The Insurance Group companies* value your privacy. The Insurance Group has established this Online Privacy Policy (“Policy”) that describes how we use, disclose, and protect the information we collect online from visitors to our The Insurance Group websites (the “Sites”). Equity Insurance Brokerage Services, Inc, DBA “insurewithbenjamin.com, insure with benjamin” in cooperation with The Insurance Group Financial, Inc & The Smith Companies, Inc, referred to as “The Insurance Group” henceforth. Depending upon your interaction with The Insurance Group, other privacy policies may apply in addition to this Policy. Specifically, we also have established privacy policies pertaining to how we protect information that is collected when you apply for or use a The Insurance Group product or service. We also may send you a privacy notice in connection with your use of a particular product or service. Please check here for a list of our privacy policies.

Collection of personal information

• Information we collect directly from you.We collect personal information, including, but not limited to, name, address, date of birth, telephone number, Social Security number, email address, and policy number from you if you desire online account access, submit an inquiry to us, complete an online form, or participate in a survey. The scope of the information that we collect directly from you varies on your interaction with the Sites.
• Job applicants.We may accept applications for employment online through our Sites, and we will collect personal information from you in connection with your application, such as your contact information, employment history, among other data. You also may sign up for updates on career opportunities with The Insurance Group Financial.
• Information we automatically collect.We may automatically collect the following information about your use of our Sites through cookies, web beacons, and other technologies: your domain name; your browser type and operating system; web pages you view; links you click; your IP address; the length of time you visit our Sites; the referring URL, or the webpage that led you to our Sites; and our access time, browser type, domain name, and IP address. Please see the section “Tracking Visitors to our Sites” below for additional information.

How we use your information

We use the information that we gather about you through our Sites for the following purposes:

• To respond to your inquiry or to your request for a call, referral, or quote, and for other customer service purposes;
• To process transactions;
• To tailor the content and information that we may send or display to you, to offer location customization, and personalized help and instructions, and to otherwise personalize your experiences while using our Sites.
• Where permitted, for marketing and promotional purposes, such as to provide information to you about the products and services we offer;
• If you choose to “like” The London Team page on LinkedIn, or take any similar action on another social media site, you are providing your consent to receive information updates, including solicitations from The Insurance Group Financial.
• To authenticate registered customers; and
• To better understand how users access and use our Sites, to improve our Sites, respond to user desires and preferences, and for other research and analytical purposes.

How we share your information

We do not sell or share your information with non-affiliated third parties who want to offer you their own products and services. We may share your information with the following persons and for the following purposes:

• The Insurance GroupWe may disclose information collected on our Sites to a The Insurance Group company (our affiliate) so that it can respond to your request or inquiry or tell you about a product or service it offers. For example, we may disclose your information to The Insurance Group sales agent to provide you with quotes or other information regarding insurance and financial service products. The use and disclosure of your personal information by The Insurance Group companies and affiliates will be subject to this Privacy Policy, and where applicable our Privacy Practices Notice.
• Service providers.We may disclose the information we collect from you to third party vendors, service providers, contractors, or agents who perform functions on our behalf. These service providers may include financial service providers (e.g., third party administrators, broker-dealers, insurance agents and brokers, credit bureaus, among others), as well as service providers that assist us in maintaining our network, assisting with customer service and marketing.
• Joint marketers.We may disclose your personal information to financial services companies with which we have a joint marketing agreement for the purpose of marketing our products and services to you as well as products and services that we jointly offer to you.
• Business transfers.If we are acquired by or merged with another company, if substantially all of our assets are transferred to another company, or as part of a bankruptcy proceeding, we may transfer the information we have collected from you to the other company.
• In response to the legal process.We also may disclose the information we collect from you in order to comply with the law, or a judicial proceeding, court order, or other legal processes, such as in response to a subpoena.
• To protect us and others.We also may disclose the information we collect from you where we believe it is necessary to investigate, prevent, or take action regarding illegal activities, suspected fraud, situations involving potential threats to the safety of any person, violations of our Terms of Use or this Policy, or as evidence in litigation in which Company is involved.
• Aggregate and de-identified information.We may share aggregate or de-identified information about users with third parties for marketing, advertising, research, or similar purposes.

