EFFECTIVE: October 2021

This Privacy Policy applies to this website and to other websites, applications, services and mobile applications on or in which this Privacy Policy is linked or referenced (the “Sites”), as well as our interactions with you online and offline, including when you visit any of our locations (collectively with the Sites, our “Services”). Our Services are owned and/or operated by Choice Financial Group, LLC (sometimes referred to as “we” or “us”). We hope that this Privacy Policy helps clarify how we collect and process your information.

This Privacy Policy describes:

  • The information we collect on or through our Services and how we collect it.
  • How we use and process the information we collect.

PLEASE REVIEW THIS PRIVACY POLICY CAREFULLY BEFORE ACCESSING AND USING OUR SERVICES. When you use our Services or otherwise submit information to us, you consent to the collection and processing of information as described in this Privacy Policy.

If you have not done so already, please also review our Terms & Conditions (“Terms”), which apply to your use of the Sites. The Terms contain provisions that limit our liability to you and require you to resolve any dispute with us through final and binding arbitration on an individual basis and not as part of any class or representative action.

IF YOU DO NOT AGREE TO THE TERMS OF THIS PRIVACY POLICY, THEN PLEASE DO NOT USE OUR SERVICES.

1. CHANGES TO THIS PRIVACY POLICY


The Last Updated Effective Date of this Privacy Policy is set forth at the top of this webpage. As we add new features, we may need to modify this Privacy Policy. Whenever possible, we will provide you with advance written notice of our changes. Your continued use of our Services after the Effective Date constitutes your acceptance of the amended Privacy Policy. The amended Privacy Policy supersedes all previous versions. We will not, however, make retroactive changes that reduce your privacy rights unless you affirmatively agree to those changes.

2. INFORMATION WE COLLECT


“Personal Information” means information that identifies, relates to, describes, is reasonably capable of being associated with, or could be reasonably linked with a particular individual or household.

Depending on how you use our Services, we may collect the following categories of your Personal Information:

  • Direct identifiers and contact data, such as your email address, telephone number, social media profile (if you link your account to our Services) and b. national ID or passport information;
  • Demographic data, such as your gender, your date of birth and your zip code;
  • Professional and employment-related data, such as your employer;
  • Geolocation and other location data, including the precise location of your device and your location as that, may be captured through our security measures used at our offices;
  • Internet and network activity data, such as your browsing activity, search history, IP address, and dates/times you access our Services (as further discussed in Section 3.b. below); and
  • Profile information, such as your newsletter preferences.

We also collect non-identifiable data (such as browser type and device type) and aggregate data sets that show us group-level data and trends about our users and guests (“Non-Identifiable and Aggregate Information”). Non-Identifiable and Aggregate Information does not contain any individual-level data and cannot be used to identify you.

3. HOW WE COLLECT INFORMATION


We collect information that you provide to us and through our Services. The information that we collect and how we process it depends on how and why we collected it. Some information is collected through use of cookies and similar data collection tools (as further discussed in Section 5 below).

Information that You Provide to Choice Financial Group, LLC: You may provide us with your direct identifiers and contact data and demographic information when you contact us for help or information, create an account to use one of our Services or otherwise voluntarily supply your Personal Information to us. We may collect information as otherwise described to you at the point of collection or pursuant to your consent.

Information that We Collect When You Use the Sites: When you use the Sites, we may automatically collect internet and network activity information about how you interact with the Sites, such as your (i) IP address; (ii) domain server; (iii) type of device(s) used to access the Sites; (iv) web browser(s) used to access the Sites; (v) statistics and information associated with the interaction between your browser or device and the Sites; and (vi) referring web page or other source through which you accessed the Sites.

Information Collected from Other Sources: Third parties that assist us with our business operations also collect your direct identifiers and contact information and internet activity information from you and share it with us. For example, we may purchase mailing lists and use email service providers that help us to more effectively administer our communications and marketing programs.

