Evolution Partners Insurance Marketing, Inc. (also referred to collectively and individually as “Company,” “we,” “our,” “us”) is an insurance network membership organization, which may also act in capacities of an insurance wholesaler, broker and managing general agent.
- What Information Do We Gather?
- What Do We Do With the Information We Collect?
- Who Can Use the Information We Collect and How?
- How Do We Protect the Personal Information We Collect?
- What Are Your Rights Regarding Your Personal Data?
- How Do You Opt-out of Personal Information Sharing with Our Business Partners?
- How Do You Correct and Update Your Personal Data?
- What Happens When You Link to a Third-Party Web Site?
- Your California Privacy Rights
- What If You Have Questions?
1. What Information Do We Gather? When you visit our Website and Portal (“Site”), we collect only the information and personal data you have agreed to provide to us that is necessary to identify your needs and to provide you with better service. Through your use of the Site or registration as a new user, we may request personal data including, but not limited to:
- Name, company and job title
- Contact information including email address and cell phone number
- Demographic information including postal code, product preferences and interests
- Internet Protocol (“IP”) Address and other persistent identifiers
- Other information relevant to customer surveys and offers
If you become a registered user or if you conduct transactions through this Site, we will collect information about the transactions you engage in while on the Site and other potential activities on the Site. This information may include, without limitation, areas of the Site that you visit, transaction type, content that you view, download or submit, transaction amount, payment, and billing information as well as the nature, quantity and price of the goods or services you exchange and the individuals or entities with whom you communicate or transact business.
Some of this personal data, including name, company and contact information, will only be collected if you voluntarily provide it during the user registration process. We may also track information such as the domain name and the name of the web page from which you entered our Site, and how much time you spend on each of our pages. We collect information that is combined with other web visitors’ information, such as how many times visitors click on each web page and the methods by which our Site was found.
2. What Do We Do With the Personal Information We Collect? You will be asked to provide personal data in certain fields on this Site that allow you to be able to use our Services. The personal data we collect is used only for the purpose we state at the time of collection or for purposes contained below. For example, our uses may include, but are not limited to, the following:
- To process transactions. COMPANY uses personal data such as name, physical address, telephone number, email address, and company/institution to engage in interactions with you, including contacting you about your transactions with the site.
- To process payments. We use financial/credit card and payment information to process your order and may need to share some of this information with delivery services, credit card clearing houses, and other third parties to complete the transaction.
- To provide support or other services. COMPANY may use your personal data to provide you with support or other services that you have ordered or requested. COMPANY may also use your personal information to respond directly to your requests for information, including registrations for newsletters, webinars, or other specific requests, or pass your contact information to the appropriate COMPANY distributor or reseller for further follow-up related to your interests.
- To provide information based on your needs and respond to your requests. COMPANY may use your personal data to provide you with notices of new product releases and service developments.
- To select content, improve quality, and facilitate use of the websites. COMPANY may use your personal data, including the information gathered as a result of site navigation and electronic protocols and cookies (including third-party cookies), to help create and personalize website content, improve website quality, track marketing campaign responsiveness, evaluate page response rates, conduct usability testing, and facilitate your use of the websites (for example, to facilitate navigation and the login process, avoid duplicate data entry, enhance security, keep track of shopping cart additions, and preserve order information between sessions).
- To serve personalized advertising to you. We don’t share your personal data with advertisers without your consent. We allow advertisers to choose the characteristics of users who will see their advertisements, and we may use any of the non-personally-identifiable data attributes we have collected to select the appropriate audience for those advertisements. When you click on or otherwise interact with an advertisement, there is a possibility that the advertiser may place a cookie in your browser and that your attributes meet the criteria the advertiser selected.
- To assess usage of COMPANY products and services. COMPANY may track your usage of COMPANY products and services to determine your level of usage, and those usage statistics may be made available to COMPANY’s content licensors and your company/institution.
- To communicate with you about events. We may communicate with you about events hosted or co-sponsored by COMPANY or one of our business associates. This may include information about the event’s content, event logistics, payment, updates, and additional information related to the event. Information you provide when registering for or participating in a conference managed or co-sponsored by parties, other than or in addition to COMPANY may be shared with those parties, and the treatment of such information is further subject to the privacy policies of those parties. COMPANY and its conference co-sponsors may contact you after the event about the event, subsequent iterations of the event and related events. Please note that COMPANY event organizers, co-sponsors, exhibitors, and other third parties may directly request your personal information at their conference booths or presentations. Providing your information to them is optional, and you should review their privacy policies to address your particular needs and concerns about how they will treat your personal information.
- To update you on relevant COMPANY benefits, programs, and opportunities. COMPANY may communicate with you regarding relevant COMPANY benefits, programs, and opportunities available to you.
