Privacy Policy

This privacy policy applies to First Connect Insurance Services, LLC (“First Connect,” “we,” “our” and “us”). This privacy policy applies to information collected through ourwebsites, and API applications, and any of our other online products and services that display or link to this privacy policy, information collected through our call center agents and service representatives, information collected offline, and information obtained from third parties (collectively “Services”).

This privacy policy describes the information we collect about you, how we use this information and the choices you have regarding such use, and other important information regarding our privacy practices. If you have any questions or comments about this privacy policy or the ways in which First Connect uses the information we collect about you, please contact us using the information provided in the contact section below.

Please note the First Connect Consumer Privacy Notice applies to information that we collect about individuals who seek, apply for, or obtain our insurance and non-insurance products or services for personal, family or household purposes, whether that information comes through our Services or any other means. The information contained in this privacy policy is not intended to amend, replace, contradict, change, or otherwise affect the policies outlined in the First Connect Consumer Privacy Notice. Please read the First Connect Consumer Privacy Notice for information about your rights with respect to the information collected in connection with seeking, applying for, or obtaining insurance products or services from us. If you are a California consumer, you may find the California Financial Information Privacy Act Notice after our Consumer Privacy Notice.

Before engaging with us, submitting information to us, or buying or using our Services, please review this privacy policy carefully.

You may print or download a pdf version of this privacy policy.

Table of Contents

1. We May Collect Your Information When You Use Our Services, When You Apply for Products, From Third Parties, or Automatically
2. We May Collect Information You Provide Us When You Use Our Services
3. We May Collect Your Information When You Apply for or Use Our Services
4. We May Collect Your Personal Information From Third Parties
5. We May Collect Information Automatically From Your Use of Our Services
6. We May Use Your Information to Provide You With Our Services
7. We May Retain Your Information for Our Business Purposes
8. We May Share Your Information to Provide You With Our Services
9. We May Share Personal Information for Marketing Purposes
10. You Can Manage Your Browser Cookies
11. We May Use Analytics Services Provided by Others
12. We May Use Advertising Services Provided by Others
13. You May Opt Out of Interest-Based Advertising
14. We Do Not Respond to Do Not Track Signals
15. We May Provide Links to Other Companies
16. We May Record Calls to Our Call Centers and In-House Agents
17. You May Withdraw Consent for Sharing
18. You May Unsubscribe From Our Marketing Communications
19. We Encourage Caution in Posting Information Publicly
20. We Take Measures to Protect Your Personal information
21. Our Services Are Not Intended for Minors
22. We Provide You With Additional Disclosures Relating to Various State Privacy Laws
23. You May Have Additional Rights Under Various State Privacy laws
24. Victims of Domestic Violence May Have Confidentiality rights
25. We Are Based in the United States
26. We May Change This Privacy Policy
27. First Connect Provides You With a Consumer Privacy Notice
28. First Connect Provides You With a California Financial Information Privacy Act Notice
29. You May Contact Us

We May Collect Your Information When You Use Our Services, When You Apply for Products, From Third Parties, or Automatically

We may collect information from you in various ways, including the following:

• We collect information you provide us when you use our Services;
• We collect information when you apply for or use our Services;
• We collect information from third parties, such as our service providers, data providers, or partners; and
• We collect information automatically.

We May Collect Information You Provide Us When You Use Our Services

When you use our Services, we may collect the information you provide us, for example, when you:

• Ask a question;
• Email us or modify your account;
• Conduct transactions;
• Apply for Services;
• Request access or quote;
• Begin or complete a form;
• Contact customer support;
• Use tools and calculators;
• Respond to a survey;
• Earn any incentives or rewards;
• Provide feedback or a complaint; or
• Apply for a job.