Tracking visitors to our sites

We use cookies and other tracking mechanisms to track aggregate information about your use of our Sites. We may combine this information with personal information about you.

We do not process or comply with any web browser’s “do not track” signal or other similar mechanisms that indicates a request to disable online tracking of individual users who visit our Sites.

• Cookies are alphanumeric identifiers that we transfer to your computer’s hard drive through your web browser for record-keeping purposes. Some cookies allow us to make it easier for you to navigate our Sites, while others are used to enable a faster log-in process or to allow us to track your activities on our Sites. There are two types of cookies: session and persistent cookies.

Session cookies exist only during an online session and disappear from your computer when you close your browser or turn off your computer. We use session cookies to allow our systems to uniquely identify you during a session or while you are logged into the Site so that we can process your online transactions and requests and verify your identity as you move through our Sites. Persistent cookies remain on your computer after you have closed your browser or turned off your computer. We use persistent cookies to track aggregate and statistical information about user activity.

• Third-Party Cookies.We may also engage third parties to track and analyze data about our Sites. We use such data to help us administer and improve the quality of our Sites and to analyze usage data. Such third parties may combine the information that we provide about you with other information that they have collected. This Policy does not cover such third parties’ use of the data.
• Disabling Cookies.Most web browsers automatically accept cookies, but if you prefer, you can edit your browser options to block them in the future. The Help portion of the toolbar on most browsers will tell you how to prevent your computer from accepting new cookies, how to have the browser notify you when you receive a new cookie, or how to disable cookies altogether. Visitors to our Sites who disable cookies will be able to browse certain areas of the Site, but some features may not function.
• Local Storage Objects.We may use Flash Local Storage Objects (“Flash LSOs”) to store your preferences and to personalize your visit. Flash LSOs are different from browser cookies because of the amount and type of data stored. Typically, you cannot control, delete, or disable the acceptance of Flash LSOs through your web browser. For more information on Flash LSOs, or to learn how to manage your settings for Flash LSOs, go to the Adobe Flash Player Help Page, choose “Global Storage Settings Panel” and follow the instructions. To see the Flash LSOs currently on your computer, choose “Website Storage Settings Panel” and follow the instructions to review and, if you choose, to delete any specific Flash LSO.
• Clear GIFs, pixel tags, and other technologies.Clear GIFs are tiny graphics with a unique
  identifier, similar in function to cookies. In contrast to cookies, which are stored on your computer’s hard drive, clear GIFs are embedded invisibly on web pages. We may use clear GIFs (a.k.a. web beacons, web bugs, or pixel tags), in connection with our Sites to, among other things, track the activities of visitors to our Sites, help us manage content, and compile statistics about Site usage. We and our third-party service providers also use clear GIFs in HTML e-mails to our customers, to help us track e-mail response rates, identify when our e-mails are viewed, and track whether our e-mails are forwarded.
• Third-Party Analytics.We use automated devices and applications, such as Adobe Site Catalyst, to evaluate usage of our Sites, and to assist us, when applicable, in determining where to improve our Sites.

Security of our sites

The Insurance Group seeks to protect the personal information you provide to us. That is why we have implemented commercially reasonable precautions, including, where appropriate password protection, encryption, SSL, firewalls, and internal restrictions on who may access data to protect the information we collect from loss, misuse, and unauthorized access, disclosure, alteration, and destruction.

Please keep in mind that the Internet is not a completely secure medium of communication and no data security measures can guarantee 100% security. We do not guarantee or warrant that any part of our Sites, including files available for download, are free of viruses or other harmful code. It is your responsibility to take appropriate precautions, such as the use of anti-virus software, to protect your computer hardware and software while using the Internet. You should also take steps to protect against unauthorized access to your password, phone, and computer by, among other things, signing off after using a shared computer, choosing a robust password that nobody else knows or can easily guess, and keeping your log-in and password private. We are not responsible for any lost, stolen, or compromised passwords or for any activity on your account via unauthorized password activity.

