InsureSync Agent Platform Privacy Notice

Effective Date: August 7, 2023

This Website is a part of the InsureSync Agent Platform (the "Platform"). This Privacy Notice applies to each individual ("User") who accesses the Platform, including but not limited to usage of this Website. As used in this Privacy Notice, the terms "Infinite Spark," "we" and "us" refer to Infinite Spark, LLC. To the extent applicable, they also refer to our affiliates, service providers and licensors, and their respective officers, directors, employees, contractors, and agents. If you are accepting the terms of this Privacy Notice as an employee or representative of a company or other legal entity, the terms "you" and "your" will refer to both you, personally, and the entity you represent. The term "customer" will refer to any person whose information is provided to the Platform for you to access, manage, or provide service as a User of the Platform.

Infinite Spark is committed to protecting and respecting your privacy and your customers’ privacy. This Privacy Notice describes how we collect, use, protect and share information about you and your customers. This Privacy Notice also applies to information that we obtain when you or your customers communicate or interact with us outside of the Website, including by e-mail, telephone and otherwise.

Your use of the Website is also governed by the Terms of Use (which define your responsibilities as a Platform User in protecting the privacy of yourself and your customers), any additional terms made available to you in connection with certain features, functionality, tools, content and promotions available on or through the Website ("Supplemental Terms"), and any and all policies and rules referenced herein or therein, posted on the Website, or otherwise communicated to our Users (the "Website Policies"). To the extent that a provision of the Terms of Use, Supplemental Terms or Website Policies conflicts with this Privacy Notice, such provision shall control.

Please read this Privacy Notice carefully before you use our Platform or communicate with us. Changes to this Privacy Notice are discussed at the end of this document.

For purposes of this Privacy Notice:

BY ACCESSING OR USING OUR WEBSITE OR PLATFORM, OR COMMUNICATING WITH US OUTSIDE OF THE WEBSITE, YOU ARE ACCEPTING AND CONSENTING TO THE PRACTICES DESCRIBED IN THIS PRIVACY NOTICE, WHICH MAY BE UPDATED AND AMENDED FROM TIME TO TIME. IF YOU DO NOT AGREE TO THE TERMS OF THIS PRIVACY NOTICE, YOU MUST NOT ACCESS OR USE OUR WEBSITE OR PLATFORM OR OTHERWISE COMMUNICATE WITH US.

INFORMATION WE COLLECT

Personally Identifiable Information

Some of the information we collect about you may personally identify you ("Personally Identifiable Information"). The types of Personally Identifiable Information you may submit in connection with use of the Website include, but are not limited to:
  • contact information (such as name, address, email address and telephone number);
  • National Producer Number (NPN); and
  • payment card information and other billing information (such as card number, cardholder name, expiration date and card verification code) associated with your account.
Some of the information we collect about your customers may also be Personally Identifiable Information. The types of Personally Identifiable Information collected about your customers in connection with your use of the Website include, but are not limited to:
  • contact information (such as name, address, email address and telephone number);
  • date of birth;
  • gender;
  • social security number;
  • health or medical history; and
  • payment card information and other billing information (such as card image, card number, cardholder name, expiration date and card verification code) associated with payment for health insurance or healthcare products.

Information You Provide to Us

We collect information about you that you provide directly to us, including the information provided in your User account and when you contact us for support, questions, or to provide feedback about the Website. We also collect information that you provide about your customers for the purpose of managing and servicing those customers’ health insurance or healthcare product needs.
We may also collect information about you if a company or organization authorizes you to manage its account or use our Website on its behalf.

