- Overview
- Scope
- Information Collected for Texting Program
- Personal Information We Collect / Sources of Personal Information
- Use of Personal Information
- Disclosing Personal Information
- Cookie Policy
- Children Under the Age of 16
- Your Privacy Rights
- Your Privacy Rights – California
- Retention of Data
- Data Security
- Third-Party Applications and Integrations
- Financial Services Information
- Updates to This Privacy Policy
OVERVIEW
This Privacy Policy describes how Integrity, LLC and all its subsidiaries and affiliates (collectively, “Integrity,” “we,” “us,” or the “Company”) collect, use, and disclose personal information from both the business-to-business and consumer context through our websites and services. A full list of the Integrity subsidiaries is available here.
Integrity provides tools, technology, and support services to licensed insurance agents, prospective insurance agents (“Agents”), investment advisor representatives, and registered representatives (collectively, “Financial Professionals”). In connection with these services, we receive or share personal information about individuals who are applying or seeking information about insurance or financial products and services, as well as customers who maintain an ongoing relationship with us (collectively “Consumers”).
For Services involving the sale of life and health insurance products, we may engage third-party lead vendors (“Lead Vendors”). These Lead Vendors collect inquiries from Consumers and pass such inquiries to Agents, Company representatives, and Financial Professionals. Lead Vendors must obtain consent from Consumers to be contacted about specific products before providing us with such Consumers’ information.
Note: The term “affiliates” refers to companies related by common ownership or control with Integrity that can be financial or nonfinancial entities.
SCOPE
This Privacy Policy uses the term “Personal Information” to describe information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household. This includes “nonpublic personal information” under the Gramm-Leach Bliley Act (“GLBA”) and may include information governed by other state comprehensive and sector specific privacy laws.
Since we facilitate the sale of a diverse range of insurance and financial products, our processing of some information on behalf of our agents may fall under another state or federal regulatory framework, like the Health Insurance Portability and Accountability Act (“HIPAA”) and related state laws, or the GLBA and related state laws.
When Integrity acts on behalf of a Covered Entity (e.g., a health insurer) and receives or transmits Protected Health Information (“PHI”), we function as a “Business Associate” under HIPAA. In this role, we use and disclose PHI to provide services on behalf of health plans. This Privacy Policy applies to personal information that is not covered by HIPAA. This Privacy Policy also does not apply to “consumer health data” which is a subset of personal information defined under the Washington State My Health My Data Act. For more information about how we collect consumer health data please review our Consumer Health Data Privacy Notice.
INFORMATION COLLECTED FOR TEXTING PROGRAM
We may also contact Agents, Financial Professionals, Consumers, and other users via text messaging, but only if such individuals opt-in to receive text messages. Any information that we collect when you opt into receiving SMS and MMS text messages from us is used solely for the management of such texting communications program. No mobile opt-in or text message consent will be shared with third parties or affiliates for marketing purposes.
PERSONAL INFORMATION WE COLLECT/SOURCES OF PERSONAL INFORMATION
The type of personal information we collect depends on the products or services you obtain from us. The table below details the categories of Personal Information that we may collect or obtain. In addition to the sources listed below, we may collect this information from third-party service providers or vendors, including data analytics providers.
Category |
Examples & Sources |
|---|---|
| Contact Information | Consumers’, Agents’, Financial Professionals’ name, phone number, and email address, as well as Consumers’ postal address.
We may collect this information about Consumers from Lead Vendors, Agents, Financial Professionals’, insurance carriers, data brokers, and agencies. We collect this information about Agents and Financial Professionals from the Agent or Financial Professional themselves, marketing organizations in the Agents’ product sale hierarchy, broker-dealers, or registered investment advisors. |
| Login Credentials | This includes username and password* when Agents, Financial Professionals, or Consumers choose to create an account with us. |
| Identification Information* | Agents’ National Producer Number and Agents and Financial Professionals Social Security number.
We collect this information from Agents and Financial Professionals when they begin working with us. Consumers’ driver’s license, Social Security, and/or similar government-issued identification numbers. We collect this information about Consumers provided in the course of discussions with an Agent, Financial Professional, or representative, which is relevant to the processing of an application for an insurance or financial product. |
| Demographic Information* | Consumers’ age, date of birth, marital status, language preference, ethnicity, race, and sex or gender.
