Privacy Policy

We collect personal information that you voluntarily provide to us when you express an interest in obtaining information about us or our products and Services, when you participate in activities on the Services, or otherwise when you contact us.

‍Personal Information Provided by You. The personal information that we collect depends on the context of your interactions with us and the Services, the choices you make, and the products and features you use. The personal information we collect may include the following:

1. email addresses
2. mailing addresses
3. job titles
4. contact preferences
5. names
6. phone numbers

Sensitive Information. We do not process sensitive information.

All personal information that you provide to us must be true, complete, and accurate, and you must notify us of any changes to such personal information.

We automatically collect certain information when you visit, use, or navigate the Services. This information may include device and usage information, such as your IP address, browser and device characteristics, operating system, language preferences, referring URLs, device name, country, location, information about how and when you use our Services, and other technical information. This information is primarily needed to maintain the security and operation of our Services, and for our internal analytics and reporting purposes.

The information we collect includes:

• Log and Usage Data. Log and usage data is service-related, diagnostic, usage, and performance information our servers automatically collect when you access or use our Services and which we record in log files. Depending on how you interact with us, this log data may include your IP address, device information, browser type, and settings and information about your activity in the Services (such as the date/time stamps associated with your usage, pages and files viewed, searches, and other actions you take such as which features you use), device event information (such as system activity, error reports (sometimes called "crash dumps"), and hardware settings).

• Device Data. We collect device data such as information about your computer, phone, tablet, or other device you use to access the Services. Depending on the device used, this device data may include information such as your IP address (or proxy server), device and application identification numbers, location, browser type, hardware model, Internet service provider and/or mobile carrier, operating system, and system configuration information.

• Location Data. We collect location data such as information about your device's location, which can be either precise or imprecise. How much information we collect depends on the type and settings of the device you use to access the Services. For example, we may use GPS and other technologies to collect geolocation data that tells us your current location (based on your IP address). You can opt out of allowing us to collect this information either by refusing access to the information or by disabling your Location setting on your device. However, if you choose to opt out, you may not be able to use certain aspects of the Services.

In order to enhance our ability to provide relevant marketing, offers, and services to you and update our records, we may obtain information about you from other sources, such as public databases, joint marketing partners, affiliate programs, data providers, and from other third parties. This information includes mailing addresses, job titles, email addresses, phone numbers, intent data (or user behavior data), Internet Protocol (IP) addresses, social media profiles, social media URLs, and custom profiles, for purposes of targeted advertising and event promotion.

We and our third-party service providers use cookies, pixels, local storage objects, log files, and other mechanisms to automatically collect browsing, activity, device, and similar information on our Services. We use this information to, for example, analyze and understand how users access, use, and interact with our Services, to identify and resolve bugs and errors, to assess, secure, protect, optimize and improve the performance of our Services, for analytics purposes, and to personalize content on our Services.

Cookies. Cookies are alphanumeric identifiers we transfer toyour device’s hard drive through your web browser forrecord-keeping purposes. Some cookies allow us to make it easier foryou to navigate our Services, while others are used to enable afaster log-in process, support the security and performance of thewebsite, or allow us to track activity and usage data within thewebsite.

Pixel Tags. Pixel tags (sometimes called web beacons or clearGIFs) are tiny graphics with a unique identifier, similar in functionto cookies. While cookies are stored locally on your device, pixeltags are embedded invisibly within web pages and online content. Wemay use these, in connection with our website to, among other things,track the activities of users, and help us manage content and compileusage statistics. We may also use these in our emails to let us knowwhen they have been opened or forwarded, so we can track responserates and gauge the effectiveness of our communications.

Local Storage Objects. Local storage is a web storagemechanism that allows us to store data on a browser that persistseven after the browser window is closed. Local storage may be used byour web servers to cache certain information in order to enablefaster loading of pages and content when you return to our websites.You can clear data stored in local storage through your browser.Please consult your browser help menu for more information.

Third-Party Analytics and Tools. We use third party tools,such as Google Analytics, which are operated by third partycompanies. These third-party analytics companies may use cookies,pixels, and other similar tools to collect usage data about ourwebsite in order to provide us with reports and metrics that help usevaluate usage of our Services and improve performance and userexperiences. To learn more about Google’s privacy practices, pleasereview the Google Privacy Policy at https://www.google.com/policies/privacy/partners/.You can also download the Google Analytics Opt-out BrowserAdd-on to prevent data from being used by Google Analytics at https://tools.google.com/dlpage/gaoptout.

We process your personal information for a variety of reasons, depending on how you interact with our Services, including:

• Services and Support. To provide and operate our Services, manage your account, conduct (re)insurance brokerage, underwriting, and claims-related services, communicate with you about your use of the Services, provide customer support, and for other similar support purposes, and to otherwise run our day-to-day operations.
• Analytics and Improvement. To better understand how users access and use the Services, and for other research and analytical purposes, such as to evaluate and improve the Services, and business operations, including to develop our Services and their features, and for internal quality control and training purposes.
• Communication. To respond to your questions and inquiries, fulfill your requests, send you requested materials and newsletters, as well as information and materials regarding our Services and our offerings. We may also use this information to send administrative information to you, for example, information regarding the Services, notifications and updates regarding your policy applications or claims, and changes to our terms, conditions, and policies.
• Security, Protection of Rights, and Fraud Mitigation. To protect the Services and our business operations, our rights and those of our stakeholders and investors, to prevent and detect fraud, unauthorized activities and access, and other misuse of our Services, including where we believe necessary to investigate, prevent or take action regarding illegal activities, suspected fraud, situations involving potential threats to the safety or legal rights of any person or third party, or violations of our policies or terms.
• To comply with our legal obligations. We may process your information to comply with our legal obligations, respond to legal requests, and exercise, establish, or defend our legal rights.
• Auditing, Reporting, and Other Internal Operations. To conduct financial, tax and accounting audits, audits and assessments of our operations, including our privacy, security and financial controls, as well as for risk and compliance purposes. We may also use personal information to maintain appropriate business records and enforce our policies and procedures.
• General Business and Operational Support. To assess and implement mergers, acquisitions, reorganizations, bankruptcies, and other business transactions such as financing, and to administer our business, accounting, auditing, compliance, recordkeeping, and legal functions.

We may need to share your personal information in the following situations:

• Subsidiaries and Affiliates. We may disclose the personal information we collect from or about you to our subsidiaries and affiliated companies, including Ledgebrook Re.
• Carriers, brokers, and others. To manage policies, underwriting, and claims administration, we may disclose personal information to carriers, brokers, underwriters, reinsurers, claims adjusters and administrators, third party administrators, government agencies, law enforcement, and law firms.
• Vendors and Services Providers. We may disclose the personal information we collect to vendors and service providers who perform functions on our behalf, such as IT and website hosting providers, payment processors, marketing and marketing research providers, customer support, data storage, data analytics providers, auditors, consultants, and legal counsel.
• Third Party Analytics Providers. We may also disclose certain personal information, such as device and browsing, and activities and usage information, and other similar information, to third party data analytics providers, and other companies who provide analytics services on our behalf.
• Business Transfers. If we or our affiliates are or may be acquired by, merged with, or invested in by another company, or if any of our assets are or may be transferred to another company, whether as part of a bankruptcy or insolvency proceeding or otherwise, we may disclose or transfer the personal information we have collected from you with or to the other company in accordance with applicable laws. We may also disclose certain personal information as necessary prior to the completion of such a transaction or other corporate transaction such as a financing or restructuring, to lenders, auditors, and third-party advisors, including attorneys and consultants.
• Compliance and Legal Obligations. We may also disclose personal information to third parties to the extent required by applicable law and legal obligations. For example, we may disclose information in response to subpoenas, court orders, and other lawful requests by regulators, government entities, and law enforcement, including responding to national security or law enforcement disclosure requirements, or as otherwise required by law or legal process. In addition, we may disclose the names of sweepstakes and contests winners in accordance with applicable law.
• Security and Protection of Rights. Where we believe doing so is necessary to protect the Services, our rights and property, or the rights, property, and safety of others. For example, we may disclose personal information to (i) prevent, detect, investigate, and respond to fraud, unauthorized activities and access, illegal activities, and misuse of the Services, (ii) situations involving potential threats to the health, safety, or legal rights of any person or third party, or (iii) enforce, detect, investigate, and take action in response to violations of our terms. We may also disclose personal information related to litigation and other legal claims or proceedings in which we are involved, as well as for our internal accounting, auditing, compliance, recordkeeping, and legal functions
• Other Disclosures. We may disclose personal information in other ways not described above that we notify you of or that we obtain your consent for, or that are otherwise authorized or required by law.

We will keep your personal information for as long as it is necessary for our internal purposes, including for any periods that are required or permitted by law (such as tax, accounting, or other legal requirements).

We have implemented technical and organizational security measures designed to protect the security of any personal information we process. However, despite our safeguards and efforts to secure your information, no electronic transmission over the Internet or information storage technology can be guaranteed to be 100% secure, so we cannot promise or guarantee that hackers, cybercriminals, or other unauthorized third parties will not be able to defeat our security and improperly collect, access, steal, or modify your information. Although we will do our best to protect your personal information, transmission of personal information to and from our Services is at your own risk. You should only access the Services within a secure environment.

We do not knowingly solicit data from or market to children under 18 years of age. By using the Services, you represent that you are at least 18 or that you are the parent or guardian of such a minor and consent to such minor dependent’s use of the Services. If we learn that personal information from users less than 18 years of age has been collected, we will deactivate the account and take reasonable measures to promptly delete such data from our records. If you become aware of any data we may have collected from children under age 18, please contact us at privacy@ledgebrook.com.

If you are located in the EEA or UK and you believe we are unlawfully processing your personal information, you also have the right to complain to your local data protection supervisory authority. You can find their contact details here: https://ec.europa.eu/justice/data-protection/bodies/authorities/index_en.htm.

If you are located in Switzerland, the contact details for the data protection authorities are available here: https://www.edoeb.admin.ch/edoeb/en/home.html.

‍Withdrawing your consent: If we are relying on your consent to process your personal information, which may be express and/or implied consent depending on the applicable law, you have the right to withdraw your consent at any time. You can withdraw your consent at any time by contacting us by using the contact details provided in the section "HOW CAN YOU CONTACT US ABOUT THIS NOTICE?" below.

However, please note that this will not affect the lawfulness of the processing before its withdrawal nor, when applicable law allows, will it affect the processing of your personal information conducted in reliance on lawful processing grounds other than consent.

If you have questions or comments about your privacy rights, you may email us at privacy@ledgebrook.com.

Most web browsers and some mobile operating systems and mobile applications include a Do-Not-Track ("DNT") feature or setting you can activate to signal your privacy preference not to have data about your online browsing activities monitored and collected. At this stage no uniform technology standard for recognizing and implementing DNT signals has been finalized. As such, we do not currently respond to DNT browser signals or any other mechanism that automatically communicates your choice not to be tracked online. If a standard for online tracking is adopted that we must follow in the future, we will inform you about that practice in a revised version of this privacy notice.

California Civil Code Section 1798.83, also known as the "Shine The Light" law, permits our users who are California residents to 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 in writing to us using the contact information provided below.

If you are under 18 years of age, reside in California, and have a registered account with Services, you have the right to request removal of unwanted data that you publicly post on the Services. To request removal of such data, please contact us using the contact information provided below and include the email address associated with your account and a statement that you reside in California. We will make sure the data is not publicly displayed on the Services, but please be aware that the data may not be completely or comprehensively removed from all our systems (e.g., backups, etc.).

‍CCPA Privacy Notice

‍The California Code of Regulations defines a "resident" as:

(1) every individual who is in the State of California for other than a temporary or transitory purpose and

(2) every individual who is domiciled in the State of California who is outside the State of California for a temporary or transitory purpose

All other individuals are defined as "non-residents."

If this definition of "resident" applies to you, we must adhere to certain rights and obligations regarding your personal information.

‍What categories of personal information do we collect?

‍We have collected the following categories of personal information in the past twelve (12) months:

We may also collect other personal information outside of these categories through instances where you interact with us in person, online, or by phone or mail in the context of:

• Receiving help through our customer support channels;
• Participation in customer surveys or contests; and
• Facilitation in the delivery of our Services and to respond to your inquiries.

How do we use and share your personal information?

‍More information about our data collection and sharing practices can be found in the Why do we process your information section of this privacy notice.

Will your information be shared with anyone else?

More information about our data disclosure practices can be found in When and with whom do we share your personal information section of this privacy notice.

Sales and Sharing of Personal Information. The CCPA defines "sale" as disclosing or making available personal information to a third party in exchange for monetary or other valuable consideration, and “sharing” includes disclosing or making available personal information to a third party for purposes of cross-contextual behavioral advertising. We do not “sell” or “share” personal information under the CCPA, and, consequently, we do not sell or share personal information about individuals we know are under the age of 16.

Right to request deletion of the data — Request to delete

You can ask for the deletion of your personal information. If you ask us to delete your personal information, we will respect your request and delete your personal information, subject to certain exceptions provided by law.

Right to be informed — Request to know

Depending on the circumstances, you have a right to know:

• whether we collect and use your personal information;
• the categories of personal information that we collect;
• the purposes for which the collected personal information is used;
• whether we sell or share personal information to third parties;
• the categories of personal information that we sold, shared, or disclosed for a business purpose;
• the categories of third parties to whom the personal information was sold, shared, or disclosed for a business purpose;
• the business or commercial purpose for collecting, selling, or sharing personal information; and
• the specific pieces of personal information we collected about you.

In accordance with applicable law, we are not obligated to provide or delete consumer information that is de-identified in response to a consumer request or to re-identify individual data to verify a consumer request.

Right to Opt-Out of Sales and Sharing. You have the right to opt-out of “sales” and “sharing” of your personal information, as those terms are defined under the CCPA. However, we do not “sell” or “share” personal information as defined under the CCPA.

