Insurance Home Office Services, LLC. (or “we”, “us”, “our”, etc.) is committed to maintaining the privacy of individuals and protecting personal information in its custody or control in accordance with privacy legislation applicable to Insurance Home Office Services, LLC..
Application
This Policy describes and summarizes the practices of Insurance Home Office Services, LLC. and its affiliates with respect to our collection, use and/or disclosure of personal information related to all individuals other than employees and individual contractors of Insurance Home Office Services, LLC.; those individuals are subject to a separate policy. Employees of Insurance Home Office Services, LLC. dealing with personal information are expected to be familiar with this Policy.
Definitions
In this Policy, the following terms have the meanings below:
Personal information means information about an identifiable individual, which does not include information of an aggregate or anonymous nature where a specific individual or individuals cannot be identified. Personal Information also does not include business contact information, as long as business contact information is used to contact an individual in their capacity as an employee or official of an organization, and for no other purpose. Information about a corporation, firm, trust, union or other non-individual entity is not personal information.
Business contact information means an individual’s name and position or title as an official or employee of an organization, as well as their business telephone number, business address, business e-mail, business fax number and other business contact information.
Privacy and our Website
We do not collect any personal information from individuals who simply visit our website. However, individuals should be aware that most web servers do collect some information about visitors, such as the browser and version being used, the operating system, and the “IP” or internet address of the visitor, which may identify the individual’s Internet Service Provider or computer but not necessarily the individual using it.
Insurance Home Office Services, LLC.’s website server also uses cookies, which are small text files containing information sent to the computer of a visitor to our website. Cookies are used to help our web server track such things as user preferences that the user may submit in order to make the website more interactive with the user and more responsive to their preferences. Information stored in cookies is used to pre-populate form fields and to remember user preference. This is done for user convenience as well as to provide us with information on which parts of our website are being viewed and by how many visitors. The tracking process is anonymous and no personal information is used.
If you voluntarily submit personal information to us by e-mail for purposes of obtaining information, we will consider that you have done so with your consent for purposes reasonably related to your providing the information. If reasonable to do so, after our initial response, we may send further information to you with information that may be useful, but we will include instructions on how to terminate receiving such further information. Please be advised that the Internet and e-mail are inherently insecure media, and we cannot take responsibility for the security or privacy of personal information in transit over the Internet.
Third Party Websites
Please note that our website may contain links to other websites which are provided as a convenience for visitors to our website only. Any third party websites will have their own privacy policies and practices, and we cannot be responsible for such third parties, their websites, or their privacy practices.
Sources of Personal Information
Insurance Home Office Services, LLC. generally collects, uses, and discloses personal information about the following types of individuals:
Customers, employees of, and contractors to customers;
Prospective or potential customers or their employees;
Subscribers to Insurance Home Office Services, LLC. newsletters or similar types of information;
Employees and independent contractors (where such contractors are individuals) of Insurance Home Office Services, LLC. for the purposes of establishing, managing, and terminating employment and contractor relationships;
Other individuals who may voluntarily choose to provide Insurance Home Office Services, LLC. with personal information.
Shareholders and investors in Insurance Home Office Services, LLC. and directors of Insurance Home Office Services, LLC..
Notification and consent
Subject to this Policy and applicable legislation, Insurance Home Office Services, LLC. will identify the purposes for collection, use and disclosure in advance of collection, and will notify the individual of the purposes for collection, use or disclosure at or before the time of collection.
There are a number of exceptions to the above provisions in that in some circumstances, such as with certain personal information related to employees, Insurance Home Office Services, LLC. does not require consent to collect, use or disclose personal information but is required to provide notification in advance.
In other circumstances, specifically those set out in applicable legislation, the law does not require that Insurance Home Office Services, LLC. obtain consent or provide notification. Insurance Home Office Services, LLC. reserves all its rights to rely on any available statutory exemptions and exceptions.
Exceptions to the requirement for consent
Insurance Home Office Services, LLC. may collect personal information without consent in circumstances that include but are not limited to the following:
Where a reasonable person would consider that the collection of the information is clearly in the interests of the individual and consent of the individual cannot be obtained in a timely way or the individual would not reasonably be expected to withhold consent;
Where the collection of the information is pursuant to a statute or regulation authorizes or requires the collection;
Where the collection of the information is from a public body and that public body is authorized or required by an enactment to disclose the personal information to Insurance Home Office Services, LLC.;
Where the collection of the information is reasonable for the purposes of an investigation or a legal proceeding;
Where the information is publicly available;
Where the collection of the information is necessary in order to collect a debt owed to Insurance Home Office Services, LLC. or for Insurance Home Office Services, LLC. to repay to individual money owed by Insurance Home Office Services, LLC..
In addition to the above, the law generally provides that an individual is deemed to consent to the collection, use or disclosure of personal information about that individual for a particular purpose if the individual voluntarily provides the information for that purpose, and it is reasonable that a person would voluntarily provide that information. If an individual provides personal information to us voluntarily, we will rely on deemed consent and consider that the individual consents to our collection, use or disclosure of their personal information as necessary to carry out the purposes for which they provided the information.
Where a new purpose for the use or disclosure of personal information previously collected arises, Insurance Home Office Services, LLC. will contact the individual in question to obtain any required consent or to provide any required notification for use and/or disclosure for such new purpose or purposes.
Where practical, Insurance Home Office Services, LLC. will try to collect personal information directly from the individual. Where necessary, Insurance Home Office Services, LLC. will collect personal information from other sources. When Insurance Home Office Services, LLC. collects personal information about individuals directly from them, except when their consent to the collection is deemed or has otherwise been previously and lawfully obtained, or is not required, we will tell them the purpose for which the information is collected, and, if reasonable to do so, the name of a person who can answer questions about the collection.
Why we collect, use, and disclose personal information
Insurance Home Office Services, LLC. generally collects uses and discloses personal information for the following purposes:
Customers, employees of and contractors to customers: To establish, maintain, manage and terminate a relationship with a customer.
Prospective or potential customers or their employees: To attempt to establish a relationship with a customer.
Subscribers to Insurance Home Office Services, LLC. newsletters, white papers or similar types of information: To provide services, information or documentation and to solicit business.
Suppliers (including non-individual contractors to Insurance Home Office Services, LLC.), employees of and contractors to suppliers: To establish, maintain, manage and terminate a supplier relationship.
Individuals who may voluntarily choose to provide Insurance Home Office Services, LLC. with personal information: To fulfill the purposes for which such information was provided.
Insurance Home Office Services, LLC. employees and individual contractors: To recruit, establish, maintain, manage and terminate an employment or individual contractor relationship.
Shareholders and investors: To manage our relationship with and our obligations to investors and shareholders. Insurance Home Office Services, LLC. is required by applicable laws and regulatory authorities to collect, as well as use and disclose certain information with respect to its shareholders.
Directors and officers: To manage our relationship with and our obligations to directors and officers. Insurance Home Office Services, LLC. is required by applicable laws and regulatory authorities to collect, as well as to use and disclose, certain information with respect to its directors and officers.
Other individuals: Personal information from other individuals may be collected, used or disclosed when such individuals contact Insurance Home Office Services, LLC. for a variety of reasons personal to them. For example, if an individual contacts us with an inquiry, we will use the information provided to assist us in responding to that individual and communicating with them. Generally, such information is used to contact or reply to individuals who have contacted us where such contact or reply is reasonable in the circumstances, or is subject to deemed consent, or is legally required.
Telephone Conversations: Please refer to the more comprehensive section on telephone conversations in this Policy.
To fulfill our legal obligations.
Use of Personal Information
As with collection, there are exceptions to the requirement of consent with respect to use. For example, Insurance Home Office Services, LLC. may use personal information without consent in circumstances that include but are not limited to the following:
Where a reasonable person would consider that the use of the information is clearly in the interests of the individual and consent of the individual cannot be obtained in a timely way or the individual would not reasonably be expected to withhold consent;
Where the use of the information is pursuant to a statute or regulation that authorizes or requires the use;
Where the information in question was collected is from a public body and that public body is authorized or required by an enactment to disclose the personal information to Insurance Home Office Services, LLC.;
Where the use of the information is reasonable for the purposes of an investigation or a legal proceeding;
Where the information is publicly available;
Where the collection of the information is necessary in order to collect a debt owed to
Insurance Home Office Services, LLC. or for Insurance Home Office Services, LLC. to repay to the individual money owed by Insurance Home Office Services, LLC.;
In certain circumstances, where the information may be disclosed without consent, it may also be used without consent.
Insurance Home Office Services, LLC. will in all cases use personal information as permitted or required by applicable law.
Disclosure of personal information
It is the general policy of Insurance Home Office Services, LLC. to not disclose personal information in its custody or control except with the consent of the individual and then only for identified purposes. However, individuals should be aware that there are exceptions to the above.
Law permits us to collect, use or discloses personal information about an individual in some circumstances without the individual’s consent and/or knowledge. Such circumstances include (but are not limited) to where:
the collection, use or disclosure is clearly in the interests of the individual and consent cannot be obtained in a timely way;
collection, use, or disclosure is reasonable for the purposes of an investigation or proceeding;
the personal information is available to the public from a prescribed source; or
The collection, use, or disclosure is required or authorized by a statute or regulation.
Insurance Home Office Services, LLC. will in all cases disclose personal information as required or permitted by applicable law.
Insurance Home Office Services, LLC. does not disclose trade or sell its customer or contact lists.
Telephone Calls
All incoming and outgoing telephone calls using Insurance Home Office Services, LLC.’s telephone systems are subject to automated recording and archiving. Recording is a function of certain technology and cannot be turned off by individual Insurance Home Office Services, LLC. employees or contractors for particular cases.
Recording is carried out for the following purposes:
To ensure accuracy of communication. This includes ensuring accuracy of our understanding of customer requirements, orders and agreements made with customers, and, if necessary, to accurately document such agreements in the event of a misunderstanding or dispute to protect both Insurance Home Office Services, LLC. and the customer;
To ensure quality of service provided by Insurance Home Office Services, LLC. representatives.
Recordings of telephone calls are initially not reviewed or overheard in any manner, but are archived in digital format on a secure server without review. Such recordings may be subsequently reviewed by Insurance Home Office Services, LLC. at any time for any one or more of the stated purposes and, in particular, may be used without notification or consent as evidence in the event of an investigation or legal proceeding related to such telephone conversation, or to review the quality of service provided in situations where Insurance Home Office Services, LLC. has a basis to believe that such quality may not be adequate and generally only with respect to those Insurance Home Office Services, LLC. representatives who interact with customers.
Callers from outside Insurance Home Office Services, LLC. are advised that their call may be recorded and potentially used on the foregoing basis by posting a notice to that effect on Insurance Home Office Services, LLC.’s web site. Callers have the option at their request of opting out of such recording by asking their Insurance Home Office Services, LLC. representative to call them back on a cell phone, which is not subject to automated recording. Individuals may also communicate with Insurance Home Office Services, LLC. via e-mail, fax or mail.
Recordings, including recordings that are not reviewed, are retained on the same basis as other personal information pursuant to this Policy. Where required or permitted by law, Insurance Home Office Services, LLC. may use or disclose personal information contained in recordings. Insurance Home Office Services, LLC. does not use information contained in recordings for marketing or solicitation purposes. Access to such recordings is restricted to particular individuals within Insurance Home Office Services, LLC. who have obligations of confidentiality to Insurance Home Office Services, LLC. and who have a need to review such recordings as part of their obligations to Insurance Home Office Services, LLC..
Computer Interaction
There are occasions where Insurance Home Office Services, LLC. representatives may remotely access a computer of an Insurance Home Office Services, LLC. customer in order to provide services, including technical support or product support. Such access may include an exchange of information of a conversational nature and, while not intended to do so, such access may result in the collection of personal information incidental to our providing services. The activities carried out during such access are recorded and archived so that the recording of such activities may later be viewed or reviewed for the purposes of providing services to the customer in question. The recording is a video file without sound and is subsequently used only for the purposes of assisting the customer. In all cases where a computer becomes subject to access by Insurance Home Office Services, LLC., such access will be with the customer’s knowledge and consent.
Law allows us, for legal or business purposes, to retain personal information for as long as is reasonable. Upon expiry of an appropriate retention period, bearing in mind reasonable legal and business requirements, personal information will either be destroyed in a secure manner or made anonymous.
Should consent to our collection, use, disclosure or retention of personal information be revoked by the individual in question, the law also allows us to continue to retain the information for as long as is reasonable for legal or business purposes. In the event that revocation of consent may have consequences to the individual concerned, we will advise the individual of the consequences of revoking their consent where it is reasonable in the circumstances to do so.
When we collect, use or disclose personal information, we will make reasonable efforts to ensure that it is accurate, up to date, and complete.
Security
We recognize our legal obligations to protect the personal information we have gathered about individuals. We have therefore made arrangements to secure against unauthorized access, collection, use, disclosure, copying, modification, disposal or destruction of personal information. These arrangements may include physical security measures, network security measures, and organizational measures such as non-disclosure agreements and need-to-know access.
Requests for Access
Law permits individuals to submit written requests to us to provide them with:
access to their personal information under the custody or control of Insurance Home Office Services, LLC.;
information about the purposes for which their personal information under the custody or control of Insurance Home Office Services, LLC. has been and is being used; and
The names of organizations or persons to whom and the circumstances in which personal information has been and is being disclosed by Insurance Home Office Services, LLC..
Requests for access are subject to the following:
Any requests must be in writing.
We do not accept such requests or respond to such requests via e-mail.
In order to receive a response to such a request, the individual must provide us with sufficient information to locate their record, if any, and to respond to them.
We will respond to requests in the time allowed by law, which is generally 45 days. In certain circumstances, we may have a right to extend this period of time and will advise in writing if we are doing so.
We will make a reasonable effort to assist applicants and to respond as accurately and completely as reasonably possible.
All requests may be subject to any fees and disbursements the law permits us to charge.
Where appropriate to do so, we may require advance payment of a deposit or the entire costs of responding to a request for access to personal information.
Please note that an individual’s ability to access his or her personal information under our control is not an absolute right. Law provides that Insurance Home Office Services, LLC. must not disclose personal information where:
the disclosure could reasonably be expected to threaten the safety, physical, or mental health of an individual other than the individual who is requesting;
the disclosure would reveal personal information about another individual; or
The disclosure would reveal the identity of an individual who has in confidence provided us with an opinion about another individual and the individual providing the opinion does not consent to the disclosure of his or her identity.
Law also provides that Insurance Home Office Services, LLC. may choose not to disclose personal information where:
the personal information is protected by any legal privilege;
the disclosure of the information would reveal confidential commercial information and it is not unreasonable to withhold that information;
the personal information was collected by Insurance Home Office Services, LLC. for an investigation or legal proceeding;
the disclosure of the personal information might result in similar information no longer being provided to us when it is reasonable that it would be provided;
the personal information was collected or created by a mediator or arbitrator in the conduct of a mediation or arbitration for which he or she was appointed to act
under an agreement,
under an enactment, or
by a court; or
The personal information relates to and may be used in the exercise of prosecutorial discretion.
Insurance Home Office Services, LLC. reserves all its rights under the above.
Responses to Requests
Our responses to requests for access to personal information will be in writing, and will confirm:
whether we are providing all or part of the requested information,
whether or not we are allowing access or providing copies, and,
If access is being provided, when and how that will be given.
If access to information or copies are refused by us, we will provide written reasons for such refusal and on which that refusal is based. We will also provide the name of an individual at Insurance Home Office Services, LLC. who can answer questions about the refusal and particulars of our decision. In order to receive a response to such a request, the individual must provide us with sufficient information to locate their record, if any, and to respond to them.
Requests for Correction
Law permits individuals to submit written requests to us to correct errors or omissions in their personal information that is in our custody or control. If an individual alleges errors or omissions in the personal information in our custody or control, we will either:
correct the personal information and, if reasonable to do so, and if not contrary to law, send correction notifications to any other organizations to whom we disclosed the incorrect information; or
Decide not to correct the personal information but annotate the personal information that a correction was requested but not made.
Corrections or amendments will not make to opinions as opposed to factual information, although we reserve the right to modify opinions where changes in the facts on which those opinions are based occur.
Amendment
Insurance Home Office Services, LLC. may amend this Policy from time to time as required and without notice, in order to better meet our obligations under the law.
Contacting Insurance Home Office Services, LLC.
If you have any questions with respect to our policies concerning the collection, use, disclosure or handling of your personal information, or if you wish to request access to, or correction of, your personal information under our care and control, or if you are dissatisfied with how we handle your personal information, please contact us at:
info@ihosllc.com
If you remain dissatisfied after our Privacy Contact has reviewed and responded to your concern, or have other concerns or questions, you have the write at any time to:
2201 Cantu Court, Suite 200
Sarasota, FL 34232