Created: July 17, 2024

GRADEPOINT INSURANCE GROUPPrivacy Notice

At GradePoint Insurance Group (

“GradePoint”

,

“Company”

,

“we”

,

“our”

or

“us”

), we value your trust. We are committed to acting responsibly when we collect, use and protect your non-personal and personal information.

We believe in being clear and open about how we collect data related to you when you visit our website at

www.gradepointinsurance.com

(

“Website”

), become our customer as defined by the federal Gramm-Leach-Bliley Act (GLBA) and applicable state laws, subscribe to our newsletter, interact with us, participate in online advertisements or marketing emails, opt-in to receive SMS mobile messages or engage with any other websites, pages, features, or content we own, operate and/or provide (collectively with the Website, the

“Services”

) that direct you to this Privacy Notice (

“Privacy Notice”)

.

The Privacy Notice to our customers is required by GLBA and applicable state laws under either of the following conditions:

You have financial products or services (banking, securities, or insurance) which are used primarily for personal, family or household purposes; orGradePoint has your information in connection with these types of products or services.

This Privacy Notice does not apply to information collected by:

Us offline or through any other means, including on any other website operated by Company that does not direct you to this Privacy Notice or any third party (including our affiliates and subsidiaries); orAny third party (including our affiliates and subsidiaries), including through any application or content (including advertising) that may link to or be accessible from or through the Website.

This Privacy Notice is designed to help you understand how we collect, use, share and safeguard the information you provide to us and to assist you in making informed decisions when using our Services. Please read this Privacy Notice very carefully.

By accessing and using the Services, you consent to our collection, storage, use and disclosure of your Personal Information as described in this Privacy Notice and the Cookie Policy located at <

LINK

> (“Cookie Policy”).
The Services are intended for users located in the United States only, and you hereby expressly acknowledge and agree that if you are accessing and/or using the Services that you reside in the United States and will only access and/or use the Services in the United States. The use of the Services is subject to the Terms and Conditions located at <

LINK

>.

In this Privacy Notice you will find information about:

Types Of Data We CollectChildren’s Online Privacy Protection Act (“COPPA”)Information you Provide to UsCollected via TechnologyInformation we Obtain from Other Sources

Use of Your Personal InformationUse of Non-Personal InformationHow We Share Your Personal InformationLinks to Third Party Websites and Third Party Providers

Promotional and Marketing Communications

Your Rights and ChoicesSecurity of Your Personal Information and Personal Data

How we Retain Your Personal InformationAccessibilityChanges to This Privacy NoticeOther JurisdictionsContact Information

Types of Data We Collect

We collect “Non-Personal Information” and “Personal Information” and the information we collect from you depends on how you use the Services.

“Non-Personal Information”

includes information that cannot be used to personally identify you, such as anonymous usage data, general demographic information we may collect, referring/exit pages and URLs, platform types, preferences you submit and preferences that are generated based on the data you submit and number of clicks.

“Personal Information”

means data that allows someone to identify or contact you, including, for example, your name, address, telephone number, email address, as well as any other non-public information about you that is associated with or linked to any of the foregoing data. This includes:

Context

Types of Data that we may process

Website User Information

We collect the name, email address, phone number and information you decide to include in your message when a user contacts us.

If you opt-in to receive text messages from us, we may send you a text message that contains promotional information that may be of interest to you. You can opt-out of receiving future text messages by replying "STOP."

Web Consultation

If you schedule a consultation with us through our online web form powered by Calendly, we collect your:

●




name

●




email address,

●




additional guest information, if applicable

●




any additional information that you share to help us prepare for our meeting.

For all recorded web consultations, you will be asked to provide consent to being recorded. If you do not provide consent, your microphone will be muted, and your video will be off if you join a meeting with recording or live streaming already in progress. Your microphone and video settings will revert back to default if you provide consent

Webinars

When you sign up for a webinar that we offer hosted via Zoom we will collect your username and email address.

The information is needed to provide you access to the webinar and any recordings thereof.

For all recorded Zoom webinars, you will be asked to provide consent to being recorded. If you do not provide consent, your microphone will be muted, and your video will be off if you join a meeting with recording or live streaming already in progress. Your microphone and video settings will revert back to default if you provide consent.

