Privacy Policy

We at Jems of Insurance Group Inc. (the “Site”, or “Us”, “Our” or “We”) understand that You, the user of the Site and its services (“You”) value Your privacy and We strive to respect that privacy when You are using the Site or Our services. This Privacy Policy describes what information We gather from You, how We use that information, who We share it with, and what We do to protect it. By using this Site, You are expressly consenting to the information handling practices described in this Privacy Policy. If You do not agree with this Privacy Policy, do not use the Site and do not submit any information to Us.

Information We Collect From You

The information We collect from You, includes, but is not limited to: name, age, gender, physical address, email address, phone number, household information, income, marital status, and personal health information such as medical history. We reserve the right, and the Site may collect from time to time, any other lawful personal information about You, such as information that will help us match products and services that may be of interest to You.

The Site also collects and retains non-personal, technical information about Your visit(s) to the Site, including, without limitation, IP address assigned to the computer You are using, the type of browser You are using, Your location, time of visit, and the operating system Your computer or device is using.

How We Use Your Information

We use Your personal information to match Your request for insurance products and services with Our network of providers of insurance products and services.

We may also use Your personal information for any other lawful purpose, including, without limitation, sharing Your personal information with third parties who may send You ads or marketing communications about their products and offers which may be of interest to You.

By submitting Your information to Us, You are authorizing these third parties to contact You through any lawful means, including, without limitation, email, telephone (even if Your telephone number is on the do not call list), text, or online ads, regarding their products and services. If You subsequently desire that these third parties no longer contact You, You will need to communicate Your request directly to them.

We may also share Your information with third-party contractors who provide services to Us so that We can provide You with the Site and its various services. These third-party contractors are prohibited from using the information We provide for purposes other than performing services for Us. We may transfer Your information to third parties that are involved in a corporate merger or acquisition with Us.

The non-personal data that the Site collects is generally used in the aggregate to analyze the ways in which the Site is used, and how We can improve the user experience, and may be shared with third parties such as advertisers, marketers, and other vendors who provide Us with services. We use information about You and Your activities on the Site for research and reporting purposes.

We may also disclose Your information to third parties when We reasonably believe We are obligated to do so by law. We may also do so in order to investigate, prevent, or take action regarding suspected or actual prohibited activities, including, without limitation, fraud, situations involving potential threats to the Site or the physical safety of any person, and violations of any applicable law.

Cookies

We may use cookies, web beacons, and other tracking technologies to collect information about You and Your interaction with the Site. We may also use tracking technologies for interest-based advertising, as described below. Typically, Our cookies will expire after 30 days. Most web browsers are set to accept cookies by default, but You can usually change Your settings to reject cookies. For more information about interest-based ads, see the “Interest-Based Ads” section below.

Do Not Track

Most browsers have a “Do Not Track” functionality of Your web browser by visiting the Preferences or Settings page of Your web browser. Because there are currently no industry standards for Do Not Track signals and responses, the Site is not designed to respond to the “Do Not Track” setting of Your browser.

Interest-Based Advertising

We and Our third-party partners may engage in marketing tactics, including what is known as “interest-based advertising”. As described above, We and Our partners may set a cookie on Your device and/or browser. Among other things, this technology allows Us and Our partners to provide You with interest-based or targeting advertising, that is, offers to products and services which will be of interest to You based on websites You’ve visited, Your visit to this Site, or other data or information which marketers may have about You. Such tactics may include tracking Your use of a web service over time and across different websites, in what is known as “retargeting”. Retargeting means that after visiting the Site or other websites, marketers may deliver ads to You on this or other websites. Marketers may track Your Internet usage across websites and combine data from other sources to personally identify You.

For more information about interest-based advertising, please visit http://www.allaboutcookies.org/. To opt out of Your web browsing information being used in this manner, please visit http://optout.aboutads.info. This opt-out process is managed and governed by industry self-regulatory bodies such as the Digital Advertising Alliance (http://digitaladvertisingalliance.org/), not by Us. Note that in the opt-out process, You may opt-out of interest-based advertising on a company-by-company basis, or You may opt out of interest-based ads from all companies who have elected to participate in the program. We do not participate directly in the program, however, Our third-party partners who may be showing You ads through Our interest-based marketing efforts, such as Google, Inc., do participate. And, although some companies may provide their own, direct opt-out mechanism, this Site does not currently offer that option.

If You do elect to take advantage of this opt-out, please note that it remembers Your preference by setting a cookie on Your device or browser. Therefore, if You change computers or browsers, or delete cookies, You will have to opt-out again for each of the companies You previously opted out of. It is also important to note that opting-out of interest-based ads does not mean that You will no longer receive advertising, nor will it prevent the receipt of interest-based advertising from third parties that do not participate in these programs. It will, however, exclude You from interest-based advertising conducted through participating networks, as provided by their policies and choice mechanisms.

Revoking Your Consent

If, after submitting Your personal information to Us, You subsequently decide that You no longer want Us to retain and use Your personal information, please email Us at hsilva@jemsofinsurance.com and We will use commercially reasonable efforts to delete Your personal information which is no longer needed for our legal compliance purposes (for example, some laws may require that we keep records of Our transactions regarding Your Personal Information), and we will cease sharing your Personal Information with third parties. However, please note that if We have shared Your personal information with any third parties, You will have to contact them directly with Your request to delete Your information. They may or may not have policies which allow such actions; We do not have knowledge or control their practices.

Opting Out of Email Marketing Communications

If We are sending you email marketing communications and You no longer wish Us to send You those email marketing communications, please click on the unsubscribe link in the email We send you or send Your opt-out request to Jems of Insurance Group Inc. and We will implement Your opt-out request within 10 business days. Again, if We have shared Your email address with any third parties, You will have to contact those companies directly. Please note that You cannot opt-out of email communications that are not marketing in nature, that is, emails which are used for administrative or technical communications.

Third Party Sites, Links, and Content Appearing on Jems of Insurance Group Inc.

The Site may contain links to, advertisements for, or other content from third party sites and services which are operated by such third parties and not Us. Such third parties’ practices and policies regarding the handling of Your information may differ from Ours. While We endeavor to associate only with reputable partners and third-party sites, We are not be responsible for their actions or policies. This Privacy Policy does not address any such third parties. Please review their privacy policies directly.

Protecting Your Information

We use industry standard safeguards in storing and maintaining Your personal information in a secure manner, and in transmitting Your personal information to Our third-party partners in a secure manner. However, You understand and agree the internet is not 100% secure. Please keep Your security software up to date and always be cautious when sharing Your personal information.

Information Relating to Children

Only individuals 18 years of age or older have permission to use the Site. If You are not at least 18 years old, do not use the Site. Any individual who uses the Site or provides their information to Us represents that they are 18 years of age or older.

The Site is not intended for or directed at children under 13 years of age. We do not knowingly collect personal information from children under 13 years of age. If You are under 13 years of age, do not use this Site or provide Your information to Us. If We discover that a child under the age of 13 has provided Us with personal information, or that We have inadvertently collected such information, We will promptly delete it from Our systems. However, third parties which we have passed such information on to will still have such information. If anyone believes that We have been provided with the personal information of a child under the age of 13, please notify Us immediately at hsilva@jemsofinsurance.com, and we will use commercially reasonable efforts to promptly delete such information. Please be advised, however, that such persons will also need to contact third parties which We have shared such information with.

Your California Privacy Rights

Under California law, residents of California may request certain information about Our disclosure of personal information during the prior calendar year to third parties for marketing purposes. To request this information, please contact Us at hsilva@jemsofinsurance.com.

Changes to this Privacy Policy

We may make changes to this Privacy Policy at any time, for any or no reason, with or without notice to You. Such changes may take place due to a change or expansion in Our services or policies. As You use the Site, You are required to periodically check this Privacy Policy for any changes. To assist You, We provide Our Privacy Policy’s effective date at the top of this page. You are responsible for reading and understanding this Privacy Policy, and Your continued use of the Site or Our services following a change or update to this Privacy Policy constitutes Your continued agreement and consent to the practices described herein.

If You have any questions or comments regarding Our Privacy Policy, please visit Us at Our “Contact Us” page.

Privacy Notice for California Residents

This Privacy Notice for California Residents supplements the information contained in our privacy policy above and applies solely to all visitors, users, and others who reside in the State of California (“consumers” or “you”). We adopt this notice 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.

Category Examples Collected
A. Identifiers. (Identifiers) A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, Social Security number, driver’s license number, passport number, or other similar identifiers. YES
B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)). (Related Information) A name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver’s license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information. Some personal information included in this category may overlap with other categories. YES
C. Protected classification characteristics under California or federal law. (Characteristics) Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information). YES
D. Commercial information. (Commercial Information) Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies. NO
E. Biometric information. (Biometric Information) Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as, fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data. NO
F. Internet or other similar network activity. (Internet Activity) Browsing history, search history, information on a consumer’s interaction with a website, application, or advertisement. YES
G. Geolocation data. (Geolocation data) Physical location or movements. YES
H. Sensory data. (Sensory data) Audio, electronic, visual, thermal, olfactory, or similar information. NO
I. Professional or employment-related information. (Professional Information) Current or past job history or performance evaluations. NO
J. Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)). (Non-public Education Information) Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records. NO
K. Inferences drawn from other personal information. (Inferences) Profile reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes. YES

Personal information does not include:

  • Publicly available information from government records.
  • De-identified or aggregated consumer information.
  • Information excluded from the CCPA’s scope, like:
    • health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and the California Confidentiality of Medical Information Act (CMIA) or clinical trial data;
    • personal information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FRCA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver’s Privacy Protection Act of 1994.

We obtain the categories of personal information listed above from the following categories of sources:

  • Directly from you (e.g., via telephone, text message, email, website form submission, etc.).
  • Publicly accessible sources (e.g., property records, public directories, etc.).
  • Third parties (e.g., marketing vendors and social media, digital advertising, and data aggregation businesses).
  • Indirectly from you (e.g., via cookies, digital trackers, analytics, and IT and security systems).

Use of Personal Information

We may use, or disclose the personal information we collect for one or more of the following business purposes:

  • To fulfill or meet the reason you provided the information. For example, if you share
  • To fulfill the reason you provided the information (e.g., to match you with an insurance agent, provide support, respond to an inquiry, etc.).
  • To market products and services to you (including by third parties with whom we may share your personal information).
  • To personalize your website experience and to deliver content and product and service offerings relevant to your interests, including targeted offers and ads through our website, third-party sites and companies, and via email, telephone, text message, or other means (with your consent as required by applicable law).
  • For other marketing purposes.
  • To help maintain the safety, security, and integrity of our website, products and services, databases and other technology assets, and business.
  • To evaluate or conduct a merger, restructuring, sale, or other corporate transaction in which personal information is among the assets transferred.
  • To investigate and prevent fraud and abuse of our website, products, and services.
  • To comply with our legal and regulatory obligations.
  • For other business purposes.

Sharing Personal Information

We may disclose your personal information to a third party for a business purpose or sell your personal information, subject to your right to opt-out of those sales (see Personal Information Sales Opt-Out and Opt-In Rights). 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. The CCPA prohibits third parties who purchase the personal information we hold from reselling it unless you have received explicit notice and an opportunity to opt-out of further sales.

  • Persons or companies that offer products or services on our websites (Providers).
  • Marketing vendors and social media, digital advertising, and data aggregation companies (Marketers).
  • Auditors, attorneys, consultants, professional service providers, etc. (Professional Services).
  • Other parties with a legal interest (including private parties and government or regulatory entities) (Legal Parties).
  • Other service providers we use to help provide our products or services (Service Providers).

Disclosures of Personal Information for a Business Purpose

In the preceding twelve (12) months, we have disclosed for a business purpose Identifiers, Related Information, Characteristics, Internet Activity and Geolocation Data to Providers and Marketers.

Sales of Personal Information

In the past twelve (12) months, we have disclosed for business purposes Identifiers, Related Information, Characteristics, Internet Activity, Geolocation Data and Inferences to Professional Services and other Service Providers.

Your Rights and Choices

The CCPA provides consumers (California residents) with specific rights regarding their personal information. This section describes your CCPA rights and explains how to exercise those rights.

Access to Specific Information and Data Portability Rights

You have the right to request that we 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:

  • The categories of personal information we collected about you.
  • The categories of sources for the personal information we collected about you.
  • Our business or commercial purpose for collecting or selling that personal information.
  • The categories of third parties with whom we share that personal information.
  • The specific pieces of personal information we collected about you (also called a data portability request).
  • If we sold or disclosed your personal information for a business purpose, two separate lists disclosing:
    • sales, identifying the personal information categories that each category of recipient purchased; and
    • disclosures for a business purpose, identifying the personal information categories that each category of recipient obtained.

Deletion Request Rights

You have the right to request that we delete any of your personal information that we collected from you and retained, subject to certain exceptions. 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:

  • 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.
  • Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
  • Debug products to identify and repair errors that impair existing intended functionality.
  • Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
  • Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et. seq.).
  • Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
  • Comply with a legal obligation.
  • Make other internal and lawful uses of that information that are compatible with the context in which you provided it.

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 by sending us an email to hsilva@jemsofinsurance.com. Only you, or a person registered with the California Secretary of State that you authorize to act on your behalf, 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.

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

  • Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative.
  • Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

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 will only use personal information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.

Response Timing and Format

We endeavor to respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time (up to ninety (90) days), we will inform you of the reason and extension period in writing. 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, specifically by electronic mail communication.

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.

Personal Information Sales Opt-Out and Opt-In Rights

We do not knowingly collect information from individuals under eighteen (18) years of age. No information should be submitted to, or posted at, our websites by individuals under eighteen (18) years of age. Consumers who opt-in to personal information sales may opt-out of future sales at any time. To request that we do not sell your personal information, click the Do Not Sell My Personal Information hyperlink located near the bottom of the landing page on our website.

Once you make an opt-out request, we will wait at least twelve (12) months before asking you to reauthorize personal information sales. However, you may change your mind and opt back into personal information sales at any time by visiting our website and sending us a message. We will only use personal information provided in an opt-out request to review and comply with the request.

Non-Discrimination

We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not:

  • Deny you goods or services.
  • Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.
  • Provide you a different level or quality of goods or services.
  • Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.

However, we may offer you certain financial incentives permitted by the CCPA that can result in different prices, rates, or quality levels. Any CCPA-permitted financial incentive we offer will reasonably relate to your personal information’s value and contain written terms that describe the program’s material aspects. Participation in a financial incentive program requires your prior opt in consent, which you may revoke at any time.

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 information to third parties for their direct marketing purposes. To make such a request, please send us an email to hsilva@jemsofinsurance.com or write us at our address listed on our webpage.

Changes to Our Privacy Notice

We reserve the right to amend this privacy notice at our discretion and at any time. When we make changes to this privacy notice, we will post the updated notice on the Website and update the notice’s effective date. Your continued use of our Website following the posting of changes constitutes your acceptance of such changes.

Contact Information

If you have any questions or comments about this notice, the ways in which we collect and uses your information described herein, your choices and rights regarding such use, or wish to exercise your rights under California law, please do not hesitate to contact us as follows: