Last Updated: October 2023
- Our former, current and prospective clients;
- Individuals who communicate with us; and
- Individuals who use our products and services (collectively with our Sites, the “Services”) and individuals whose personal information we receive in providing the Services.
Consumers with disabilities may access this notice by using a standard screen reader or contacting us at (617) 330-5700.
Information We Collect
The categories of personal information we collect can include:
- Personal identifiers such as your name, email address, mailing address, phone number, date of birth, and government-issued identifiers (e.g., social security or national insurance number, passport number, ID number, tax identification number or driver’s license number).
- Customer records such as your identification documents, account credentials, and payment and billing information (credit or debit card or other financial information).
- Commercial information such as your communication with us or interest or participation in an insurance product, risk consulting service or other Services.
- Demographics such as race, ethnicity, gender, marital status, date and place of birth.
- Health or medical information such as health and medical history, conditions, diagnoses, services received, claims, coverage, medications, allergies, accommodation needs and any other information related to health insurance Services.
- Sensory information such as photos and videos of you and audio recordings of phone calls between you and us, where permitted by law.
- Preferences you provide to us or generated through your use of the Services, including inferences we may make based on our experience with you.
- Internet, network and device information from the browser or device you use to access our Services, which could include your IP address, device ID, cookie identifiers, browser type, internet service provider, referring/exit pages, operating system, date/time stamp and or clickstream data.
- Professional information in connection with your role as a brokerage or carrier partner, agent, vendor or research partner.
- Background check information that we may receive from third-party sources, such as criminal and sex offender registry information.
Keep reading to learn more about how we collect personal information you provide to us directly through the Sites, information we collect through your use of the Services, and information we receive through third parties.
Information You Provide Through the Sites
When using our Sites, you may voluntarily provide information about yourself. We collect this information when you contact us through our Sites, create an account, provide us with personal information required to fulfill Services, or interact with us for any other purpose.
We may collect the following personal information about you through our Sites:
- Personal identifiers such as contact information;
- Customer records such as billing information and user name, account number, and password;
- Preference information such as preferences about marketing publications and your interests in relation to our Services; and
- Commercial information associated with your inquires to us, including information you may voluntarily submit to us by completing forms on our Sites.
Information Processed Through the Services
We may also collect additional personal information (subject to applicable legal requirements and restrictions) in providing our Services, operating our business, and interacting with individuals in the course of our business, which may include:
- Personal identifiers such as government issued identification numbers;
- Customer records such as billing information, Income and other financial information, and records of real property;
- Commercial information about the insurance quotes individuals receive and the policies they obtain, current and/or previous claims;
- Demographic information;
- Health and medical information and other Information necessary to secure insurance products, provide risk consulting services, offer guidance on other Services to you, process claims;
- Sensory information such as voice recordings when you call us;
- Preferences such as inferences we may make based on our experience with you;
- Professional information such as employer, job title and employment history; and
- Background check information such as criminal records data and other information from credit and background checks.
Information Automatically Collected When You Use our Services
Like most digital platforms, we collect certain personal information automatically when you visit our online Services, including:
- Internet, network and device information. We may place, or allow to be placed, cookies, web beacons and similar technologies (“cookies”) on our Services to give you the best experience, perform analytics, analyze traffic, personalize content, offer a range of features and functionality, and offer ads that match your interest. The information collected through cookies may include your IP address, browser type, Internet service provider, device type/model/manufacturer, operating system, date and time stamp, and a unique ID that allows us to identify your browser or your account (including, for example, a persistent device identifier or an Ad ID), and other similar information. We may also work with third-party partners to employ cookies and analytical tools, including the application of statistical modeling tools, that permit us to recognize and contact you across multiple devices; and
- Preferences such as inferences about your interests that we may make based on your cookie data.
