Guidelines for IntegrityCONNECT Leads Vendors

Topical Consents

• Must disclose that the purpose of the mailer, online/digital consent form, etc. is to sell insurance
• If selling one to one to an individual purchaser — must identify a licensed producer/insurance agent by providing his/her producer number and name
• If collecting a general consent, must be topically relevant and must include Integrity and subaffiliates/agents in the potential companies to receive the consumer’s information

False or Misleading Statements/Marketing and Relevant Industry Compliance

• Do not imply with either language or use of images that it is from a government entity
• Do not imply with either language or use of images that it is from a bank, lending institution or any other financial institution
• Do not use co-registration means, survey-farms, forced opt-ins or content locking methods for generating leads for multiple categories within a single user-flow
• No incentivization of leads in any way not approved in advance by Integrity; do not offer gifts, inducement or anything else of value to a person(s) to obtain a lead; any pre-approved incentivization must adhere to any state gifting rules/laws
• Do not use sweepstakes or lottery messaging to solicit collection of leads
• Do not use language that is misleading or deceptive

Lead Exclusivity and Freshness

• Clearly identify if leads are shared or exclusive; if selling Integrity specifically “shared” leads, in the instance of aged marketplace leads, guarantee that leads will not be sold to more than three advertisers and that in each instance of the sale, the consumer consented specifically to be sold to that specific advertiser
• Leads must be delivered in real time if designated/labeled as real-time leads or as otherwise required contractually
• Aged leads must include a clearly stated lead creation or original submission date

Accuracy of Information

• Validate the email and phone in the lead are accurate and match any other communication with the lead
• Ensure all relevant fields are accurate
• Any leads with an invalid phone number or email address must be credited back to Integrity
• Ensure all required fields are included in the lead submission and are pertinent and relevant to the lead type

Consent Language and DNC Adherence

• If generating Medicare leads, any/all Medicare Advantage or Original Medicare leads must collect one to one consent at the agent level; all materials related to MA and related products must have appropriate disclosures and required industry/CMS filings
• Every lead must be generated with proper consumer express written consent, per the TCPA
• Documentation of consent must be stored and retrievable upon request, including submission of Jornaya and Trustedform proof of consents
• Be clear that the individual providing the consent will be contacted by an insurance agent to discuss specific products related to insurance
• Ensure use of Integrity’s general consent language to ensure capture of relevant consents for automated dialing, SMS, etc.
• Leads must be scrubbed against state/federal DNC lists and known litigator lists prior to submission; maintain up-to-date scrubbing systems
• Notify Integrity immediately if/when a consumer contact is added to a supplier’s DNC list or otherwise requests to be removed from any list; notify Integrity to remove the consumer’s information from IntegrityCONNECT Leads and to add them to Integrity’s internal DNC list

Source Transparency

• Disclose all domains, publishers and methods used to generate leads
• Identify if generating leads via owned and operated means vs. third-party affiliate/aggregator websites