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GLBA Notice

WHAT DOES POULTON ASSOCIATES, LLC DO WITH YOUR PERSONAL INFORMATION?
Rev. September 2025

Why?

Financial companies choose how they share your personal information. Federal law gives consumers the right to limit some—but not all—sharing. Federal law also requires us to tell you how we collect, share, and protect your personal information. Please read this notice carefully to understand what we do.

What?

The types of personal information we collect and share depend on the product or service you have with us. This information can include:

  • Name, address, email, phone number, and insurance license or NPN (for producers)

  • Policy, application, quote, and claims information

  • Payment and transaction information

  • Internet or device network activity (e.g., logs, cookies)

  • Geolocation (approximate)

  • Mobile messaging data (your number, opt-in/opt-out status, message logs)

When you are no longer our customer, we continue to share your information as described in this notice.

 

 

How?

All financial companies need to share customers’ personal information to run their everyday business. In the section below, we list the reasons financial companies can share their customers’ personal information, whether Poulton Associates shares, and whether you can limit this sharing.

Reasons we can share your personal information

Reason
Do we share?
Can you limit you sharing?
For nonaffiliates to market to you
No
We don’t share
For our affiliates’ everyday business purposes—information about your creditworthiness
No
Yes (if applicable)
For our affiliates’ everyday business purposes—information about your transactions and experiences
No
No
For joint marketing with other financial companies
No
We don’t share
For our marketing purposes—to offer our products and services to you
No
We don't share
For our everyday business purposes—such as to process your transactions, maintain your accounts, respond to court orders and legal investigations, or report to credit bureaus
Yes
No

Who we are

Who is providing this notice?
Poulton Associates, LLC, including our online platforms (e.g., CATcoverage.com) that link to this notice.

What we do

How does Poulton Associates protect my personal information?
We use administrative, technical, and physical safeguards that comply with federal and state law. These include access controls, encryption in transit where appropriate, network monitoring, and workforce training.

How does Poulton Associates collect my personal information?
We collect personal information, for example, when you:

  • Request a quote, bind coverage, service a policy, or file a claim

  • Pay premiums or use our websites/portals

  • Work with us as a licensed insurance professional

  • We also collect information from affiliates, insurers, reinsurers, service providers, consumer reporting agencies, public databases, and anti-fraud partners.

Why can’t I limit all sharing?
Federal law gives you the right to limit only:

  • Sharing for affiliates’ everyday business purposes—information about your creditworthiness.

  • Affiliates from using your information to market to you; and

  • Sharing for nonaffiliates to market to you.

  • State laws and individual companies may give you additional rights.

What happens when I limit sharing for an account I hold jointly with someone else?
Your choices will apply to everyone on your account.

Definitions

Affiliates
Companies related by common ownership or control. They can be financial and nonfinancial companies.

Nonaffiliates
Companies not related by common ownership or control. They can be financial and nonfinancial companies.

  • Nonaffiliates we share with for everyday business purposes can include insurers, reinsurers, program administrators, inspection firms, adjusters, IT and communications vendors, and other service providers.

Joint marketing
A formal agreement between nonaffiliated financial companies that together market financial products or services.​

Other important information

  • We do not sell personal information, and we do not share it for cross-context behavioral advertising.

  • We do not sell, rent, or share mobile/SMS opt-in data with third parties for their own marketing purposes. We disclose mobile numbers and messaging metadata only to vendors as needed to deliver messages and to comply with law.

Questions?

Call 1-888-POULTON (768-5866) or email legal@poulton.com

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