Privacy Policy

This privacy policy ("Privacy Policy") generally the information CoverWallet, Inc. (“CoverWallet”, “We” or “us”) collects when you use or access its website and any of its platforms, products or services (collectively, the "Services"). CoverWallet is part of the Aon family of companies. It also explains how we use and share the information and what steps we take to protect it.

This Privacy Policy applies to any personal information you provide to CoverWallet and any personal information we collect when you contact us, visit or use our websites or applications, visit a CoverWallet location, attend CoverWallet events or seminars, request a service from us or use other services that refer to or link to this Privacy Policy (the "Services"). The personal information depends on the nature of the Services we provide and how you interact with us. This Privacy Policy may be supplemented by additional privacy statements, terms or notices relevant to the applicable Services. Please also review the Terms and Conditions that govern your use of our Services. This Privacy Policy does not apply to your use of any third-party sites linked to from our websites or Services.

1. Information we collect

What types of information we collect depends on the product or Services you have with us.

The information we collect about you may include:

• Contact details: such as your name, contact information, driver's license number and social security number;
• Demographic details: such as your date of birth, gender, and marital status;
• Unique identifiers: such as Passport Number, National ID, National Insurance Number or pension scheme reference number;
• Account information: such as your login information when you log into our platform;
• Financial information: such as business ownership information, including profit sharing and ownership interests, payment history, claims information, credit history, credit or debit card number and bank account details, and information needed to process transactions;
• Employment information: such as job title, employee number, employment status, salary, employment benefits, and employment history, qualifications and affiliations;
• Benefits information: such as benefit elections, pension entitlement information, date of retirement and any relevant matters impacting your benefits e.g. voluntary contributions, pension sharing orders, tax protections or other adjustments;
• Claims details: such as information about any claims concerning your or your employer’s insurance policy;
• Online information: such as computer, device and connection information (e.g. IP address, browser type, operating system, unique device identifier), usage data collected when visiting our websites, device location information;
• Background checking information: such as inclusion on a sanctions list or a public list of disqualified directors, the existence of previous or alleged criminal offenses, or confirmation of clean criminal records, information in relation to politically exposed persons (“PEPs”); and
• Driving history, certifications and insurance details: such as driving license details, the period for which a license has been held, existing and previous insurance policy details, previous accident and claims history and details of any motoring convictions.

We may supplement the information we collect about you with data from third-parties. This information may include:

• Information from other sources such as financial records, employment history, medical records or other third-party data; and
• Information from other reporting agencies, state and federal government agencies, such as state motor vehicle departments and credit reporting agencies.

We treat all information about you, whether received from you or from a third-party, in accordance with this Privacy Policy and our Terms and Conditions. Some of the personal information CoverWallet collects may be considered “sensitive personal information” under certain data protection laws, such as financial or health information collected in connection with benefits enrollment.

2. Sources of information

We collect personal information about you in the following ways:

• From You. We collect your contact information, registration/account information, payment information, and any other personal information when you provide it to us on the Services. When you make a purchase on the Services, we also retain a record of your purchases and order history.
• From your Organization. We may obtain personal information about you from the organization with which you are employed or affiliated, in order to provide Services to them and/or manage your access to and use of the organization’s Service.
• Automatically from Your Device. Our websites use cookies, in combination with pixels, local storage objects, and similar devices (collectively, "cookies" unless otherwise noted) to distinguish you from other users of the website. You do not need to allow cookies to visit most of the websites. However, enabling cookies may allow for a more tailored browsing experience and is required for certain parts of the website to work. For more information please see “Cookies and Other Tools” below.
• From Third Parties. We may collect personal information about you from other third parties, such as recruitment agencies, insurers, underwriters, reinsurers, credit reference agencies, medical professionals, government bodies, claimants, sponsors, joint venture entities or business partners, as well as vetting and data validation agencies and other professional advisory service providers.

Where you provide personal information to CoverWallet about third-party individuals (e.g. information about your spouse, civil partner, child(ren), dependents or emergency contacts), where appropriate, you should provide these individuals with a copy of this Privacy Policy beforehand or ensure they are otherwise made aware of how their information will be used by CoverWallet. Where you provide information to us about your beneficiaries, we may require you to provide explicit consent on their behalf.

3. How do we use the information we collect?

We use the information we collect to provide, maintain, protect, optimize and improve our Services, and to enhance your user experience. We may also use the information we collect in the following ways:

• Regular Business Purposes: We use the information you provide to provide our Services to you, update your account(s), process or service requested or authorized transactions, secure quotations for insurance, obtain insurance coverage or report or process claims.
• For Our Own Analytic Purposes: CoverWallet, Inc. may also use your information to develop new Services, conduct research and to create anonymous or aggregated reporting for its own use.
• For Our Own Marketing Purposes: CoverWallet, Inc. may use your information to offer products or Services to you.
• To Comply with Legal Requirements and Enforce Our Legal Rights: It may be necessary to provide information collected from you to respond to subpoenas, other discovery requests, legal investigations or court orders. We may also use personal information to enforce our agreements, trace debtors and recover any outstanding debt in connection with the Services provided. We may share information pursuant to a governmental agency or investigatory body request.
• For Our Own Internal Purposes: We may use your personal information to carry out due diligence, identity, credit reference, bankruptcy, sanctions, data validation, anti-money laundering, “Know Your Customer” and other business acceptance, vetting and risk management agency checks.

4. How is your information disclosed?

CoverWallet, Inc. generally discloses your personal information with the following categories of recipients where necessary to offer, administer, and manage the Services provided to you.

• Within our family of companies: We may disclose your personal information with our parent company, Aon, and our affiliates and subsidiaries for the processing purposes outlined in this Privacy Policy.
• With Other Insurance Providers: If we do not have an insurance product that works for you, we may disclose your contact information to other insurance providers who can serve you.
• With Our Service Providers and Third Parties: We may share your personal information with other companies and individuals to perform functions or services for us or on our behalf, such as hosting this site, sending email messages, and making phone calls. These may also include third parties such as vetting and risk management agencies, legal advisers, loss adjusters, claims investigators, medical professionals, and government bodies. These parties are contractually restricted from using any personal information for purposes other than providing services for CoverWallet, Inc. or on our behalf.
• For Administrative and Legal Reasons: See “Service Providers and Business Partners” above. Additionally, CoverWallet, Inc. also reserves the right to disclose or use information if it has a good faith belief that such action is necessary to: (a) protect and defend the rights, property, or liability of CoverWallet, Inc. or its affiliates, other users of this platform, or the public; (b) enforce the Terms and Conditions; (c) respond to claims that any content violates the rights of third-parties; (d) respond to claims of suspected or actual illegal activity; (e) detect, address or prevent fraud, security or technical issues; or (f) respond to an audit.
• With Business Partners: We disclose personal information, as necessary, in providing our products and services. In order to sell, solicit, and negotiate insurance, we may disclose your information to insurers, reinsurers, insurance intermediaries, brokers, underwriters, insurance reference bureaus, medical service providers, fraud detection agencies, our advisers, loss adjusters, lawyers, accountants, and others involved in the claims handling process.

We may also use session replay or session recording cookies for real-time collection, storage, use, and share of information on your device (e.g., IP address, device type, settings), or information provided by you (e.g., mouse movements and clicks), to help us improve our website and make it more convenient for users. Session data may be shared with our session replay vendors that may only use it to provide the service to us. See How is your information disclosed? (section 4) above.

We allow certain companies to place tracking technologies like cookies on our websites. Those companies receive information about your interaction with our websites that is associated with your browser or device and may use that data to serve you relevant ads on our websites or others. For details on how to opt-out of this activity, please visit the Your Rights and Choices section.

5. What steps does CoverWallet take to protect your information?

CoverWallet protects your personal/private information through the use of encryption technology. We use industry standard security protocol (Secure Sockets Layer or "SSL") to ensure that the connection between your browser and our server remains protected. Unfortunately, no data transmitted over the Internet or data storage system can be guaranteed 100% secure. If you believe your connection with us is no longer secure for any reason, please notify us immediately.

6. External Links and Third-party Privacy Policies

CoverWallet, Inc. may post links to third-party websites that are governed by their own terms and are not subject to this Privacy Policy. We do not exercise control over these third-party sites and are not responsible for the privacy practices of any third-party. We encourage you to read the privacy policies and terms of use of any third-party web sites you visit.

7. International Users

The Services are operated in the United States and intended for users located in the United States. If you access this site from a location outside of the United States, your information may be transferred to the United States and you agree to such transfer. Furthermore, you acknowledge that the United States may not provide the same level of protections as the laws of your country.

8. Children

The Services are not intended for anyone under the age of 16, and we do not knowingly collect, use or disclose information of children under the age of 16. We will delete any personal information collected that we determine to be from a user younger than the age of 16. Where you provide information to us about your beneficiaries, we may require you to provide consent on their behalf.

9. Rights and Choices

Depending upon where you reside, you may have the following rights with respect to personal information we have collected about you:

• Right to know and access: a right to access and inspect your personal information or be provided with a permanent copy of the information being held about you.
• Right to correct: a right to request the correction of your personal information or in cases where the accuracy of information is disputed, to supplement the information to give notice that you dispute its accuracy.
• Right to deletion: a right to request the erasure of your personal information, particularly where the continued use of the information is no longer necessary.
• Right to portability: The right to request that some aspects of your personal information be provided to you or a third party of your choice in electronic form to enable its reuse.
• Direct marketing opt-outs. If you would like to opt-out of receiving direct marketing correspondence, you can do so by following the instructions in the marketing message you receive.
• Opt-out of the sale or sharing of your personal information or use of your personal information: To exercise the right to opt-out of “Selling” or “Sharing” your information for targeted advertising, you may indicate your cookie preferences by visiting Aon Cookie Notice via this link or you may configure your browser to send the Global Privacy Control (“GPC”) signal, which will transmit your opt-out request to CoverWallet automatically. To turn on the GPC signal, you can download one of the supported browsers or extensions. You may visit https://globalprivacycontrol.org/#download for a list of the available browsers or extensions.

We will not discriminate against you and will not restrict or deny you access to our services because of choices and requests you make in connection with your personal information. Please note, certain choices may affect our ability to deliver our Services. For example, if you sign up to receive marketing communications by email, then ask us to delete all of your information, we will be unable to send you marketing communications. Unless permitted by an applicable US privacy law, 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.

To submit a verifiable request, please email us at privacy@coverwallet.com , by toll-free phone +1 646-844-9933 or via one of the form links below. Only you, or someone legally authorized 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. If you are an authorized agent making a request, we may require and request additional information to protect the personal information entrusted to us, including information to verify that you are authorized to make that request. You may only make a verifiable consumer request for access 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.

  Right to Opt-out of the Sale of Your Personal Information

  Right to Request Deletion

  Right to Access Your Information

  Right to Correct Your Information

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 may also be unable to comply with your request if we have a legal or regulatory obligation to keep your personal information, such as when the information is necessary to complete a transaction. Other reasons your request may be denied are if it jeopardizes the privacy of others, or would be extremely impractical to honor.

Making a verifiable consumer request does not require you to create an account with us. However, we do consider requests made through your password protected account sufficiently verified when the request relates to personal information associated with that specific account. We will only use personal information provided in a verifiable consumer request to verify the requestor's identity or authority to make the request.

10. US Location-specific Residents

Categories of Personal Information We Collect

CoverWallet may have collected the following categories of personal information in the past 12 months:

• Identifiers such as a name, Internet Protocol address, email address, phone number, or other similar identifiers
• Categories of personal information described in subdivision (e) of California Civil Code Section 1798.80. Information that identifies, relates to, describes, or is capable of being associated with, a particular individual, including, but not limited to, his or her 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.
• Commercial information, including records of products or services purchased or considered.
• Internet or other electronic network activity information.
• Geolocation data.
• Audio, electronic, or similar information, such as recordings of customer service and sales calls.
• Professional or employment-related information.
• Inferences drawn from any of the information identified above.
• Other Personal Information That Consumers Voluntarily Choose to Provide

This information is collected and used for the purposes disclosed in this Privacy Policy. CoverWallet may have sold, rented, released, disclosed, disseminated, made available, transferred, or otherwise communicated any of the above categories of personal information to another business or a third party for monetary or other valuable consideration in the past 12 months.

For more information about how Aon collects, discloses, and shares Sensitive Personal Information of specific state residents, please reference the Privacy Notice for US Locations with Applicable Privacy Laws, available on the Aon Global Privacy Statement.

How is your information disclosed?

With Affiliates:

• CoverWallet We share your personal information with other businesses owned by Aon PLC, which have their own privacy statements and are not subject to this Privacy Statement.

With Non-Affiliates:

CoverWallet, Inc. has shared or disclosed your personal information to third parties for the third-parties’ direct marketing purposes and other business purposes in the last 12 months. Therefore, California’s “Shine the Light” law (California Civil Code § 1798.83) applies. In accordance with this law, we provide you with the ability to opt out of such disclosures at no cost through the “Do Not Sell or Share My Personal Information” link in the footer section of our website or as provided in the Privacy Policy at “US Location-specific Residents.”

• Service Providers: We engage service providers to provide services such as credit-card and billing processing, marketing, advertising optimization, interest-based targeting, e-mail and text message distribution, data processing, mobile and website analytics, user authentication, security, and promotions management. We may share any personal information we collect about you with these service providers and authorize them to collect personal information from you directly to support the services they provide to us. We do not authorize our service providers to share or use your personal information with any other third parties.
• Data Partners: Data partners may use cookies and other tracking technologies to enable the delivery of interest-based advertising to users. We do not authorize our data partners to share your e-mail address with their other clients.
• Business Partners: We partner with businesses that provide us leads from their customer base, and we share/sell their customer's personal information consisting of contact information, payment information, and demographic information (such as income and occupation) back to the Business Partner for inclusion into their customer's overall total relationship profile.

Information We Sell: CoverWallet sells leads received from marketing partners and third-party lead sellers to Aon affiliated and non-affiliated entities, and to other lead aggregators. All leads that CoverWallet receives are initially used to broker insurance, however leads of unbound applicants could then be sold to other insurance entities or lead aggregators to assist in facilitating the acquisition of appropriate insurance coverage for the lead.

When you visit CoverWallet websites or apps (collectively, “Sites”), certain information may be collected from your computer in the course of your use of our Sites. As with many websites, we may use both session based and persistent "cookies" and/or other technology (e.g., web bugs, e-mail bugs, clear GIFs, web beacons, tracker GIFs =) in our Sites or in our electronic communications with you to enhance the functionality of our Sites and Services. These technologies also make your transactions and other activities more convenient and efficient.

11. Cookies and Other Tools

"Cookies" are small amounts of data that a website can send to your web browser and store on your computer. Most web browsers are initially set up to accept cookies. You have the option of disabling or refusing cookies at any time in your browser preferences. However, note that some parts of our Sites will not function properly or may be considerably slower if you refuse cookies. For example, without cookies, you will not be able to set personalized preferences, and/or may have difficulty completing transactions. To find out more about cookies, visit www.aboutcookies.org. The use of cookies is an industry standard, and as such, you will find that most major websites use them. We have two (2) primary uses for cookies. First, we use them to specify a user's preferences so you don't have to repeatedly tell us your preferences. Second, we use cookies to track Site usage trends and patterns, including through the use of session recording code. This helps us understand our users' needs better and improve areas of our Sites.

Because there is not yet a consensus on how companies should respond to web browser-based do- not-track (“DNT”) mechanisms, we do not respond to web browser-based DNT signals at this time. Please note that not all tracking will stop even if you delete cookies.

Third Party Use of Technology

Third parties (including, but not limited to, software vendors, advertisers, ad servers, content providers, and services providers) may also use similar technologies by or through our Sites or through their own websites. Such entities may collect information about you and your usage activity on this and other websites. CoverWallet does not control these third parties and is not responsible for the actions of our third party business partners. We encourage you to check their terms of use and privacy policies for such information.

Interest Based Advertising

We may use third-party servicing technology and service providers to serve ads on our behalf across the Internet and sometimes on our Sites. They may collect information about your visits to our Sites, and your interaction with our products and Services. They may also use information about your visits to send you targeted advertisements for goods and services. This information is collected through the use of a pixel tag, or similar technology which is industry standard technology used by most major websites.

We may also share Site usage information about visitors to our Sites with select third parties for the purpose of targeting our Internet banner advertisements on our websites and other websites. To do this, we use web beacons and cookies provided by our third-party ad server on our Site. In connection therewith, such third parties may have access to and use information about your online usage activity. The use of advertising cookies and web beacons sent by such third-party Web servers is standard for commercial activity in the Internet industry.

To understand more about your choices with respect to sharing your personal information for cross-context behavioral advertising and interest based advertising, please see the “Rights and Choices” section below.

12. Retention

We will keep your personal information for as long as we have an ongoing legitimate business need to do so. This includes providing you with a service you have requested from us or to comply with applicable legal requirements. It also includes keeping your personal information for so long as there is any possibility that you or we may wish to bring a legal claim, or where we are required to keep your personal information for legal or regulatory reasons. If you wish to receive further information regarding our record retention procedures, please contact us using the contact details provided under the “Contact Us” section below.

13. Contact Us

For additional information, or if you have questions regarding this Privacy Policy or privacy practices at CoverWallet, Inc., please send correspondence to privacy@coverwallet.com or via postal mail to:

CoverWallet, Inc.
One Liberty Plaza, Suite 3201
New York, NY 10006
United States

14. Changes to Privacy Policy

This Privacy Policy may be revised at any time to reflect changes in the law or in CoverWallet, Inc.'s business operations. Any changes will be effective immediately upon the posting of the revised Privacy Policy. Sometimes there may be material changes to this Privacy Policy that we want to apply retroactively. If so, we will notify you and obtain your consent to the extent required by law.

Revision Date: May 2024