Last revised: May 24, 2023
- any other services, transactions, engagements, or other interactions you have with us (all of which are collectively referred to as the “Services”).
1. INSURANCE DISCLAIMER
We are not an insurance company or an insurance agent. We help connect individuals and businesses with companies that may be able to provide insurance products. We do not charge individuals or businesses to submit inquiries regarding obtaining insurance through our Site/Services, instead, we receive a payment from the companies with whom we connect potential buyers such as insurance agents, insurers, and third-party insurance service websites (such websites and their operators referred to herein as “Insurance Services”).
3. INFORMATION WE COLLECT
a. Personal Information
When you view content on our website, we automatically collect PII about your computer hardware and software. This information can include your IP address, browser type, domain names, internet service provider (ISP), the files viewed on our site (e.g., HTML pages, graphics, etc.), operating system, clickstream data, access times and referring website addresses. We use this information to provide general statistics regarding use of the Websites. For these purposes, we do link this automatically-collected data to other Personal Information such as name, email address, address, and phone number.
We collect information that personally identifies, relates to, describes, or is capable of being associated with you (“Personal Information”), including:
This information can be provided to us by you through our websites or webforms an/or information we collect automatically when you use our websites and webforms.
Inferences drawn from the above categories of Personal Information that relate to your preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.
The types of Personal Information we collect about you may vary based on how you use the Site and/or Services and your role in the insurance marketplace (e.g., consumer, agent, insurer).
From time to time, and in order to provide you with the best service possible, we may use your information for automated decision making.
b. Consumer Report Notice
In some cases, insurance agents, insurers, and Insurance Services may need to obtain additional background information about you. For example, consumer reports (including credit reports) may be ordered in connection with your insurance application. These reports provide information that may assist in determining your eligibility for insurance and the price you may be charged. Consumer reports may also be used for updates, renewals, or extensions of insurance. Insurance companies may also obtain and use a credit-based insurance score based on information contained in your consumer report. Insurance agents, insurers, and Insurance Services may use a third-party service provider in connection with the development of your insurance score and rate quote. By providing information to us for use in obtaining an insurance quote, you give your express consent for insurance agents, Insurers, Insurance Services, and associated third-party service providers with whom we share your Personal Information to obtain and use a consumer report as described in this paragraph.
c. Usage Data
We automatically collect information in connection with the actions you take on the Site and in connection with using the Services (“Usage Data”). For example, each time you use the Site, we use a log file to automatically collect your IP address, the type of web browser you use, the type of device you use, your device’s operating system, your Internet Service Provider, the pages you view, referring and exit pages, the date and time of your visit, and the number of clicks to, from, and within the Site. We use this information to improve the performance and functionality of our Site and Services, and to better understand how individuals interact with our Site and Services. If this information is capable of being associated with you, directly or indirectly, we treat it as Personal Information. If this information is not capable of being individually associated with you, we treat it as Usage Data.
d. Call Recording
We and/or our Service Providers (as defined below), may record all calls and retain the content of all text messages or other written/electronic communications between you and us and/or our Service Provider, regardless of whether we make the call to you or you make the call to us. By communicating with us, you consent to such recording and retention of communications.
e. Session Recording
We and/or our Service Providers (as defined below), may monitor and/or record and retain the content of all activity, clicks, and keystrokes on our owned and affiliated websites for informational and quality control purposes. By continuing to utilize our website and its content, you consent to such recording and retention.
4. HOW WE COLLECT INFORMATION
a. Voluntary Disclosure
We may ask you to provide us with Personal Information when you register with the Site/Services, submit an inquiry form, complete a survey, communicate with us (online or offline), sign-up for a newsletter, and at other times. You are not required to provide us your Personal Information; however, if you choose not to provide the requested information, you may not be able to use some or all of the features of the Site or Services or we may not be able to fulfill your requested interaction.
b. Third-Party Data Sources
We collect Personal Information from third-party data sources such as insurance agents, insurers, Insurance Services, consumer reporting companies, and data brokerage companies. This Personal Information may be appended to Personal Information we have already collected from or about you.