- To engage with third parties. COMPANY may share your personal data with third parties in connection with services that these individuals or entities perform for or with COMPANY. These third parties are restricted from using this data in any way other than to provide services for COMPANY or for the collaboration in which they and COMPANY are contractually engaged (for example, hosting a COMPANY database or engaging in data processing on COMPANY’s behalf, or mailing you information that you requested). These third parties are carefully selected by COMPANY and obligated to keep your data secure. From time to time, we may also share your information with third parties whom we think might provide content, products, or services of interest to you.
- To get feedback or input from you. In order to deliver products and services of most interest to our customers, from time to time, we may ask members, customers, volunteers, and website visitors to provide us input and feedback (for example through surveys, usability studies, focus groups).
- To protect COMPANY information assets as well as your own personal data. The COMPANY Information Security Program protects the confidentiality, integrity, and availability of COMPANY information assets by following a risk management approach based on policies, standards, guidelines, and procedures to meet security objectives while supporting business and operational goals.
- To assist in Business Transfers. As we continue to develop our business, we may buy, merge, or partner with other companies. In such transactions, (including in contemplation of such transactions) user information may be among the transferred assets. If a portion or all of COMPANY’s assets are sold or transferred to a third-party, customer personal data (including your email address) would likely be one of the transferred business assets. If such transfer is subject to additional mandatory restrictions under applicable laws, COMPANY will comply with such restrictions.
- To the extent that we collect certain demographic information about you, we may use this information in our market research, but we will do so only after we “anonymize” or “pseudonymize” the data, i.e., remove information that would confirm your identity. We will not use your personal data, however, to send commercial or marketing messages to you unless we have a legal basis for doing so, such as your consent or a contract with us for which, in either case, you will have the ability to opt out of by sending an email to [email protected].
This Site does not collect personal data when you browse the Site and request pages from our servers unless you voluntarily and knowingly provide such information to us. This means that we will not know your name, your email address, or any other personal data just because you browse the Site unless you:
- access the Site from a link in an email that we have sent to you;
- have created a profile and you either log-in to your account or choose to be remembered via your cookie or your web-enabled mobile device.
In these cases we will know who you are based on the information you previously supplied to us. When you request a page from our Site, our servers log the information provided in the HTTP request header including the IP number, the time of the request, the URL of your request and other information that is provided in the HTTP header. We collect the HTTP request header information in order to make sure our Site functions correctly and provides you with the functionality that you expect to see. We also use this information to personalize content presented to you, better understand how visitors use our Site and how we can better tune it, its contents, and functionality to meet your needs. We only use your personally identifiable information for those activities listed at the time you submit your information to us. For example, if you provide us with an email to inform you of special events, then that is what we will use your email address to do. If we would like to use your personally identifiable information for an unrelated activity, we will first request your consent to do so.
3. Who Can Use the Information We Collect and How? We may provide your personal data to third parties, or third parties may collect personal data from you on our behalf if we have contracted with that third party to provide some part of the information or service that you have requested. Other than those who act on our behalf and except as explained in this Policy, personal data you provide at this Site will not be transferred to unrelated third parties, unless we have a legal basis to do so. However, please note that personal data provided to this Site is subject to disclosure pursuant to judicial or other government subpoenas, warrants or orders. Unless otherwise required by law, we will only provide this information after approximately two weeks following receipt of a valid subpoena or other legal process in a civil case.
4. How Do We Protect the Personal Information We Collect?
Security of Personal Data
We are committed to protecting the security of your personal data. Depending on the circumstances, we may hold your information in hard copy and/or electronic form. For each medium, we use technologies and procedures to protect personal data. We review our strategies and update as necessary to meet our business needs, changes in technology, and regulatory requirements. We take our security obligations seriously and so should you. While we are responsible for maintaining the security of this Site, you must also access and use this Site in a manner that is responsible and secure. We adhere to internationally recognized security standards. In addition, we have implemented a series of policies, procedures, and training to address data protection, confidentiality, and security, and we update and review the appropriateness of these measures on a regular basis.
Storage and Transfer of Personal Data
COMPANY also collaborates with third parties such as cloud hosting services and suppliers located around the world to serve the needs of our business, workforce, and customers. In some cases, we may need to disclose or transfer your personal data within COMPANY or to third parties in areas outside of your home country. When we do so, we take steps to ensure that personal data is processed, secured, and transferred according to applicable law.
If you would like to know more about our data transfer practices, please contact our Data Protection Officer through our compliance office at [email protected].
