of the lists provided by our clients or these data compilers. We may collect the following personal information from third-party sources. Please note that we may not collect all categories of information for every individual:

  • Name
  • Address
  • Gender
  • Marital status
  • Age band
  • Individual and/or household income band
  • Home ownership status (including market value of the home and year the home was built)
  • Mortgage information.

 

We may also collect information from you that you provide to us in response to a marketing mailing.

Purposes for Which We Collect Personal Information

IMH uses personal information we obtain from third parties in order to directly market insurance products to targeted consumers on behalf of our clients. Specifically, IMH may use personal information to tailor direct mailing and email campaigns to recipients more likely to be interested in those campaigns. We may use this information, alone or in combination with other personal information we collect to enhance our ability to provide relevant marketing and content to you and to develop and provide you with more relevant products, features, and service.

We may also use consumer personal information for business purposes, such as analyzing and managing our business and/or measuring the effectiveness of campaigns. 

The Categories of Third Parties with Whom, and Purposes for Which, We Share Personal Information

We do not sell your personal information. Categories of personal information that we collect may be shared with our clients and our affiliates. We may share your personal information with our clients for the purposes of fulfilling our contractual obligations to our clients by providing marketing leads or forwarding your information when you choose to purchase a product or enroll in a service.

YOUR RIGHTS UNDER THE CCPA 

You have the right to request that we disclose to you the categories and specific pieces of personal information we have collected about you. 

Please note that the CCPA limits our ability to provide you with the requested information only upon receipt of a verifiable consumer request from you, or a person registered with the Secretary of State that is authorized by you to act on your behalf.

When we receive a verifiable consumer request from you to access personal information, we will promptly take steps to disclose and deliver, free of charge to you, the personal information required by the CCPA. We may choose to deliver the information by mail or electronically. If we are delivering the information electronically, the information will be in a portable and, to the extent technically feasible, readily useable format that allows you to transmit this information to another entity without hindrance.

Pursuant to the CCPA, we may provide you with personal information at any time, but we are not required to provide that information to you more than twice in a 12-month period.

Please note that the CCPA does not require us to retain any personal information collected for a single, one-time transaction, if that information is not sold or retained by us.  It also does not require us to reidentify or otherwise link information that is not maintained in a manner that would be considered personal information.

Exercising Access, Data Portability, and Deletion Rights

You may take advantage of the following designated methods for submitting requests concerning your personal information:

(1) our toll-free telephone number: 888.268.2677;

or

(2) by emailing us directly at [email protected]

Verification of Identity

A verifiable consumer request means a request that is made by:

  • a consumer,
  • by a consumer on behalf of the consumer’s minor child, or
  • by a natural person or a person registered with the Secretary of State, authorized by the consumer to act on the consumer’s behalf,

and that the business can reasonably verify under the law to be the consumer about whom the business has collected personal information.

Please be aware that after we receive a verifiable consumer request from you, we will take steps to determine whether the request being made is a verifiable consumer request. In light of the nature of the personal information requested, we will require authentication of your identity. However, you are not required to create an account with us in order to make a verifiable consumer request.

Pursuant to the CCPA, and for your security, we will not provide information in response to a consumer request if we cannot verify that the consumer making the request is the consumer about whom the business has collected information or is a person authorized by the consumer to act on such consumer’s behalf.

Timeframe for Our Response to a Verifiable Consumer Request

Once we receive a verifiable consumer request from you, we will disclose and deliver the required information to you free of charge within 45 days.  It may be necessary for us to extend the time period to provide you with the required information by an additional 45 days.  If that is the case, we will provide you with notice of the extension.

The CCPA provides that our disclosure shall cover the 12-month period preceding our receipt of your verifiable consumer request.  We will make the required disclosure in writing and it will be delivered through your account with us, if you maintain an account with us.  We may also make the required disclosure in writing and delivered by mail or electronically if you do not maintain an account with us. 

Deletion Request Rights

You have the right to request that we delete any personal information about you that we have collected from you. 

After we receive a verifiable consumer request from you to delete your personal information, we will delete your personal information from our records in accordance with the CCPA.  We will also direct any applicable service providers to delete your personal information from their records.

Please note that the CCPA limits our obligation to comply with your request to delete your personal information if your personal information is necessary in order to:

(1) Complete the transaction for which your personal information was collected, provide a good or service requested by you, or reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform a contract between you and us.

(2) Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity; or prosecute those responsible for that activity.

(3) Debug to identify and repair errors that impair existing intended functionality.

(4) Exercise free speech, ensure the right of another consumer to exercise that consumer’s right of free speech, or exercise another right provided for by law.

(5) Comply with the California Electronic Communications Privacy Act pursuant to Chapter 3.6 (commencing with Section 1546) of Title 12 of Part 2 of the Penal Code.

(6) Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when our deletion of the information is likely to render impossible or seriously impair the achievement of such research, if you have provided informed consent.

(7) To enable solely internal uses that are reasonably aligned with your expectations based on your relationship with us.

(8) Comply with a legal obligation.

(9) Otherwise use your personal information, internally, in a lawful manner that is compatible with the context in which you provided the information.

Personal Information Sales Opt-Out and Opt-In Rights

The CCPA provides consumers with the right, at any time, to direct a business that sells personal information about the consumer to third parties not to sell the consumer’s personal information. The CCPA refers to this right as the right to opt-out.  Please note that we do not sell your personal information, so the right to opt-out does not apply to our business relationship.

While we do not sell your personal information, you may opt-out of receiving communications from IMH and from our clients. You may opt-out from our communications by completing our online form here.

The CCPA also provides that a business shall not sell the personal information of consumers if:

  • the business has actual knowledge that the consumer is less than 16 years of age, unless the consumer, in the case of consumers at least 13 years of age and less than 16 years of age, or
  • the consumer’s parent or guardian, in the case of consumers who are less than 13 years of age, has affirmatively authorized the sale of the consumer’s personal information.

The CCPA refers to this right as the “right to opt-in.”  Please note that this website and the services we provide are intended for audiences and consumers at least 18 years old. We do not knowingly collect or disclose any personal information from anyone under the age of 18. IMH reserves the right to delete from its records any such information provided to us.  Accordingly, because we do not knowingly collect or sell personal information of consumers that are the subject of the right to opt-in, the right to opt-in is not applicable.

Limitations on the Applicability of the CCPA

The CCPA does not restrict a business’ ability to:

(1) Comply with federal, state, or local laws.

(2) Comply with a civil, criminal, or regulatory inquiry, investigation, subpoena, or summons by federal, state, or local authorities.

(3) Cooperate with law enforcement agencies concerning conduct or activity that the business, service provider, or third party reasonably and in good faith believes may violate federal, state, or local law.

(4) Exercise or defend legal claims.

(5) Collect, use, retain, sell, or disclose consumer information that is deidentified or in the aggregate consumer information.

(6) Collect or sell a consumer’s personal information if every aspect of that commercial conduct takes place wholly outside of California. Commercial conduct takes place wholly outside of California if the business collected that information while the consumer was outside of California, no part of the sale of the consumer’s personal information occurred in California, and no personal information collected while the consumer was in California is sold. The CCPA does not permit a business from storing personal information about a consumer when the consumer is in California and then collected that personal information when the consumer and stored personal information is outside of California.

Please further note that the CCPA does not currently apply in all respects to personal information that we collect from a person in the course of the person acting as a job applicant, employee, owner, director, officer, or contractor of IMH to the extent that the person’s personal information is collected and used by us solely within the context of the person’s role, or former role, as a job applicant, employee, owner, director, officer, or a contractor of IMH. The CCPA also does not apply to personal information that we collect that constitutes emergency contact information of a person acting in any of the aforementioned roles to the extent that the personal information is collected and used solely within the context of having an emergency contact on file. Lastly, the CCPA does not apply to personal information that is necessary for us to retain in order to administer benefits relating to a person’s capacity in any of the aforementioned roles to the extent that the personal information is collected and used by IMH solely within the context of administering those benefits.

CALIFORNIA’S SHINE THE LIGHT LAW

IMH does not share your personal information with non-affiliated third parties for their own marketing use.

CHANGES TO OUR PRIVACY POLICY

IMH reserves the right to amend this Privacy Policy at our discretion and at any time. When we make changes to this privacy notice, we will post the updated notice on the Site and update the notice’s effective date. Your continued use of our Site following the posting of changes constitutes your acceptance of such changes.

CONTACT INFORMATION

If you have any questions about our Privacy Policy, please contact us:

Insurance Marketing Hub
Richmond, VA  23220
(833) 426-3282
[email protected]

Last Updated: March 31, 2020