We use the following types of cookies:
Your acceptance of cookies is not required for visiting our website.
Most internet browsers accept cookies automatically. If you do not wish this to be so, you may set up your browser so that it will inform you about the setting of cookies so that you may permit this only in individual cases; or that you refuse to accept cookies for certain cases or on a general basis; or that you activate the automatic deletion of the cookies when you close the browser. In addition, you may at any time delete cookies that have already been set by using an internet browser or other software programs.
Many devices and browsers give you the option to manage and/or disable cookies and other online tracking technologies. To opt-out of the use of these technologies, you can change your browser options to stop accepting cookies or to prompt you before accepting cookies. To assist you, we compiled directions for some commonly used browsers and devices in the table below. Keep in mind that not all devices and browsers are the same so the methods described below may not work for your browser, browser version, or device and may change at any time. We encourage you to refer to the relevant instructions for your particular device or browser.
Before you dive in, please note, if you opt out of the collection and use of information via cookies and other tracking technologies, you may still see customized advertising displayed by advertising networks from which you have not opted out. In addition, your opt-out will not prevent any advertising network from displaying advertising that is not customized to you and your interests and, consequently, may be less relevant to you. You will need to make such choices on each browser and device you may use to visit our websites and webforms.
Other Options for Disabling Online Tracking. Blocking cookies in your browser may not prevent cross-site tracking of your online activity using other online tracking technologies. In addition to managing your cookie settings for your browser, you can opt-out of tracking directly with the businesses that operate the tracking technologies. To opt-out of certain analytic tracking by our service providers visit the links below:
Do Not Track. Some web browsers may transmit “do not track” signals (go here to learn more). Web browsers may incorporate or activate these features differently, making it unclear if users have consciously activated them. As a result, we do not take steps to respond to such signals.
d. Online Behavioral Advertising
e. Information from Advertisements and Insurance Services
If you arrive at the Site via an advertisement (e.g., banner ad) or an Insurance Service, we may collect information regarding the advertisement or Insurance Service with which you interacted and your interactions (e.g., item clicked, date and time)
f. Tracking Pixels and Clear GIFs
We employ software technology that enables us to track certain aspects of a user's visit to the Site. This technology helps us better manage content on the Site by informing us what content is effective, how consumers engage with the Site, and how consumers arrive at and/or depart from the Site. The software typically uses two methods to track user activity: (1) "tracking pixels" and (2) "clear gifs." Tracking pixels are pieces of executable code that are embedded in a web page that track usage activity including which pages are viewed, when they are viewed, and how long the pages are viewed. Clear gifs are tiny graphics with unique identifiers which are embedded in web pages and email messages that track whether or not a user has viewed a particular web page or email message. User activity information may be associated with additional information about a user's session, such as IP addresses and the type of browser used, and Personal Information, if provided by the user.
g. Google Analytics Advertising Features
We utilize certain Google Analytics tools to improve the Site experience for our users, but also to aggregate the characteristics and browsing habits of our users, on an anonymized basis, to provide products and services that are more tailored to our users.
h. Social Media Widgets
The Site may include social media features, such as the Facebook, YouTube, LinkedIn, and Twitter widgets. These features may collect information about your IP address and the pages you visit on our Site as well as other Personal Information. A cookie may be set to ensure that a feature properly functions. Your interactions with social media features are governed by the privacy policies of the companies that provide them.