We May Collect Your Information When You Apply for or Use Our Services

We may collect information when you apply for or use our Services, including:

• Name, email address, postal address, or residential property address;
• Social security number or federal employer identification number;
• Insurance information and identification numbers;
• Account username and password and related security questions;
• Date of birth;
• Your signature and phone number;
• Payment card information, financial account information, or insurance policy information;
• Age and gender;
• Records of Services requested or purchased; and
• Other information you provide to us.

Some forms on our Services may require that you provide certain information to submit the form. You may choose not to provide information in those cases, but this may prevent you from being able to access or use certain features of our Services.

We May Collect Your Personal Information From Third Parties

We may collect personal information about you from third parties. In some instances, we may combine the personal information we collect about you from third parties with personal information we collect from you. For example, we may collect personal information about you from third parties in order for us to provide you with our Services. We also may obtain personal information about you from consumer reporting agencies or insurance support organizations as well as from commercially available sources such as data aggregators and public databases. Depending on your relationship with us, this personal information we collect from third parties may include:

• Name, email address, postal address, or residential property address;
• Demographic information;
• Information we obtain when you connect to First Connect through social media; or
• Information relating to your insurance license and any regulatory history related thereto.
• We may also receive information about you from public databases or third parties from whom we have obtained data, among other sources. We may combine this information with other information we have about you.

We may also use the personal information that we collect from you and about you to draw inferences, such as information regarding your preferences or habits.

We May Collect Information Automatically From Your Use of Our Services

We may collect information automatically using cookies and similar online technologies or when you use our Services, send us an email, or interact with our emails or advertisements. The information we may collect automatically using these technologies or methods may include:

• Internet protocol address;
• Device and advertising identifier;
• Browser type and language;
• Operating system;
• Date and time stamp;
• Session ID;
• Internet service provider;
• Data regarding network-connected hardware;
• Pages visited;
• Internet protocol address geolocation or other location information;
• Click or touch stream data, movement, scroll, and in some cases, keystroke activity; and
• Third-party sites or services you were using before interacting with our Services.

We use this automatically-collected information to:

• Conduct analyses about our Services;
• Associate the different devices you use;
• Remember your browser or device;
• Remember your preferences and interactions;
• Deliver relevant advertisements or other content;
• Market our Services to you;
• Collect information about our Services; and
• Log activity on our Services.

We may use these technologies for providing our Services, security, authentication, analytics, product or service improvement, advertising, fraud detection, and for other similar purposes.

We may use local storage or similar technologies to store content information or preferences or to display advertising.

We May Use Your Information to Provide You With Our Services

We may use your information in a variety of ways, including to:

• Create, maintain, and customize your account or membership;
• Service your policy or account;
• Permit our network of third-party providers to provide you with Services including, but not limited to, Services requested by you;
• Respond to your requests, questions, or comments;
• Administer and satisfy incentives and rewards programs;
• Process payments and prevent transactional fraud;
• Communicate with you and others;
• Provide you with customized content, targeted offers, and advertising;
• Provide you with information, newsletters, and promotional materials;
• Promote customer reviews and testimonials in marketing and advertising material;
• Develop new Services;
• Improve our existing Services;
• Address problems and review the usage and operations of our Services or business;
• Improve our Services, content, products, and offerings;
• Protect the security and integrity of our Services and our business, including to detect fraud or illegal activities;
• Enforce our terms of use and other applicable policies;
• Protect and defend our rights and property or the rights of third parties;
• Conduct research studies;
• Evaluate usage patterns and advertisement interactions with our Services; and
• As otherwise described to you at the point of collection.

If you provided your information for a job application, we may use that information for human resources, job placement, qualification, or other related purposes.

We May Retain Your Information for Our Business Purposes

We may retain and use your information in accordance with our records retention schedule, as required or permitted by law, to comply with our legal obligations, to resolve disputes, and to enforce our agreements. We also retain your information as needed to provide Services to you and while you maintain an account with us.

We May Share Your Information to Provide You With Our Services

In addition to sharing your information as described at time of collection, we may share your information with the following persons or entities or in the following circumstances, among others:

• When we have your consent or at your direction;
• To perform or provide the Services you requested;
• With a parent, subsidiary, or affiliate entity within the First Connect corporate family, as permitted by law;
• With third parties that play a role in transactions such as insurance companies, payment vendors, contractors, investigators, attorneys andother third parties who provide services relating to a service that we offer;
• With participating reinsurance companies and regulators;
• With our vendors, as needed to perform their functions for us;
• With third parties to provide you with a product or service, as permitted by law;
• With consumer reporting agencies;
• With legal entities, if required by law, or a regulatory authority or at the request of governmental, law enforcement, or regulatory authorities;
• When we believe such sharing is necessary, such as to protect the rights, property, life, security, or safety of First Connect or others; and
• In the case of a corporate transaction, such as a merger, acquisition, or divestiture.

We may also maintain aggregate data or other deidentified information about you, such as usage statistics, online traffic patterns and user feedback. This aggregated or deidentified information is not personal information. In addition to using this information for the purposes discussed in this privacy statement, we may disclose this aggregated or other deidentified information to third parties without restriction.

We May Share Personal Information for Marketing Purposes

For our financial products, we may share your personal information with affiliates for marketing purposes. You may ask us not to share your personal information with our affiliates to market new products to you. For our non-financial products, we may share your information with affiliates, non-affiliates, and our business partners to market new products to you. Please remember that we offer many different products and services. You may not want to opt out if you would like to learn about these products directly from one of these companies. If you choose to opt out of this sharing, please call us at 1-877-287-6055.

You Can Manage Your Browser Cookies

Most internet browsers allow you to block, manage, or delete cookies or local storage through the privacy features of your browser. Please refer to the help section of your browser or mobile device for additional information. Your browser may also offer add-ons, plugins, or extensions to manage local storage objects, scripts, or similar technologies mentioned in our privacy policy. Please note that if you block cookies or similar technologies, you may not be able to use the full functionality of our Services. For further information about cookies and similar technologies, including how to manage and delete cookies on your device, you can visit All About Cookies.

We May Use Analytics Services Provided by Others

Our Services may use Google Analytics, Google Audiences, LinkedIn Analytics, Facebook Connect, Heap, Full Story, Pingdom, and others for audience measurement and analytics purposes. These analytics services may use cookies or similar technologies to collect information to help us analyze users and how they use our Services. The information collected by these technologies is used to assess how often you visit our Services, what pages you view when you visit our Services and what other websites you visited before coming to our Services. Information generated by these services may be transmitted to and stored by these providers and they may use this information for purposes such as evaluating your use of our Services, compiling statistics reports on the website’s activity, and providing other services relating to website activity and other internet usage.

You may review Google’s data privacy practices for Google Analytics and data privacy practices for Google Tag Manager. You may also review Google’s Privacy Policy and Terms of Service for more information. To opt out of being tracked by Google Analytics, you may download and install the Google Analytics Opt-out Browser Add-on.

We may use Google reCAPTCHA on our Services, which checks whether our Services are being used by humans or bots. reCAPTCHA analyzes website visitor behavior based on various characteristics, including mouse movements, visit duration, IP address, and other information.

We May Use Advertising Services Provided by Others

Our Services may use service providers and partners to serve advertisements on our behalf on our Services and across the internet, and to track and report on the performance of those advertisements. These service providers may include Google Adwords, LinkedIn Ads, and others. These entities may use cookies or similar technologies to identify your device when you use our Services and interact with our electronic communications and ads, as well as when you visit other online services. Data collected and maintained by such third-party ad providers will be subject to the terms of use and privacy policies of those providers. You may learn more about online interest-based advertising by visiting this Federal Trade Commission website.

You May Opt Out of Interest-Based Advertising

We work with advertising companies to provide you with advertisements that are intended to be in line with your interests. This is often referred to as interest-based advertising. First Connect may use cookies or similar technologies for such advertising. We share this information with our service providers to manage our online advertising.

You may opt out of receiving interest-based advertisements by calling us at 1-877-287-6055. You may also opt out of receiving interest-based advertisements from third-party advertisers and ad networks who are members of the Network Advertising Initiative (NAI) by visiting the NAI website. You may opt out of receiving interest-based advertisements from other companies that perform interest-based advertising services who are members of the Digital Advertising Alliance (DAA) by visiting the DAA website.

The use of your personal information for behavioral advertising purposes may be considered to be a “sale” or “sharing” of personal information under applicable laws. You may opt out that sale or sharing of your personal information by managing your cookies or using our cookie banner.

Please note that when using the ad industry opt-out tools described above, you may need to execute opt-outs for each browser or device that you use. Opting out of interest-based advertising does not mean you will no longer see advertising online, but it does mean that the companies from which you opt out will no longer show ads that have been tailored to your interests. If you use industry opt-out tools, your opt out will only apply to companies who are participating in those industry organization tools.

For your mobile device, you can opt out of online interest-based advertising by using “Limit Ad Tracking,” “Opt out of Ads Personalization,” or a similar feature.

You may continue to see generic or non-targeted advertisements after opting out.

We Do Not Respond to Do Not Track Signals

Our Services do not currently respond to Do Not Track signals. To learn more about Do Not Track signals, you may visit the Future of Privacy Forum’s website for additional information.

We May Provide Links to Other Companies

Our Services, other materials, and products may contain references or links to third-party websites and services, including references and links to third parties that accept and process your payments to us. We are not responsible for any third party’s data collection or privacy practices, and we have no control over what information third parties track or collect. Any access to and use of such linked websites is not governed by this privacy policy but instead is governed by the privacy policies of those third-party websites. We encourage you to review the privacy policies posted on those third-party websites for further information.

We May Record Calls to Our Call Centers and In-House Agents

We may record or monitor our conversations with you if you call our customer service centers or if our customer service centers or agents call you. We may use these recordings for business records, training, quality assurance, fraud prevention, and other business purposes. We may use your voiceprint for verification or anti-fraud purposes when you call our call centers or in-house agents.

You May Withdraw Consent for Sharing

As a First Connect customer, you may choose to opt out of the sharing of your personal information. Please refer to the First Connect Consumer Privacy Notice at the end of this policy to do so.

You May Unsubscribe From Our Marketing Communications

If you no longer wish to receive marketing emails and other marketing communications from us, you may unsubscribe at any time by clicking the “unsubscribe” link in the promotional emails sent to you or by contacting us using the information below in the contact section. Please note that even if you opt out of receiving promotional emails from us, we may continue to send you transactional emails.

We Encourage Caution in Posting Information Publicly

Our Services may permit you to post or submit content publicly. If you choose to submit content containing personal information to any public area of our Services, your content will be accessible by anyone, including us. We encourage you to exercise caution when making decisions about what you disclose publicly.

We Take Measures to Protect Your Personal Information

We may take reasonable measures designed to secure your personal information. However, we cannot guarantee that your personal information will not be lost, accessed without authorization, disclosed, altered, or destroyed. Any information you provide to us is at your own risk.

Our Services Are Not Intended for Minors

Our Services are not intended for children under the age of 13. We do not knowingly collect any personal information from anyone under the age of 13. You must be 18 years of age or older to submit any information to us.

We Provide You With Additional Disclosures Relating to Various State Privacy Laws

You may have additional privacy rights that we describe in further detail below.

Various state comprehensive privacy laws give individuals the right to know what personal information is collected about them, including whether it is being sold or disclosed to third parties. These state privacy laws also grant these individuals certain rights and prevent companies from retaliating against consumers for exercising those rights. This notice applies to all activities of First Connect, including those activities that occur online and offline.

The types of personal information we have collected or disclosed in the last twelve (12) months or beyond depend on your relationship with First Connect. If the nature of your relationship with First Connect changes, an additional data privacy notice may apply.

The personal information that First Connect collects about you may include the following categories of personal information:

1. Identifiers, such as real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, driver’s license number, passport number, or other similar identifiers;
2. Personal information described in California Civil Code Section 1798.80(e), such as signature, physical characteristics or description, telephone number, insurance policy number, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information;
3. Characteristics of protected classifications under California or federal law, such as race, gender, physical or mental disability, and religion;
4. Commercial information, such as records of personal property, Services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies;
5. Biometric information, such as your voiceprint when you call our call centers;
6. Internet or other electronic network activity information, such as browsing history, search history, and information regarding a consumer’s interaction with an internet website, application, or advertisement;
7. Geolocation data, such as information used to identify your physical location, including geolocation data collected in connection with your use of our Services;
8. Audio, electronic, visual, thermal, olfactory, or similar information;
9. Professional or employment-related information, such as information collected from job applications and resumes;
10. Education information, such as information collected from job applications, transcripts, or resumes;
11. Inferences, such as those drawn from any of the information First Connect collects to create a profile about a consumer reflecting the consumer’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes; and
12. Sensitive personal information, such as driver’s license number, passport number, account log-in, financial account, debit card, or credit card number in combination with any required security or access code, password, or credentials allowing access to an account, precise geolocation, racial or ethnic origin, religious beliefs, mental or physical health condition or diagnosis, sex life or sexual orientation, or citizenship or immigration status.

For all categories of personal information, we may collect data directly from you, from third parties, including those to whom you have previously provided data, and from our service providers.

We collect and use personal information for business or commercial purposes. For all categories of personal information, these purposes may include auditing; detecting security incidents; protecting against and prosecuting illegal activity (such as fraud); ensuring the physical safety of individuals; debugging, short-term transient use of personal information; performing services on behalf of First Connect, such as maintaining or servicing accounts, providing customer service, processing or fulfilling orders and transactions, verifying customer information, processing payments, providing analytic services, providing storage, or providing similar services on behalf of First Connect; providing advertising and marketing services; undertaking internal technological research; verifying or maintaining the quality or safety of a service or device; improving a service or device; monitoring and improving our Services’ functionality; and personalizing your Services experience. We combine the data that we collect in order to provide these functions.

We also collect and use personal information to comply with our legal obligations, resolve disputes, enforce our agreements, and for everyday servicing purposes.

For all categories of personal information, we may disclose your personal information to third parties in the event First Connect is involved in a merger, acquisition, or sale or transfer of all or part of its assets. We may also disclose all categories of personal information with our affiliates and subsidiaries. First Connect may be required to disclose your personal information to law enforcement, regulatory agencies, or litigants based on enforceable requests for this information. We may also need to disclose information based on fraud protection, credit risk reduction, or other legal purposes.

Please note that for all categories of personal information, we may also disclose your personal information to our service providers, partners, or collaborators we work with in the course of our business, agents or other insurance producers, any entity you instruct us to disclose your personal information to, and others.

First Connect retains personal information in accordance with our legal obligations, to defend against claims, or in compliance with our data retention policies and procedures. Also, we may retain your personal information in our backup or archived systems until the retention period of those systems expires.

You May Have Additional Rights Under Various State Privacy Laws

You may have the following rights with respect to your personal information:

