Privacy policy.

 

Privacy Policy

InnSure Corporation (“IC,” “we,” “us,” “our”) is a not for profit entity which seeks to foster new ventures for the insurance industry.  This Privacy Policy (“Policy”) explains how IC collects, uses and discloses information about you when you use our website or when you otherwise interact with us as described below.­­

We respect and value the privacy of visitors to our website and will only collect and use information in a manner consistent with your rights and our obligations under the law.  Please read this Policy to understand how we collect and use your personal information when you visit our website and what rights you have in relation to your Personal Information (as defined below).

A. WHAT INFORMATION DO WE COLLECT OR RECEIVE?

We collect or receive information in several different ways. In many cases, you choose what information to provide; however, some of this information may be Personal Information.  “Personal Information” means any information relating to an identified or identifiable natural person, such as your name and contact information and, in some cases, your Internet Protocol (IP) address.

1.     Information Provided or Made Public by You.  You are not required to provide any Personal Information when visiting the publicly accessible pages on our website. 

However, you may do so by completing various forms found on our website, including the following: 

  • create an account on our website;

  • complete a registration form to attend an event or program;

  • purchase services or merchandise on our website;

  • if you apply to or otherwise agree to participate in IC programming;

  • signing up for our newsletters; and

  • contacting us by any means.

We may also collect or obtain your Personal Information that you choose to make public, including via social media and business networking profile.

2.     Cookies and Other Tracking Tools; Third Party Analytics Services. We use cookies, Clear GIFs, Web Beacons, Tracking Technologies or other similar solutions (“Tracking Technologies”) to collect or receive certain information when you visit or use our website or read an email, newsletter, or otherwise interact with content from us. These Tracking Technologies may include first party cookies (i.e., those placed by the website being visited) and third party cookies (i.e., those placed by a website other than the one being visited), local shared objects (commonly referred to as “Flash Cookies” or “HTML 5 Cookies”) and tracking pixels (including transparent or clear gifs).

Cookies are small data files which are placed on your computer or mobile device when you visit a website or use an online service. For example, cookies enable us to identify and authenticate you and remember your preferences so we can enhance your experience on our website. They also help us understand and improve our service, and know when content has been shown to you. Because your web browser may request advertisements and beacons directly from third party ad network servers, these networks can view, edit, or set third party cookies, just as if you had requested a web page from their site. Ads served by the website may also set third party cookies. Most browsers are initially set up to accept cookies, but you can reset your browser to refuse all cookies or to indicate when a cookie is being sent.

We strongly recommend that you leave the cookies activated, however, because cookies enable you to take advantage of some of the features of the website and if you decline or delete them then parts of the website may not work properly. Even if you decline or delete cookies, you may continue to be served with advertisements. Where legally permitted, we will assume that you have agreed to receive all cookies on our website through your continued use; otherwise, your acceptance of such cookies by way of your browser settings or our consent management tool shall be deemed your acceptance of the use of such Tracking Technologies.

We use several different types of cookies on our website, including the following.

  • Strictly Necessary Cookies. Strictly necessary cookies facilitate the operation of our website. Without the use of these cookies, portions of our website would not function properly.

  • Performance Cookies. Performance cookies help us monitor the performance of our website and how users interact with them. These cookies collect information such as how often users visit our website, what pages they visit when they do so, and what other websites they used prior to coming to our website, and provide us with information that allows us to improve our website and services.

  • Functional Cookies. Functional cookies are used to remember your preferences on our website and to authenticate your identity. For example, we use functional cookies to recognize and save your name and password on our website.

  • Flash Cookies. When you use our website or content posted on it that employs Macromedia Flash Player, a small Flash Cookie may be used. The purpose of using these cookies is to store your flash player preferences and enhance your browsing experience.

Although our website does not currently respond to “do not track” browser headers, you can limit tracking through third-party programs and by taking the other steps discussed in this section. You may opt-out of internet-based advertising by removing cookies or by setting your web browser settings to refuse cookies and similar Tracking Technologies. Please note that web browsers operate using different identifiers. As such, you must adjust your settings in each web browser and for each computer or device that you would like to opt-out on. Further, if you simply delete your cookies, you will need to remove cookies from your device after every visit to websites. You may download a browser plugin that will help you maintain your opt-out choices by visiting www.aboutads.info/pmc. You may block cookies entirely by disabling cookie use in your browser or by setting your browser to ask for your permission before setting a cookie. Blocking cookies entirely may cause some websites to work incorrectly.

