QQ Privacy Statement

Vertafore, Inc. ("Company" or "We") respects your privacy and is committed to protecting it through our compliance with this statement. This statement describes the types of information we may collect from you or that you may provide when you use Vertafore Solutions (the "Solution(s)").

This Privacy Statement is also a notice to California residents, to comply with the California Consumer Privacy Act of 2018 (CCPA) and any terms defined in the CCPA have the same meaning when used in this notice.

Please read this statement carefully to understand our policies and practices regarding your information and how we will treat it. When you use the Service, you consent to our collection, use and disclosure of information about you and your clients described below.

If you do not agree with our policies and practices, your choice is not to use our Solution. This statement may change from time to time. Your continued use of this Solution after we make changes is deemed to be acceptance of those changes, so please check the policy periodically for updates.

COLLECTION

(1) This statement applies to information we collect:

Where such collected Information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or device ("Personal Information").

In particular, the Solution has collected the following categories of Personal Information from its consumers within the last twelve (12) months:

Category Examples
Identifiers. A real name, alias, postal address, email address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, Social Security number, driver's license number, passport number, current or past job history, or other similar identifiers.
Commercial information. Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.
Usage. Information on the User's interaction with the Solution.
Geolocation data. Physical location, generally.
(2) Vertafore obtains the categories of Personal Information listed above from the following categories of sources: (3) This Statement does not apply to information collected by: (4) Information We Collect Through Automatic Data Collection Technologies

As you navigate through and interact with our Solution, we may use automatic data collection technologies to collect certain information about your equipment, browsing actions, and patterns, including:

The information we collect automatically may include Personal Information or we may maintain it or associate it with Personal Information we collect in other ways or receive from third parties. It helps us to improve our Solution and to deliver a better and more personalized service.

(5) The technologies we use for this automatic data collection may include:

USE OF YOUR INFORMATION

(1) How We Use Your Personal Information

We use information to provide the Solution functionality, fulfill your requests, improve the Solution quality, engage in research and analysis relating to the Solution, personalize your experience, track usage of the Solution, market the Solution, provide customer support, message you, back up our systems, allow for disaster recovery, enhance the security of the Solution, and comply with legal obligations. Even when we do not retain such information, it still must be transmitted to our servers initially and stored long enough to process.

We also use information that we collect about you or that you provide to us, including any Personal Information:

We may use or disclose the Personal Information we collect for one or more of the following business purposes:

Vertafore will not collect additional categories of Personal Information or use the Personal Information we collected for materially different, unrelated, or incompatible purposes without providing you notice.

(2) Sales of Personal Information

In the preceding twelve (12) months, Vertafore has not sold Personal Information it has received by and through the Solution to any third party. However, we have de-identified and aggregated certain information for both internal and commercial use.

(3) Sharing Personal Information

Vertafore may disclose your Personal Information to a third party for a business purpose or when they integrate with the Solution through the API. When we disclose Personal Information for a business purpose, we enter a contract that describes the purpose and requires the recipient to both keep that Personal Information confidential and not use it for any purpose except performing the contract. We contractually require these third parties to keep Personal Information confidential and use it only for the purposes for which we disclose it to them.

(4) We may also disclose your Personal Information: (5) Choices About How We Use and Disclose Your Information

We strive to provide you with choices regarding the Personal Information you provide to us. We have created mechanisms to provide you with the following control over your information:

YOUR RIGHTS AND CHOICES

Certain regulations (including the CCPA) provide individuals with specific rights regarding their Personal Information. This section describes your CCPA rights and explains how to exercise those rights.

(1) Access to Specific Information and Data Portability Rights

You have the right to request that Vertafore disclose certain information to you about our collection and use of your Personal Information over the past 12 months. Once we receive and confirm your verifiable consumer request we will disclose to you:

(2) Deletion Request Rights

You have the right to request that Vertafore delete any of your Personal Information that we collected from you and retained, subject to certain exceptions including regulatory data retention requirements. Once we receive and confirm your verifiable consumer request, we will delete (and direct our service providers to delete) your Personal Information from our records, unless an exception applies.

We may deny your deletion request if retaining the information is necessary for us or our service provider(s) to:

  1. Complete the transaction for which we collected the Personal Information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you.
  2. Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
  3. Debug products to identify and repair errors that impair existing intended functionality.
  4. Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
  5. Comply with a legal obligation.
  6. Make other internal and lawful uses of that information that are compatible with the context in which you provided it.
(3) Exercising Access, Data Portability, and Deletion Rights

To exercise the access, data portability, and deletion rights described above, please submit a verifiable consumer request to us through the Solution or your MyVertafore account.

Only you may make a verifiable consumer request related to your Personal Information. You may also make a verifiable consumer request on behalf of your minor child or as a user of the Solution with regards to Vertafore as your Service Provider (meaning at the request of an individual whose Personal Information you have provided to us in the normal course of and purpose for using the Solution).

You may only make a verifiable consumer request for access or data portability twice within a 12-month period. The verifiable consumer request must:

We cannot respond to your request or provide you with Personal Information if we cannot verify your identity or authority to make the request and confirm the Personal Information relates to you.

We do consider requests made through your password protected account sufficiently verified when the request relates to Personal Information associated with that specific account.

We will only use Personal Information provided in a verifiable consumer request to verify the requestor's identity or authority to make the request.

(4) Response Timing and Format

We endeavor to respond to a verifiable consumer request within sixty (60) days of its receipt. If we require more time (up to 90 days), we will inform you of the reason and extension period in writing.

If you have an account with us, we will deliver our written response to that account. If you do not have an account with us, we will deliver our written response by mail or electronically, at your option.

Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request's receipt. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your Personal Information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance.

We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.

DATA SECURITY

We have implemented measures designed to secure your Personal Information from accidental loss and from unauthorized access, use, alteration, and disclosure.

The safety and security of your information also depends on you. Where we have given you (or where you have chosen) a password for access to certain parts of our Solution, you are responsible for keeping this password confidential. We ask you not to share your password with anyone.

Unfortunately, the transmission of information via the internet is not completely secure. Although we do our best to protect your Personal Information, we cannot guarantee the security of your Personal Information transmitted to our Solution. Any transmission of Personal Information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on the Solution.

CHILDREN UNDER THE AGE OF 16

Our Solution is not intended for children under 16 years of age. No one under age 16 may provide any Personal Information to or in the Solution. We do not knowingly collect Personal Information from children under 16. If you are under 16, do not use or provide any information on this Solution or through any of its features, register on the Solution, or provide any information about yourself to us, including your name, address, telephone number, email address, or any screen name or user name you may use. If we learn we have collected or received Personal Information from a child under 16 without verification of parental consent, we will delete that information. If you believe we might have any information from or about a child under 16, please contact us through the helpdesk within the Solution.

CHANGES TO OUR PRIVACY POLICY

Vertafore reserves the right to amend this privacy notice at our discretion and at any time. When we make changes to this privacy statement, we will post the updated notice in the Solution and update the notice's effective date. Your continued use of our Solution following the posting of changes constitutes your acceptance of such changes.

Last Updated: June 15, 2019