Security of Information Transmissions. Information you provide to us when filling out secure forms on our Sites, as well as information we supply when you are visiting those areas, is protected while passing through the Internet using encryption technology called Secure Sockets Layer or SSL. Your browser will indicate when you are within a secure area of our Sites by displaying a symbol, such as a locked padlock or an unbroken key. Although we will use reasonable efforts to safeguard the confidentiality of your information, Internet transmissions cannot be made absolutely secure. We are not liable for the unintended disclosure of information due to errors in transmission or unauthorized acts of or breaches of security by third parties.

Please also note that regular Internet e-mail is not secure. To protect your privacy, you should not use e-mail to communicate information that you want to remain confidential. If you are concerned about the security of the Internet for the communication of personal information, you may want to consider using alternative forms of communication such as telephone, fax, or regular mail.

Advertising

We may use third parties such as network advertisers to display advertisements on our Sites and other websites. Network advertisers are third parties that display advertisements based on your visits to our Sites as well as other websites. This enables us and these third parties to target advertisements by displaying ads for products and services in which you might be interested.

We use Display & Video 360, Campaign Manager, and Search Ads 360. We also use third-party ad network providers, advertisers, sponsors and/or traffic measurement services may use cookies, JavaScript, web beacons (including clear GIFs), Flash LSOs and other technologies to measure the effectiveness of their ads and to personalize advertising content to you. These third party cookies and other technologies are governed by each third party’s specific privacy policy, not this one. We may provide these third-party advertisers with information about your usage of our Sites, as well as aggregate or non-personal information about users of our Sites. These third parties may collect certain non-personally identifiable information, such as what website a visitor came from, your IP address, and what type of browser you are using.

You may opt-out of many third-party ad networks, including those operated by members of the Network Advertising Initiative (“NAI”) and the Digital Advertising Alliance (“DAA”). For more information regarding this practice by NAI members and DAA members, and your choices regarding having this information used by these companies, including how to opt-out of third-party ad networks operated by NAI and DAA members, please visit their respective websites: www.networkadvertising.org/optout_nonppii.asp (NAI) and http://www.aboutads.info/consumers (DAA).

Opting out of one or more NAI member or DAA member networks (many of which will be the same) only means that those members no longer will deliver targeted content or ads to you. It does not mean you will no longer receive any targeted content or ads on our Site or other websites. You may continue to receive advertisements, for example, based on the particular website that you are viewing. Also, if your browsers are configured to reject cookies when you visit this opt-out page, or you subsequently erase your cookies, use a different computer or change web browsers, your NAI or DAA opt-out may no longer be effective. Additional information is available on NAI’s and DAA’s websites accessible by the above links.

Links to third party sites

Our Sites may be reached by links from or contain links to other websites (“third-party sites”) that are not owned or controlled by us. These third-party sites may have privacy policies controlling the collection and use of personal information about you that is different from our Privacy Policy; this Privacy Policy does not apply to those third-party sites. A link to or from a third-party site is not an endorsement by us of the site, its content, its privacy practices or its sponsoring organization, and we are not responsible for the practices, content or accuracy of third-party sites.

Children under 13

This website is not directed toward children. We do not knowingly collect or post information from children under the age of 13.

Changes to our online privacy policy

This Policy is effective as of January 2020. We reserve the right to change this Policy. If we change it, we will post the current Policy on this page. Any changes to this Policy will be effective as of the day they are posted.

Contact us

If you have questions about this Policy, please contact [email protected]

Additional notice for California consumers

This part of our Online Privacy Policy only applies to residents of California that visit our website and relates to our processing of their personal information.