Cookies and first party tracking

We use Cookies and clear GIFs. “

Cookies

” are small pieces of information that a website sends to a computer’s hard drive while a website is viewed. See our Cookie Policy for more information on how we use Cookies.

https://www.gradepointinsurance.com/cookie-policy

Cookies and Third-Party Tracking

We participate in behavior-based advertising, this means that a third party uses technology (i.e.: a cookie, pixel or ‘LAL’) to collect information about your use of the Service so that they can provide advertising about products and services tailored to your interests.

Email Interconnectivity

If you receive email from us, we may use certain tools to capture data related to when you open our message, click on any links or banners it contains and make purchases.

Feedback/Support

We collect Personal Information from you contained in any inquiry you submit to us regarding the Services, such as completing our online forms, calling or emailing for the purposes of general inquiries, support requests, or to report an issue.

When you communicate with us over the phone, your calls may be recorded and analyzed for training, quality control and for sales and marketing purposes. During such calls we will notify you of the recording via either voice prompt or script and advise you of our privacy policies.

E-mail List

When you sign up for our e-mail, we collect your name,
email address and we may also collect your phone number.

Mobile Devices

We collect information from your mobile device such as unique identifying information broadcast from your device when using the Services.

Website Interactions

We use technology to monitor how you interact with the Services. This may include: IP addresses, preferences, web pages you visited prior to using the Services, information about your browser, network or device (such as browser type and version, operating system, internet service provider, preference settings, unique device IDs and language and other regional settings), information about how you interact with the Services (such as timestamps, clicks, scrolling, browsing times, searches, transactions, referral pages, load times, and problems you may encounter, such as loading errors).

Logs

We collect information, including your browser type, operating system, Internet Protocol (“

IP

”) address (a number that is automatically assigned to a computer when the Internet is used), domain name, click-activity, referring website, and/or a date/time stamp for visitors.

Demographic Information

We collect Personal Information, such as your age or location.

Geolocation Information

When you use our Website and Services we collect your location from the GPS, Wi-Fi, and/or cellular technology in your device to determine your location to better serve you.

Children’s Online Privacy Protection Act (“COPPA”)

Our Services are not designed for children under 13, and we do not intentionally or knowingly collect Personal Information from users who are under the age of 13 or from other websites or services directed at children. If we discover that a child under 13 has provided us with Personal Information, we will delete such information.

Information You Provide to Us

We collect Personal Information from you listed in Section 1 above.We will maintain the information you send via email in accordance with applicable federal law.In compliance with the CAN-SPAM Act, all emails sent from our organization will clearly state who the email is from and provide clear information on how to contact the sender. In addition, all email messages will also contain concise information on how to remove yourself from our mailing list so that you receive no further e-mail communication from us.

Collected via Technology

In an effort to improve the quality of the Services, we reserve the right to track information provided to us by your browser or by our software application when you view or use the Services, such as the website you came from (known as the “referring URL”), the type of browser you use, the device from which you connected to the Services, the time and date of access, and other information that does not personally identify you. We track this information using Cookies. Cookies are sent to a user’s browser from our servers and are stored on the user’s computer hard drive or mobile device. Sending a Cookie to a user’s browser enables us to collect Non-Personal information about that user and keep a record of the user’s preferences when utilizing our Services, both on an individual and aggregate basis. Please review the Cookie Policy for more information. [LINK]We may also use third party analytics services such as Matomo and GoHighLevel to collect information about how you use and interact with our Services. Such third-party analytics services may use Cookies to gather information such as the pages you visited, your IP address, a date/time stamp for your visit and which website referred you to the Website.Some content or applications, including advertisements, on the Services are served by third parties, including advertisers, ad networks and servers, content providers, and application providers. These third parties may use Cookies alone or in conjunction with web beacons or other tracking technologies to collect information about you when you use our Services. The information they collect may be associated with your Personal Information or they may collect information, including Personal Information, about your online activities over time and across different websites and other online services. They may use this information to provide you with interest-based (behavioral) advertising or other targeted content. We do not control these third parties' tracking technologies or how they may be used and we are not liable for any third party providers, acts or omissions. If you have any questions about an advertisement or other targeted content, you should contact the third party provider directly.

Information We Obtain from Other Sources

Our affiliates, data analytics providers, advertising networks, internet service providers, operating systems and platforms and social networks may also provide us information about you. We may also collect information from publicly available sources.

