In this Privacy Policy (“Policy”), we describe how we collect, use, maintain, and share information that we obtain about visitors to our consumer-facing websites where this Policy is posted (the “Sites”) and any online service, including any website or mobile application, that posts a link to this Policy, and any interactive features, widgets, plug-ins, applications, content, downloads and other services that we may own and control and make available through any websites that we own and control and that link to this Policy (collectively, the “Services”), regardless of how you access or use them, whether via personal computer, browser, laptop, tablet, mobile phone or other device (each a “Device”). To the extent that we provide you with notice through our Site or Services of different or additional privacy policies or practices (e.g., at the point of collection), those additional privacy policies shall govern such data collection and use.
By visiting the Sites, or using any of our Services, you agree that your personal information will be handled as described in this Policy. Your use of our Services, and any dispute over privacy, is subject to this Policy and our Terms of Use, including its applicable limitations on damages and the resolution of disputes. The UIG Terms of Use are incorporated by reference into this Policy.
This Policy is written in the English language. We do not guarantee the accuracy of any translated versions of this Policy. To the extent any translated versions of this Policy conflict with the English language version, the English language version of this Policy shall control.
Overview
We think transparency is important. In this overview, we summarize the personal information we collect and how we use it, which is further explained in our Policy below. Keep in mind that the actual personal information we collect and how we use it varies depending upon the nature of our relationship and interactions with you. Also, in some cases (such as where required by law), we ask for your consent or give you certain choices prior to collecting or using certain personal information.
Categories of Personal Information Collected. Generally, we may collect the following categories of personal information:
- Identifiers
- Customer Records
- Commercial Information
- Usage Data
- Geolocation Data
- Audio, Video and Electronic Data
- Professional information
- Education Information
- Protected Classifications
- Inferences
Use of Personal Information. In general, we may use and disclose the personal information we collect for the following business and commercial purposes:
- Providing our Services
- Communicating with you
- Personalizing content and experiences
- Marketing and advertising
- Analyzing and improving the Services and our business
- Complying with legal obligations
- Protection of rights
- In support of our general business operations
- Securing and protecting assets and rights
California Residents: If you are a California resident, please refer to the “Additional Information for California Residents” section below for important information about the categories of personal information we collect and disclose, as well as your rights under California privacy laws.
You can review more detailed information about our privacy practices and your rights and choices below in our Policy
Information We Collect About You
We collect information about you directly from you, from third parties, and automatically through your use of our Services.
Information We Collect Directly From You. The information we collect from you depends on how you use our Services. For example, when you use our Services to request a potential quote for or other information about insurance, we collect your first and last name, address, age, spouse’s name, spouse’s age, email address, and phone number. In addition, on some of our Sites, we provide an open comments field for you to provide us with any additional information you would like to include in your submission. Please do not include any sensitive personal information in this field, including any health-related information.
Information We Collect From Third Parties. We collect certain information from third parties, such as data brokers. This includes your contact information and certain demographic information such as your income.
Information We Collect Automatically. We automatically collect information about your use of our Services through cookies, web beacons, and other technologies, such as: domain name, your browser type and operating system, web pages you view on the Services, links you click on the Services, your IP address, the length of time you visit our Sites or use our Services, and the referring URL or the webpage that led you to our Services.
To the extent permitted by applicable law, we combine this information with other information we collect about you, including your personal information. Please see the section “Our Use of Cookies and Other Tracking Mechanisms” below for more information.
How We Use Your Information
We may use and disclose your information, including your personal information, for the following business and commercial purposes and in a manner that is consistent with this Policy and the context of our relationship with you:
- Providing our Services: to provide and operate our Services, including to contact you regarding insurance quotes or other information you request, to provide troubleshooting and technical support, to fulfill your orders and requests, and to protect and secure our Services.
- Communicating with you: to communicate with you about your use of our Services, to administer surveys and questionnaires, such as for market research or member satisfaction purposes; and for other customer service purposes.
- Personalizing content and experiences: to tailor the content and information that we may send or display to you, to offer location customization, and to otherwise personalize your experiences while using the Services.
- Marketing and advertising: to send you newsletters or other information we think may be of interest you; to contact you about our Services or information we think may be of interest you; to administer promotions and contests; to assist us in advertising on third-party websites, mobile apps, and other online services; and to evaluate the success of our marketing and adverting campaigns (including our online targeted advertising on third party sites and platforms and our offline promotional campaigns). Where required by applicable law, we will obtain your consent to use your personal information for marketing and related purposes. You may unsubscribe from our mailing lists at any time by using the “unsubscribe” feature in any marketing emails you receive from us.
- Analyzing and improving the Services and our business: to better understand how users access and use our Services, as well as other products and offerings, both on an aggregated and individualized basis; and to administer, monitor, and improve our Services, for our internal purposes and for other research and analytical purposes. For example, we may evaluate which features of our Sites are most used by users.
