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Privacy Policy

COTERIE DATA PRIVACY POLICY

Coterie Insurance Agency, LLC (“Coterie”, ”we”, ”us”, ”our”), inclusive of its parents, subsidiaries and affiliates, has published this “Privacy Policy” (or “Policy”) to detail our policies and procedures regarding the collection, use, and disclosure of personally identifiable information received in the course of our users and customers visiting and using our website(s) (the “Site”), our mobile application(s) (the “App”) and/or any other related services we offer. Within this Policy, we will be referring to the Site, the App and any other service offered by Coterie collectively as the “Service(s).”

This Privacy Policy applies to information that is provided to us when you use the Services. We reserve the right in our sole discretion to modify this Privacy Policy at any time.  We will post the most recent version of this Policy on this page of our Site. We encourage you to periodically review this page for the latest information on our privacy practices.

Feel free to email us, or contact us by mail:

Coterie Insurance Agency, LLC

Attn: Privacy Officer

7817 Cooper Road, Suite B

Cincinnati, Ohio 45242

[info@coterieinsurance.com]

1. Collecting PII and other Information

While using Coterie’s Services, We will ask you to provide us with specific personal identifying information in order to provide the Services, contact you, and to set up your personal account (“Personal Identifying Information” or “PII”). You can always refuse to disclose PII, but in doing so, you may limit our ability to successfully deliver the Services. PII may include, but is not limited to, your name, postal addresses, email addresses, telephone number, date of birth, social security number, marital status, family member information, employer and employment information, credit history, payment history, credit card number, and/or other billing information.  We may also collect information during your use of our App and our Site including operating system, your phone carrier, hardware you use, pages you viewed, your IP address, how often you use the Services, events that occur within the Site or the App during your use, aggregated usage information, performance data, the site and location from where you downloaded or otherwise accessed the Services, your browser type, your Internet service provider, the referring and exit pages, installed fonts, device IDs, language and time zone settings, and other information relating to your use of or access to the Services through the use of automatic data collection tools.

In connection with your initial insurance application or renewal of insurance to the extent permitted by law and with your consent, we may review your credit report or obtain or use a credit-based insurance score, based on information contained in your credit report. An insurance score uses information from your credit report to help predict how often you are likely to file claims and how expensive those claims will be. Typical items from a credit report that could affect a score include, but are not limited to, the following: payment history, number of revolving accounts, number of new accounts, the presence of collection accounts, bankruptcies and foreclosures. The information used to develop the insurance score comes from various credit reporting agencies.

2. Using PII

Coterie uses PII in a number of ways, including, but not limited to, the following: (i) to provide and improve aspects of the Services, including the products we offer and the service we provide in response to claims and other requests you may have; (ii) to improve the experience for all customers, including identifying, completing and expediting any problems, issues or requests customers may have related to our Services; (iii) to project, predict and understand customer usage and needs; (iv) to communicate with customers regarding product updates, announcements, changes, and other offerings from Coterie; (v) to facilitate auditing, prevent or investigate fraud, comply with requests from regulatory and law enforcement authorities, protect our rights, protect your safety, protect the safety of others, comply with applicable law, respond to subpoena or court order, and otherwise investigate, establish, exercise, and defend legal rights; and, (vi) 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.

3. Social Media

You may see various social media links on our Site (Facebook, Instagram, Twitter, LinkedIn, etc.). While we encourage our users to use these features, know that these features may collect PII, which will subsequently be hosted on these third-party sites or servers. As such, you will need to read and agree to each site’s respective privacy policy.  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 PII that is not expressly identified in this Policy.

4. Payment Processing

When you purchase our products by using our Services, we will collect personal information from you in order to process that payment. This information will likely include the items of PII listed above. 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 PII necessary to process your payment to our third party payment processor, and that payment processor will store and process your that PII.

5. Email

By using our Services, you have the opportunity to provide us with your contact information in order to receive periodic updates and newsletters about Coterie and its Services. We may use third-party communication software to send these emails and we may make your contact information available to our referral partners.  By using the Services, you agree to this disclosure, but have the ability to opt out of any such communications.

6. Children

As we do not provide our Services to anyone under the age of 13, we similarly do not collect PII from anyone under the age of 13.  If you are under the age of 13, please do not provide any PII to Coterie. Regardless of your age, please do not provide Coterie with any PII of any person under the age of 13.  If you are a parent or a guardian who has discovered that your child under age 13 has submitted his or her personally identifiable information to us without your permission or consent, we will make reasonable efforts to remove the information from our database, at your written request. To request the removal of your child’s information, please contact us as provided at the beginning of this Policy and include in your message your child’s name and the email address that your child submitted.

7. Security

We take the security of your PII very seriously, but no system is 100% secure. While we do our best to keep everything secure, we cannot guarantee the absolute security of your information. However, rest assured that we follow industry best practices when it comes to the transmission and submission of your data, and every member of our team who is responsible for handling data follows these practices.

8. Anonymous and De-identified Data

We may use third-party advertising services that collect non-personally identifying information using cookies and the other tools mentioned above. From your web browsing patterns and other non-specific, non-identifying information, we are better able to create targeted advertising campaigns. You may opt out of this data collection at any time by contacting us as provided at the beginning of this Policy, and include your name and email address.

Additionally, we may use aggregated, de-identified data to show larger trends in the use and delivery of our Services. No PII is ever disclosed in the process.

9. Analytics and Tracking

a. Cookies and Local Storage

Coterie actively collects information through the use of “cookies” and “local storage.” We use these to observe usage patterns and traffic on our Site, and subsequently link the appropriate cookies to your PII and account in order to optimize your customer experience. When visiting our site, your browser may alert you to our usage of cookies or local storage. You can always set your browser setting to limit their usage, however, it may limit the features of our Services.

b. Web Beacons

Another tracking technology that we employ is the Web Beacon (a.k.a. web bugs or clear gifs). These tools help us manage and observe our content, track email campaigns, and other communications, and optimize the way we present content. Like cookies, these tools can be linked to PII in order to provide better customization and specificity.

c. Log Data

Our servers automatically record certain information about how visitors interact with our Site - this is known as “Log Data.” Log Data is a broad category of data, but it can include, but is 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; and (vi) links clicked.

10. Disclosure of Your Information to Third Parties

Coterie does not sell any of its users’ Personal Identifying Information without express consent. PII will only be disclosed as expressly set forth in this Policy.

11. Third-Party Services

Coterie may use third-party platforms or services in order to deliver, maintain, or update Coterie’s Services and software. As such, Coterie may disclose PII to these third-party providers in order to maintain and continue the operation of Our Services.

12. Accessing and Managing Your Information

Every Coterie customer or account holder can request access to their PII.  You may request to review your PII by contacting us at any time as provided at the beginning of this Policy. If you believe that the information 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. We will be happy to make corrections whenever possible. Coterie reserves the right to archive or save data in order to comply with laws and regulations.

13. Your California Privacy Rights

We may collect customer information from persons other than the individual or individuals applying for coverage. Such customer information as well as other personal or privileged information subsequently collected may, in certain circumstances, be disclosed to third parties without your authorization as permitted by law. Residents of the State of California, under the California Civil Code, have the right to request from certain companies conducting business in California a list of all third parties to which the company has disclosed personal information during the preceding year for direct marketing purposes and a disclosure of the shared information. To make such a request, contact us as at the contact information provided at the beginning of this Policy.

If you are a California resident under age 18 who has registered an account with us, you may request the removal of the content you publicly posted on our Site or App. To request such removal, contact us at the contact information provided at the beginning of this Policy. Please include with your request your username and a clear statement that you would like us to remove the content you posted to the Site or the App. We may ask, and you will provide us with, additional details to remove such content. Your request does not ensure the complete or comprehensive removal of the content you posted. We are not required to remove content you posted if you fail to follow our instructions related to such removal or if (i) we are required by law to maintain the content; (ii)a third party stored, posted, republished, or reposted the content; or, (iii) we anonymize the content so that you cannot be individually identified by it.

14. Governing Law, Jurisdiction, Venue

The information collected from our Services is hosted in the United States. If you are using or accessing the Services from outside the United States or any other region with laws or regulations governing personal data collection, use and disclosure that differ from the United States laws, please be advised that through your use of the Services, which are governed by United States law, you are transferring information to and from the United States and you consent to that transfer.

The laws of the State of Ohio and applicable United States law govern all matters arising out of or relating to this Policy, including, without limitation, interpretation, construction, performance, and enforcement, without giving effect to such state’s conflicts of law principles or rules of construction concerning the drafter hereof. You hereby irrevocably and unconditionally submit to the jurisdiction of the federal and state courts venued in Hamilton County, Ohio for the purpose of any suit, action, or other proceeding arising out of or based upon this Policy, your access to or your use of the Services, which courts are the exclusive forum for any such suit, action, or other proceeding.

15. Assignment

The rights granted under this Policy are non-transferable and non-assignable by you, and such rights are not enforceable by anyone other than you, pursuant to applicable laws.  However, Coterie may transfer and/or assign any rights under this Policy without limitation and without notice or consent from you.

16. Acceptance of Policy

By using or accessing the Services, you acknowledge that you have reviewed and understand this Policy, and consent to the procedures identified in this Policy.  You accept and consent to the collection of PII, the retention of PII, the handling of PII, and potential disclosure of PII as identified in this Policy.

EFFECTIVE DATE: 3/8/2019