We may use this information to determine the way you access and use our Services and to improve your online browsing experience. This may include, for example, the site from which you came and the site to which you are going when you leave our services, the pages you visit, the links you click (also known as “clickstream data”), whether you open emails or click the links contained in emails, whether you access the services from multiple devices, and other actions you take on the services
Please see the Your Choices section below for information on how to block or delete cookies from your browser or device.
Information Provided by Third-Party Sources
In addition to the personal information collected above, we may also collect personal information from the following third-party sources:
- Social media. If you choose to interact with us on social media, we may collect personal information about you from the social media accounts that you make public. We use personal information collected in connection with your social media account to communicate with you, better understand your interests and preferences, and better understand our customer base more broadly.
- Business partners. Our business partners may collect the personal information listed above in connection with the Services and may share some of this information with us. This includes our customers, the insureds, employers, administrators or other participants in the Services offered to you and the other third parties in the supply chain for providing the Services to you.
- Service providers. Our service providers, such as payment processors and marketing providers, collect the personal information and often share it with us. For example, we receive personal information from payment processors to confirm that an individual’s payment for the Services was accepted. We also receive information about the success of our email campaigns, including information about who has opened our marketing communications and when.
- Information providers. We may, from time to time, obtain information from third-party information providers to correct or supplement personal information we collect. For example, we may obtain updated contact information from third-party information providers to confirm an address or reconnect with an individual, or we may receive the results of a background check from a third party provider. We may also enrich the data we own with third-party information, such as demographic information about business contacts to understand our audience and develop better marketing communications.
- Publicly available information. We may collect personal information from publicly available sources, such as government records or public review websites, to help improve our business and services.
How We Use Your Information
In addition to the above, we and our third party partners may use personal information for any lawful purpose, including the following:
- To create, maintain and service your account;
- To respond to your inquiries or otherwise communicate with you;
- To evaluate your eligibility for and provide Services you request, including to provide publications to which you subscribe;
- To operate, personalize, and improve the Sites and their features, including for analytics purposes;
- To send promotions and marketing materials that may be of interest to you;
- To present advertising online and via other communication channels, including through social media platforms and internet search engines;
- To send you important information regarding the Services, such as certain changes to our terms, conditions, policies, and other administrative information. Because this information may be material to your use of the Services, you may not opt-out of receiving such communications;
- To administer and manage our vendors and business partners
- To analyze, improve and grow our business;
- For our other business purposes, such as analysis, research, audits, fraud detection and prevention, payment processing, developing new products and features, identifying usage trends, and our internal operational purposes;
- To help maintain the safety, security, and integrity of our Services, technology assets, and business; and
- With your consent, or as otherwise disclosed at the time information is collected.
We may also use aggregate, deidentified and anonymous information in a manner for any lawful, legitimate purpose such that the information does not uniquely identify you or any other user of the Services. Where we maintain deidentified data, we will maintain and use the data in deidentified form and not attempt to reidentify the data except as required or permitted by law.
Disclosure of Information
- Business partners. We share information with our business partners, such as the third party agents, contractors, brokers, carriers, administrators or other third parties involved in providing the Services;
- Service providers. We share personal information with third-party vendors, consultants and other service providers who perform functions or services on our behalf and under our instructions to make our Services available to you. For example, this may include vendors and providers who engage in marketing or advertising activities or provide mailing or email services, tax and accounting services, auditing and compliance, fraud prevention, infrastructure provisioning, analytics services, IT services, product fulfillment, and web hosting;
- Business transaction or reorganization. We may take part in or be involved with a corporate business transaction, such as a merger, acquisition, joint venture, or financing or sale of company assets. We may disclose personal information to a third-party during negotiation of, in connection with or as an asset in such a corporate business transaction. Personal information may also be disclosed in the event of insolvency, bankruptcy, or receivership;
- Legal obligations and rights. We may disclose personal information to third parties, such as legal advisors, auditors and law enforcement:
- in connection with the establishment, exercise, or defense of legal claims;
- to comply with laws or to respond to lawful requests and legal process;
- to detect, suppress, or prevent fraud;
- to reduce credit risk and collect debts owed to us;
- to protect the health and safety of us, our customers, or any person; or
We may share information that has been anonymized or aggregated without limitation.