We collect this information about Consumers when Lead Vendors, insurance carriers, financial services companies, credit reporting agencies, Agents, Financial Professionals, data brokers, or agencies provide it to us. |
| Financial Information* | Consumer’s assets, account information, income, credit score, tax bracket, information about your transactions with us or our affiliates or nonaffiliated third parties, and other government-issued information depending on the products or services you obtain from us.
We collect this information when you create an account with us, apply for insurance or financial products, seek advice about your investments, or tell us about your investment or retirement portfolio. We may also collect this from other companies, affiliates, credit reporting agencies, and government agencies. |
| Health Information* | Consumers’ health information provided in the course of discussions with an Agent, Financial Professional, or representative, which is relevant to the processing of an application for an insurance or financial product. For example, notes about a Consumer may state that the Consumer has diabetes, as is relevant for an application for a life insurance product. |
| Sensory Information | Audio recordings of Consumer conversations with representatives, Agents, and Financial Professionals in connection with inquiries regarding insurance and/or financial products. We may also have access to video snippets of user website activity evidencing consent to be contacted. This information is collected from Lead Vendors, Agents, Financial Professionals, insurance carriers, and agencies. |
| Commercial Information | We collect information about the products requested by Consumers, including information entered into insurance and/or financial product applications, as provided by you, a Lead Vendor, Agent, Financial Professional, data brokers, insurance carriers, financial institutions, advertising and/or social media networks, or an agency. We also collect information regarding your purchase of insurance and/or financial products, including the type of product purchased and the corresponding carrier. |
| Internet or Other Similar Network Activity | Automatically collected information on users’ interaction with our websites. This may include your browsing history (including the site you came from before visiting our website and the site you went to after leaving our website), duration of browsing session, device ID, and IP address. We may also collect this information from advertising networks. |
| Geolocation Data | We collect geolocation, which may include precise geolocation,* from users. We automatically collect this information from you and may also collect this from advertising networks. |
| Educational and Professional Information | We collect from data brokers Personal Information about Consumers’ educational background, profession, income, product preference, consumer behavior, and asset ownership. This information is used for offline marketing. We also collect this information from Agents and Financial Professionals when they begin working with us. |
Some or all of the types of Personal Information marked with an asterisk (*) may be considered “sensitive” personal information according to some state laws.
We may also partner with financial processors or payment vendors to provide services to Agents and Financial Professionals.
We do not collect biometric information relating to an individual’s physiological, biological, or behavioral characteristics including an individual’s DNA that can be used with other data to establish an individual’s identity.
Your information may be provided to us by your spouse or other family member.
HOW WE USE THE PERSONAL INFORMATION WE COLLECT
We may use or disclose the Personal Information that we collect for one or more of the following purposes:
- Operate our websites;
- Communicate with you regarding our websites;
- Contact Consumers through our employed agents or Financial Professionals regarding insurance and/or financial products in which the Consumer expressed interest;
- Address users’ and Consumers’ inquiries;
- Joint marketing with nonaffiliated financial service companies;
- Process transactions;
- Tailor the content and information that we may send or display to you;
- Analyze use of our products and services;
- Develop new products and services;
- Comply with legal obligations;
- Protect our rights, property, and safety or the rights, property, and safety of others; and
- Evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by us about our customers is among the assets transferred. You hereby consent to such transfers and we may assign and transfer all of the rights, benefits, duties, and obligations of this Privacy Policy, under the circumstances described in this paragraph.
From time to time, we may contact users via email and mail, for the purpose of providing announcements, promotional offers, alerts, confirmations, surveys, and/or other general communication. If you would like to stop receiving marketing or promotional communications via email or mail from us, you may opt out of such communications by contacting us through the data rights portal, the toll-free number, or the email address listed below.
HOW WE SHARE THE PERSONAL INFORMATION WE COLLECT
We may disclose all categories of Personal Information described above in “Personal Information We Collect” to the third parties listed below for the purpose of facilitating the sale of insurance and/or financial products to individuals.
If you are a new customer, we may begin sharing your Personal Information, as set forth above, 30 days from the date we sent this notice, unless you opt out, as permissible.
- With Our Service Providers. We may share Personal Information with vendors that perform services on our behalf. These services may include payment processors, data hosting, communications delivery, cloud services, risk management, information technology, mail services, and other operational platforms that support the functionality of our services.
- With Affiliates. We share Personal Information with companies under common ownership or control, including affiliated marketing organizations, insurance distributors, registered investment advisers, and broker-dealers. Sharing includes transaction data, account history, and information regarding creditworthiness, for everyday business purposes and regulatory compliance. This may also include joint marketing efforts permitted under GLBA.
