ACCLAIM PRIVACY POLICY

ACCLAIMIQ, LLC (“ACCLAIM“, “we“, “us“ and “our“) is committed to protecting your personal information and your right to privacy. This privacy notice provides information about our use of personal information and your rights and choices. If you have any questions or concerns about this privacy notice, or our practices with regards to your personal information, please contact us at info@acclaimiq.com.

ACCLAIM provides an Application hosted by the Microsoft Azur Cloud.

This privacy notice applies to all information collected when you visit or use our website https://acclaimiq.com (the “Website“ or “Site”), and when you sign up for, login to, access use or communicate with the ACCLAIM Application or Services.

1. WHAT INFORMATION DO WE COLLECT?

We collect information that you provide to us when you access or use our Website or Services, submit a form, express an interest in obtaining information about us or our products and Services, or otherwise when you contact us.

The information that we collect depends on the context of your interactions with us and the Website, the choices you make and the products and features you use. Personal information includes information about an individual from which that individual may be identified such as name, phone number, email address, or payment information.

Information collected that you provide to us:

We automatically collect certain information when you visit, use or navigate the Website. This information does not reveal your specific identity (like your name or contact information) but may include device and usage information, such as your IP address, browser and device characteristics, operating system, language preferences, referring URLs, device name, country, location, information about how and when you use our Website and other technical information. This information is primarily needed to maintain the security and operation of our Website, and for our internal analytics and reporting purposes.

Like many businesses, we also collect information through cookies and similar technologies.

The information we collect automatically includes:

a) Log and Usage Data. Log and usage data is service-related, diagnostic, usage and performance information our servers automatically collect when you access or use our Website and which we record in log files. Depending on how you interact with us, this log data may include your IP address, device information, browser type and settings and information about your activity on the Website (such as the date/time stamps associated with your usage, pages and files viewed, searches and other actions you take such as which features you use), device event information (such as system activity, error reports (sometimes called ‘crash dumps’) and hardware settings).

b)   Device Data. We collect device data such as information about your computer, phone, tablet or other device you use to access the Website. Depending on the device used, this device data may include information such as your IP address (or proxy server), device and application identification numbers, location, browser type, hardware model Internet service provider and/or mobile carrier, operating system and system configuration information.

c)  Location Data. We collect location data such as information about your device’s location, which can be either precise or imprecise. How much information we collect depends on the type and settings of the device you use to access the Website. For example, we may use GPS and other technologies to collect geolocation data that tells us your current location (based on your IP address).

Information collected from our business partners:

We partner with the National Insurance Producer Registry (“NIPR”) and receive Producer information from the NIPR that is passed to a customer’s instance on the Microsoft Azur Cloud platform. This information includes (1) contact and profile information, such as: name, social security number, date of birth, email address, phone number, physical address), title, and professional details; (2) producer licensing information, such as: National producer number (“NPN”), license numbers, region, state, and related business contact information; and (3) regulatory action information, such as: action type, action date, disposition, and relevant penalties or fines

Information collected from other sources:

In order to enhance our ability to provide relevant marketing, offers and services to you and update our records, we may obtain information about you from other sources, such as public databases, joint marketing partners, affiliate programs, data providers, social media platforms, as well as from other third parties. This information includes mailing addresses, email addresses, phone numbers, intent data (or user behavior data), Internet Protocol (IP) addresses, producer business information such as Federal Employer Identification Number (“FEIN”), business name and licensing state and custom profiles.

2. COOKIES

A)  WHAT ARE COOKIES?
Cookies are small text files that are set by our Site or by third parties that provide content or features on our Site and are stored on your computer or mobile device. Cookies can be described by who created and placed them and how long they last. Types of cookies include the following:

(i)  Persistent Cookies: A persistent cookie stays in your browser and will be read by us when you return. A persistent cookie helps us recognize you as an existing user.

(ii) Session Cookies: A session cookie is temporary and enables you to move from page to page on our Site. A session cookie is deleted when you close your browser or after a short period of time.

(iii) First-party cookies: These are cookies set by the website or online service you are visiting, either by us, or by a third party at our request.

(iv) Third-party cookies: These are cookies that are set by a party other than the party whose website you are visiting.

B) WHAT INFORMATION DO COOKIES COLLECT?

Cookies collect different types of information depending on the type of cookie and its purpose. Some examples of information that may be collected by cookies when you use our Site include:

(i)  The pages you visit within the Site;

(ii) The buttons you click on our Site;

(iii) The date and time you visit our Site;

(iv) The amount of time you spend on our Site;

(v) The IP address used to connect your computer to the Internet; and

(vi) Your computer and connection information such as your browser type and version, operating system and platform.

C) COOKIES ACCLAIM USES AND FOR WHAT PURPOSES

We, or our service providers or agents acting on our behalf, use the following persistent and session cookies on our Site:

a) Strictly Necessary Cookies: These cookies are essential because they enable our Site to work, and they cannot be disabled. Without these cookies, some of the functionality on our Site cannot be provided. These cookies do not gather information about you for marketing purposes. For example, these cookies are used to:  

(i)  Remember information that you fill in when performing certain activities on the Site;

(ii) Pass information from one page to the next, for example when filling out forms;

(iii) Read your browser and device settings to optimize the display of the Site;

(iv) Locate and identify misuse of the Site;

(v)  Load the Site uniformly to maintain accessibility; and

(vi)  Prevent fraud.

b) Performance or Analytics Cookies: These cookies help us understand how the Site is being accessed, used, or performing, such as the frequency and duration of use of the Site. These analytics cookies may collect information about the content you view, what websites you visit immediately prior to and after visiting our Site, and your system and geographic information. The information generated by these cookies will be transmitted to and stored by the applicable analytics services.

One type of analytics cookie we may use is Google Analytics, a web analytics service provided by Google. For more information on the privacy practices of Google, please visit the Google Privacy Policy: https://policies.google.com/privacy?hl=en. Please see the “Your Choices” section below for a link to opt out of Google Analytics. For example, analytics cookies are used to:

(i) Maintain and continually improve the Site;
(ii) Keep track of the number of visitors to the pages within the Site;
(iii) Keep track of the length of time that each visitor spends on the pages within the Site;
(iv) Determine the order in which a visitor visits the various pages within the Site;
(v)  Determine the website a visitor was at before navigating to the Site and the website a visitor is going to immediately after leaving the Site;
(vi) Identify performance issues with the Site;
(vii) Assess which parts of the Site need improvement; and
(viii) See how successful our marketing campaigns or other Site goals are.

YOUR CHOICES

You can exercise your preferences in relation to cookies served on our Site by taking the steps outlined below. To learn more about cookies, including how to manage cookies and opt-out of cookies being placed on your device, please visit http://www.allaboutcookies.org/manage-cookies/index.html.

a) Browser Settings

To manage your cookie preferences, you may alter the cookie settings in your browser settings at any time. You may accept all, or certain, cookies. If you do disable cookies in your browser settings, you may find that certain sections of the Site will not work.
(i) First-Party Cookies: If you do not want cookies placed on your computer or mobile device, you can adjust the setting of your Internet browser to reject some or all cookies and to alert you when a cookie is placed on your device. To do this, follow the instructions provided by your browser (usually located within the “Help”, “Tools” or “Edit” settings). While adjusting your browser settings can prevent the future placement of cookies, it does not remove existing persistent cookies.
(ii) Third-Party Cookies: Modern browsers also allow you to block third-party cookies using the steps described above for first-party cookies.

b) Preferences Tools

The following are additional services that can assist you with managing your cookie preferences. Please note that ACCLAIM has no affiliation with, and is not responsible for, the below third-party websites.
(i) Google Analytics: You can prevent your information from being used by Google Analytics by downloading and installing the Google Analytics Opt-out Browser Add-on, available at https://tools.google.com/dlpage/gaoptout/.

(ii) Do Not Track: You may turn on the Do Not Track (“DNT”) setting in your browser, which will enable your browser to send a special signal to websites, analytics companies, plug-in providers and other web services you encounter while browsing to stop tracking your activity. To turn on your DNT signal, please visit https://allaboutdnt.com/#adjust-settings. Please note that ACCLAIM does not respond to DNT signals.

3. HOW DO WE USE YOUR INFORMATION?

We use personal information collected via our Website for a variety of business purposes described below. We process your personal information for these purposes in reliance on our legitimate business interests, in order to enter into or perform a contract with you, with your consent, and/or for compliance with our legal obligations. We indicate the specific processing grounds we rely on next to each purpose listed below.

We use the information we collect or receive:
(i)  To facilitate account creation and logon process. If you choose to link your account with us to a third-party account (such as your Google or Facebook account), we use the information you allowed us to collect from those third parties to facilitate account creation and logon process for the performance of the contract.
(ii) To manage user accounts. We may use your information for the purposes of managing our account and keeping it in working order.
(iii)  To request feedback. We may use your information to request feedback and to contact you about your use of our Services.
(iii)  To protect our Services. We may use your information as part of our efforts to keep our Services safe and secure (for example, for fraud monitoring and prevention).
(iv)  To enforce our terms, conditions and policies for business purposes, to comply with legal and regulatory requirements or in connection with our contract.
(v) To respond to legal requests and prevent harm. If we receive a subpoena or other legal request, we may need to inspect the data we hold to determine how to respond.
(vi) To fulfill and manage your orders. We may use your information to fulfill and manage your orders, payments, upgrades, or refunds made through the Website or otherwise through our Services.
(vii) To deliver and facilitate delivery of services to the user. We may use your information to provide you with the requested service.
(viii) To respond to user inquiries/offer support to users. We may use your information to respond to your inquiries and solve any potential issues you might have with the use of our Services.
(ix) To send you marketing and promotional communications. We and/or our third-party marketing partners may use the personal information you send to us for our marketing purposes, if this is in accordance with your marketing preferences. For example, when expressing an interest in obtaining information about us or our Services, subscribing to marketing or otherwise contacting us, we will collect personal information from you. You can opt-out of our marketing emails at any time (see the “WHAT ARE YOUR PRIVACY RIGHTS?” below).
(x)  To send administrative information to you. We may use your personal information to send you product, service and new feature information and/or information about changes to our terms, conditions, and policies.
(xi) To deliver targeted advertising to you. We may use your information to develop and display personalized content and advertising (and work with third parties who do so) tailored to your interests and/or location and to measure its effectiveness.
(xii) For other business purposes. We may use your information for other business purposes, such as data analysis, identifying usage trends, determining the effectiveness of our promotional campaigns and to evaluate and improve our Website, Services, products, marketing and your experience. We may use and store this information in aggregated and anonymized form so that it is not associated with individual end users and does not include personal information. We will not use identifiable personal information without your consent.

3. WILL YOUR INFORMATION BE SHARED WITH ANYONE?

We may process or share your data that we hold based on the following legal basis:
(a) Consent: We may process your data if you have given us specific consent to use your personal information for a specific purpose.
(b) Legitimate Interests: We may process your data when it is reasonably necessary to achieve our legitimate business interests.
(c)  Performance of a Contract: Where we have entered into a contract with you, we may process your personal information to fulfill the terms of our contract.
(d)  Legal Obligations: We may disclose your information where we are legally required to do so in order to comply with applicable law, governmental requests, a judicial proceeding, court order, or legal process, such as in response to a court order or a subpoena (including in response to public authorities to meet national security or law enforcement requirements).
(e) Vital Interests: We may disclose your information where we believe it is necessary to investigate, prevent, or take action regarding potential violations of our policies, suspected fraud, situations involving potential threats to the safety of any person and illegal activities, or as evidence in litigation in which we are involved.

More specifically, we may need to process your data or share your personal information in the following situations:

(f)  Business Transfers. We may share or transfer your information in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company.

(g) Vendors, Consultants and Other Third-Party Service Providers. We may share your data with third-party vendors, service providers, contractors or agents who perform services for us or on our behalf and require access to such information to do that work. Examples include payment processing, data analysis, email delivery, hosting services, customer service and marketing efforts. We may allow selected third parties to use tracking technology on the Website, which will enable them to collect data on our behalf about how you interact with our Website over time. This information may be used to, among other things, analyze and track data, determine the popularity of certain content, pages or features, and better understand online activity. Unless described in this notice, we do not share, sell, rent or trade any of your information with third parties for their promotional purposes. We have contracts in place with our data processors, which are designed to help safeguard your personal information. This means that they cannot do anything with your personal information unless we have instructed them to do it. They will also not share your personal information with any organization apart from us. 

They also commit to protect the data they hold on our behalf and to retain it for the period we instruct.
(h)  Affiliates. We may share your information with our affiliates, in which case we will require those affiliates to honor this privacy notice. Affiliates include our parent company and any subsidiaries, joint venture partners or other companies that we control or that are under common control with us.
(i)  Business Partners. We may share your information with our business partners to offer you certain products, services or promotions.

4. WHO WILL YOUR INFORMATION BE SHARED WITH?

We only share and disclose your information with the following categories of third parties. If we have processed your data based on your consent and you wish to revoke your consent, please contact us using the contact details provided in the section below titled “HOW CAN YOU CONTACT US ABOUT THIS NOTICE?“.
• Ad Networks
• Affiliate Marketing Programs
• Cloud Computing Services
• Communication & Collaboration Tools
• Data Analytics Services
• Data Storage Service Providers
• Finance & Accounting Tools
• Order Fulfillment Service Provider
• Payment Processors
• Performance Monitoring Tools
• Product Engineering & Design Tools
• Retargeting Platforms
• Sales & Marketing Tools
• Social Networks
• Testing Tools
• User Account Registration & Authentication Services
• Website Hosting Service Providers

5. IS YOUR INFORMATION TRANSFERRED INTERNATIONALLY?

ACCLAIM is based in the United States, and the Services are designed for use in the United States. The personal information that we collect or receive will be transferred to and processed in the United States. We also transfer personal information to the third parties mentioned in the circumstances described above, which may be located outside of your country or regional area, and may be processed by staff, agents, or contractors operating outside of your country or regional area. The data protection laws of the United States or other countries may not be as comprehensive as or equivalent to those in your country of residence. We take appropriate steps to protect personal information when it is transferred as required under applicable law.

6. HOW LONG DO WE KEEP YOUR PERSONAL INFORMATION:

We will retain and use your personal information for the period necessary to comply with our legal obligations, resolve disputes, and enforce our agreements unless a longer retention period is required or permitted by law. We may use any aggregated data derived from or incorporating your personal information after you update or delete it, but not in a manner that would identify you personally. Once the retention period expires, personal information shall be deleted. Therefore, the right to access, the right to erasure, the right to rectification and the right to data portability cannot be enforced after the expiration of the retention period.

7. HOW DO WE KEEP YOUR INFORMATION SAFE?

We have implemented appropriate technical and organizational security measures designed to protect the security of any personal information we process. However, despite our safeguards and efforts to secure your information, no electronic transmission over the Internet or information storage technology can be guaranteed to be 100% secure, so we cannot promise or guarantee that hackers, cybercriminals, or other unauthorized third parties will not be able to defeat our security, and improperly collect, access, steal, or modify your information. Although we will do our best to protect your personal information, transmission of personal information to and from our Website is at your own risk. You should only access the Website within a secure environment.

8. WHAT ARE YOUR PRIVACY RIGHTS?

(a) Account Information
If you would at any time like to review or change the information in your account or terminate your account, you can:
• Contact us using the contact information provided.
• Log in to your account settings and update your user account.
Upon your request to terminate your account, we will deactivate or delete your account and information from our active databases. However, we may retain some information in our files to prevent fraud, troubleshoot problems, assist with any investigations, enforce our Terms of Use and/or comply with applicable legal requirements.

(b) Cookies and similar technologies: Most Web browsers are set to accept cookies by default. If you prefer, you can usually choose to set your browser to remove cookies and to reject cookies. If you choose to remove cookies or reject cookies, this could affect certain features or services of our Website. To opt-out of interest-based advertising by advertisers on our Website visit http://www.aboutads.info/choices/.

(c) Opting out of email marketing: You can unsubscribe from our marketing email list at any time by clicking on the unsubscribe link in the emails that we send or by contacting us using the details provided below. You will then be removed from the marketing email list — however, we may still communicate with you, for example to send you service-related emails that are necessary for the administration and use of your account, to respond to service requests, or for other non-marketing purposes. To otherwise opt-out, you may:
• Contact us using the contact information provided.
• Access your account settings and update your preferences.
• Use the unsubscribe link at the bottom of any marketing emails, newsletters, or other non-essential communications

9. CONTROLS FOR DO-NOT-TRACK FEATURES

Most web browsers and some mobile operating systems and mobile applications include a Do-Not-Track (“DNT”) feature or setting you can activate to signal your privacy preference not to have data about your online browsing activities monitored and collected. At this stage no uniform technology standard for recognizing and implementing DNT signals has been finalized. As such, we do not currently respond to DNT browser signals or any other mechanism that automatically communicates your choice not to be tracked online. If a standard for online tracking is adopted that we must follow in the future, we will inform you about that practice in a revised version of this privacy notice.

10. PRIVACY OF CHILDREN

We do not knowingly collect any personal information from children under the age of 18. Children under the age of 18 are not permitted to use our Services or to provide any personal information. If you learn that your child has provided us with personal information, please contact us at info@acclaimiq.com If we learn we have collected or received personal information about a child under the age of 18 without verification of parental consent, we will delete that information as required by applicable law.

11. CHANGES TO THIS PRIVACY NOTICE?

We may update this privacy notice from time to time. The updated version will be indicated by an updated “Revised” date and the updated version will be effective as soon as it is accessible. We encourage you to review this privacy notice frequently to be informed of how we are protecting your information.

12. HOW CAN YOU CONTACT US ABOUT THIS NOTICE?

If you have questions or comments about this notice, you may contact us by email at info@acclaimiq.com or by mail at:

ACCLAIMIQ, LLC
2 Corporate Drive
Shelton, CT 06484