Information Collected from our Mobile App: The Choice Financial Group, LLC mobile app collects geolocation information. If your device is equipped with GPS or can connect with wireless access points or hot spots, or if your device is also a phone that communicates with cell towers or satellites, then your device is able to use these features to determine its precise geographic location. If you have consented using your device’s user interface, the geographic location of your device will be transmitted to our servers in real time any time that the App is running (even if you are not actively using the App or it is minimized on your device). Once you set your device to transmit its location information to us, your device will continue to transmit its location information to us (when it is open) until you set your device to no longer do so. You may at any time opt-out from further allowing us to have access to your device’s location information by accessing the App’s location settings on your device and setting your device not to share its location with us.

4. HOW WE USE, SHARE AND DISCLOSE INFORMATION


a. How We Use Information
We use each of the categories of Personal Information that we collect or that you provide to us to operate, maintain and enhance our Services, including:

To present our Services to you and to customize, improve, and develop content and functionality that helps us better serve your needs;

To operate our business and provide services and products requested by you;

For customer service and to troubleshoot problems;

To facilitate communication between Choice Financial Group, LLC and you;

To prevent, detect and investigate prohibited or illegal activities, such as claims of copyright infringement and security breaches;

To send emails and other communications that display content that we think will interest you, such as news about our products, services and promotions;

To generate statistical information about how users interact with our Services and conduct analyses to support, improve and enhance our Services;

To carry out our obligations and protect our rights arising from any contracts entered into between you and us, including our Terms & Conditions;

To protect the safety, security and legal rights of other users of our Services;

To send you important administrative information regarding our Services, such as changes to this Privacy Policy or our other policies; and

To fulfill any other purpose for which you provide information to us or to which you consent.

We and our business partners also may combine different types of information collected from or about you through various sources, including Personal Information, to create Non-Identifiable and Aggregate Information and use the Non-Identifiable and Aggregated Information for the purposes described in this Privacy Policy.

b. How We Share and Disclose Information

We may share and disclose each category of Personal Information:

With third party service providers that we retain to perform functions on our behalf, such as web hosting, data analyses, and promotion services providers, communication services providers, reservations, and property management providers and technology and data service providers, that have access to Personal Information needed to perform their functions;

To enforce our agreements with other users or third parties, including in connection with claims of copyright infringement;

To protect the safety and security of users and clients.

With companies with which we plan to merge or an acquirer of all or substantially all of Choice Financial Group, LLC assets (we will continue to process information consistent with this Privacy Policy and, when possible, will provide you with notice before Personal Information is transferred or becomes subject to a different privacy policy);

To comply with a subpoena, regulation, binding order of a data protection agency, legal process, governmental request or other legal or regulatory process; and

If we believe you have or are violating our Terms & Conditions or in order to protect or defend Choice Financial Group, LLC rights or property, even without a subpoena, warrant or other court order.

We and our business partners also may share and disclose Non-Identifiable and Aggregate Information for any purpose permitted by law.

5. ONLINE ADVERTISING, DATA COLLECTION AND “DO NOT TRACK”


a. Cookies & Other Data Collection Tools. “Data Collection Tools” means technology, such as cookies and web beacons, that collects information about your use of our Sites and potentially about your activities when you leave our Sites and visit other websites on the Internet.

b. Online Advertising. Our Sites use Data Collection Tools to help manage our online advertising program. These Data Collection Technologies are provided by us as well as our ad management partners and other third parties.

In addition, we and our ad management partners may use these Data Collection Tools to track the actions of users of our Sites, to measure statistics of our marketing efforts, to deliver advertisements on our Sites that may be more relevant to individual consumers and that will improve the consumer experience on our Sites, and to deliver advertisements to users of our Sites when they visit other third-party sites.