Collection of personal information and sources of personal information for the last twelve months

We collect personal information, as further described above in “Collection of personal information,” when users visit and use our website automatically and through their interactions with the Sites. The personal information we have obtained on California residents includes the following:

• Identifiers such as a real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, social security number, driver’s license number, passport number, or other similar identifiers.
• The following categories of personal information described in California Civil Code § 1798.80(e): (1) the personal information listed in the preceding bullet point as “identifiers,” (2) signature, (3) telephone number, (4) employment, (5) payment information (including payment card details or online payment services number and invoicing address) and financial information (such as bank account numbers), and (5) the other information that identifies, relates to, describes, or is capable of being associated with, a particular individual that we describe above in “Collection of personal information.”
• Characteristics of protected classifications under California or federal law.
• Commercial information, including records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.
• Internet or other electronic network activity information, including, but not limited to, browsing history, search history, and information regarding a consumer’s interaction with an internet web site, application, or advertisement.
• Geolocation data.
• Professional or employment-related information.
• Education information, defined as information that is not publicly available personally identifiable information as defined in the Family Educational Rights and Privacy Act (20 U.S.C. section 1232g, 34 C.F.R. Part 99).
• Inferences are drawn from any of the information identified in this subdivision to create a profile about a consumer reflecting the consumer’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.

Disclosures of personal information on California consumers for business purposes for the last twelve months

We have disclosed the categories of personal information identified in this Additional Notice to service providers for various business purposes as specified below. For more information on the service providers with whom we share information, please see “How we share your information.”

No sales of personal information for the last twelve months

The Insurance Group has not sold any personal information pursuant to California law as described in this Policy to third parties within the previous twelve (12) months and will not sell personal information.

Business purposes for collecting personal information for the last twelve months

We collected the personal information identified in this Additional Notice for business purposes including those listed below:

• Audits and reporting relating to particular transactions and interactions, including online interactions, you may have with us or others on our behalf;
• Detecting and protecting against security incidents, and malicious, deceptive, fraudulent or illegal activity, and prosecuting the same;
• Debugging to identify and repair errors in our systems;
• Short-term, transient use including contextual customization of ads;
• Providing services on our behalf or on behalf of another, including maintaining or servicing accounts, providing customer service, fulfilling transactions, verifying identity information, processing payments, and other services;
• Conducting internal research to develop and demonstrate technology; and
• Conducting activity to verify, enhance, and maintain the quality of services which we may own, control, or provide.

Your California privacy rights

If you are a California resident, you have the following rights for purposes of the personal information covered by this Privacy Policy.

Right to Know About Personal Information Collected, Disclosed, or Sold and Right to Access. You have the right to request that we disclose the following information about your personal information we collect, use, and disclose:

• the categories of personal information we have collected about you;
• the categories of sources from which the personal information is collected;
• our business or commercial purpose for collecting or selling personal information;
• the categories of third parties with whom we share personal information;
• the specific pieces of information we have collected about you;
• if any, the categories of personal information about you that we have sold, by category or categories of personal information for each third party to which we sold the personal information; and
• the categories of personal information about you that we disclosed for a business purpose.

Right to Deletion of Personal Information. You have the right to request the deletion of your personal information we collected from you.

Right to Non-Discrimination for Exercise of a California Privacy Rights. We may not discriminate against you because of your exercise of any of the foregoing rights, or any other rights under the California Consumer Privacy Act (“CCPA”), including by:

• Denying you goods or services;
• Charging different prices or rates for goods or services, including through the use of discounts or other benefits or imposing penalties;
• Providing you a different level or quality of goods or services; or
• Suggesting that you will receive a different price or rate for goods or services or a different level or quality of goods or services.

We may, however, charge different prices or rates, or provide a different level or quality of goods or services, if that difference is reasonably related to the value provided to The Insurance Group by your personal information.

How to exercise your California rights; how we may verify your request

You may request the rights listed above by:

• calling us at 954-439-4220

When you make a request, we may take steps to verify your identity before responding to your request. In order to verify your identity with respect to the non-sensitive data that is subject to this notice, we may take any or all of the following steps:

• Utilize a third-party identity verification service to ask you questions designed to verify your identity;
• Utilize our normal verification processes for our existing products and services, based on our relationship with you; and/or
• Additional steps to verify your identity using other information we may have about you, based on the nature of your request and our relationship with you.

As described by CCPA and its regulations, you may designate an authorized agent to make a request on your behalf. You may make such a designation by providing the agent with written permission to act on your behalf. As permitted by law, we may take steps to verify your own identity in response to a request even if you choose to use an agent.