Retention of Personal Data
COMPANY retains personal data for as long as necessary to provide the services and fulfill the transactions you have requested, or for other business purposes such as complying with our legal obligations, resolving disputes, and enforcing our agreements. We are required by law to keep some types of information for certain periods of time (e.g., statute of limitations). If your personal data is no longer necessary for the legal or business purposes for which it is processed, we will generally destroy or anonymize that information.
5. What Are Your Rights Regarding Your Personal Data?
We respect your right to access and control your personal data. You have choices about the data we collect. When you are asked to provide personal data that is not necessary for the purposes of providing you with our Products and Services, you may decline. However, if you choose not to provide data that is necessary to provide a Service, you may not have access to certain features, Sites, Products, or Services.
Access to personal data
In some jurisdictions, you have the right to request access to your personal data. In these cases, we will comply, subject to any relevant legal requirements and exemptions, including identity verification procedures. Before providing data to you, we will ask for proof of identity and sufficient information about your interaction with us so that we can locate any relevant data. We may also charge you a fee for providing you with a copy of your data (except where this is not permissible under local law).
Correction and deletion
In some jurisdictions, you have the right to correct or amend your personal data if it is inaccurate or requires updating. You may also have the right to request deletion of your personal data. Please note that such a request could be refused because your personal data is required to provide you with the products or services you requested, e.g. to deliver a product or send an invoice to your email address, or that it is required by the applicable law.
If you have provided us with your contact information, we may, subject to any applicable Spam Act or similar regulation, contact you via email, postal mail or telephone about COMPANY products, services and events that may be of interest to you, including newsletters.
E-mail communications you receive from COMPANY will generally provide an unsubscribe link allowing you to opt-out of receiving future email or to change your contact preferences. E-mail communications may also include a link to directly update and manage your marketing preferences. Please remember that even if you opt out of receiving marketing emails, we may still send you important Service information related to your accounts.
We will make a good faith reasonable effort to honor your DNT browser settings for opting out of receiving targeted third-party advertising based on your overall Internet usage. Please note that various browsers frequently update technology or change their settings and business practices without advance notice, and we may not have the latest information on how to honor your preferences. If you exercise either opt-out option – the cookie opt-out or the browser opt-out – you will continue to receive advertising, but such advertising may not relate to your specific interests, previous purchases, or search history.
However, you cannot opt-out of our contextual analytics and advertising, which is based on your usage of only our Services. We will continue to serve you contextual advertising. We will also continue to monitor your usage and search or transaction history to provide us with analytics on how well our Services, features, and activities are functioning and used. We will also share this information in an aggregated or anonymized form (meaning that no one individual person can be identified) within the Company.
You can also opt out of our marketing emails at any time by contacting us at [email protected] or by sending us correspondence to “OPT OUT”, Evolution Partners Insurance Marketing, Inc., 23001 La Palma Avenue, Suite 120, Yorba Linda, CA 92887, Attn: Compliance Department.
7. How Do You Correct and Update Your Personal Data? We aim to keep all personal data that we hold accurate, complete and up-to-date. While we will use our best efforts to do so, we encourage you to tell us if you change your contact details. If you believe that the information we hold about you is incorrect, incomplete or out-of-date, please contact [email protected]. You can change or correct your personal data at any time. Just send an email with your old information and your corrections to [email protected] with “Correction” in the subject line.
11. Your California Privacy Rights If you are a California resident and have an established business relationship with us and want to receive information about how to exercise your third-party disclosure choices, you must send a request to the following address with a preference on how our response to your request should be sent (email or postal mail). You may contact us in two ways. Send an email to [email protected]. Alternatively, you may contact us at:
Evolution Partners Insurance Marketing, Inc.
23001 La Palma Avenue, Suite 120
Yorba Linda, CA 92887
Attn: Your California Privacy Rights
c/o Privacy Administrator
For requests sent via email, you must put the statement “Your California Privacy Rights” in the subject field of your email. All requests sent via postal mail must be labeled “Your California Privacy Rights” on the envelope or post card and clearly stated on the actual request. For all requests, please include your name, street address, city, state, and zip code. (Your street address is optional if you wish to receive a response to your request via email. Please include your zip code for our own recordkeeping.) We will not accept requests via the telephone or by facsimile. We are not responsible for responding to notices that are not labeled or not sent properly, or do not have complete information.
If you are a California resident under the age of 18, and a registered user of any site where this policy is posted, California Business and Professions Code Section 22581 permits you request and obtain removal of content or information you have publicly posted. To make such a request, please send an email with a detailed description of the specific content or information to [email protected]. Please be aware that such a request does not ensure complete or comprehensive removal of the content or information you have posted and that there may be circumstances in which the law does not require or allow removal even if requested.
12. What If You Have Questions? If you have questions or concerns regarding this statement, you should first contact us via email at [email protected].
Last Updated, March 2023