Please note that the use of online tracking mechanisms by third parties is subject to those third parties’ own privacy policies, and not this Privacy Policy. You may remove yourself from the targeted advertising of companies within the Network Advertising Initiative by opting out here, or of companies participating in the Digital Advertising Alliance program by opting out here, the Digital Advertising Alliance of Canada (DAAC) (for Canadian users) by opting out here; or the European Interactive Digital Advertising Alliance (EDAA) (for users in the EU) by opting out here.

For clarity, we have identified some of our primary third-party Tracking Technologies below.

o  Google Analytics.  Our website uses Google Analytics, a web analysis service of Google, Inc.  Google Analytics employs cookies that are stored to your computer in order to facilitate an analysis of your use of the site. The information generated by these cookies, such as time, place and frequency of your visits to our Site, to, among other things, improve our website and your user experience.  Google Analytics also uses electronic images known as web beacons (sometimes called single pixel gifs) and are used along with cookies to compile aggregated statistics to analyze how our site is used.  You can prevent cookies from being installed by adjusting the settings on your browser software accordingly as noted elsewhere in this Privacy Policy. You should be aware, however, that by doing so you may not be able to make full use of all the functions of our website.  Google Analytics also offers a deactivation add-on for most current browsers that provides you with more control over what data Google can collect on websites you access. The add-on tells the JavaScript (ga.js) used by Google Analytics not to transmit any information about website visits to Google Analytics. However, the browser deactivation add-on offered by Google Analytics does not prevent information from being transmitted to us or to other web analysis services we may engage.  You can install the Google Analytics Opt-out Browser Add-on by clicking here.  You can also opt out of Google’s use of cookies by visiting Google’s ad settings and/or you may opt out of a third-party vendor’s use of cookies by visiting the Network Advertising Initiative opt-out page.

 

o   Google reCAPTCHA. In addition to the foregoing, in order to protect our registration forms and other website features, we use Google reCAPTCHA provided by Google Inc. (“reCAPTCHA”). We employ reCAPTCHA to check whether data is entered into our forms by a person or by an automated program, script or bot. reCAPTCHA analyzes the behavior of the person entering the data using various features. This analysis starts automatically as soon as the website is accessed. For analysis, reCAPTCHA evaluates various information (e.g., IP address, browser type, settings, and plugins, URL of the referring website, time spent on the respective website, mouse movements, input characteristics of the data entry, including speed, sequence and selection of inputs, etc.). The data collected during the analysis is forwarded to a Google server in the USA, where it is stored and evaluated. We carry this processing out based on our legitimate interest in preventing the misuse of our websites through automated means. You can find Google’s current privacy policy at: https://policies.google.com/privacy. Detailed information about Google reCAPTCHA can be found at the following address: https://www.google.com/recaptcha.

B. CATEGORIES OF PERSONAL INFORMATION THAT WE MAY PROCESS

We may process any Personal Information or data disclosed, revealed, or provided as set forth in Section A above, including your name, your contact information, information about our website, information about your interactions with our website, and details regarding your employer.  For the purposes of this Policy, “Process”, “Processing” or “Processed” means anything that is done with any Personal Information, whether or not by automated means, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.  We do not seek to collect or Process any Sensitive Personal Data, herein defined as Personal Information about race or ethnicity, political opinions, religious or philosophical beliefs, trade union membership, physical or mental health, sexual life, any actual or alleged criminal offences or penalties, national identification number, or any other information that may be deemed to be sensitive under applicable law.

C. WHY WE COLLECT AND STORE YOUR INFORMATION

We collect information from you in order to provide you with our content and services.  Additionally, the collection and use of your information helps us tailor and improve our services and communicate with you effectively and to maintain records of interactions in connection with our services and our website. Additionally, it helps us improve the quality of our content, events, and services, to understand our website visitors’ preferences, to improve our website user experience.