- Complying with legal obligations: to comply with legal obligations, as part of our general business operations, and for other business administration purposes.
- In support of our general business operations: relating to audits and assessments of our business operations, security controls, financial controls, records and information management program, and otherwise relating to the administration of our general business, accounting, record keeping and legal functions.
- Securing and protecting assets and rights: to protect our business operations, secure our network and information technology assets and services; to prevent and detect fraud, unauthorized activities, access, and other misconduct; where we believe necessary to investigate, prevent or take action regarding suspected violations of our Terms and other agreements, as well as fraud, illegal activities, and other situations involving potential threats to the rights or safety of any person or third party; and as necessary to defend our legal interests and rights.
Aggregate, De-identified or Anonymous Data. We also create and use aggregate, anonymous, and de-identified data to assess, improve and develop our business, products and the Services, and for similar research and analytics purposes. This information is not generally subject to the restrictions in this Policy, provided it does not identify, and could not be used to identify, a particular individual.
How We Share Your Information
We may disclose the personal information we collect as follows:
- Service providers: to service providers, contractors, or agents who perform functions on our behalf. These service providers include information technology service providers and other professional services service providers.
- Affiliates and agents: to our affiliates or subsidiaries and independent insurance agents so that they can provide you with information about goods and services that may be of interest to you.
We also may disclose the personal information we collect for the following business and commercial purposes:
- Mergers, acquisitions, and business transfers: to another company, where (i) we or our affiliates are or may be acquired by, merged with, or invested in by such company or (ii) if any of our assets are or may be transferred to such company, whether as part of a bankruptcy or insolvency proceeding or otherwise. As part of the business transfer process, we also may disclose certain personal information with lenders, auditors, and third party advisors, including attorneys and consultants, subject in each case to our compliance with applicable laws.
- Compliance and legal process: : to comply with the law, a judicial proceeding, court order, or other legal process, such as in response to a court order or a subpoena.
- To protect us and others: when we believe it is appropriate to do so to investigate, prevent, or take action regarding illegal activities, suspected fraud, situations involving potential threats to the safety of any person, violations of our Terms of Use or this Policy, or as evidence in litigation in which we are involved.
Aggregate and de-identified information. We also may share aggregate, anonymized, or de-identified information about users with third parties for marketing, advertising, research, or similar purposes.
Our Use of Cookies and Other Tracking Mechanisms
We use automatic data collection technology when you use our Services to record information that identifies your computer, to track your use of our Services, and to collect certain basic information about you and your surfing habits (“Usage Information”).
Usage Information may include:
- Information about your operating system,
- Your IP addresses, browser type and language,
- Referring and exit pages and URLs, keywords,
- Date and time,
- Amount of time spent on particular pages,
- What sections of the Services you visit; and
- Similar information concerning your use of the Services
We and our third party providers may use cookies, clear GIFs/pixel tags, JavaScript, local storage, log files, and other mechanisms to automatically collect and record information about your browsing activities and use of the Services. We may combine this Usage Information with other personal information we collect about you. We may use this usage data to understand how our Services are used, track bugs and errors, provide and improve our Services, verify account credentials, allow logins, track sessions, prevent fraud, and protect our Services, as well as for targeted marketing and advertising, to personalize content, and for analytics purposes.
Cookies. Cookies are alphanumeric identifiers that we transfer to your device’s hard drive through your web browser for record-keeping purposes. Some cookies allow us to make it easier for you to navigate our Services, while others are used to enable a faster log-in process or to allow us to track your activities at our Services. Most web browsers automatically accept cookies, but if you prefer, you can edit your browser options to block them in the future. The Help portion of the toolbar on most browsers will tell you how to manage your cookie selections. Visitors to our Services who disable cookies will be able to browse certain areas of the Services, but some features may not function.
Pixels. Pixels are tiny graphics with a unique identifier, similar in function to cookies. In contrast to cookies, which are stored on your computer’s hard drive, pixels are embedded invisibly on web pages. We may use pixels (also referred to as web beacons, web bugs, or clear GIFs), in connection with our Sites to, among other things, help us manage ads and content and compile statistics about usage of our Services. We may also use pixels in HTML emails to our customers.
Third Party Analytics. We use automated devices and applications, such as Google Analytics, to evaluate usage of our Services. We also may use other analytic means to evaluate our Services. We use these tools to help us improve our Services’ performance and user experiences. These entities may use cookies and other tracking technologies, such as web beacons or local storage objects (LSOs), to perform their services. To learn more about Google’s privacy practices, please review the Google Privacy Policy at https://www.google.com/policies/privacy/. You can also download the Google Analytics Opt-out Browser Add-on to prevent their data from being used by Google Analytics athttps://tools.google.com/dlpage/gaoptout.
Do-Not-Track. Currently, our systems do not recognize browser “do-not-track” requests. You may, however, disable certain tracking as discussed in this section (e.g., by disabling cookies); you also may opt-out of targeted advertising by following the instructions in the Third Party Ad Network section directly below.