- With Non-Affiliates. Non-affiliates are companies not related by common ownership or control. We share Personal Information with non-affiliated entities including:
- Insurance carriers and underwriters
- Financial service companies and qualified custodians
- Independent agencies and marketing organizations involved in insurance or financial product distribution
- Nonfinancial entities such as professional associations or membership groups where permitted by law.
- Note: Sharing with non-affiliates may be subject to opt-out rights where required under GLBA or state law.
- With Law Enforcement, Government Agencies, or Parties to a Legal Proceeding. We disclose Personal Information as necessary to comply with applicable law, regulation, legal process, or governmental requests. This includes responding to subpoenas, cooperating with regulatory or law enforcement investigations, and protecting our rights or the rights of others.
- With Our Independent Agents and Advisors. Agents and Financial Professionals have access to the Personal Information about Consumers that is provided by the Consumers when requesting information regarding insurance and/or financial products.
- With Data Analytics Providers and Advertising Service Providers. Third-party data analytics providers may collect Personal Information about users over time and across different websites, applications, and devices for the purposes of targeted advertising. These providers may collect Personal Information, specifically internet or other similar network activity information, your input on the website, social media information, and/or commercial information in this manner on our websites. For more information on these third parties, please see the below “Cookie Policy.”
We may partner with these third parties to tailor and customize our advertising to Users. The practice of targeted advertising may be considered a “sale” of Personal Information under some state privacy laws. For more information about your choices related to this practice, please see “Your Privacy Rights” below.
Sale and Sharing of Personal Information
We facilitate the sale of insurance and financial products, and may engage in targeted advertising, which may be considered “selling” or “sharing” personal information as defined under certain state privacy laws, including California. In the last twelve (12) months, we have “sold” or “shared” the categories of personal information identified in “PERSONAL INFORMATION WE COLLECT” with advertising networks, data analytics vendors, insurance carriers, and Licensed Agents and Financial Professionals.
NOTICE: We may sell your sensitive personal data.
COOKIE POLICY
Our websites may use cookies, pixel tags, web beacons, and similar technologies to track and enhance user experience, including technologies placed on the website by third parties, such as advertising network partners. Users’ web browser places cookies on their hard drive for record-keeping purposes and sometimes to track information about them. Cookies can also enable us to track and target the interests of our users to enhance their experience on our website. We may use the following types of cookies: advertising and analytics and social media.
You may choose to set your web browser to refuse cookies or to alert you when cookies are being sent. If you do so, some parts of our websites may not function properly. Our websites do not recognize “Do Not Track” signals, but it may recognize other opt-out preference signals, such as the Global Privacy Control (GPC). You may set such a signal through your browser or browser extension.
CHILDREN UNDER THE AGE OF 16
The Services are not intended for children under 16 years of age. We do not knowingly collect Personal Information from children under 16, and we do not have actual knowledge that we sell or share the Personal Information of children under 16. If we learn we have collected or received Personal Information from a child under 16 without verification of parental consent, we will delete that information in accordance with applicable law.
YOUR PRIVACY RIGHTS
State consumer privacy laws may provide their residents with additional rights regarding our use of their Personal Information as described in more detail below. However, these rights are not absolute, and, in certain cases, we may decline your request as permitted by law.
Consumer Right |
Description |
|---|---|
| Right to Know | You may request the categories of Personal Information collected by Company about the data subject, the purpose and source of that collection, whether or not the Personal Information was sold to a third party, and the categories of third parties to whom Company disclosed the data subject’s Personal Information. |
| Right to Access | You may request to access, inspect, and receive a copy of Personal Information |
| Right to Delete Personal Information | You may request to delete non-exempt Personal Information held or stored by Company or on Company’s behalf. Some exceptions apply to these types of requests. |
| Right to Correct | You may request to edit or correct your Personal Information at any time. |
| Right to Opt-out | You may request to opt-out of certain uses or disclosures of Personal Information, including selling or “sharing” (i.e., using Personal Information from non-Integrity websites for targeted advertising (“targeted advertising”)).
Under the GLBA, Consumers can opt-out of sharing of personal information about your creditworthiness for our affiliates’ everyday business purposes, for our affiliates or non-affiliates to market to you, and upon termination by a representative or financial institution. |
| Right to Request to Appeal | Some data subjects may have the right to request that Company reconsider a denial of a data subject request.