Use of Your Personal Information

In general, Personal Information you submit to us is used either to respond to requests that you make, or to aid us in serving you better. We use your Personal Information in the following ways:

to provide you Services as you requested;to identify you as a user in our system;to provide improved administration of the Services;to improve the quality of experience when you interact with the Services;set up a web consultation per your request;register you for a webinar;to send you administrative email notifications, such as security or support and maintenance advisories;to periodically send newsletters, surveys, offers, and other promotional materials related to our Services and for other marketing purposes including those of third parties;to perform marketing or data analysis;

to comply with legal obligations, as part of our general business operations, and for other business administration purposes; and

in very limited circumstances where we believe necessary to investigate, prevent or act regarding illegal activities, suspected fraud, situations involving potential threats to the safety of any person or violations of this Privacy Notice.

Use of Non-Personal Information

In general, we use Non-Personal Information to help us improve the Services and customize the user experience. We also aggregate Non-Personal Information in order to track trends and analyze use patterns on the Services. This Privacy Notice does not limit in any way our use or disclosure of Non-Personal Information and we reserve the right to use and disclose such Non-Personal Information to our partners, advertisers and other third parties at our discretion.

How We ShareYour Personal Information

We may disclose your Personal Information as described below and as described elsewhere in this Privacy Notice.

Other GradePoint Companies. We may share your Personal Information with other GradePoint companies such as GradePoint Financial and GradePoint Financial Group to provide current and/or future services to you.

Third Party Service Providers.We may share your Personal Information with third party service providers to provide you with the Services that we offer you; to provide you with an insurance quote per your request; to conduct quality assurance testing; to perform marketing; to run data analysis; to facilitate creation of accounts; to provide technical support; and/or to provide future services to you.

Integrations and Third-Party Services.We integrate third-party Application Programming Interface (“API”) in connection with the Services that we offer you. The information collected by GradePoint when using the API, is processed in compliance with this Privacy Notice. Information collected by third-party API partners is governed by their privacy policies and GradePoint does not own or control those third parties. The API services we use to provide the Services include but are not limited to:Back9ins for the purpose of providing you an insurance quote and enable you to contact a licensed life insurance advisor and/or to purchase the insurance. To learn more about Back9ins please review their privacy policy here:Privacy Policy | Synapse (synapsefi.com)Matomo for web analytics. To learn more about Matomo please review their privacy policy here: https://matomo.org/privacy-policy/

Business Transfers.If (i) GradePoint is acquired by, merges with, or receives investment from another company or (ii) if any of the GradePoint’s assets are or may be transferred to another company, whether as part of a bankruptcy or insolvency proceeding or otherwise, we may transfer the information we have collected from you to the other company. As part of the business transfer process, we may share certain of your Personal Information with lenders, auditors, attorneys and consultants.

Other Disclosures.Regardless of any choices you make regarding your Personal Information (as described below), we may disclose Personal Information if it believes in good faith that such disclosure is necessary (a) in connection with any legal investigation; (b) to comply with relevant laws or to respond to subpoenas or warrants served on us; (c) to protect or defend our rights or property, or the rights or property of users of the Services; (d) to investigate, prevent, or take action regarding illegal activities, suspected fraud, situations involving potential threats to the safety of any person and/or (e) to investigate or assist in preventing any violation or potential violation of the law, this Privacy Notice, or any agreements you may have with us, as applicable.

Links to Third Party Websitesand Third Party Providers

As part of the Services, we provide links to or compatibility with other websites or applications; however, we are not responsible for the privacy practices employed by those websites or the information or content they contain nor are we liable for third party products, services, acts and/or omissions. This Privacy Notice applies solely to information collected by us in relation to the Services and your use of the Services. Therefore, this Privacy Notice does not apply to your use of a third-party website accessed by selecting a link on our Website or via the Services. To the extent that you access or use the Services through or on another website or application, then the privacy policy of that other website or application will apply to such access and/or use. We encourage our users to read the privacy statements of other websites before proceeding to use them.

Promotional and Marketing Communications

We may send periodic promotional emails to you. You have the right at any time to prevent us from contacting you for marketing purposes. When we send a promotional communication to a user, the user can opt out of further promotional communications by following the unsubscribe instructions provided in each promotional email. Please note that notwithstanding the promotional preferences you indicate by unsubscribing, we may continue to send you administrative emails including, for example, periodic updates to our Privacy Notice. You may unsubscribe to promotional emails by following the opt-out instructions contained in the email. Please note that it may take up to 10 business days for us to process unsubscribe requests. If you unsubscribe from receiving promotional emails, we may still send you emails about the Services.

Your Rights and Choices

If applicable privacy laws allow, you may have rights over your Personal Information.
This includes, but is not limited to:

Right to Know.You have the right to request disclosure about our Personal Information collection practices during the prior 12 months, including the categories of Personal Information we collected, the sources of the information, our business purposes for collecting or sharing the information and the categories of third parties with whom we shared such information. You may request a copy of the specific pieces of Personal Information we may have collected about you in the last 12 months.Right to Delete. You may request that we delete (and direct our service providers to delete) your Personal Information, subject to certain exceptions.Right to Opt-Out. You have the right to opt-out of any ‘sales’ of your Personal Information, if a business is selling your information.Non-Discrimination.You have the right to not be discriminated against for exercising these rights.

You can make the following choices regarding your Personal Information:

Access To Your Personal Information.You may request access to your Personal Information by contacting us at the address below. If required by law, upon request, we will grant you reasonable access to the Personal Information that we have about you. We will provide this information in a portable format, if required. Note that California residents may be entitled to ask us for a notice describing what categories of Personal Information (if any) we share with third parties or affiliates for direct marketing.Changes To Your Personal Information. We rely on you to update and correct your Personal Information. Please contact us at the address below immediately if there are any changes to your Personal Information. Note that we may keep historical information in our backup files as permitted by law.Deletion Of Your Personal Information.Typically, we retain your Personal Information for the period necessary to fulfill the purposes outlined in this Privacy Notice, unless a longer retention period is required or permitted by law, or as otherwise described in this Privacy Notice. You may, however, request information about how long we keep a specific type of information, or request that we delete your Personal Information by contacting us at the address below. If required by law we will grant a request to delete information, but you should note that in many situations we must keep your Personal Information to comply with our legal obligations, resolve disputes, enforce our agreements, or for another one of our business purposes.Objection to Certain Processing. You may object to our use or disclosure of your Personal Information by contacting us at the address below.Online Tracking.We do not currently recognize automated browser signals regarding tracking mechanisms, which may include ‘Do Not Track’ instructions.Promotional Emails.You may choose to provide us with your email address for the purpose of allowing us to send free newsletters, surveys, offers, and other promotional materials to you, as well as targeted offers from third parties. You can stop receiving promotional emails by following the unsubscribe instructions in e-mails that you receive. If you decide not to receive promotional emails, we may still send you communications related to your use of the Services and administrative purposes for reasons such as providing you with updates to this Privacy Notice.Tracking Technologies and Advertising.You can set your browser to refuse all or some browser cookies, or to alert you when cookies are being sent. To learn how you can manage your Flash cookie settings, visit the Flash player settings page on Adobe's website. If you disable or refuse cookies, please note that some parts of this site may then be inaccessible or not function properly.

Revocation Of Consent.If you revoke your consent for the processing of Personal Information, then we may no longer be able to provide you Services. In some cases, we may limit or deny your request to revoke consent if the law permits or requires us to do so, or if we are unable to adequately verify your identity. You may revoke consent to processing (where such processing is based upon consent) by contacting us at the address below.How to Exercise your Right(s).You may enquire about your Personal Information by contacting us as described below in Section 17 below, and we’ll generally respond to all access requests within 30 days of the receipt of all necessary information. As required by law, we will require you to prove your identity before providing you with the Personal Information we hold about you. We may verify your identity by phone call or email. Depending on your request, we will ask for information such as your name or other account information. We may also ask you to provide a signed declaration confirming your identity. Following a request, we will use reasonable efforts to supply, correct or delete Personal Information about you in our files. In circumstances where we are not able to provide access, or if additional time is required to fulfill a request, we will advise you in writing.

In some circumstances, you may designate an authorized agent to submit requests to exercise certain privacy rights on your behalf.
We will require verification that you provided the authorized agent permission to make a request on your behalf.
You must provide us with a copy of the signed permission you have given to the authorized agent to submit the request on your behalf and verify your own identity directly with us.
If you are an authorized agent submitting a request on behalf of an individual you must attach a copy of the following information to the request:

A completed written notice indicating that you have authorization to act on the consumer’s behalf signed by you and the consumer.If you are a business, proof that you are registered with the appropriate Secretary of State to conduct business in that state.

If we do not receive this information, the request will be denied.

