Last Modified: June 5, 2019
- Information We Collect
- How We Use Information We Collect
- How We Share Collected Information
- Cookies and Similar Technologies
- How to Access & Control Your Personal Data
1. Information We Collect
When You Visit our Websites
You are free to explore the Websites without providing any Personal Information about yourself. When you visit the Websites or request a quote, we ask that you provide Personal Information about yourself, and we collect Navigational Information.
Personal Information refers to any information that you voluntarily submit to us, and that identifies you personally, including contact information, such as your name, email address, phone number, and other information about yourself or your health. Personal Information can also include information about any transactions, which you enter into on the Websites, and information about you that is available on the internet, such as from Facebook, LinkedIn, Twitter and Google, or publicly available information that we acquire from service providers.
Personal Information also includes Navigational Information where such information can directly or indirectly identify an individual. Navigational information refers to information about your computer and your visits to this website such as your IP address, geographical location, browser type, referral source, length of visit and pages viewed. Please see the “Navigation Information” section below. Except for this, we do not collect Sensitive Information from you.
When you use our services or view content provided by us, we automatically collect information about your computer hardware and software. This information can include your IP address, browser type, domain names, internet service provider (ISP), the files viewed on our site (e.g., HTML pages, graphics, etc.), operating system, clickstream data, access times and referring website addresses. This information is used by International Citizens Group, Inc. to provide general statistics regarding use of the Website. For these purposes, we do sometimes link this automatically-collected data to Personal Information such as name, email address, address, and phone number.
Information We Collect from Third Parties
We may receive Personal Information about you from third party sources including insurance partners with which we are sourcing quotes from on your behalf or from whom you have purchased a policy where we are the Broker of Record, and publicly available sources such as social media websites.
Information About Children
The Websites are not intended for or targeted at children under 16, and we do not knowingly or intentionally collect information about children under 16 If you believe that we have collected information about a child under 16, please contact us at email@example.com, so that we may delete the information.
2. How We Use Information We Collect
We Never Sell Personal Information
We will never sell your Personal Information to any third party.
Use of Personal Information
- improve your browsing experience by personalizing the Websites;
- send information or content to you which we think may be of interest to you by post, email, or other means and send you marketing communications relating to our business;
- promote the use of our services to you and share promotional and information content with you per your communication preferences;
- provide other companies with statistical information about our users — but this information will not be used to identify any individual user;
- meet legal requirements.
We may contact you on behalf of external business partners about a particular offering that may be of interest to you. In those cases, we do not transfer your Personal Information to the third party.
The Legal Basis for Processing Personal Information (EEA visitors only)
Our legal basis for collecting and using the personal information described above will depend on the personal information concerned and the specific context in which we collect it. However, we will typically collect personal information from you only where we have your consent to do so, where we need the personal information to perform a service for you, or where the processing is in our legitimate interests and not overridden by your data protection interests or fundamental rights and freedoms. In some cases, we may also have a legal obligation to collect personal information from you.
If we ask you to provide personal information to comply with a legal requirement or to perform a service for you, we will make this clear at the time of the request and advise you whether the provision of your personal information is mandatory or not. We will also alert you to the possible consequences if you do not provide your personal information. Similarly, if we collect and use your personal information in reliance on our legitimate interests (or those of any third party), we will make clear to you at the relevant time what those legitimate interests are.
If you are a visitor/customer located in the European Economic Area (“EEA”), you can contact our Data Protection Officer at firstname.lastname@example.org.
Use of Navigational Information
We use Navigational Information to operate and improve the Websites. We may also use Navigational Information alone or in combination with Personal Information to provide you with personalized information about International Citizens Group, Inc.
Customer Testimonials and Comments
We post customer testimonials and comments on our Websites, which may contain Personal Information. We obtain each customer’s consent via email before posting the customer’s name and testimonial.
Use of Credit Card Information
If you give us credit card information, we use it solely to collect payment from you on behalf of our Insurance Partners. We do not store, retain, or use the information you provide except for the sole purpose of credit card processing on your behalf.
Security of your Personal Information
We use a variety of security technologies and procedures to help protect your Personal Information from unauthorized access, use or disclosure. We secure the Personal Information you provide on computer servers in a controlled, secure environment, protected from unauthorized access, use or disclosure. All Personal Information is safeguarded using appropriate physical, technical and organizational measures.
Social Media Features
Retention of Personal Information
How long we keep the information we collect about you depends on the type of information, as described in further detail below. After such time, we will either delete or anonymize your information or, if this is not possible, then we will securely store your information and isolate it from any further use until deletion is possible.
We retain Personal Information that you provide to us where we have an ongoing legitimate business need to do so. For example, as long as is required to contact you about the quotes you requested, or to manage your policy as the Broker of Record, or as needed to comply with our legal obligations, resolve disputes and enforce our agreements).
When we have no ongoing legitimate business need to process your Personal Information, we securely delete the information or anonymize it or, if this is not possible, then we will safely store your Personal Information and isolate it from any further processing until deletion is possible. We will delete this information from the servers at an earlier date if you so request, as described in “To Unsubscribe from Our Communications” below.
If you have elected to receive marketing communications from us, we retain information about your marketing preferences for a reasonable period from the date you last expressed interest in our content, products, or services, such as when you last opened an email from us or canceled your policy. We retain information derived from cookies and other tracking technologies for a reasonable period from the date such information was created.
3. How We Share Collected Information
We employ other companies and people to provide services to visitors to our Websites, and our customers, and may need to share your information with them to provide information, products or services to you. Examples may include removing repetitive information from prospect lists, analyzing data or performing statistical analysis, providing marketing assistance, supplementing the information you provide us to provide you with better service and providing customer service or support. In all cases where we share your information with such agents, we explicitly require the agent to acknowledge and adhere to our privacy and customer data handling policies.
International Citizens Group Partners
Also, we may share data with trusted Insurance Partners to contact you based on your request to receive such communications, help us perform statistical analysis, or provide customer support. Such third parties are prohibited from using your Personal Information except for these purposes, and they are required to maintain the confidentiality of your information.
If we (or our assets) are acquired by another company, whether by merger, acquisition, bankruptcy or otherwise, that company will receive all information gathered by International Citizens Group, Inc. on the Websites. In this event, you will be notified via email or a prominent notice on our website, of any change in ownership, uses of your Personal Information, and choices you may have regarding your Personal Information.
We reserve the right to use or disclose your Personal Information if required by law or if we reasonably believe that use or disclosure is necessary to protect our rights, protect your safety or the safety of others, investigate fraud, or comply with a law, court order, or legal process.
4. Cookies and Similar Technologies
Third Party Tracking Technologies
5. How to Access & Control Your Personal Data
Reviewing, Correcting and Removing Your Personal Information
You have the following data protection rights:
- You can request access, correction, updates or deletion of your personal information.
- You can object to the processing of your personal information, ask us to restrict the processing of your personal information or request portability of your personal information.
- If we have collected and processed your personal information with your consent, then you can withdraw your consent at any time. Withdrawing your consent will not affect the lawfulness of any processing we conducted before your withdrawal.
- You have the right to complain to a data protection authority about our collection and use of your personal information. Contact details for data protection authorities in the EEA, Switzerland and certain non-European countries (including the US and Canada) are available here.)
To exercise any of these rights, please contact us at email@example.com or by mail to International Citizens Group, Inc., 18 Shipyard Drive, Suite 2A, Hingham, MA 02043 USA, Attention: Privacy. We will respond to your request to change, correct, or delete your information within a reasonable timeframe and notify you of the action we have taken.
To Unsubscribe From Our Communications
You may unsubscribe from our marketing communications by clicking on the “unsubscribe” link located on the bottom of our emails, or by sending us an email at firstname.lastname@example.org or postal mail to International Citizens Group, Inc., 18 Shipyard Drive, Suite 2A, Hingham, MA 02043 USA, Attention: Privacy. Customers cannot opt out of receiving transactional emails related to their account.
To Unsubscribe from Our Insurance Partners’ Communications
Our Insurance Partners are solely responsible for their marketing emails and other communications; we cannot unsubscribe you from their communications. You can unsubscribe from our customers’ marketing communications by clicking on the “unsubscribe” link located on the bottom of their emails, or by contacting them directly.
International Citizens Group, Inc.
18 Shipyard Drive, Suite 2A
Hingham, MA 02043 USA