Afficiency Platform Privacy Policy

Afficiency Inc. (“Afficiency”) provides a platform-as-a-service for delivering life insurance products via API to digital distributors (“platform”). This privacy policy (“Privacy Policy”) explains how we collect, use, and disclose information about you through our website and technology services.

Privacy Practices

When it comes to processing personal data through our platform, we follow the following privacy practices –

Whose personal data is collected by the platform:

  • Website users:

If you submit your information to us via our website (e.g. on a ‘contact us’ form), we will collect and process your personal data solely to provide the service you have requested.

  • Portal users:

Our platform and services include access to specific services and technologies for certain registered users (including insurance agents and insurance carrier partners). We may collect personal information of such users where necessary for the purpose of administering account logins, passwords, and security. We may also share usage statistics and other individual user information with our insurance agency and carrier partners. Our platform collects personal data of these users who access our platform’s portal services via a login username and password.

  • Insurance agents:

Our services include hosting websites on behalf of insurance distributors and agencies, enabling their insurance agents to sell insurance products to consumers. We collect limited personal information of such agents for the purpose of associating such insurance sales with the relevant insurance producer.

  • Insurance purchasers:

Our API and website services enable our insurance distributor and agency partners to sell insurance products to consumers on behalf of insurance carriers. Our platform collects the personal information of such consumers as necessary to complete an insurance application specified by the relevant insurance carrier. Such information is collected in our platform and shared with the relevant insurance carrier for the purpose of decisioning your application for insurance and issuing you a policy.

What personal data is processed through the platform:

The nonpublic personal information we collect may include, but is not limited to, your name, address, telephone number, e-mail address, Social Security number, date of birth and your transaction and experience history with Afficiency. We may use this information in connection with certain aspects of our business. For example, we may use this information to complete your requested transaction or to otherwise manage your relationship with the Afficiency or our insurance company or distribution partners.

Our website and services are not directed toward children. Afficiency does not intend to collect and takes steps to avoid collecting personal information from children, or permanent residents of countries other than the USA, except in the limited scenario of collecting information about child beneficiaries of a life insurance policy or child insureds on a rider to a parent’s life insurance policy.

How we use your information:

We use your personal information primarily to provide the services and products you have requested from us or our insurance agency partners. If you purchase insurance products via our services made available to you by your employer or workplace, we may share information we collect with your employer or workplace for administration purposes.

Disclosure of personal information:

We will not disclose your personal information to anyone outside Afficiency unless: 1) we have received proper consent from you; 2) we are legally permitted to do so; or 3) we reasonably believe, in good faith, that we are legally required to do so. For example, we may provide the information to assist us with various aspects of conducting our business, to comply with laws or industry regulations, and/or to action any request you have made, including the following:

  • Unaffiliated service providers (e.g., data processing or hosting services, fulfillment companies and securities clearinghouses, printers and mailing facilities) engaged by us
  • Unaffiliated service providers (e.g., third-party administrators) engaged by your employer or insurance carrier from whom you have purchased insurance via our services
  • Government agencies, other regulatory bodies and law enforcement officials (e.g., for tax purposes or for reporting suspicious transactions)
  • Other organizations, as permitted or required by law (e.g., for fraud prevention)

Security of your information:

We take information security seriously and use reasonable industry standard physical, electronic, and procedural measures to protect your information. Afficiency conducts periodic information security and privacy risk assessments to address new or changed risks to the personal data processing and rights of data subjects. The security measures we use include, but are not limited to, access controls, encryption, anonymization, etc., as appropriate. Staff involved in the development, maintenance, and support of the platform receive periodical training and updates related to these measures. We contractually require service providers to protect your personal information and use it exclusively for the purpose of performing certain business functions on our behalf. System operations and underlying infrastructure is monitored to detect and respond to any suspicious event that may result in a data breach. Procedures are in place to notify data subjects, supervisory authorities, and other relevant stakeholders of any data breach, should it happen. However, no electronic data transmission or storage of information can be guaranteed to be 100% secure. Please note that we cannot ensure or warrant the security of any information you transmit to us, and you use the Platforms and provide us with your information at your own risk.

Your privacy rights, choice, and access

You control the personal information that you provide to us on our platform, but some personal information is required by us in order for you to obtain services from us or for you to use our platform. If you choose not to provide us with your personal information via our platform when requested, you may not be able to take advantage of some of the services we offer or use some functionality on the platform. Except as provided in the previous section, we will not share your personal information with third parties without your consent.

If you wish to modify, verify, correct, or delete any of your personal information collected through the platform, you may edit your registered user information (if you have a login name and password for our site) or contact us at affigee@afficiency.com. In accordance with our routine record keeping, we may delete certain records that contain personal information you have submitted. We are under no obligation to store such personal information indefinitely and disclaim any liability arising out of, or related to, the destruction of such personal information. It may not always possible to completely remove or delete all of your information from our databases without some residual data because of backups and other reasons. We will retain your information (including geo-location data) for as long as your account is active (if you have a login name and password for our site) or as needed to provide you services. If you wish to cancel your online account or request that we no longer use your information to provide you services through the platform, contact affigee@afficiency.com. We will retain and use your information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.

Consent to processing and transfer of information

The website is governed by and operated in, and in accordance with the laws of the United States. We make no representation that the website is governed by or operated in accordance with the laws of any other nation. By using the website, or providing us with any information, you (a) acknowledge that the website is subject to the laws of the United States, (b) consent to the collection, processing, maintenance and transfer of such information in and to the United States and other applicable territories in which the privacy laws may not be as comprehensive as or equivalent to those in the country where you reside and/or are a citizen, and (c) waive any claims that may arise under those laws.

Changes

We may update this Privacy Policy to reflect changes to our information practices. If we make any material changes we will notify you by email or by means of a notice on our platform prior to the change becoming effective. We encourage you to periodically review this page for the latest information on our privacy practices.

How to report requests, feedbacks, and concerns regarding your personal data:

If you have any questions or concerns about this privacy policy or the practices described herein, please contact us at affigee@afficiency.com.

v2.0 (3/23)

Address

Afficiency, Suite 404
101 Greenwich Street, New York, NY, 10006

 

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