5. HOW WE USE AND SHARE INFORMATION
We use Personal Information for internal purposes, such as to
If you provide a testimonial, we may post it publicly on the Site or in other advertising material. By providing a testimonial, you give us permission to use it in any manner and for any purpose, including in marketing and advertising communications, without compensation to you.
c. Service Providers
From time to time, we may establish a relationship with other businesses that we believe are trustworthy and that we believe have privacy practices consistent with ours that may include corporate affiliates (“Service Providers”). We contract with Service Providers to provide certain services to us, including:
We only provide our Service Providers with the information necessary for them to perform these services on our behalf. Each Service Provider is expected to use reasonable security measures appropriate to the nature of the information involved to protect your Personal Information from unauthorized access, use, or disclosure. Service Providers are prohibited from using Personal Information other than as specified by us. We share the following types of Personal Information with one or more Service Providers: personal identifiers; characteristics of protected classification; contact information; commercial information; financial account information; consumer reports; internet or other electronic network activity; professional or employment-related information; education information; health information; and inferences drawn from the above categories of Personal Information that relate to your preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.
d. Third-Party Selling
We sell your Personal Information to third-party companies who want to advertise and market products or services likely to be of interest to you, or to provide you with special offers and opportunities because of your relationship with us. For example, we may sell your Personal Information to insurance agents who may be able to provide the type of insurance you are interested in obtaining or Insurance Services that may obtain and present additional insurance options. In the past twelve months we have sold the following types of Personal Information with one or more third-party companies for their marketing purposes: personal identifiers; characteristics of protected classification; contact information; commercial information; financial account information; consumer reports; internet or other electronic network activity; professional or employment-related information; education information; health information; and inferences drawn from the above categories of Personal Information that relate to your preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.
e. Email Marketing
We may use your Personal Information to market products or services likely to be of interest to you, or to provide you with special offers and opportunities, via email. With respect to commercial email communications from us, you may opt out of these emails via a link in the footer of all commercial email messages.
We recognize the importance of safeguarding the confidentiality of your Personal Information. Accordingly, we employ commercially reasonable administrative, technical, and physical safeguards to protect your Personal Information from unauthorized access, disclosure, and use. Even with these safeguards, no data transmission over the Internet or other network can be guaranteed 100% secure. As a result, while we strive to protect information transmitted on or through our Site and Services we cannot, and do not, guarantee the security of any information you or we transmit on our Site or using our Services, or that you or we transmit over any other electronic network and you accept any associated risk.
7. BLOGS & FORUMS
Our Site and/or Services may contain features such as blogs, forums, message boards, or other public-facing message systems. If you use one of these features, your comments, including any Personal Information you share, will be viewable to other users and the public. You use such features at your own risk. We are not responsible for the Personal Information you share using such features or any consequences that result therefrom.
We reserve the right, but are under no obligation, to remove any comments from such features that we believe, in our sole discretion, constitute defamation, libel, slander, obscenity, pornography, profanity, hate speech, discrimination, or otherwise offend other users or our brand.
8. OTHER WEBSITES
Please be aware that third-party websites accessible through the Site or Services may have their own privacy and data collection policies and practices. We are not responsible for any actions, content of websites, or privacy policies of such third parties. You should check the applicable privacy policies of those third parties when providing information through linked websites.
9. COMPLIANCE WITH LAWS AND LAW ENFORCEMENT
We cooperate with government and law enforcement officials and private parties to enforce and comply with the law. We may disclose Personal Information, Usage Data, and any other information about you to government or law enforcement officials or private parties if, in our sole discretion, we believe it is necessary or appropriate to respond to legal requests (including court orders, investigative demands, and subpoenas), to protect the safety, property, or rights of ourself, users, or any other third party, to prevent or stop any illegal, unethical, or legally actionable activity, or to comply with law.
10. OTHER TRANSFERS
We may share Personal Information and Usage Data with businesses controlling, controlled by, or under common control with us. If we are merged, acquired, or sold, or in the event of a transfer of some or all of our assets, we may disclose or transfer Personal Information and Usage Data in connection with such transaction.
11. HOW LONG WE RETAIN YOUR DATA
We retain your Personal Information for as long as we have a relationship with you. We also retain your Personal Information for a period of time after our relationship with you has ended where there is an ongoing business need to retain it. This includes retention to comply with our legal, regulatory, tax, and/or accounting obligations. Generally, we retain Personal Information until you ask us to delete it, or otherwise in accordinace with applicable law and our internal data retention policies
12. CHILDREN’S PRIVACY
The Site is not intended for children under the age of 18 and we do not knowingly collect Personal Information from children under the age of 18. If we become aware that we have inadvertently received Personal Information from a child under the age of 18, we will delete such information from our records.