We permit our trusted business partners and third-party advertising companies (including ad servers, ad agencies, technology vendors, or providers of sponsored content, collectively “ad partners”) to collect your browsing information and numerical identifiers associated with your browser or device to provide ads on our behalf that are tailored to your interests. These ads may appear on our website, and on other third-party websites. Using cookies, our ad partners collect data from a particular browser or device about a user’s web viewing behaviors over time, across unrelated websites, and in some cases combine such data with data collected from other browsers or devices associated with the same user or household, and use such data to predict user preferences and to deliver advertisements to that user which are calculated to target that user’s predicted preferences across devices. If you take steps to block advertising cookies or opt out of interest-based advertising, note that this does not mean that you will no longer receive ads from Accession, as these ads are only one form of digital advertising. Throughout our online advertising practices we support the self-regulatory principles of the Digital Advertising Alliance (“DAA”).
You have some choices regarding how we use your personal information, including those in this section and, depending on where you live, please see the Region-Specific Disclosures section below for additional information that may apply to you.
- Correcting and updating your information. You may change any of your personal information in your account by editing your profile within your account. If you have questions about reviewing, changing, or deleting your information, you can contact us directly using the contact information below. We may not be able to change or delete your information in all circumstances.
- Marketing emails. If you decide that you do not wish to receive marketing emails from Accession, you may opt-out of receiving further e-mails by clicking “Unsubscribe” in such emails. You may also opt out or unsubscribe from future emails by sending a request to email@example.com using the subject line “Unsubscribe from email communications.” To ensure your opt-out request is properly processed, be sure to send your message using the same email account to which we sent our correspondence.
- Cookies and Online Advertising: Most browsers accept cookies automatically, but you can block or delete cookies at any time to prevent the collection of your browsing information for purposes of delivering interest-based ads and tracking visitor behavior. You can block or opt out of cookies or collection of data for interest-based advertising by adjusting settings within your device or browser. For instructions, check your browser’s technical information. You can also find options for restricting cookies placed by some of our ad partners, on the DAA’s opt-out page (http://optout.aboutads.info/) or the by using the NAI’s opt-out tool (https://optout.networkadvertising.org/?c=1).
If you are using a mobile device, your device may also include a feature ("Limit Ad Tracking" on iOS or "Opt Out of Ads Personalization" on Android) that allows you to opt out of having certain information collected through mobile apps used for behavioral advertising purposes. If you block cookies at a browser- or device-level and use a different computer or browser to access our platforms, you should review your cookie settings again. Please be aware that blocking or deleting cookies may also disable or interfere with shopping features on our services and other sites that you may visit.
Third-Party Links and Tools
Our Sites may also include integrated social media tools or “plug-ins,” such as social networking tools offered by third parties. If you use these tools to share personal information or you otherwise interact with these features on the Sites, those companies may collect information about you and may use and share such information in accordance with your account settings, including by sharing such information with the general public. Your interactions with third-party companies and your use of their features are governed by the privacy notices of the companies that provide those features. We encourage you to carefully read the privacy notices of any accounts you create and use.
Accession is committed to protecting the privacy needs of children and encourages parents and guardians to take an active role in their children’s online activities and interests. We do not knowingly collect information from children under the age of sixteen (16), and Accession does not target or direct its Sites to children.
• By phone at (617) 330-5700.
• Email at firstname.lastname@example.org.
Notice to Certain U.S. State Residents
Sensitive Information. The following categories of personal information we collect may be classified as “sensitive” under the U.S. state privacy laws (“sensitive information”):
- Government-issued identifiers;
- Username and password;
- Demographics such as race, ethnicity, citizenship status, sexual orientation or sex life;
- Information about a known child under the age of 13;
- Health and medical information; and
- Payment card and financial account information.