Information Generated from Use of the Website

We also collect certain technical information when you access, browse and use our Website, including information that we automatically receive and record from your browser or mobile platform on our server logs. This technical information helps us operate and provide our Website to you, and includes standard information about visits and system capabilities, such as:
  • information about the device(s) you use to access our Website, including MAC address, IP address, browser type and version, your location, time zone setting, browser plug-in types and versions, operating system and platform, device type, device and application identifiers, operating information, mobile carrier, and cookies;
  • information about your visits to the Website, including the full URL clickstream to, through, and from the Website, including dates and times;
  • information we need and use to facilitate your use of our Website (including to provide access to third party websites and services), such as URL requests, destination IP addresses, or device configuration details;
  • pages you view, searches you run, length of time browsing search results, specific search results you select to view, length of visits to pages, page interaction information (such as scrolling, clicks, and mouse-overs), your engagement with certain variable/dynamic elements of a page and methods used to browse away from the page;
  • page response times and Website errors; and
  • information generated using cookies. See below for more details regarding our use of cookies, and your choices with respect to such tracking technologies.
Technical information from your use of the Website is treated as "Non-Personally Identifiable Information," unless it is combined with Personally Identifiable Information, or unless otherwise required by applicable law.

Information from Other Sources

We may receive certain information about you or your customers from the organizations or entities on behalf of which we provide the Website to you and/or on behalf of which you access or use the Website.
We may also supplement the technical information we collect from your use of the Website with information collected by third parties. Such third parties may include service providers, such as Google Inc., that help us understand our Users and provide better service to our Users.
On occasion, we may compare or combine Personally Identifiable Information from third party sources to/with other information we have collected. For example, we may obtain address information from the United States Postal Service to verify, complete, or correct a customer’s address; or we may receive additional information about a customer that was provided to a partner website such as Healthcare.gov or an insurance company's website.

HOW INFORMATION MAY BE USED

Personally Identifiable Information

We may use the Personally Identifiable Information we collect about you to:
  • create and manage your account;
  • provide the Website to you;
  • operate our Website, including, without limitation, providing quotes, and submitting and monitoring health insurance applications, access management, payment processing, Website administration, internal operations, troubleshooting, data analysis, testing, research, statistical and survey purposes;
  • send you information that enables you to use our Website;
  • contact you about activity on your account;
  • respond to your requests, feedback or inquiries;
  • notify you about updates, information, or alerts regarding our Website;
  • process payments;
  • protect and enforce our rights, the rights of other Users, and the rights of customers against unlawful activity, including identify theft and fraud, and other violations of our Terms of Use;
  • protect and enforce our rights arising under any agreements entered into between you and us, including billing and collection;
  • protect the integrity and maintain the security of our Website, including secured areas of the Website; and
  • operate, evaluate and improve our business, including conducting surveys and market research, developing new products, services, and promotions (such as, for example, special events, programs, offers, contests), analyzing and enhancing existing products, services, and promotions, managing our communications; performing accounting, auditing, and other internal functions.
We may use the Personally Identifiable Information we collect about your customers to:
  • operate our Website, including, without limitation, providing quotes, and submitting and monitoring health insurance applications, Website administration, internal operations, troubleshooting, data analysis, testing, research, and statistical purposes; and
  • protect and enforce our rights and the rights of customers against unlawful activity, including identify theft and fraud, and other violations of our Terms of Use.

Non-Personally Identifiable Information

In addition to the uses described above, we may also use Non-Personally Identifiable Information about you to:
  • deliver content tailored to your interests and the manner in which you use our Website;
  • present content in a manner that is optimized for your device; and
  • measure and analyze the effectiveness of content and services we provide.
We may also combine technical information, or Non-Personally Identifiable Information, about your use of our Website with information that we obtain from other Users to use in an aggregate or anonymous manner for similar purposes.

HOW INFORMATION MAY BE SHARED

Personally Identifiable Information

We will not sell or share Personally Identifiable Information about you or your customers with third parties for the third party's own direct marketing purposes without your express consent.
We may share your Personally Identifiable Information with:
  • the Centers for Medicare and Medicaid Services ("CMS") in order to obtain an eligibility determination for a customer and to enroll a customer in health insurance plans offered on the Federally Facilitated Marketplace when you are to be the agent of record;
  • third party insurance companies to which you submit a customer’s application for health insurance on or through the Website when you are to be the agent of record;
  • third party associations and healthcare product providers to which you submit a customer’s application for enrollment on or through the Website when you are to be the agent of record;
  • the organizations or entities on behalf of which we are providing the Website to you and/or on behalf of which you access or use the Website, such as your agency, employer, and other companies associated with those organizations;
  • our service providers to the extent reasonably necessary to enable us operate our business and provide our Website to you, as described in this Privacy Notice (e.g., to an e-mail service provider in order to enable us to e-mail you);
  • a buyer or other successor in interest to Infinite Spark in the event of a merger, divestiture, restructuring, reorganization, dissolution, liquidation, 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 Personally Identifiable Information held by us about our Users is among the assets transferred;
  • other third parties with your express consent for any purpose disclosed by us when you provide the information; and
  • you, upon your written request.
We may share your customers’ Personally Identifiable Information with:
  • the Centers for Medicare and Medicaid Services ("CMS") in order to obtain an eligibility determination for the customer and to enroll the customer in health insurance plans offered on the Federally Facilitated Marketplace;
  • third party insurance companies to which the customer’s application for health insurance is submitted on or through the Website;
  • third party associations and healthcare product providers to which the customer’s application for enrollment is submitted on or through the Website;
  • the organizations or entities on behalf of which we are providing the Website to you and/or on behalf of which you access or use the Website, such as your agency, employer, and other companies associated with those organizations;
  • the customer, upon the customer’s written request.
We may also share Personally Identifiable Information with law enforcement agencies, government officials, or other third parties as necessary for the purpose of:
  • complying with any court order, law or legal process, including to respond to any government or regulatory request;
  • preventing fraud protection and credit risk reduction;
  • investigating potential unauthorized access or misuse of our Website or other breach of our Terms of Use, Supplemental Terms, Website Policies or other agreements;
  • protecting the assets or property, and enforcing the rights of Infinite Spark, including for billing and collection purposes; and
  • protecting the rights, property, or safety of our Users or others.

Non-Personally Identifiable Information

In addition, we may share Non-Personally Identifiable Information, including aggregated or anonymized data:
  • with our partners about how our Users collectively use our Website, so that our partners may also understand how often people use their services and our Website;
  • with analytics companies, search engines, or other service providers that help us improve our Website;
  • to report to our affiliates, licensors and service providers about the use of various aspects of the Website; and
  • with other Users or prospective Users of the Website.

COOKIES AND OTHER TRACKING TECHNOLOGIES

We may use cookies and similar automatic data collection technologies, now or in the future, to support the functionality of our Website. These technologies help us provide a better experience when you visit our Website and allows us to improve our Website. The technologies we may use for this automatic data collection may include:
  • Browser Cookies. A browser cookie is a small file placed on the hard drive of your computer. That cookie then communicates with our servers or those of other companies that we authorize to collect data for us and allows recognition of your personal computer. Cookies created and used by our Website do not contain Personally Identifiable Information. We associate cookies with Personally Identifiable Information only if you use the logged in areas of the Website, order a Service, use the personalization services available as part of the Website, or ask us to contact you with additional marketing information. We do not otherwise collect Personally Identifiable Information from browser cookies and we do not associate browser cookies with your Personally Identifiable Information. You may use the tools available on your computer or other device to set your browser to refuse or disable all or some browser cookies, or to alert you when cookies are being set. However, if you refuse or disable all browser cookies, you may be unable to access certain parts or use certain features or functionality of our Website. Unless you have adjusted your browser settings so that it refuses all cookies, we may use cookies when you direct your browser to our Website.
  • Other Tracking Technologies. Our Website may also use other tracking technologies such as embedded scripts, location-identifying technologies, and other similar technologies. These technologies execute on our Website or in your browser and allow us to recognize you when you return to the Website and understand how our users use and interact with our Website.
Our service providers may use cookies and other similar tracking technologies to collect and share Non-Personally Identifiable Information about your activities both on our Website and on other websites, including, for example, to provide you targeted advertising based upon your interests. In addition, third parties that are unaffiliated with us may also collect information about you, including tracking your browsing history, when you use our Website. We do not have control over these third-party collection practices. If you wish to minimize these third-party collections, and you can adjust the settings of your browsers or install plug-ins and add-ins.