Interest-based Advertising
We use third parties such as network advertisers to serve advertisements on third-party websites or other media (e.g., social networking platforms). This enables us and these third parties to target advertisements to you for products and services in which you might be interested. Third-party ad network providers, advertisers, sponsors, and/or traffic measurement services may use cookies, JavaScript, web beacons (including clear GIFs), Flash LSOs, and other tracking technologies to measure the effectiveness of their ads and to personalize advertising content to you. These third-party cookies and other technologies are governed by each third party’s specific privacy policy, not this one. We may provide these third-party advertisers with information, including personal information, about you.
Users in the United States may opt out of many third-party ad networks. For example, you may go to the Digital Advertising Alliance (“DAA”) Consumer Choice Page for information about opting out of interest-based advertising and their choices regarding having information used by DAA companies. You may also go to the Network Advertising Initiative (“NAI”) Consumer Opt-Out Pagefor information about opting out of interest-based advertising and their choices regarding having information used by NAI members.
Opting out from one or more companies listed on the DAA Consumer Choice Page or the NAI Consumer Opt-Out Page will opt you out from those companies’ delivery of interest-based content or ads to you, but it does not mean you will no longer receive any advertising through our Services, or on other websites. You may continue to receive advertisements, for example, based on the particular website that you are viewing (i.e., contextually based ads). Also, if your browsers are configured to reject cookies when you opt out on the DAA or NAI websites, your opt out may not be effective. Additional information is available on the DAA’s website at www.aboutads.info or the NAI’s website at www.networkadvertising.org.
Third-Party Links
Our Services may contain content, services, advertising and other materials that link to websites operated by third parties. Any access to and use of such linked websites is not governed by this Policy, but instead is governed by the privacy policies of those third party websites. We are not responsible for the information practices of such third party websites.
Security of My Personal Information
We have implemented reasonable precautions to protect the information we collect from loss, misuse, and unauthorized access, disclosure, alteration, and destruction. Please be aware that despite our best efforts, no data security measures can guarantee security.
Social Security Protection Policy Statement
It is our policy to protect the confidentiality of Social Security numbers (SSNs) from misuse and improper disclosure by maintaining and enforcing physical, electronic, and procedural safeguards. We prohibit unlawful disclosure of SSNs, and limit access to SSNs to our personnel who need access to SSNs in order to perform their job functions. We do not disclose SSNs to third parties except where required or permitted by law.
Changes to My Personal Information
You may modify personal information that you have submitted by contacting us – see the Contact Us section below. If so, we will make good faith efforts to make requested changes in our then active databases as soon as reasonably practicable (but we may retain prior information as business records).Please note that copies of information that you have updated, modified or deleted may remain viewable in cached and archived pages of the Services for a period of time.
Important Notice to Users Outside of the U.S.
If you are from a non-U.S. country, please be aware that the personal information you submit, including information provided through our Services, is being sent to a location in the United States. The data protection laws in the United States are likely different from those of the country in which you are located, and your personal information may be subject to access requests from governments, courts, or law enforcement in the United States according to laws of the United States. By providing such personal information through the Services, you are consenting to (and represent that you have authority to consent to), the transfer of such information to the United States for the uses and purposes described in this Policy. Without limiting the above, for the avoidance of doubt we do not have an establishment or target people in the EEA or UK.
Additional Information for California Residents
If you are a resident of California, you have additional rights under California law. Please review our California Consumer Privacy Act Privacy Policy here for more information about additional rights under California law.
Residents of California may also, under §1798.83, known as the “Shine The Light” law, request and obtain from us, once a year and free of charge, information about categories of personal information (if any) we disclosed to third parties for direct marketing purposes and the names and addresses of all third parties with which we shared personal information in the immediately preceding calendar year. If you are a California resident and would like to make such a request, please submit your request clearly in writing to us using the contact information provided below.
Communication Preferences
We may send periodic promotional emails to you. You may opt-out of promotional emails by following the opt-out instructions contained in the email. Please note that it may take up to 10 business days for us to process opt-out requests. If you opt-out of receiving promotional emails, we may still send you emails about your account or any services you have requested or received from us.
Children Under 13
Our Services are not designed for children under 13. If we discover that a child under 13 has provided us with personal information, we will delete such information from our systems. If you believe that we might have any personal information from or about a minor, please contact us at compliance@ltcglobal.com.
Contact Us
If you have questions about the privacy aspects of our Services or would like to make a complaint, please contact us at compliance@ltcglobal.com.
Changes to this Policy
This Policy is current as of the Effective Date set forth below. We may change this Policy from time to time, so please be sure to check back periodically. We will post any changes to this Policy on our Sites. If we make any changes to this Policy that materially affect our practices with regard to the personal information we have previously collected from you, we will endeavor to provide you with notice in advance of such change by highlighting the change on our Sites and/or emailing you at the email address we have for you.
EFFECTIVE DATE: January 1, 2023