Right to Limit Use and Disclosure of Sensitive Personal Information

We do not engage in uses or disclosures of “sensitive personal information” that would trigger the right to limit use of sensitive personal information under the CCPA.

Right to Non-Discrimination for the Exercise of a Consumer’s Privacy Rights

We will not discriminate against you if you exercise your privacy rights.

Verification process

Upon receiving your request, we will need to verify your identity to determine you are the same person about whom we have the information in our system. These verification efforts require us to ask you to provide information so that we can match it with information you have previously provided us. For instance, depending on the type of request you submit, we may ask you to provide certain information so that we can match the information you provide with the information we already have on file, or we may contact you through a communication method (e.g., phone or email) that you have previously provided to us. We may also use other verification methods as the circumstances dictate.

If we cannot verify your identity from the information already maintained by us, we may request that you provide additional information for the purposes of verifying your identity and for security or fraud-prevention purposes. We will delete such additionally provided information as soon as we finish verifying you.

Other privacy rights

• You may object to the processing of your personal information.
• You may request correction of your personal data if it is incorrect or no longer relevant, or ask to restrict the processing of the information.
• You can designate an authorized agent to make a request under the CCPA on your behalf. We may deny a request from an authorized agent that does not submit proof that they have been validly authorized to act on your behalf in accordance with the CCPA.

To exercise these rights, you can contact us by email at privacy@ledgebrook.com. If you have a complaint about how we handle your data, we would like to hear from you.

Virginia CDPA Privacy Notice

Under the Virginia Consumer Data Protection Act (CDPA):

"Consumer" means a natural person who is a resident of the Commonwealth acting only in an individual or household context. It does not include a natural person acting in a commercial or employment context.

"Personal data" means any information that is linked or reasonably linkable to an identified or identifiable natural person. "Personal data" does not include de-identified data or publicly available information.

"Sale of personal data" means the exchange of personal data for monetary consideration.

If this definition "consumer" applies to you, we must adhere to certain rights and obligations regarding your personal data.

The information we collect, use, and disclose about you will vary depending on how you interact with Ledgebrook Inc. and our Services. To find out more, please visit the following links:

• Personal data we collect
• Why we use your personal data
• When and with whom we share your personal data

Your rights with respect to your personal data

• Right to be informed whether or not we are processing your personal data
• Right to access your personal data
• Right to correct inaccuracies in your personal data
• Right to request deletion of your personal data
• Right to obtain a copy of the personal data you previously shared with us
• Right to opt out of the processing of your personal data if it is used for targeted advertising, the sale of personal data, or profiling in furtherance of decisions that produce legal or similarly significant effects ("profiling")

Ledgebrook Inc. has not sold any personal data to third parties for business or commercial purposes. Ledgebrook Inc. will not sell personal data in the future belonging to website visitors, users, and other consumers.

‍Exercise your rights provided under the Virginia CDPA

‍More information about our data collection and sharing practices can be found in this privacy notice.

You may contact us by email at privacy@ledgebrook.com or by referring to the contact details at the bottom of this document.

If you are using an authorized agent to exercise your rights, we may deny a request if the authorized agent does not submit proof that they have been validly authorized to act on your behalf.

Verification process

We may request that you provide additional information reasonably necessary to verify you and your consumer's request. If you submit the request through an authorized agent, we may need to collect additional information to verify your identity before processing your request.

Upon receiving your request, we will respond without undue delay, but in all cases, within forty-five (45) days of receipt. The response period may be extended once by forty-five (45) additional days when reasonably necessary. We will inform you of any such extension within the initial 45-day response period, together with the reason for the extension.

Right to appeal

If we decline to take action regarding your request, we will inform you of our decision and reasoning behind it. If you wish to appeal our decision, please email us at privacy@ledgebrook.com. Within sixty (60) days of receipt of an appeal, we will inform you in writing of any action taken or not taken in response to the appeal, including a written explanation of the reasons for the decisions. If your appeal if denied, you may contact the Attorney General to submit a complaint.

We may update this privacy notice from time to time. The updated version will be indicated by an updated "Revised" date and the updated version will be effective as soon as it is accessible. If we make material changes to this privacy notice, we may notify you either by prominently posting a notice of such changes or by directly sending you a notification. We encourage you to review this privacy notice frequently to be informed of how we are protecting your information.

If you have questions or comments about this notice, you may email us at privacy@ledgebrook.com or by post to:

Ledgebrook Inc.
‍22 Boston Wharf Road
7th Floor
Boston, MA 02210
United States

Based on the applicable laws of your country, you may have the right to request access to the personal information we collect from you, change that information, or delete it. To request to review, update, or delete your personal information, please submit a request by contacting privacy@ledgebrook.com.