We support the Self-Regulatory Principles for Online Behavioral Advertising of the Digital Advertising Alliance (“Principles”). This means that we allow you to exercise choice regarding the collection of information about your online activities over time and across third-party websites for online interest-based advertising purposes. More information about these principles can be found at www.aboutads.info.

c. Opting Out of Interest-Based Advertisements. If you want to “opt out” of receiving online interest-based advertisements, please follow the instructions at www.aboutads.info/choices, or www.networkadvertising.org/choices/. An “opt-out” Cookie will be placed on your device indicating that you do not want to receive interest-based advertisements. If you delete Cookies on your device generally, you will need to opt-out again.

Please note that when you “opt-out” of receiving interest-based advertisements, this does not mean you will no longer see advertisements from us or on our Sites. It means that the online ads that you do see will not be based on your particular interests.

In addition, please note that certain third parties that we do not control may use Data Collection Tools on Sites. When you “opt-out” of receiving interest-based advertisements through one of the links above, these Data Collection Tools may still collect information about your use of our Sites, including for analytics and fraud prevention as well as any other purpose permitted under the principles.

6. INFORMATION PROTECTION


Choice Financial Group, LLC has implemented safeguards intended to protect your information from unauthorized access and use. We also strive to ensure that our agents, contractors and business partners that have access to information in connection with providing services for Choice Financial Group, LLC protect your information. But, while we do work hard to protect your information, we cannot guarantee the privacy or security of your information. DISCLOSURE OF INFORMATION TO CHOICE FINANCIAL GROUP, LLC IS AT YOUR OWN RISK. We urge you to take every precaution to protect your information when you use the Internet or store information on your computer, tablet, or mobile device.

7. LINKS TO OTHER SERVICES


This Privacy Policy applies solely to information collected by or through our Services. As noted in the Terms, our Services may contain links to third-party websites and services, including social media (collectively, “Linked Services”). Linked Services are not under the control of Choice Financial Group, LLC and Choice Financial Group, LLC is not responsible for Linked Services. The inclusion of a link does not imply endorsement by Choice Financial Group, LLC of the Linked Services or any association with the operators of the Linked Services. Choice Financial Group, LLC does not investigate, verify, or monitor the Linked Services. We provide links to Linked Sites for your convenience only. You access Linked Services at your own risk. We encourage you to read about the privacy practices of any Linked Service that you access.

8. THESE SERVICES ARE NOT FOR USE BY CHILDREN


We do not knowingly collect information from minors. To use our Services, you must be the age of legal majority in your place of residence. By using our Services, you hereby represent that you are at least the age of legal majority in your place of residence. All information provided to Choice Financial Group, LLC is treated as if provided by an adult.

If we learn that a minor has submitted information about himself/herself to us, we delete it as soon as possible. If you believe that we have collected Personal Information from a minor, please contact us at youragent@choiceins.com.

9. CALIFORNIA CONSUMER RIGHTS INFORMATION


If you are a resident of California, you may be entitled to the following privacy rights:

a. The right to know. You have the right to request to know (i) the specific pieces of Personal Information we have about you; (ii) the categories of Personal Information we have collected about you in the last 12 months; (iii) the categories of sources from which that Personal Information was collected; (iv) the categories of your Personal Information that we sold or disclosed in the last 12 months; (v) the categories of third parties to whom your Personal Information was sold or disclosed in the last 12 months; and (vi) the purpose for collecting and selling your Personal Information. Generally:

Within the preceding 12 months, we have collected the categories of Personal Information detailed in the “Information We Collect” section above.

We do not and will not sell your Personal Information.

We have not disclosed your Personal Information to third parties within the preceding 12 months.

b. The right to deletion. You have the right to request that we delete the Personal Information that we have collected or maintained about you. We may deny your request under certain circumstances, such as if we need to comply with our legal obligations or complete a transaction for which your Personal Information was collected. If we deny your request for deletion, we will let you know the reason why.

c. The right to opt out of the sale of your Personal Information. You have the right to opt out of the sale of your Personal Information. We do not and will not sell your Personal Information. If we change our business practices, we will update this Privacy Policy, notify you, and honor your right to opt out of the sale of your Personal Information.

d. The right to equal service. If you choose to exercise any of these rights, we will not discriminate against you in any way. If you exercise certain rights, understand that you may be unable to use or access certain features of our services.

You may exercise your right to know and your right to deletion twice a year free of charge. To exercise your right to know or your right to deletion, contact us at youragent@choiceins.com or call us at 855-467-8733.

We will take steps to verify your identity before processing your request to know or request to delete. We will not fulfill your request unless you have provided sufficient information for us to reasonably verify you are the individual about whom we collected Personal Information. If you have any policies with us, we will use our existing account authentication practices to verify your identity. If you do not have any policies with us, we may request additional information about you to verify your identity. We will only use the Personal Information provided in the verification process to verify your identity or authority to make a request and to track and document request responses unless you initially provided the information for another purpose.

You may use an authorized agent to submit a request to know or a request to delete. When we verify your agent’s request, we may verify both your and your agent’s identity and request a signed document from you that authorizes your agent to make the request on your behalf. To protect your Personal Information, we reserve the right to deny a request from an agent that does not submit proof that they have been authorized by you to act on their behalf.

e. Shine the Light – Third Party Marketing: California Civil Code section 1798.83 law permits residents of California to opt-out of Choice Financial Group, LLC disclosure of Personal Information to third parties for their direct marketing purposes. You may choose to opt-out of the sharing of your personal information with third parties for marketing purposes at any time by submitting a request in writing to our contact address below or by emailing us at youragent@choiceins.com. We honor all such opt-out requests and it is our policy not to share personal information with third parties for direct marketing purposes where you have submitted such a request. Please note that this opt-out does not prohibit disclosure made for non-marketing purposes.

Under California Civil Code Section 1789.3, we are required to provide California residents with the following specific consumer rights information:

i. Our Services are owned and/or operated by Choice Financial Group, LLC ,
ii. Unless otherwise expressly stated, our Services are provided without charge.
iii. To file a complaint regarding any of our services or to receive further information regarding use of the services, please send a letter to Choice Insurance Agency, 4664 S Blvd, Virginia Beach, Virginia 23452 or contact us via email at youragent@choiceins.com (with “California Resident Request” as the Subject Line). You also may contact the Complaint Assistance Unit of the Division of Consumer Services of California’s Department of Consumer Affairs in writing at 400 R Street, Suite 1080, Sacramento, California 95814 or by telephone at (916) 445-1254 or (800) 952-5210.

10. DESIGNATED COUNTRIES UNDER GENERAL DATA PROTECTION


Processing Purposes and Data Collection

Choice Financial Group, LLC collects and processes your Personal Information for the purposes set forth above in this Privacy Policy. Choice Financial Group, LLC processing and data collection activities include processing such information as necessary to comply with our legal obligations to you and third parties, safety of our clients, employees and others, and other legitimate business interests. All processing and data collection are pursuant to your consent and may be withdrawn at any time by writing to youragent@choiceins.com. We retain Personal Information about you for the time necessary to accomplish the purpose for which such information was collected, usually for the duration of any contractual relationship and for any period thereafter as legally required or permitted by applicable law. Our retention policies reflect applicable statute of limitation periods and legal requirements.

Each specific basis for the processing your personal information is based upon the purpose for such information will be used as specified below:

a. Collection at offices: When you bind a policy with us, we process your Personal Information (such as your name, address, email address, phone number and the details of your insurance policies) on the basis of our contract to provide you with the services you request. Additionally, we process such data for marketing, surveys and service improvements as specified in the above Privacy Policy.

c. Surveys: Completion of surveys is entirely voluntary. We process the information obtained from surveys based upon your consent and in furtherance of our business interests, including marketing, service improvements and analytics.

d. Social Media: Participation in Choice Financial Group, LLC sponsored social media activities and offerings is voluntary – we process information obtained from social media participation based on your consent and in furtherance of our related business interests, including for marketing, service improvements and analytics and service personalization, as described in our Privacy Policy (above).

e. Direct Marketing and Promotions: We use your Personal Information to send you marketing messages and promotions on the basis of your consent.

Data Provider Rights

Data Provider has the following protections and rights upon request:

1. Access, Correction and Erasure Requests by Data Provider:

  • ask us to confirm whether we are processing your Personal Information
  • receive information on how your data is processed
  • obtain a copy of your Personal Information
  • request that we update or correct your Personal Information
  • request that we delete Personal Information in certain circumstances

2. Right to Object to Processing: You have the right to request that Choice Financial Group, LLC cease processing of your Personal Information:

  • for marketing activities, including profiling
  • for statistical purposes
  • where such processing is based on our legitimate business interests, unless we are able to demonstrate a compelling legitimate basis for such processing or we need to process your Personal Information for the establishment, exercise, or defense of a legal claim

3. Right to Restrict Processing: You have the right to request that Choice Financial Group, LLC limit the processing of your Personal Information:

  • while Choice Financial Group, LLC is evaluating or in the process of responding to a request by you to update or correct your personal information
  • where such processing is unlawful and you do not want Choice Financial Group, LLC to delete your data
  • where Choice Financial Group, LLC no longer requires such data, but you want us to retain the data for the establishment, exercise, or defense of a legal claim
  • where you have submitted an objection to processing based on our legitimate business interests, pending our response to such request

4. Data Portability Requests: You have the right to request that we provide you or a third party that you designate with certain of your Personal Information in a commonly used, machine readable format. Please note, however, that data portability rights apply only to personal information that we have obtained directly from you and only where our processing is based on consent or the performance of a contract.

Submitting Requests: Your requests may be submitted in writing to youragent@choiceins.com, or the Choice Financial Group, LLC ATTN: Marketing Department, 4664 S Blvd Virginia Beach, Virginia 23452. We will respond to all such requests within 30 days of our receipt of the request, unless there are extenuating circumstances, in which event we may take up to 60 days to respond. We will inform you if we expect our response to take longer than 30 days. Please note, however, that certain Personal Information may be exempt from such rights pursuant to applicable data protection laws. In addition, we will not respond to any request unless we are able to appropriately verify the requestor’s identity. We may charge you a reasonable fee for subsequent copies of data that you request.

If you have concerns about our data practices or the exercise of your rights, you may contact Choice Financial Group, LLC at youragent@choiceins.com.

Right to Withdraw Consent: You have the right to withdraw your consent to any processing that we conduct solely based on your consent (such as sending direct marketing materials to your personal email account). You may withdraw your consent to marketing activities by following the instructions on any marketing emails or contacting youragent@choiceins.com.

International Data Transfers: We may transfer the personal information we collect about you pursuant to the purposes described in this Privacy Policy to countries that have been found by the European Commission to not provide adequate protection. We use appropriate safeguards for the transfer of personal information among our affiliates in various jurisdictions.

To opt out or obtain a copy of theses clauses or additional information on transfers, you may send your request to youragent@choiceins.com.

11. INFORMATION TRANSMISSION


Our Services are based in the United States and provided for access and use only by persons located in the United States. Our Services are hosted in the United States and other jurisdictions in which Choice Financial Group, LLC operates. Choice Financial Group, LLC may transfer your personal information to third parties located in another country for purposes of processing, storage or fulfillment. If you are visiting our Services from outside the United States, your information may be transferred to, stored and processed in the United States. The data privacy and protection and other laws of the United States may not be as comprehensive as those in your country. By using our Services, you consent to the transfer of your information to our facilities as described in this Privacy Policy.

12. HOW TO CONTACT US


If you have questions about this Privacy Policy or to request corrections, amendments or deletions to any Personal Information that you have provided through our Services, please contact us at youragent@choiceins.com or call us at 855-467-8733. Choice Financial Group, LLC will use reasonable efforts to supply you with requested Personal Information and correct any factual inaccuracy or delete your Personal Information from our databases. To honor your request, we will need the exact information you wish to correct, amend or delete.