D. HOW WE USE YOUR INFORMATION

We use, aggregate, and retain your Personal Information as needed to provide you with access to content, events, professional comradery, and services catered to your professional interests with your consent and for other legitimate business reasons. Some information is required in order to use our websites and for us to provide you with services.  At a high level, we use the Personal Information that has been provided by you directly or indirectly to:

  • Provide you with information relevant to our services or industry, news, and offers about our services;

  • Connect you with peers in your industry;

  • Provide you with services including, content, and information that you request, access, or which may be of interest to you in connection with our industry;

  • Send you satisfaction questionnaires, surveys, and marketing information;

  • Tailor the content delivered to you based on your interests and responsibilities;

  • Contact you for direct marketing purposes regarding information about, and invitations for, products, services, programs, and events relevant to your professional interests and responsibilities;

  • Communicate with you, advertise to you or invite you to join us on social media platforms on which you participate;

  • Operate our website and improve our products and services;

  • Understand trends and usage statistics;

  • Respond to your product or service inquiries or support requests and comments;

  • Test and evaluate potential new products and features;

  • Diagnose and resolve problems, analyze trends, and monitor usage and resource needs; and

  • For any other purpose that we tell you about when you give us your Personal Information.

By way of example, we analyze information collected from you to (a) track, accumulate and report information on our website and (b) help us improve the content that you are shown while visiting our website and our programs.

E. GROUNDS FOR PROCESSING YOUR PERSONAL INFORMATION

When we collect or otherwise process any Personal Information within the scope of European data protection laws, we will only do so provided that we have a lawful basis for such actions. These lawful bases include where it is: necessary for the performance of a contract to which you are a party; necessary for us to take steps, at your request, to enter into such a contract; necessary for the purposes of our legitimate interests or those of a third party and not overridden by the interests or fundamental rights and freedoms of any data subject; where you provide us with consent; or necessary for compliance with a legal obligation to which we are subject. Under applicable law, we may be obliged to secure and maintain technical and organizational measures to protect the security of your data, investigate and report any (suspected) breaches of those technical and organizational measures, or comply with legal and regulatory obligations, including, but not limited to, complying with minimum retention periods for certain types of data.

F. PARTIES WITH WHOM WE SHARE YOUR PERSONAL DATA

We share information with service providers and other third parties where it is necessary to meet the requirements of our Terms of Use, to provide our services, or for any other purposes described in this Privacy Policy.

·       Vendors and Service Providers. We may provide your Personal Data to certain vendors and service providers who are working for or with us as described in this Privacy Policy and who require access to such information to facilitate the provision of our services, such as the provision of data storage or processing activities. We will always attempt to limit the information that we provide to what is reasonably sufficient for those vendors or service providers to carry out their responsibilities as they relate to the fulfillment of our services.

·       Third-Party Analytics. We allow our third-party analytics to collect certain information on our Websites, as described above.

·       Business transfers, Affiliates, and Subsidiaries. We may share or transfer the information that we collect in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of IU to another company. We may share your Personal Data within our organization in order to facilitate the provision of services in connection with your use of our websites or your membership to our network of websites.

·       Vital Interests. We may disclose the information that we collect where we believe that it is necessary in order to protect the vital interests of any person, or to exercise, establish, or defend our legal rights.

·       Other ways in which you specifically consent. We may share the information that we collect in other ways that you specifically consent.

·       Legal Compliance and Public Safety. We may share your Personal Information when required by law, subpoena, or other legal process or if we have a good faith belief that disclosure is reasonably necessary to (a) investigate, prevent, or take action regarding suspected or actual illegal activities or to assist government enforcement agencies; (b) enforce our agreements, (c) investigate and defend ourselves against any third-party claims or allegations, (d) protect the security or integrity of our services; or (e) exercise or protect the rights and safety of our members, personnel, or others. We may attempt to notify members about legal demands for their Personal Information when appropriate in our judgment, unless prohibited by law or court order or when the request is an emergency. We may dispute such demands when we believe, in our discretion, that the requests are overbroad, vague or lack proper authority, but we do not promise to challenge every demand.

G. SECURITY OF YOUR PERSONAL INFORMATION

We take the security of your Personal Information seriously. We have implemented technical, organizational and administrative measures which are generally accepted by the industry to protect the Personal Information in its possession to ensure a level of security appropriate to the level of risk. These measures include, but are not limited to, the implementation of current security technologies and processes to protect your information from loss, misuse and unauthorized access, disclosure, alteration or destruction. Unfortunately, the internet cannot be guaranteed to be completely secure at all times, and we cannot ensure or warrant the security of any information you provide to us. We cannot guarantee the security of your data transmitted to us using the internet – any such transmission is at your own risk and you are responsible for ensuring that any Personal Data that you send to us are sent securely.  To the fullest extent permitted by applicable law, we do not accept liability for unintentional disclosure. 