YOUR CHOICES

We offer you and your customers certain choices in connection with the information we collect:

Limit Use of Customer Information for Health Insurance Purposes

Your customers may request that you and Infinite Spark limit the collection, creation, disclosure, access, maintenance, storage and use of their Personally Identifiable Information for the sole purpose of assisting them in applying for health insurance or obtaining an eligibility determination, facilitating payment for their first premium, assisting them in updating or canceling their enrollment in a health insurance plan, and for performing other authorized functions specified in our agreements with CMS. Any customer may request such a limitation by sending an email to privacy_help@insuresync.com.

Email Communications

You may have the opportunity to receive certain communications from us related to our Website. If you provide us with your e-mail address in order to receive communications, you can opt out of marketing e-mails at any time by following the instructions at the bottom of our e-mails and adjusting your e-mail preferences. Please note that certain e-mails may be necessary for the operation of our Website. You will continue to receive these e-mails, if appropriate, even if you unsubscribe from our optional communications.

Cookies

If you wish to minimize information collected by cookie, you can adjust the settings of your browsers to notify you when you receive a cookie, which lets you choose whether or not to accept it. You can also set your browser to automatically reject any cookies. You may also be able to install plug-ins and add-ins that serve similar functions. However, please be aware that some features and services on our Website may not work properly if we are not able to recognize and associate you with your account.

Network Advertising Initiative

Certain websites you visit may provide options regarding advertisements you receive. If you wish to minimize the amount of targeted advertising you receive, you can opt out of certain network advertising programs through the Network Advertising Initiative (NAI) Opt–Out Page. Please note that even if you choose to remove your information (opt out) you will still see advertisements while you're browsing online. However the advertisements you see may be less relevant to you. For more information or to opt out of certain online behavioral advertising, please visit http://www.aboutads.info.
Additionally, many advertising network programs allow you to view and manage the interest categories that they have compiled from your online browsing activities. These interest categories help determine the types of targeted advertisements you may receive. The NAI Opt–Out Page provides a tool that identifies its member companies that have cookies on your browser and provides links to those companies.

Do Not Track

Some browsers support a "Do Not Track" (or, DNT) feature, a privacy preference that Users can set in certain web browsers, which is intended to be a signal to websites and services that you do not wish to be tracked across different websites or online services you visit. Our Website does not currently recognize or respond to DNT signals, so DNT settings do not change the way the Website operates.
Please note that we cannot control how third-party websites or online services you visit through our Website respond to Do Not Track signals. Check the privacy policies of those third parties for information on their privacy practices.

Updating Information

The accuracy of the information we have about you and your customers is very important. To review, correct or delete your Personally Identifiable Information stored by us, please contact us at agent_service@insuresync.com. Your customers can also review, correct, or delete their Personally Identifiable Information stored by us by contacting us at agent_service@insuresync.com.
We will retain your information for as long as your account is active or as needed to provide the Services. We will retain information about you and any customers who you enroll in health insurance or a healthcare product through our Website as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.
Please note that once your customer’s application has been submitted to their chosen health insurance company or any other relevant party (such as the federal government in the case of an application involving advanced premium tax credits) they may be required to contact the insurance company or such other party directly to update their application or other information that may have collected by that party.