• The right to a notice about our collection, use, disclosure, sale, or sharing of personal information about you. This statement is intended to satisfy this right.
• The right to request access to the personal information, including the specific pieces of personal information that First Connect has about you and personal information about any automated-decision making concerning you made by First Connect.
• The right to request that First Connect correct or amend your personal information.
• The right to request that we delete the personal information we have about you. We may not be required to delete personal information under particular circumstances.
• The right to opt out of the sale or sharing of your personal information. The use of your personal information for behavioral advertising purposes may be considered to be a “sale” or “sharing” of personal information under applicable laws. You may opt out that sale or sharing of your personal information by managing your cookies or using our cookie banner.
• The right to ask us to limit our use of your sensitive personal information.
• The right to obtain a copy of your personal information in an easily understandable and portable format that you may also request be transmitted to another entity.
• The right to appeal First Connect’s denial of your request to exercise a right herein.
• The right to opt out with respect to First Connect’s use of automated decision-making technology, including profiling.
• The right to be free from retaliation for exercising these rights. We may, however, offer you incentives in return for your data. When you exercise your rights, you may lose access to these incentives, which can include discounts, coupons, or additional services.
• The right to use an authorized agent to submit a request on your behalf.
• The right to request a statement be placed in your file for others accessing your file if you disagree with First Connect’s refusal to correct, amend, or delete your personal information with a concise statement of what you think is correct, relevant, or fair information and the reasons you disagree with First Connect’s refusal to correct, amend, or deleted recorded personal information.

You may call us at 1-877-287-6055, email us at agentsupport@fcis.com, or write to us at First Connect, P.O. Box 909 Austin, TX 78767 to exercise your rights.

First Connect will honor all Global Privacy Control requests in accordance with applicable U.S. law.

Your authorized agent may call us at 1-877-287-6055 to make a request on your behalf. You will be asked to confirm your identity with at least two identification factors, such as a verified email and phone number. If we cannot verify your identity, we will let you know and may deny the request. We must also receive a properly executed authorization form that adequately describes you, your designated agent, and the purpose of the designation. We may deny a request from an agent that does not submit proof that they have been authorized by you to act on your behalf. We may also require that you directly confirm with us that you provided the authorized agent permission to submit the request. The authorized agent must be a natural person or a business entity that is registered with the appropriate state regulatory agency to conduct business in the state they operate and must comply with the requirements of applicable laws.

Victims of Domestic Violence May Have Confidentiality Rights

New York State Insurance Law § 2612 prohibits insurers from discriminating against victims of domestic violence. This law also provides that if any person covered by an insurance policy delivers to the insurer a valid order of protection against the policyholder or other person covered by the policy, then the insurer is prohibited for the duration of the order from disclosing to the policyholder or other person the address and telephone number of the insured, or of any person or entity providing covered services to the insured. If a child is a covered person, then the right established by this section may be asserted by the child’s parent or guardian.

Making a request:

To initiate a confidentiality request as it pertains to an order of protection, please submit a valid order of protection to the below listed address. You may use this confidential communication request form, if you’d like:

First Connect Insurance Services

P.O. Box 1463
Austin, TX 78767
Toll Free Line: 877-287-6055

If the protected individual is a child, the parent or guardian may make the above request.

Revoking a request:

To revoke a confidentiality request, please contact our customer service at 877-287-6055.

We Are Based in the United States

If you are visiting our Services from outside the United States, please be aware that we are based in the United States and the information we collect will be transferred to, processed, and stored on our servers in the United States in accordance with this privacy policy and applicable laws. The data protection laws and regulations applicable to your information transferred to the United States may be different from the laws in your country of residence.

We May Change This Privacy Policy

We may change this privacy policy from time to time. If we make material changes to this privacy policy, we will post the changes on our Services (or our Services that replace them) and provide you notice prior to the changes becoming effective either through the relevant Services or by some other means, such as email or through your account. Your continued use of our Services after such notice constitutes your consent to the changes. We encourage you to periodically review our privacy policy for the latest information on our privacy practices.

First Connect Provides You With a Consumer Privacy Notice

If you are a First Connect customer, then First Connect provides you with the First Connect Consumer Privacy Notice below.

First Connect Provides You With a California Financial Information Privacy Act Notice

If you are a First Connect customer in California, then First Connect provides you with the First Connect California Financial Information Privacy Act Notice below.

You May Contact Us

If you have any questions about this privacy policy or our other information practices, please contact us at agentsupport@fcis.com; 1-877-287-6055; or First Connect, P.O. Box 909 Austin, TX 78767.