GradePoint may not release certain types of information based upon exemptions specified in applicable laws. Where possible, we will sever the information that will not be disclosed and provide you with access to the remaining information. Should we be unable to provide access to or disclose Personal Information to you, we will provide you with an explanation, subject to restrictions.

In certain circumstances, such as where the request is excessive or unfounded, we may charge you an administration fee for access to your Personal Information. We may also charge for additional copies. We will advise you of any fees before proceeding with a request. You may learn more about the process or obtain assistance in completing an access request by contacting us as described below.

Security of Your Personal Information and Personal Data

We implement security measures designed to protect your information from unauthorized access, alteration, disclosure and/or destruction. Because the internet is not a completely secure environment, we cannot warrant the security of any information a user transmits to us or guarantee that information on the Services may not be accessed, disclosed, altered, and/or destroyed by breach of any of our physical, technical and/or managerial safeguards.
We further protect your information from potential security breaches by implementing certain technological security measures; however, these measures do not guarantee that your information will not be accessed, disclosed, altered or destroyed by breach of such firewalls and secure server software. While we use reasonable efforts to protect your Personal Information, we cannot guarantee the Services are absolutely secure.

How we Retain Your Personal Information

We will retain your Personal Information for as long as necessary to fulfill the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. The precise periods for which we keep your Personal Information vary depending on the nature of the information and why we need it. To determine the appropriate retention period for Personal Information, we consider the amount, nature, and sensitivity of the Personal Information, the potential risk of harm from unauthorized use and/or disclosure of your Personal Information, the purposes for which we process your Personal Information and whether we can achieve those purposes through other means, and the applicable legal requirements.

In some circumstances we may anonymize your Personal Information (so that it can no longer be associated with a user) for research or statistical purposes in which case we may use this information indefinitely without further notice.
We may retain information (including without limitation your personally identifiable information) for a commercially reasonable time for backup, archival, audit purposes, and/or to comply with legal obligations, resolve disputes and enforce agreements. In some cases, if you choose not to provide us with requested information, you may not be able to use the Services. You can request further details of retention periods for different aspects of your Personal Information by contacting us.

Please note that in the course of providing the Services, we collect and maintain aggregated, anonymized, or de-personalized information which we may retain indefinitely.

Accessibility

If you are visually impaired, you may access this Privacy Notice through your browser’s audio reader.

Changes to This PrivacyNotice

We reserve the right to change this Privacy Notice or any agreement you entered into with GradePoint from time to time. We may notify you of significant changes to this Privacy Notice by sending a notice to the primary email address specified by you or by placing a prominent notice on Website.
Significant changes will go into effect thirty (30) days following such notification. Non-material changes or clarifications will take effect immediately. Our Privacy Notice includes an “effective” and “created” or “last updated” date. The effective date refers to the date that the current version took effect. The last updated date refers to the date that the current Privacy Notice was last substantively modified.

You should periodically check the Website and this Privacy Notice for updates.

16. Other Jurisdictions

GradePoint is located in the United States. The Services are hosted in, provided from the United States, and intended for those that reside in the United States.
Personal information that you submit through the Services may be transferred outside of the jurisdiction in which you live.
Your Personal Information may be transferred to other jurisdictions that do not have the same data protection laws as the jurisdiction in which you initially provided the information. The following provisions may apply to you depending on where you are located.

Nevada.

This notice is provided to you pursuant to state law. Nevada state privacy laws permit us to make marketing calls to existing users, but if you prefer not to receive marketing calls, you may be placed on our internal opt-out list by emailing us at

[email protected]

or you may also contact the Nevada Bureau of Consumer Protection, Office of the Nevada Attorney General, 555 E. Washington St., Ste 3900, Las Vegas, NV 89101; telephone 702-486-3132; email:

[email protected]

.
We do not make marketing calls to existing users.

California.

At this time, California Privacy laws (California Consumer Privacy Act, California Privacy Rights Act) do not apply to us, but we will still protect your Personal Information as outlined in this Privacy Notice. If you feel this is incorrect, please contact us at [email protected]

Contact Information

If you have any questions, comments, or complaints concerning our privacy practices, please contact us by sending an email to [email protected] or send correspondence via mail to:

GradePoint Insurance Group

165 N. Archer Ave

Mundelein, IL 60060

We will attempt to respond to your request and to provide you with additional privacy-related information.

Effective Date: July 16, 2024