13. OPT OUT
You have the right to opt out of receiving marketing from us by emailing us at service@SmartFinancial.com If you opt out of marketing you will still receive transactional messages, such as responses to your questions. If you opt-out of receiving marketing communications from our business partners with whom we have shared your information, you will still receive marketing communications from us and any other business partners with whom your information was shared. If you do not wish us to track your location, you can turn off the GPS location or push notifications on your phone or personal computer through your local settings.
14. CONTACT US
Attn: Privacy Dept.
4041 MacArthur Blvd, Suite 210
Newport Beach, CA 92660
15. EUROPEAN VISITORS
16. ADDITIONAL CALIFORNIA CONSUMER RIGHTS
a. Right to Know
You have the right to request that we provide you (i) the categories and/or specific pieces of Personal Information we collected about you; (ii) the categories of sources from which your Personal Information was collected; (iii) the business or commercial purpose for which we collected your Personal Information; and (iv) the categories of third parties with whom we shared your Personal Information. If we sold or disclosed your Personal Information to third parties, you also have the right to request that we provide you (i) the categories of Personal Information we collected about you; (ii) the categories of your Personal Information we sold to third parties; (iii) the categories of third parties to whom we sold your Personal Information; and (iv) the categories of your Personal Information we disclosed to third parties.
Please note that we are not permitted to provide access to specific pieces of Personal Information if the Personal Information is sensitive or creates a high risk of potential harm from disclosure to an unauthorized person such as financial account information, health information, social security numbers, or driver’s license numbers. If we withhold specific personal information because of its sensitivity or risk, we will inform you.
Categories of Information Collected, Disclosed or Sold in the Past 12 Months
Whether we have sold to a third party, or disclosed for a business purpose, the category of Personal Information; and the categories of third parties to whom the information was disclosed or sold. The table does not include Personal Information provided to us by partners or other customers in a business-to-business context.
|Category of Personal Information Collected||Sold or Disclosed?||Category of Third Parties to Whom the Personal Information was Sold or Disclosed|
|Identifiers, including your name, name, IP address, email address, phone, address||Disclosed||We have disclosed for a business purpose this category of Personal Information to Service Providers|
|Customer records information, including signature, bank account number, address,||Disclosed||We have disclosed for a business purpose this category of Personal Information to Service Providers|
|Characteristics of Protected Classifications||Not Sold or Disclosed|
|Commercial Information, including records of services that you have purchased in the past||Disclosed||We have disclosed for a business purpose this category of Personal Information to Service Providers|
|Internet or Other Network Activity Information, including information about how you interact with our website||Disclosed||We have disclosed for a business purpose this category of Personal Information to Service Providers|
|Geolocation Data||Not sold or Disclosed|
|Professional or Employment-Related Information, including your job title and organizational affiliation||Disclosed||We have disclosed for a business purpose this category of Personal Information to Service Providers|
b. Right to Deletion
You have the right to request that we delete any Personal Information we have collected about you. Please understand that we are not required to honor a deletion request if we need the information to complete a requested or reasonably anticipated transaction, prevent security incidents or fraud, enable internal uses that are reasonably aligned with your expectations, comply with legal obligations, or perform other functions permitted by law.
c. Exercising your Rights to Know and Deletion
You may exercise your Rights to Know and Deletion by calling us at 855-214-2291 or completing the form on our CCPA Request Page. Please be specific in your request and provide sufficient information to allow us to locate your Personal Information in our systems based on your request. We will retain a record of your request, including a deletion request, in accordance with law. Additional information about our timeframe for response and identity verification is available on our our CCPA Request Page.
Request information about our collection, use, and sharing of their information (a "Request to Know"), including:
the categories and specific pieces of Personal Information we have collected about them;
the categories of sources from which we have collected their Personal Information;
the business or commercial purpose for collecting or selling their Personal Information;
the categories of their Personal Information that we have sold; and
the categories of third parties with whom we have shared, disclosed for a business purpose, or sold their Personal Information, and which categories of Personal Information we have sold to which categories of third parties.
We will not discriminate against users for exercising these rights. We may charge users different prices or provide different levels or quality of goods or services, if the difference is reasonably related to the value of their data. We may also offer financial incentives for the collection, sale, or deletion of your Personal Information. In addition, some Personal Information is essential for us to provide the Services. For example, we cannot provide you with an insurance quote without first collecting some Personal Information about you. In such instances, your refusal to provide the necessary Personal Information will result in the inability to use our Service.
You may exercise your Rights to Know and Deletion by calling us at 855-214-2291 or completing the form on our CCPA Request Page. Please be specific in your request and provide sufficient information to allow us to locate your Personal Information in our systems based on your request. We will retain a record of your request, including a deletion request, in accordance with law. Additional information about our timeframe for response and identity verification is available on our CCPA Request Page.
d. Right to Opt Out, Correct Inaccuracies
You have the right to direct us not to sell your Personal Information to third parties. You may exercise your Right to Opt Out by calling us at 855-214-2291 or completing the form on our CCPA Request Page. Please provide sufficient information to allow us to locate your Personal Information in our systems.
Please contact us at service@SmartFinancial.com if you would like to request access to the PII that we have collected online from you, or to correct factual errors in such information.
e. Non-Discrimination Notice
f. California “Do Not Track” Disclosure
Do Not Track is a web browser privacy preference that causes the web browser to broadcast a signal to websites requesting that a user’s activity not be tracked. At this time, our Site and Services do not respond to “do not track” signals.
g. California Site Ownership Disclosure
Under California Civil Code Section 1789.3, California residents are entitled to the following information: The provider of the Site is SmartFinancial.com Insurance LLC, 4041 MacArthur Blvd, Suite 210, Newport Beach, CA. 92660. To file a complaint regarding the Site or to receive further information about the Site, please contact us. You may also contact the Complaint Assistance Unit of the Division of Consumer Services of the Department of Consumer Affairs in writing at 1625 North Market Blvd., Suite N 112, Sacramento, California 95834 or by telephone at (800) 952-5210.
h. Right to Non-Discrimination
Should you wish to exercise your rights as a resident of California, we will not discriminate against you by showing you different products or services based solely upon your request. Kindly note, however, if the advertisers require additional data or information from you before providing quotes, rates, or other information, exercising your California rights may limit the number and range of advertisers who are displayed in response to your request.
i. Do Not Sell My Personal Information
Some of our sharing activities may be a “sale” of personal information under California law. For example, when we share information we collected automatically from you with advertisers in order to create consumer profiles and present our advertisers’ products and services to you. Subject to certain exceptions, as a California resident, you may opt-out of the “sale” of your personal information at any time by taking the following actions:
j. Shine the Light
California residents may, no more than once per calendar year, request from us information about our disclosure of certain categories of personal information to third parties for direct marketing purposes. To be valid, requests must be submitted to us at in our Privacy Center and select the “Shine the Light Request” option from the drop down menu. We will provide you within 30 days of receiving your request, a list of the categories of personal information (also known as personal data) disclosed to third parties for direct marketing purposes during the immediately preceding calendar year and the names and addresses of the third parties.
17. Nevada Residents
Subject to certain exceptions, some of our data sharing practices may be considered a “sale” of your personal information under Nevada Revised Statutes 603A. Nevada residents may opt-out of the “sale” of personal information covered under the statute, by exercising your cookie consent options as detailed in Cookies and Other Technologies or by submitting your request through our Do Not Sell My Personal Information form or call us at 855-214-2291.
18. Retention of Your Personal Data.