SECURING YOUR INFORMATION

The security of your information and your customers’ information is important to Infinite Spark, and we have established administrative, technical, and physical safeguards designed to protect the Personally Identifiable Information about you and your customers against unauthorized alteration, access, loss, theft, use or disclosure. Unfortunately, no system can guarantee complete security of information. As a result, Infinite Spark cannot ensure or warrant that your information or your customers’ information, including Personally Identifiable Information, is secure from unauthorized third parties. Thus, your use of the Website and communication with us about them is at your own risk.
You are responsible for protecting your password(s) and for the security of information that you transmit to us over the internet. See the Terms of Use to review your responsibilities as a User of the Platform in protecting the privacy and security of your customers’ information.

CHILDREN

Our Website is directed to and is intended to be used only by persons who are 18 years of age or older. We do not knowingly collect information from children under 18. If you are under 18 years of age, you are not permitted to register for an account or otherwise submit any Personally Identifiable Information to us, including your name, address or e-mail address. By registering for an account or submitting any Personally Identifiable Information to us, you represent and warrant that you are 18 years of age or older.
If we discover that we have received any Personally Identifiable Information directly from a child under the age of 18, we will suspend the associated account and remove that information from our database as soon as possible. By registering for an account or otherwise submitting any Personally Identifiable Information to us, you represent and warrant that you are 18 years of age or older. For the avoidance of doubt, this restriction does not apply to information collected from a parent or legal guardian who provides information regarding a dependent child under the age of 18 in connection with a health insurance application or other related purpose.

LINKS TO THIRD PARTY WEBSITES

Our Website may contain links to third party websites and services, including those of third-party insurance providers. Please note that these links are provided for your convenience and information, and the websites and services may operate independently from us and have their own privacy policies or notices, which we strongly suggest you review. This Privacy Notice applies to Infinite Spark and our Website only. We do not accept any responsibility or liability for the policies or practices of any third parties. If you choose to access any websites or services linked from our Website, please check the applicable policies before you use or submit any personal data to such website or service.

INTERNATIONAL JURISDICTIONS

The Website is hosted in the United States of America and is subject to U.S. state and federal law. The Website is not intended to subject Infinite Spark to the privacy laws or jurisdiction of any state, country or territory other than that of the United States, including the European Union. Infinite Spark does not represent that the Website is appropriate for use in any particular jurisdiction. Those who access the Website do so at their own initiative and are responsible for complying with all local laws, rules and regulations. If you are accessing our Website from other jurisdictions, please be advised that you are transferring your personal information to us in the United States, and by using our Website, you consent to that transfer and use of your personal information in accordance with this Privacy Notice. You also agree to abide by the applicable laws of applicable states and U.S. federal law concerning your use of the Website and your agreements with us. Any persons accessing our Website from any jurisdiction with laws or regulations governing the use of the Internet, including personal data collection, use and disclosure, different from those of the jurisdictions mentioned above may only use the Website in a manner lawful in their jurisdiction. If your use of the Website would be unlawful in your jurisdiction, you may not use the Website.

CHANGES TO OUR PRIVACY NOTICE

Infinite Spark may, in its sole discretion, change this Privacy Notice from time to time. Any and all changes to this Privacy Notice will be reflected on this page and the Effective Date will be stated at the top of this Privacy Notice. Unless stated otherwise, our current Privacy Notice applies to all information that we have about you, your account, and your customers. Users should regularly check this page for any changes to this Privacy Notice. Infinite Spark will always post new versions of the Privacy Notice on the Website. In the event that an amendment materially alters your rights or obligations, we may notify you of the amendment, such as by posting a notification to the home page of the Website, or sending a notification to you at the address we have on file for you, if any.
Your continued use of the Website or communication with us after the updated Privacy Notice has been posted (or any other indication of your consent) will constitute your acceptance of the updated Privacy Notice.
Please note that we may condition your continued access to our Website on your consent to changes to this Privacy Notice.

CONTACT US

If you have questions or comments relating to this Privacy Notice, or if you would like us to update information that we have about you, your customers, or your preferences, please contact us by email at agent_service@insuresync.com.

Infinite Spark
Attn: Legal Department
275 Argosy Ln
Montgomery, TX 77316