Your Privacy Rights. Depending on your state of residency and subject to certain legal limitations and exceptions, you may be able to exercise some or all of the following rights:
The Right to Know
The right to confirm whether we are processing personal information about you and, under California law only, to obtain certain personalized details about the personal information we have collected about you, including:
- The categories of personal information collected;
- The categories of sources of the personal information;
- The purposes for which the personal information were collected;
- The categories of personal information disclosed to third parties (if any), and the categories of recipients to whom this personal information were disclosed;
- The categories of personal information sold (if any), and the categories of third parties to whom the personal information were sold; and
- The categories of personal information shared for targeted advertising purposes (if any), and the categories of recipients to whom the personal information were disclosed for these purposes.
The Right to Access & Portability
The right to obtain access to the personal information we have collected about you and, where required by law, the right to obtain a copy of the personal information in a portable and, to the extent technically feasible, readily usable format that allows you to transmit the data to another entity without hindrance.
The Right to Correction
The right to correct inaccuracies in your personal information, taking into account the nature of the personal information and the purposes of the processing of the personal information
The Right to Control Over Sensitive Information
The right to exercise control over our collection and processing of certain sensitive information
The Right to Control Over Automated Decision-Making / Profiling
The right to direct us not to use automated decision-making or profiling for certain purposes, including any form of automated processing of personal information to evaluate, analyze, or predict personal aspects concerning an individual’s economic situation, health, personal preferences, interests, reliability, behavior, location or movements in furtherance of decisions producing legal or similarly significant effects
Right to Opt-Out of Sales or Sharing of Personal information
The right to direct us not to (a) “sell” your personal information to third parties for monetary or other valuable consideration, or (b) “share” your personal information with third parties for cross-context behavioral advertising purposes and targeted advertising purposes.
See the section Do Not Sell or Share My Personal Information below for more information.
The Right to Request Deletion
The right to request the deletion of personal information that we maintain about you, subject to certain exceptions.
Depending on your state of residency, you also have the right to not receive retaliatory or discriminatory treatment in connection with a request to exercise the above rights. However, the exercise of the rights described above may result in a different price, rate or quality level of Service where that difference is reasonably related to the impact the right has on our relationship or is otherwise permitted by law.
Do Not Sell or Share My Personal Information. Under the laws of California, Colorado, Connecticut and Utah, the definition of “sale” is broad and covers many common business activities, even when the personal information used is not exchanged for money, or when it has been partially de-identified. Accession shares personal identifiers, or internet, network and device information, and preferences for data analytics including fraud detection, marketing and advertising purposes, for example, to better understand engagement with our Services, to match your interests with similar products you may also be interested in, to offer advertising for our products across other devices that you use, and to identify other potential customers with interests similar to yours who may also be interested in our products.
Under Virginia law, “selling” is the exchange of your personal information for monetary consideration only. Accession does not sell your personal information to third parties for money for their independent business use.
When we use the term “share” or “sharing” we mean sharing, renting, releasing disclosing, disseminating making available, transferring or otherwise communicating orally, in writing, or by electronic or other means, your personal information by us to a third-party for cross-context behavioral advertising as well as targeted advertising as defined under the U.S. state privacy laws.
We do not “sell” or “share” sensitive information. We do not sell the personal information of consumers we know to be less than 16 years of age. If we wish to do so in the future, we will first seek affirmative authorization from either the minor who is between 13 and 16 years of age, or the parent or guardian of a minor less than 13 years of age. Please contact us at email@example.com to inform us if you, or your minor child, would like to opt-in to “sales”.
Exercising Your Rights. To exercise the rights described above, please choose one of the following options:
- To submit a request to exercise your Right to Know, Access, Portability, Correction, Deletion, Control Over Sensitive Information, or Control Over Automated Decision Making, please call us at (617) 330-5700 or email us firstname.lastname@example.org with sufficient information to identify you in our systems and fulfill your request.
- To submit a request to exercise your Right to Opt-Out of Sales or Opt-Out of Sharing/Use of Your Personal Information for Targeted Advertising, please complete the following steps:
- Cookie Preference Tool. Please navigate to your browser’s settings and clear your cache and delete all cookies stored on your browser. Then, please visit the Accession Site you typically interact with, and you will be presented with a cookie banner. You can opt out of the “sales” and “sharing” of your personal information by choosing the “Decline” option on the banner, or by selecting the “Cookie Settings” option and declining “Advertisement” and “Analytics” cookies. Please note that this opt-out is device- and browser-specific and will not be effective on your visits to the Services from other devices, browsers. These requests will only affect cookie-based “selling” and “sharing”. Please note that deleting and opting out of some cookies may result in an inability to take full advantage of the Services.
- Future “Sales” and “Shares”. To opt out of potential future “sales” and “sharing” of your personal information from our internal databases, please call us at (617) 330-5700 or email us email@example.com with sufficient information to identify you in our systems and fulfill your request.
- As an additional measure, we also suggest you block or opt out of cookies or collection of data for targeted advertising by adjusting settings within your device or browser. For instructions, check your browser’s technical information. You can also find options for restricting cookies placed by some of our ad partners, on the DAA’s opt-out page (http://optout.aboutads.info/). If you are using a mobile device, your device may also include a feature ("Limit Ad Tracking" on iOS or "Opt Out of Ads Personalization" on Android) that allows you to opt out of having certain information collected through mobile apps used for behavioral advertising purposes.
We will need to verify your identity and confirm your state of residence before processing your request, which will generally require the matching of sufficient information you provide to us to the information we maintain about you in our systems or the successful authentication through your account (if you have one with us).
Making a privacy rights request does not require you to create an account with us. However, 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 privacy rights request to verify the requestor's identity or authority to make the request, to process the request, and for necessary record keeping.
Authorized Agents. Only you, or someone legally authorized to act on your behalf and with written permission, may make a privacy rights request related to your personal information. In certain circumstances, you are permitted to use an authorized agent to submit requests on your behalf where (i) you provide sufficient evidence to show that the requestor is an authorized agent with written permission to act on your behalf and (ii) you successfully verify your own identity with us. We generally require evidence of either: (i) a valid power of attorney; or (ii) a signed letter containing your name and contact information, the name and contact information of the authorized agent, and a signed statement of authorization for the request. Depending on the evidence provided and your state of residency, we may still need to separately reach out to you to confirm the authorized agent has permission to act on your behalf and to verify your identity in connection with the request.
Appealing Privacy Rights Decisions. Depending on your state of residency, you may be able to appeal a decision we have made in connection with your privacy rights request. All appeal requests should be submitted by emailing firstname.lastname@example.org with the subject line “Privacy Rights Appeal.” We welcome the opportunity to discuss the decision about your privacy rights request with you.
- Colorado Residents: If your appeal is denied, you may contact the Colorado Attorney General to address your concerns here.
- Connecticut Residents: If your appeal is denied, you may contact the Connecticut Attorney General to submit a complaint here.
- Virginia Residents: If your appeal is denied, you may contact the Virginia Attorney General to submit a complaint here.
Notice to California Residents
Retention of Personal Information. We retain personal information only for as long as is reasonably necessary to fulfil the purpose for which it was collected. However, if necessary, we may retain personal information for longer periods of time, until set retention periods and deadlines expire, for instance where we are required to do so in accordance with legal, tax and accounting requirements set by a legislature, regulator or other government authority.
To determine the appropriate duration of the retention of personal information, we consider the amount, nature and sensitivity of the personal information, the potential risk of harm from unauthorized use or disclosure of personal information and if we can attain our objectives by other means, as well as our legal, regulatory, tax, accounting and other applicable obligations.
Notice to Nevada Residents
If you are a resident of the State of Nevada in the United States, Chapter 603A of the Nevada Revised Statutes permits Nevada residents to opt out of potential future sales of certain covered information that a website operator has collected or will collect about you. To exercise this right, please contact us: