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Privacy Policy

Effective Date: September 8th, 2025
Poulton Associates, LLC (“Poulton Associates,” “we,” “us,” or “our”)

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This Privacy Policy explains how we collect, use, disclose, and safeguard personal information when you interact with our websites and online services that link to this Policy (the “Sites”), including customer portals and forms. Separate product-specific notices may also apply. If you obtain insurance products or services through us, certain information is protected by the Gramm-Leach-Bliley Act (GLBA) and our GLBA Privacy Notice will govern that information.

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1) Information We Collect

We collect information directly from you, from your devices and browser, from licensed insurance professionals and business partners, from public sources, and from service providers. The categories may include:

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  • Identifiers (name, postal address, email, phone number, mobile number, IP address, account identifiers).

  • Professional/License Information (agency name, license number, NPN, appointment details).

  • Insurance & Risk Information (property details, loss history, quote/application data, policy numbers).

  • Financial Information (premium payments, billing and transaction data; no full payment card data is stored by us if a third-party processor is used).

  • Internet/Device Activity (log files, pages viewed, referring pages, browser/device type, cookies, pixels, SDK events).

  • Geolocation (approximate location derived from IP or device settings).

  • Inferences drawn from the above to improve products and fraud prevention.

  • User Content (forms, emails, support requests, reviews).

  • Mobile Messaging Data (your mobile number, opt-in/opt-out status, message history and metadata).

 

We do not knowingly collect information from children under 13, and our Sites are not directed to them.

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2) How We Use Information

We use information to:

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  • Provide, underwrite, quote, administer, service, and support insurance products and programs.

  • Operate and secure the Sites, prevent fraud, and detect security incidents.

  • Comply with law, regulatory reporting, audits, and risk management.

  • Communicate with you, including accounts, policy and transactional messages, and—where permitted—marketing communications.

  • Improve our platforms, analytics, research, and product development.

  • Honor your privacy choices and state-law rights.​

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3) How We Disclose Information

We may disclose personal information to:

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  • Service providers/contractors (hosting, IT, payment processing, communications, analytics, customer support, fraud prevention) under contracts that restrict their use to our purposes.

  • Insurance market participants (carriers, MGAs/MGUs, reinsurers, wholesale and retail producers) to place, underwrite, service, and administer insurance.

  • Business partners involved in claims handling, inspections, catastrophe modeling, and similar functions.

  • Authorities when required by law or to protect rights, safety, and security.

  • Successors in the event of a merger, acquisition, or corporate reorganization.

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We do not sell personal information and we do not share it for cross-context behavioral advertising as those terms are defined by applicable state privacy laws.​​

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4) Cookies, Analytics, and Tracking

We and our service providers use cookies, pixels, local storage, and similar technologies to operate the Sites, remember preferences, keep you signed in, measure performance, and detect fraud.

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  • You can manage cookies via your browser settings and any cookie banner controls we provide.

  • We do not allow third parties to place cookies on our Sites for their own cross-site advertising.

  • Some browsers offer “Do Not Track.” Our Sites currently do not respond to DNT signals, but you can use the controls above to manage cookies.

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5) Mobile Messaging & SMS Privacy

We offer optional text messaging for alerts, verification, and service updates.

  • No Third-Party Sharing: We do not sell, rent, or share mobile opt-in data or consent with third parties for their own marketing purposes. We only disclose mobile numbers and messaging metadata to our message delivery vendors solely to provide the service and to comply with law.

  • Opt-In/Opt-Out: By opting in, you agree to receive SMS from us at the number you provide. Message frequency varies. Reply STOP to end, HELP for help. Standard message and data rates may apply.

  • Data We Keep: Mobile number, opt-in/opt-out status, time stamps, carrier info, and message logs necessary to demonstrate compliance and operate the program.

  • Age Gate: You must be 18+ or the age of majority in your jurisdiction to enroll.

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6) Data Retention

We retain information for as long as necessary to fulfill the purposes described here, comply with legal and regulatory obligations (including insurance recordkeeping), resolve disputes, protect our rights, and enforce agreements. When no longer needed, we delete or de-identify information consistent with our retention schedule.

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7) Security

We employ administrative, technical, and physical safeguards designed to protect personal information, including access controls, encryption in transit where appropriate, network monitoring, and workforce training. No method of transmission or storage is completely secure; we cannot guarantee absolute security.

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8) Your Privacy Rights

Depending on your location, you may have the right to:

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  • Access/Know the categories and specific pieces of personal information we hold about you.

  • Correct inaccurate personal information.

  • Delete information we collected from you (subject to legal exceptions).

  • Opt-out of sales and of sharing for cross-context behavioral advertising (we do not engage in these practices).

  • Limit the use/disclosure of sensitive personal information (we only use such information for permitted purposes like service delivery, security, and compliance).

  • Appeal a denied request (where applicable).

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Submit requests at email: legal@poulton.com, or call 1-888-POULTON (768-5866). We will verify your identity before responding and will not discriminate against you for exercising your rights. Authorized agents may submit requests as permitted by law.

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California Notice at Collection: We collect the categories of personal information listed in Section 1 for the purposes in Section 2, retain them as described in Section 6, and disclose them as described in Section 3. We do not sell or share personal information as defined by California law.

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9) GLBA and Insurance Information

Information collected, processed, or disclosed in connection with providing insurance products or services is subject to the GLBA and applicable state insurance privacy laws. Where GLBA applies, our GLBA Privacy Notice governs and may provide different choices.

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10) International Users

​If you access the Sites from outside the United States, you understand that information may be processed in the U.S. and elsewhere with privacy laws that may differ from those in your jurisdiction. Where required, we implement appropriate safeguards for cross-border transfers.

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11) Third-Party Links

Our Sites may link to third-party websites or services. We are not responsible for their content or privacy practices. Review their policies before providing information.

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12) Changes to This Policy

We may update this Policy from time to time. The “Effective Date” shows the latest revision. Material changes will be posted on the Sites and, where required, we will notify you.

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13) Contact Us

Poulton Associates, LLC
3785 South 700 East,

Salt Lake City, UT 84106
Email: legal@poulton.com
Toll-Free: 1-888-POULTON (768-5866)

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