To appeal a decision regarding a consumer rights request, please fill out this form and include “APPEAL” in your request details, along with a short description of your prior request and the outcome that you are seeking. We may request more information in order to locate your prior request. |
| Right to Limit Use and Disclosure | You may request the right to limit our use and disclosure of your Personal Information defined as sensitive under the CCPA. |
| Non-discrimination | You have the right to be free from discrimination related to your exercise of any of your privacy rights. |
To exercise any of these rights, please click here. Only you, or under some state privacy laws, someone legally authorized to act on your behalf, may make a request related to your Personal Information. To place a “Do Not Call’ request, you can also call 1-866-650-1857.
Exercising Your Privacy Rights
Process |
Description |
|---|---|
| Verification | In order to protect your Personal Information from unauthorized access or deletion, we may require you to verify your account credentials before you can submit a data rights request.
We are legally obligated to verify your identity when you submit a request. We may request additional information from you to verify your identity. If you submit a request to delete your Personal Information, you will also be required to confirm the deletion request by email. If we are subsequently unable to confirm your identity, we may refuse your request. |
| Use of Authorized Agents | You may use an authorized agent to submit a data rights request. If you do so, the authorized agent must present signed written authorization to act on your behalf, and you will also be required to independently verify your own identity directly with us and confirm with us that you provided the authorized agent permission to submit the data rights request. |
YOUR RIGHTS – CALIFORNIA
To the extent the law applies to Company, Company is required under the California Consumer Privacy Act (“CCPA”), as amended, to provide certain information to California residents about how we collect, use, and share their Personal Information in our capacity as a business, and about the rights and choices California residents may have concerning their Personal Information. For purposes of this section, “Personal Information” has the meaning provided in the CCPA.
This section applies only to California residents. As a California resident, you have the rights listed below. However, these rights are not absolute, and, in certain cases, we may decline your request as permitted by law. To exercise any of these rights, please click here. Only you, or someone legally authorized to act on your behalf, may make a request related to your Personal Information.
The following disclosures are made in compliance with the CCPA, as amended. In the past twelve (12) months, we have collected the Personal Information described above, and disclosed it to the third parties listed under the section “Sharing Personal Information” for the business purposes identified therein and under the section “Use of Personal Information.” This information falls into the following categories of Personal Information under the CCPA:
- Identifiers;
- Categories of Personal Information described in section 1798.80(e) of the California Civil Code;
- Characteristics of protected classifications under California or federal law;
- Commercial information;
- Geolocation information;
- Audio, electronic, or visual information;
- Internet or electronic network activity information;
- Professional or employment-related information; and
- Sensitive personal information identified by asterisk (*) in the above table.
As disclosed above in “Sale and Sharing of Personal Information” we may engage in activity that may be considered “selling” or “sharing” Personal Information. If you wish to opt out of this use of your Personal Information, click here: Do Not Sell or Share My Personal Information
We do not use or disclose sensitive Personal Information (indicated in the section “Personal Information We Collect” with an asterisk (*)) for purposes other than those specified in Cal. Code Regs. tit. 11, § 7027(m).
Below is a summary of your rights under the CCPA. Please note that these rights are not absolute, and, in certain cases, we may decline your request as permitted by law.
Consumer Right |
Description |
|---|---|
| Access | You may request that we provide the following information about how we have collected and used your Personal Information:
|
| Request a Copy of Your Personal Information | You may request a copy of your Personal Information.
You may submit a request that Company disclose the categories and specific pieces of Personal Information that we have collected, used, or disclosed about you. Please note that simply because Company has provided the categories of Personal Information it may collect pursuant to California law does not mean Company necessarily collected all of the specific pieces of Personal Information listed for any given person. Also, please note where Personal Information was disclosed within the past twelve (12) months, it may have been disclosed only to service providers. |
| Correction | You may request to edit or correct your Personal Information at any time. |
| Deletion | You may have the right, under certain circumstances, to request that we delete the Personal Information you have provided to us. |
| Opt Out of Sales and/or Sharing | The CCPA may classify our use of some services as “selling” or “sharing” your Personal Information with the partners that provide the services. You can opt out of the “selling” and/or “sharing” of your Personal Information. |
| Limit Processing of Sensitive Personal Information | We use sensitive Personal Information only as necessary for our (1) service delivery and operations, (2) compliance and protection, (3) quality control and improvements, or (4) Service improvement and analytics purposes in accordance with CCPA. If we use sensitive Personal Information outside the permitted purposes of CCPA, you have the right to limit such processing of sensitive Personal Information. |
Exercising Your Privacy Rights
Process |
Description |
|---|---|
| Verification | In order to protect your Personal Information from unauthorized access or deletion, we may require you to verify your account credentials before you can submit a rights request. If you do not have an account with us, or if we suspect your account has been accessed without your authorization, we may ask you to provide additional Personal Information for verification.
Company is legally obligated to verify your identity when you submit a request. We may request additional information from you to verify your identity. If you submit a request to delete your Personal Information, you will also be required to confirm the deletion request by email. If we are subsequently unable to confirm your identity, we may refuse your rights request. |
| Use of Authorized Agents | You may use an authorized agent to submit a rights request. If you do so, the authorized agent must present signed written authorization to act on your behalf, and you will also be required to independently verify your own identity directly with us and confirm with us that you provided the authorized agent permission to submit the rights request. This verification process is not necessary if your authorized agent provides documentation showing that the authorized agent has power of attorney to act on your behalf under Cal. Prob. Code §§ 4121 to 4130. |
RETENTION OF DATA
We retain Personal Information where we have an ongoing legitimate business or legal need to do so. Our retention periods will vary depending on the type of data involved, but, generally, we refer to these criteria in order to determine retention period:
- Whether we have a legal, regulatory or contractual obligation to retain the data;
- Whether the data is necessary to provide our Services; and
- Whether our Consumers, Agents, Financial Professionals would reasonably expect that we would retain the data until they remove it or until their accounts are closed or terminated.
When we have no ongoing legitimate business need to process your Personal Information, we will either delete or anonymize it or, if this is not possible (for example, because your Personal Information has been stored in backup archives), then we will securely store your Personal Information and cease any further processing until deletion is possible.
DATA SECURITY
We maintain administrative, technical, and physical safeguards designed to protect the confidentiality, integrity, and availability of Personal Information. While we take reasonable steps to secure your information, no system or method of transmission is 100% secure. As such, we cannot guarantee absolute security. However, we are committed to continuously assessing and improving our security measures to protect against unauthorized access, use, or disclosure of the Personal Information we collect and maintain.
THIRD PARTY APPLICATIONS AND INTEGRATIONS
Our websites use third-party applications and integrations to enhance its experience. We disclaim any and all liability and responsibility for the use of these applications and integrations, and encourage you to review their individual privacy policies before using our websites or otherwise engaging with us. We disclaim any and all liability and responsibility for the use of these applications and integrations and encourage you to review any individual privacy policy related to those applications and integrations.
FINANCIAL SERVICES INFORMATION
If you are a new customer, we can begin sharing your personal information, as set forth above, thirty days from the date we sent this notice, unless you opt out, as permissible by law.
California, North Dakota, and Vermont Customers: Investment adviser representatives may change investment advisory firms, and the nonpublic personal information collected by us and your representative may be provided to the new firm, so that they may continue to service your account(s). If you do not want your investment adviser representative to provide this information to their new firm, please call (866) 650 -1857 or complete a request here. Some states, such as California, Vermont and North Dakota, require your affirmative consent, or an “opt-in,” rather than an opt-out, before the representative can provide your nonpublic information to the new firm. You can provide or withdraw this consent at any time. If you limit sharing on an account you hold jointly with someone else, your choices will apply to everyone on the account.
For more information about your rights, please see “Your Privacy Rights.”
As required by applicable regulations:
- You can obtain information about the Securities Investor Protection Corporation (SIPC), including the SIPC brochure, by calling them at 202.371.8300 or at sipc.org;
- You can obtain information about the professional background and registration of financial professionals and our firm by visiting FINRA BrokerCheck or by calling their BrokerCheck Hotline at 800.289.9999 or at finra.org;
UPDATES TO THIS PRIVACY POLICY
We may revise this Privacy Policy from time to time. If we make material changes to this Privacy Policy, we will notify you by email or by posting a notice on our websites prior to or on the effective date of the changes. By continuing to access or use our websites after those changes become effective, you acknowledge the revised Privacy Policy. We specify the date of the last changes at the beginning of the notice.
CONTACT INFORMATION
If you have any questions or comments about this notice, or the ways in which we collect and use your personal information, please do not hesitate to contact us at:
Phone: 866-650-1857
Email: legal@integrity.com
Address: