Axis Management Group Holdings, Inc. Subsidiaries and Affiliates (AMGH) Axis Insurance Services, LLC

Privacy Policy

7/31/2023

1. GENERAL INFORMATION
2. CONSENT
3. PERSONAL INFORMATION
4. HOW THIS PRIVACY APPLIES TO YOU BASED ON WHERE YOU LIVE
5. COLLECTION OF YOUR PERSONAL INFORMATION
6. USE OF YOUR PERSONAL INFORMATION
7. SHARING YOUR PERSONAL INFORMATION
8. CHILDREN’S PERSONAL INFORMATION
9. SECURITY OF YOUR PERSONAL INFORMATION
10. THIRD PARTY WEBSITE LINKS
11. DATA RETENTION & DISPOSAL
12. DATA STORAGE & TRANSFERS
13. CHANGES TO THIS POLICY
14. HOW WE MAY CONTACT YOU
15. CONTACT US

Additional Disclosures Based On Where You Live

I. GENERAL INFORMATION

Axis Management Group Holdings, Inc. along with its subsidiaries and affiliates including Axis Insurance Services, LLC, NJ Axis Insurance Services, LLC, Axis Insurance Services of New Jersey, LLC, NJ Axis Insurance Agency, PLRisk Specialty Insurance Agency LLC

This Privacy Policy describes, among other things, the types of information we collect when you use our Services, how we use it, and any rights you may have concerning your Personal Information.

This Privacy Policy is integrated into our Terms & Conditions of Use (“Terms & Conditions”).

Except as otherwise prescribed by applicable law, in the event of any inconsistency between the English language version and local language version of this Privacy Policy, the English Language version will prevail.

II. CONSENT

To the extent permitted by law, by using the Services and providing us with Personal Information (defined below), you agree to the practices described in this Privacy Policy and the that may be provided on our Services and to the updates of policies posted here from time to time. If you withdraw consent, you agree that despite withdrawal AMGH may continue to use your Personal Information previously provided to us to the extent that we are legally or contractually obligated to do so and to the extent necessary to enforce any contractual obligations you may have to us. You also understand that by withdrawing consent we may no longer be able to provide you with services previously available with consent.

If you consented to receiving email communication from AMGH, you will continue to do so unless you unsubscribe. You may choose to opt out of or unsubscribe from receiving future marketing email messages from us. Each marketing email sent from us contains a link with instructions on how to remove yourself from our email list.

III. PERSONAL INFORMATION

In this Privacy Policy, when we use the term “Personal Information,” and except where a different definition is noted, we mean personal information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked with you, directly or indirectly, with a particular consumer as defined under the applicable laws and regulations. Personal Information does not include information that is not covered by applicable privacy laws, including that which cannot be reasonably linked to you, (de-identified or aggregated data) or publicly available information.

When we use the term “Sensitive Information,” we mean Personal Information that is collected and analyzed concerning a consumer’s health, sex life, or sexual orientation, and information that describes a customer’s social security, driver’s license, state identification card, or passport number, a financial account in combination with any access code, password, or credentials allowing access to an account, precise geolocation, racial or ethnic origin, religious or philosophical beliefs, or union membership, contents of mail, email, and text messages unless the business is the intended recipient of the communication, and the consumer’s genetic data. Sensitive Information does not include information that is not covered by applicable privacy laws, including Sensitive Information that is publicly available.

IV. HOW THIS PRIVACY APPLIES TO YOU BASED ON WHERE YOU LIVE

This Privacy Policy is for people living in the United States.

We may choose or be required by law to provide different or additional disclosures relating to the processing of Personal Information about residents of certain countries, regions, or U.S. states.

Depending on where you live and subject to certain exceptions, which may include California, Virginia, Connecticut, Utah, and Colorado, you may have some or all of the following rights:

• Right to Know/Access: The right to request that we disclose to you the Personal Information we collect, use, or disclose, and Personal Information about our data practices.
• Right to Request Correction: The right to request that we correct inaccurate Personal Information that we maintain about you.
• Right to Request Deletion: The right to request that we delete your Personal Information that we have collected from or about you.
• Right to Opt Out: The right to opt out of the sale or sharing of Personal Information or opting out of processing of your Personal Information obtained from your activities on nonaffiliated websites or online applications for the purposes of targeted advertising.
• Right to Limit Use and Disclosure. The right to limit the use and disclosure of sensitive Personal Information.
• Right to Data Portability: The right to receive the Personal Information collected in a format easily understandable and in a usable format.
• Right to Non-Discrimination: The right not to receive discriminatory treatment for exercising your privacy rights.

Click Here for Additional Disclosures based on where you live, and how to exercise the above or other rights as permitted under law.

To submit a request to exercise your rights, and as applicable, to appeal a consumer rights action, please see the Contact Us section

V. COLLECTION OF YOUR PERSONAL INFORMATION

While using our Services, we may collect the following types of Personal Information about you which are described in more detail in the below sections:

1. Personal Information you provide to us
2. Personal Information we may automatically collect
3. Personal Information we may receive from third parties

1. Personal Information You Provide to Us

The Personal Information we may collect about you from you will depend upon the type of Service we are providing or our business relationship.  We may collect Personal Information from your submission of an insurance applications or in connection with other communications or by you directly when requesting information, documents, applications, certificates of insurance, or requesting contact from us.

The following is general overview of the categories of Personal Information we may collect.

• Identifiers
  • Business name
  • Contact information for persons at the business including first and last name, e­mail address, name, home, or work address, and/or telephone number
• Personal Identification Documentation
  • Social Security Number, driver’s license number, passport number, employee identification numbers, insurance policy number, bank account number, etc.
• Background Information
  • Occupation
  • Nationality
  • Hobbies or other background information
• Other Persons’ Information
  • Emergency contact information or relatives or other person’s Information
• Financial and Asset Information
  • Payment information, income, financial information, such as account balances, income information, assets, credit score, credit history and transaction history, tax information, bank information, payment card numbers, expiration dates, and security codes
• Credentials/Account Log-In Information
  • Account username and log in credentials, including unique identifiers such as username and password
• Information Related to Provision of Services
  • Policy, claims, insurance policy number, and other information related to your past claims and related losses, account activity and premium payment history
• Comments, Statements, and Opinions
  • Statements made by or about you
  • Survey or content submissions
  • Reviews submitted on Google or other platforms
  • Reasons why you have selected or heard about our Services
  • When you contact us directly, by email, phone, mail, text, chat, when you post on message boards, blogs or complete an online form, we may record your comments and opinions
• Marketing and Event Information
  • Participation and registration in events and seminars, opt-in marketing selection, and document or resource download references
• Commercial Information
  • Products and Services purchased, transaction information and other data obtained or considered or other purchasing or consuming histories or tendencies
• Sensitive Information
  • Some of the categories of Information that we may collect are special categories of information protected by federal law including your health records (such as your medical history and reports on medical diagnoses, injuries, and treatment) and information about your personal characteristics and circumstances of a sensitive nature such as race, color, sex, age, religion, national origin, disability, citizenship status, and genetic information.
• Job Applicant and Employee Information
  • Resume, occupation, employment status, dependent information, work samples, benefits, competition requirements, educational history, or other information provided in applications for employment, certifications, Such as information about your employing entity, business unit, manager and management reporting structure, job title, function, and the nature of your duties and responsibilities
• Communications
  • Preferences for communications and Services, chats, posts, or interactions and communications with us or our third-party providers
  • Language preferences
  • Records of communications, including emails, notes of phone conversations or other communications
• Preferences
  • Information derived from other Information about you, which could include your preferences, interests, and other information used to personalize your experience
  • Preferences set for notifications, marketing communications and how our website is displayed.
• Consent
  • Additional information as otherwise described to you at the point of collection or pursuant to your consent.
• Other
  • Any other information you choose to directly provide to us in connection with your use of the Services.

You are also responsible for ensuring the accuracy of the Personal Information you submit to us. Submitting inaccurate Personal Information or failing to maintain the accuracy of Personal Information that changes (for example, a change of email address) may disrupt your ability to use our Services, may affect the information you receive from us, and may impact our ability to contact you. You can update your Personal Information at any time by logging into and visiting your user account page.

1. Personal Information We May Automatically Collect About You

Our Services may automatically collect certain Personal Information. We use this information to help us design our Services to better suit our users’ needs and for other business purposes as described in this Privacy Policy. This Personal Information may include:

• System and Device Information
  • We collect information about the computer, tablet, smartphone, or other electronic device you use to connect to our Services.
  • Every computer on the Internet has a unique address called an Internet Protocol (“IP” Address). An IP address is just like a telephone number in that it is a long string of numbers. IP addresses are automatically assigned to all Internet Users by their Internet Service Providers (“ISP”). However, since it would be difficult to remember everyone’s IP address, the Internet allows you to type in an easy to remember name, i.e., a domain name or e-mail address which corresponds to the IP address. When you use the Internet, your IP address, as well as other information is automatically logged by web servers.
  • Along with your IP address, we also collect browser type and language; operating system; platform type; device type; software and hardware attributes; and unique device, advertising, and app identifiers.
  • Internet or other electronic network activity information, including browser and app logs, content you view or engage with, and app, browser, and device information;
  • Domain server from which you are using our Services.
  • Type of computer, web browsers, software, search engine used, operating system, or platform you use.
  • Mobile device information, including the type of device you use, operating system version, your device’s telephone number (if it has one), the device identifier (or “UDID”). This also includes behavior, use, and aggregated usage, performance data, and from where the application was downloaded.
  • Location information related to the IP address of devices used to access the Services, type of browser software, operating system, or mobile device in use, associated region or location data, Internet domain and service provider used, and referring/exit pages from which you linked to our Services.
• Date and Time
  • Date and time of your visit or use of our Services.
• Activity
  • Data identifying the Website pages you visited prior to and after visiting our website or use of our Services.
  • Your movement and activity within the website, which is aggregated with other information.
  • For example, the website from which you came and the website to which you are going when you leave our website, how frequently you access the Services, the time you access the Services and how long you use them for, whether you open emails or click the links contained in emails, whether you access the Services from multiple devices, interaction with email content, access times, error logs, and other similar information, and other actions you take on the Services.
  • Information about files you download, domain names, landing pages, browsing activity, content or ads viewed and clicked, dates and times of access, pages viewed, forms you complete or partially complete, search terms, uploads or downloads, the URL that referred you to our Services.
• Location Related Information
  • Location Data generally, or with your consent, your precise GPS location.
• Social Media
  • Information provided by social networks connected to the Service, in accordance with your privacy settings on the social media platform. The connected social network may provide us with information such as your name, ID, profile picture, network, gender, username, user ID, email address, friend list, age or age range, language, country, friends list, follower list, photos, location, generated contact, and any other information you have agreed it can share or that the social network provides to us. It also includes information you provide to us directly through our Services on social media networking and blogging platforms (e.g., Facebook, Instagram, YouTube, and Twitter).
  • Inferences drawn from any of the information identified above reflecting your preferences and characteristics.

Cookies and Technologies We Use to Collect Personal Information

As set forth in our Privacy Policy, we collect the above Personal Information directly and with third parties and by using certain technologies, such as cookies, web beacons, and other technologies. Third-party service providers, advertisers, and/or partners may also view, edit, or set their own cookies or place web beacons. The use of these technologies by such third parties is subject to their own privacy policies and is not covered by this Privacy Policy, except as required by law.

Cookies

Cookies and similar technologies are small files of letters and numbers that we store on your web browser or the hard drive of your computer or mobile device. Cookies contain information that is transferred to the hard drive of your computer or mobile device and enable the website’s or service provider’s systems to recognize the user’s browser and capture and remember certain information.

Cookies may be sent to your browser’s temporary memory system to assist you in navigating during a particular session only, or a cookie can be sent to your hard drive to serve you better when you return to the website (for example to recognize you when you return to the website, to save your password and to offer you customized content).

There are three types of cookies that we may use:

1. Strictly Necessary: These cookies are essential to enable you to browse our website and use its features. The information collected by these cookies relate to the operation of our website (e.g., website scripting language and security tokens to maintain secure areas of our Site).
2. Performance / Analytics: These cookies collect anonymous information about how you use our website (e.g., which pages you visit most often, whether you receive any error messages, and how you arrived at our Site). Information collected by these cookies is used only to improve your use of our website and never to identify you.
3. Functionality: These cookies remember choices you make (e.g., the country you visit our Services from, your language and any changes you have made to text size or other parts of web pages that you can customize), to improve your experience of our Services and to make your visits and use more tailored and enjoyable. The information these cookies collect may be anonymized and cannot be used to track your browsing activity on other websites.

Most internet browsers are automatically set up to accept cookies. However, if you want to refuse or delete any cookies (or similar technologies), please refer to the help and support area on your internet browser for instructions on how to block or delete cookies. Please note you may not be able to take advantage of all the features of our Site, including any personalized features, if you delete or disable cookies.

You can set your browser to notify you when you receive a “cookie” giving you the opportunity to accept or to refuse it. See “Help” in your browser. Deleting or not accepting cookies will not prevent you from accessing this website or participating on the website. However, if you do not employ the technology your navigation may be less convenient or personalized given the purposes for cookies.

You may refuse to accept browser cookies by activating the appropriate setting on your browser. However, if you select this setting, you may be unable to access certain parts of our Services. Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies when you direct your browser to our website.

Some website browsers have incorporated “Do Not Track” features that send an automated signal to the websites that you visit using that browser.  Currently, the Services do not recognize or respond to these signals.  However, you can adjust your preferences regarding the data we collect using the tools and methods described above.

For more information on managing cookies, please go to www.allaboutcookies.org, or visit www.youronlinechoices.eu or http://www.aboutads.info which have further information about behavioral advertising and online privacy.

Flash Cookies

We may use local shared objects (“LSOs”), also known as Flash cookies, to store your preferences such as volume control or display content based upon what you view on our website to personalize your visit. Third parties, with whom we partner to provide certain features or to display advertising based upon your browsing activity, use Flash cookies to collect and store information. Flash cookies are different from browser cookies because of the amount and type of data stored and the method of storing this data. Cookie management tools provided by your browser will not remove Flash cookies.

For Flash cookies, you can access Flash management tools from Adobe’s website. In addition, some, but not all, browsers provide the ability to remove LSOs within cookie and privacy settings.

Web Beacons

Website pages may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit us, for example, to count users who have visited those pages and for other related statistics (for example, recording the popularity of certain content and verifying system and server integrity). We also use these technical methods to analyze the traffic patterns, such as the frequency with which our users visit various parts of the Services. These technical methods may involve the transmission of information either directly to us or to a third party authorized by us to collect information on our behalf. Our Services may use retargeting pixels from Google, Facebook, and other ad networks. We may also use web beacons in HTML emails that we send to determine whether the recipients have opened those emails and/or clicked on links in those emails.

Analytics

Analytics are tools we use, such as Google Analytics, to help provide us with information about traffic to our website and use of our Services, which Google may share with other services and websites who use the collected data to contextualize and personalize the ads of its own advertising network. Learn more about Google’s Privacy Policy here: https://policies.google.com/privacy?hl=en-US. You can opt-out of having your activity on our Services made available to Google Analytics by installing the Google Analytics opt-out add-on for your web browser by visiting: https://tools.google.com/dlpage/gaoptout for your web browser.

Mobile Application Technologies 

If you access our website and Services through a mobile device, we may automatically collect information about your device, your phone number, and your physical location.

By using our Services, you agree that we may contact you by calling or sending messages to your phone, including messages sent to your personal telephone device, i.e., “Mobile Push Notifications”. You can use the settings on your mobile device to enable or turn off mobile push notifications from us or  Contact Us  directly.

1. Personal Information We May Receive From Third Parties

We may collect additional Personal Information about you from our affiliates, partners or vendors, data brokers, third-party websites, social media platforms, such as, but not limited, to Facebook, Twitter, Instagram, YouTube, LinkedIn (“Social Media Platforms”), and/or sources providing publicly available Personal Information (e.g., from the U.S. Postal Service). We may receive the following:

• Information from reporting agencies and state and federal government agencies, such as finance companies, state motor vehicle departments, insurance departments or other regulators
• Information from other sources, such as medical or health care providers and other third parties with which you or we maintain a relationship
• Information from insurance carriers, regulators, and other industry service providers, and other third parties with which you maintain a relationship (i.e., your employer, financial service, or medical or health providers)

USE OF YOUR PERSONAL INFORMATION

AMGH collects and uses your Personal Information for things that may include, but are not limited to, the following:

• To deliver the Services, including the website and to complete applications, supplements, and other forms necessary for the provision of our Services
• To better understand your needs and provide you with the Services you requested and to personalize or customize your experience
• To fulfill our legitimate business interests in providing or improving our Services and products
• To provide our carrier partners information to underwrite the insurance products we sell
• To provide claims information to carriers, attorney’s adjusters, and others to provide the Services we offer
• To inform you of other products or Services available from AMGH
• To contact you via surveys to conduct research about your opinion of current Services or of potential new Services that may be offered
• To respond to your inquiries and provide you with requested information and other communications, including by email, text, or chats, including providing customer support services
• To allow you to participate in interactive features when you choose to do so
• For general or targeted marketing and advertising purposes, including sending you promotional material or special offers on our behalf or on behalf of our marketing partners and/or their respective affiliates and subsidiaries and other third parties, if you have not already opted-out of receiving such communications
• To deliver location-based Services and comply with territorial requirements and restrictions
• To fulfill contracts we have with you
• Maintain, improve, customize, or administer the Services, perform business analysis, or other internal purposes to improve the quality of our business, the Services, resolve technical problems, or improve security or develop other products and Services
• Comply with our Terms & Conditions
• To assess your application for employment
• Analytics for business purposes and business intelligence, including how Services are used, so that we can improve and expand upon our Services
• To build predictive models, which allow us to improve our Services, as well as tailor our marketing and advertising efforts
• Comply with any applicable laws and regulations and respond to lawful requests
• Operating our business
• For any other purposes disclosed to you at the time we collect your Personal Information and/or pursuant to your consent

VII. SHARING YOUR PERSONAL INFORMATION

We may share Personal Information as set forth in this Privacy Policy and in the following circumstances:

• Third-Party Service Providers. We may share your Personal Information with third-party service providers or data processors that perform certain functions or services on our behalf (such as to host the Services, store or manage the data, perform analyses, process credit card payments, provide customer service, or send communications for us). These third-party service providers will process this data only for purposes specified by us and will be bound by contract to meeting our obligations under applicable law. Third-party service providers may include:
  • carriers and other providers for the purpose of procuring insurance, processing claims, or in general providing customer service
  • third-party vendors that operate software platforms that enable us to provide our Services or inform you of our goods and products, such as Vertafore, Salesforce, HubSpot or social media platforms
  • beneficial parties for Information necessary to resolve client disputes or inquiries
• Disclosure of Personal Information for Legal and Administrative Reasons. We may disclose your Personal Information without notice: (i) when required by law or to comply with a court order, subpoena, search warrant, or other legal process; (ii) to cooperate or undertake an internal or external investigation or audit; (iii) to comply with legal, regulatory or administrative requirements of governmental authorities (including, without limitation, requests from the governmental agency authorities to view your Personal Information); (iv) to protect and defend the rights, property or safety of us, our subsidiaries and affiliates and any of their officers, directors, employees, attorneys, agents, contractors and partners, and the website Service users; (v) to enforce or apply our Terms & Conditions; and (vi) to verify the identity of the user of our Services.
• Personal Information Shared with our Affiliates. We may share your Personal Information with our subsidiaries and affiliates. If you do not want us to share your Personal Information with our subsidiaries and affiliates, please  Contact Us.
• Safety and Security. We may share Personal Information to protect the safety and security of our users and customers, to prevent fraud, abuse, or unauthorized activities, to protect the rights of property of us, third parties, you, or others, including enforcing the terms of our agreements. This may include sharing Personal Information with banks, attorneys, consultants, carriers, or others which are necessary to protect against or prevent fraud, unauthorized transactions, claims or other liability.
• Aggregate Data. We may share general information, aggregated data, or publish Information based on aggregated data. