Last Modified: December 16, 2025

Last Modified: December 16, 2025

1. Introduction

Coterie Applications Inc. and its subsidiaries and affiliates, including Coterie Insurance Agency, (collectively “Coterie,” “we,” “us,” or “our”) has issued this Privacy Policy to detail our policies and procedures, including over the past twelve (12) months, regarding the collection, use, and disclosure of Personal Information from or about our individuals who access and use our website, https://coterieinsurance.com/, and any other sites we control on which we may post this Policy (the “Website”), mobile application (the “App”) and/or any other related services we offer. Within this Policy, we will refer to the Website, App, and any other related services we offer collectively as the “Services.”

If you do not agree with this Privacy Policy, please do not use our Services.

Summary

Scope:
This policy applies to all individuals who use Coterie’s Services, including the website, mobile app, and related offerings. It covers agents, brokers, business owners, policy applicants, and policyholders, as well as information about the devices used to access our Services.

Personal Information Categories Collected:
Coterie collects various types of Personal Information, including:

  • Identifying information (e.g., business contact details, date of birth, Social Security Number, IP address, insurance policy number, billing information)
  • Commercial information (e.g., products/services purchased or considered)
  • Internet or electronic network activity (e.g., browser type, device IDs, usage data)
  • Geolocation data (e.g., city, state, zip code)

Personal Information Use and Sharing Practices:
Coterie uses Personal information, in part, to:

  • Provide and support Coterie’s Services
  • Personalize user experience
  • Analyze service usage and effectiveness
  • Communicate with users
  • Complete transactions and respond to requests
  • Assess insurance applications and renewals
  • Enforce policies and protect rights
  • Facilitate business transitions (e.g., mergers, acquisitions)
  • To market Coterie and other third-party services to you.

Coterie may share Personal Information with service providers or vendors that help us with our business and provide the Services to you, as well as third parties for contextual or interest-based advertising. Coterie may also disclose Personal Information to comply with law or protect rights. Coterie does not directly sell or share (as those terms are defined by law) Personal Information to advertisers without consent.

Privacy Choices:
Users may have rights to:

  • Access, update, or delete their Personal information
  • Opt-out of marketing communications and targeted advertising
  • Exercise applicable data subject rights (e.g., request deletion, correction, or a copy of data)
  • Appeal denied requests.

Contact Information:
Questions regarding privacy can be directed to Coterie by email at privacy@coterieinsurance.com or by mail at Coterie Applications, Inc.; Attn: Privacy Officer; 181 S. RiverHeath Way, Suite 1200; Appleton, WI 54915. Data Subject requests to exercise your rights should be submitted through our website Privacy Settings.

Full Policy:

The full Privacy Policy is available below.

Applicability of This Policy

This Policy applies to Personal Information we collect from or about you when you use our Services, including individuals who visit the Website and use the Services, such as agents, brokers, business owners, policy applicants, and policyholders. This Policy also governs information about the equipment used to access our Services.

For information about our privacy practices regarding claimants, applicants for employment, and employees, please visit:

Contact Us

You may contact Coterie by email at privacy@coterieinsurance.com or by mail at Coterie Applications, Inc.; Attn: Privacy Officer; 181 S. RiverHeath Way, Suite 1200; Appleton, WI 54915 with any privacy questions may have. To exercise any rights you have under applicable law to access, correct, delete, or restrict the use of your Personal Information (such rights are detailed below), please visit our website Privacy Settings to submit a Data Subject Request.

Changes to this Privacy Policy

Coterie reserves the right to change this Policy at any time. All changes will be posted on the Website and, in such event, Coterie will update the “Last Modified” date above. Please be sure to review any changes made to the Privacy Policy by occasionally checking our Website for updates. Your continued use of the Website and Services will constitute your agreement to any such updates.

We will provide notice of any material changes to the Policy as required by law. All changes will be effective upon posting of the updated Privacy Policy on our Website. If you object to any change, please stop using the Services.

2. Collection of Personal Information

As you access and use the Services, we may collect your Personal Information. “Personal Information” is information that identifies, relates to, describes, or is reasonably capable of being associated with a particular person. Personal information does not include information that is publicly available or de-identified.

You may always choose not to share your Personal Information with us. Please note, however, that if you choose not to share required Personal Information, then, respectively, you may not be able to use some of our Services, including applying for a policy. We indicate which information is required depending on the service through which you are engaging, such as through our policy applications, website banners, contracts, etc. If you have questions about what Personal Information may be required to use our Services, please contact us at privacy@coterieinsurance.com.

What Categories of Information Do We Collect?

We collect the following information:

  1. Identifying Information. Such as business contact name, business postal address, business email address, business telephone number, IP address, credit card number, and billing information. Note that we do not retain your credit card information.
  2. Commercial Information. This includes products or services you have purchased, obtained, or considered, such as commercial insurance policies and quotes.
  3. Internet or other electronic network activity information. This includes your browser type, Internet service provider, the referring and exit pages to and from our Website, installed fonts, device IDs, language and time zone setting, and other information relating to your equipment and use of or access to the Services.
  4. Geolocation data. Such as your imprecise location through your city and state or zip code.

How do we Collect Information?

We collect information in the following ways:

The Website and Services

We collect information when you (i) complete information requests, contact us, or quote forms, (ii) buy or download products or services, (iii) use the Services, or (iv) interact with us on or through the Website or the Services, including the Website’s online chat function.

Cookies and Other Automatic Data Collection Technologies

Coterie and certain third parties may use various tracking technologies such as cookies, web beacons, or other similar technologies to collect information relating to the use of the Website or the Services. Use of certain tracking technologies and Personal Information are essential to provide our Services.

Cookies are small files that we may transfer to your equipment’s hard drive or to your web browser’s memory to enable our systems to recognize your browser and to provide convenience and other features to you. We may also use cookies to provide additional features or functionality to your experience when you use our Services, for example, storing your preferences and other information about you when you use the Website. There are three (3) categories of cookies we use: essential/strictly necessary, analytics, and marketing.

  • Essential/strictly necessary cookies: These cookies are necessary for the functionality of our Website and Services.
  • Analytics cookies: These cookies collect data to help us monitor and analyze website performance, such as visitor traffic and engagement metrics. Analytics cookies do not track user behavior across different websites and are not required for the website to function.
  • Marketing cookies: These cookies are used to track user behavior across different websites and may be used to deliver targeted advertising to you. Marketing cookies are not necessary for the website to function.

You may block or limit the storage of cookies via browser controls or other software. You may also delete cookies manually from your device through your internet browser, operating system, or other programs you use to access the Services. For additional information on how you may manage cookies, in addition to the cookie management banner available on our Website, please see Your Rights and Choices below. Even if you have opted-in (consented) to accepting non-essential cookies, you may always opt-out (revoke your consent). Such revocation of your consent will be effective on the date you do so and apply to our activities involving your Personal Information moving forward.

Please note that some portions of our Services may not function properly or be available if you block or delete certain cookies.

Web Beacons or Clear Gifs

Web beacons (also known as web bugs, clear GIFs, or pixel tags) are tiny graphics with a unique identifier, similar in function to cookies, and may be used to track the online movements of users, when an email has been opened, or to provide other information. In contrast to cookies, which are stored on a user’s computer hard drive, clear gifs are embedded invisibly on web pages. These technologies help us better manage content on the Website and in the Services by informing us what content is effective.

Log Data

Our servers record certain information about how visitors interact with our Site – this is known as “Log Data.” Log Data is a broad category of data, including, but not limited to: (i) browser type; (ii) operating system; (iii) Internet Protocol address; (iv) pages viewed and duration of viewing; (v) features and functionalities used; or (vi) links clicked. We may use this information to analyze trends, administer the Website and the Services, and track visitors’ movements around the Website and the Services.

Minors’ Information

Our Services are not intended for individuals under 18 years of age. We do not knowingly collect, sell, or share (as those terms are defined by applicable law) the Personal Information of any individual under 18 under this Policy. If you are under 18, do not use or provide any information to us. If you believe we may have any information from or about an individual under 18, please contact us using the contact information provided in the Contact Us section above

3. How We Use Personal Information

For What Purposes Do We Use Personal Information?

We may use Personal Information for our business purposes including:

  • To provide the Website, App, other Services, and related support services.
  • To personalize your user experience and tailor our interactions with you.
  • To analyze usage and effectiveness of the Website, the Services, and other services, products, and offerings.
  • To communicate with you about the Website, the Services, and/or other products, services, or offerings.
  • To complete your transactions or purchases or respond to your requests to us.
  • To provide you with a quote and/or assess your initial application for insurance or renewal, such as to help predict how often you are likely to file claims and how expensive those claims may be.
  • To use for any purpose permitted by law, disclosed to you at the time of collection, or with your consent.
  • To enforce our Terms of Service, this Policy, or other applicable policies or agreements with you.
  • To protect the rights, property, or safety of our business, employees, customers, or others, including for cybersecurity, fraud protection, and credit risk reduction.
  • To facilitate a merger, acquisition, bankruptcy, dissolution, reorganization, sale of some or all of our assets, financing, acquisition of all or a portion of our business, a similar transaction or proceeding, or steps in contemplation of such activities (e.g., due diligence) and/or to facilitate any other activity in connection with the creation, development, offering, provision, or servicing of our products and Services.

We may also anonymize or de-identify Personal Information in our possession so that it cannot be linked to a person. We may use such information for any purpose.

Disclosure of Information

We may share your Personal Information with the following categories of service providers, contractors, and third parties for the following purposes.

Service Providers and Contractors

Coterie uses service providers, contractors, and vendors to help maintain and deliver our Services to our customers and to support our business operations. For instance, we may use service providers to help us provide customer support, email and text message deployment, research and analytics, marketing and advertising services, data processing, management, fraud prevention, transaction and payment processing, and survey administration.

Third Parties

We may also disclose your Personal Information to our third-party marketing partner(s) who provide services on our behalf and who may also use the information we provide for their own commercial purposes. For example, some of our advertising partners may use information to market other parties’ products and services to you. For more information see Interest-based advertising.

In the twelve (12) months prior to the Last Modified Date of this Policy, we may have sold or shared as those terms are defined by applicable law, Personal Information with third parties. As of the date of this Policy, Coterie only shares or sells Personal Information with third parties with your consent.

Contextual Advertising Interest-Based Advertising

Coterie may use third-party advertisers to serve or present ads on our Website related to the Services you are seeking (contextual advertising). This type of advertising does not use or require the collection of Personal Information.

Additionally, other advertisers may use Personal Information about you and your visits to the Website and other sites to provide advertisements on the Website and other sites about goods and services that may be of interest to you (interest-based advertising). Such third-party advertisers may use cookies, clear gifs, or other similar technology to track your online activities over time and across different websites and other online services.

As of the Last Modified Date of this Policy, we do not directly sell or share (as those terms are defined by applicable law) Personal Information to advertisers without your consent.

Some of the advertisers we use may be members of the Network Advertising Initiative (NAI). Individuals may opt-out of targeted advertising delivered by NAI member ad networks by visiting www.networkadvertising.org. We may also use advertising networks that are members of the Digital Advertising Alliance. Such advertisements can be identified by the DAA icon. You can click on the DAA icon in the advertisements themselves to manage your preferences.

Finally, please note that certain technologies may offer the option of providing notice to websites that you do not wish for your online activities and Personal Information to be tracked for interest-based advertising purposes (Global Privacy Control Notice or universal opt out mechanisms). Should we engage in the sale or sharing (as those terms are defined by applicable law) of Personal Information for targeted advertising, we will respond to and abide by the signals sent through universal opt out mechanisms that are consistent with applicable law.

Required Disclosures

We may disclose your Personal Information if required by law or if such use or disclosure is necessary to protect Coterie’s or Coterie’s business partners’ rights, protect your safety or the safety of others, investigate fraud, or comply with law, a court order, or legal process. In addition, we may disclose, remove, or change information you provide about third parties if properly instructed by the individual who is the subject of such information.

Further, if Coterie goes through a business transition, such as a merger, acquisition, change in control, or sale of all or a portion of its assets, Coterie may disclose, sell, transfer, or assign its rights to the Personal Information in our possession as part of such business transition.

Google Analytics

We also use Google Analytics to analyze use of our Services, consistent with your data subject rights. For more information about how Google uses information from sites or apps that use its services, please visit https://policies.google.com/technologies/partner-sites.

Social Media and Third-Party Sites

You may see various social media links on our Site and through our Services (Facebook, Instagram, Twitter, LinkedIn, etc.). While we encourage our users to use these features, please know that these features may directly collect your Personal Information, which may subsequently be used and maintained hosted by such third-party sites. As such, you should review each site’s respective privacy policy before sharing any Personal Information. You understand, acknowledge, and agree that Coterie does not have any responsibility or authority with respect to any third party’s collection or use of Personal Information that is not expressly identified in this Policy.

4. Security

The security of your Personal Information is very important to us. We use appropriate physical, electronic, and administrative safeguards designed to protect your Personal Information from loss, misuse, and unauthorized access, use, alteration, or disclosure. Additionally, we only retain your Personal Information for as long as reasonably necessary to fulfill the purposes for which we collect it or as permitted or required by law.

We will enhance and update our physical, electronic, and administrative safeguards as necessary. However, the Internet environment is not 100% secure, and we cannot guarantee that information we collect will never be accessed in an unauthorized way.

Retention

We will retain and use your Personal information only for the period necessary for the purposes for which we collect it and as permitted by law, including to comply with our legal obligations, resolve disputes, or enforce our agreements unless a longer retention period is permitted or required by law. Following the expiration of the retention period, Personal Information will be deleted. Therefore, any data subject rights (described below) you may have cannot be exercised after the expiration of the retention period.

5. Your Rights and Choices

Marketing Information

As noted, we may use your Personal Information to send you communications to promote or recommend our own products and Services, or third parties’ products or services. You may opt-out of receiving such communications by replying to any promotional email we have sent you or following the opt-out links on that message. Such opt-out request will not apply to information provided to us and communications sent by us to complete a purchase or to provide the requested service or other service-based transaction, such as policy servicing, for example.

Accessing, Updating, and Deleting Your Information

Coterie customers or account holders can request access to their Personal Information. You may request to review your Personal Information by contacting us as provided at the beginning of this Policy at any time. If you believe that the information we maintain about you is incomplete or inaccurate, you can request that we correct it. We may not, however, be able to provide information relating to investigations, claims, litigation, or other matters and may deny your request consistent with applicable law. We will be happy to make corrections whenever possible, consistent with applicable law. To exercise your rights, please visit our website Privacy Settings.

Cookies and Other Automatic Data Collection Technologies.

Please see Cookies and Other Automatic Data Collection Technologies above for information on how to manage these technologies.

Interest-Based Advertising.

Please see Contextual Advertising and Interest-Based Advertising above for information on how to opt-out of interest-based advertising.

Data Subject Access Rights.

Depending on in which state you are resident, you may have the following rights related to your Personal Information. These rights include:

  • The right to know what Personal Information we process about you.
  • The right to request certain Personal Information that we process about you be deleted.
  • The right to request we correct Personal Information we have about you which you believe is incorrect.
  • The right to have certain Personal Information we process about you returned to you in an accessible and useable format upon your request, if such request is technically feasible.
  • The right to opt-out of having your Personal Information processed in such a way that enables us to create a profile of inferences about you or for targeted advertising purposes.
  • The right to limit the use of your Sensitive Personal Information.
  • The right to opt-out of the sale of your Personal Information.
  • The right to opt-out of any profiling in furtherance of decisions that produce legal or similarly significant effects.
  • The right to exercise your data subject rights free from discriminatory treatment, including if you are an employee, applicant, or independent contractor, the right against employment-related retaliation for exercising your data subject rights.

California Residents.

If you are a California resident, you may have additional personal rights and choices regarding your Personal Information. For example, California’s “Shine the Light” law (Civil Code Section § 1798.83) permits users of our website that are California residents to request certain information regarding our disclosure of personal data to third parties for their direct marketing purposes.

Exercising Your Data Subject Rights

To exercise your applicable data subject rights, please submit a request using the contact information provided in the Contact Us section above.

Verification of Data Subject Rights Requests

We may require that your identity be verified prior to processing verifiable rights requests. If your request requires verification, we will verify your identity by comparing the information we have about you against the information we receive when you submit your request. If we do not have enough information to verify your identity, we may request additional information from you, consistent with applicable law. We may deny a rights request if we are unable to verify your identity.

Authorized Agents

Some states permit their residents to designate an authorized agent to submit requests to exercise certain data subject rights on the individual’s behalf. Even if you use an authorized agent to submit a request on your behalf, pursuant to applicable law, we may still require that you verify your identity depending on the nature of the request and sensitivity of the information at issue.

If you are an authorized agent submitting a request on behalf of an individual, please submit a request using the contact information provided in the Contact Us section above. You must include a copy of the written, signed permission indicating that you are permitted to act on that person’s behalf.

Appealing a Denied Data Subject Rights Request

In some circumstances, we may deny your request to exercise one or more of the rights described above. If you disagree with our decision to deny your request or any portion of your request, you may appeal our decision within sixty (60) days of receipt of notice that your request has been denied. If you submit an appeal to a denied request more than sixty (60) days after you have been notified of our decision to deny the request, we may deny your appeal. If you submit a timely appeal, we will respond within forty-five (45) days of our receipt of your appeal.

If you wish to appeal a decision, please clearly and plainly describe your disagreement with our decision by responding through the same means by which we communicated our decision or by submitting your appeal using the information provided in the Contact Us section above. We will review your appeal and either amend or uphold our decision. In either case, we will provide a written explanation of the reason for the decision. This decision will be final.

6. Payment and Commissions Processing

When you purchase our products by using our Services, we will collect Personal information from you to process that payment. While we do not store your payment info (except for the last four (4) digits of your credit card which we may store for verification), we will provide the Personal Information necessary to process your payment to our third-party payment processor, and that payment processor may store and process that Personal Information.

Further, we may pay Commissions to certain agents through a third-party processor using ACH information. While we do not store ACH information, we will provide the Personal Information necessary to process payment of your Commission through our third-party processor, and that processor may store and process that Personal Information.

7. Carrier Privacy Policy Additional Information