H. RETENTION AND STORAGE OF YOUR PERSONAL INFORMATION

We will retain your Personal Information only for as long as reasonably necessary to fulfill the purpose for which it was collected and for which your account remains in existence, to comply with our legal obligations, resolve disputes, and enforce our agreements. We may also retain Personal Information, for a limited period, if requested by law enforcement.  You may make a request to remove any and all data collected by us. See our contact information below. 

I. DATA PROTECTION LAWS AND YOUR RIGHTS

We strive to maintain a high level of privacy for anyone who shares information with us, regardless of where they reside. 

IC takes reasonable steps to ensure that your Personal Information is accurate and kept up-to-date.  We also take measures to minimize the amount of Personal Information that we collect and retain in our records.

We are committed to ensuring that you are comfortable with our data collection and use practices.  If you have a question or complaint about our services or this Policy, please contact us using the information below.  We will work with you and any appropriate regulatory bodies to resolve complaints regarding any transfer of data that is in breach of this Policy. We will respond timely and thoroughly to any verified complaints and inquiries in accordance with applicable law.  Notwithstanding the foregoing, if you have consented to receiving communications from IU, we may provide you with marketing information we think would be of interest. You may opt out of receiving such marketing communications at any time by contacting us via any other means specified in this Privacy Policy.

IC is headquartered in the United States. You agree that we may store and process the information we collect anywhere in the world, including but not limited to, the United States, the European Union, or other countries.

1.     EUROPEAN UNION PERSONAL DATA

If you are located in the European Union (“EU”), United Kingdom, Lichtenstein, Norway, or Iceland, you may have additional rights under the EU General Data Protection Regulation (“GDPR”) with respect to your Personal Information.

 Upon request, we agree to provide you with information regarding any of your personal data that we have processed. You always have the right to withdraw your consent, update your Personal Information, request erasure of your Personal Information we hold, and/or object to further processing of such information. Please email us at the contact email provided below to exercise your rights regarding the processing your Personal Information.

2.     CALIFORNIA RESIDENTS

If you are a California resident, California Civil Code Section 1798.83 permits you to request information regarding the disclosure of your Personal Information to third parties. To learn more about your California privacy rights, please read our California Privacy Notice and to receive more information about our data collection and disclosure practices targeted towards California law. 

Notwithstanding the foregoing, if you are a California resident, you may contact us using the contact information below to exercise your disclosure choice options.

J. CHILDREN’S PRIVACY

Our website complies with the Children’s Online Privacy Protection Act of 1998 (COPPA). COPPA and its accompanying regulations protect the privacy of children using the Internet. Our website is intended for persons who are eighteen (18) years of age or older. However, per COPPA, anyone under the age of thirteen (13) must seek the permission of a parent or guardian before using this website.

Our website will not knowingly contact or collect Personal Information from anyone under the age of thirteen (13), and does not intend to solicit information of any kind from persons under the age of thirteen (13).   If we learn that we have inadvertently received or collected Personal Information from someone under the age of fourteen (14), we will delete such information from our databases.

K. LIMITS OF THIS PRIVACY POLICY

This Privacy Policy does not apply to the following parties and circumstances.  We encourage you to review the privacy policies of the parties in the categories below for additional information about their data collection and use practices.

  • third parties who may advertise our events and services;

  • companies who may link to our website; and

  • third party websites linked or referenced in our content and in our services, including our programs.

L. REVISIONS TO THIS POLICY

IC reserves the right to change this Privacy Policy, without notice, at its discretion, by posting updates on our website. If we change our Privacy Policy, we will post those changes in addition to updating the “Last Updated” date at the bottom of this Policy. You are encouraged to revisit this page periodically in order to stay informed of any changes. The Policy posted at any time via our website shall be deemed to be the Policy then in effect.  Where applicable, your continued use of our services, website, or content posted on our website shall constitute your acceptance of the modified or amended Policy. Notwithstanding the foregoing, if we make any changes to this Policy that will impact the use of your Personal Information in a manner that is materially different from that stated at the time of collection, we will notify you by posting a notice on our website.

M. CORRECTING OR UPDATING YOUR INFORMATION 

You are invited to help us keep your Personal Information up to date by notifying us of any changes. You may contact us to correct or update your Personal Information.

N. HOW TO CONTACT US

If you have any questions or concerns regarding this Policy or how we use your Personal Information, please email us at info.innsure.org  Please include “ATTN Privacy Protection Officer” in the subject line.  In the alternative, you are welcome to write a letter to the attention of our Privacy Protection Officer at One Broadway Street, Cambridge, MA 02142.

 

Effective:5/27/20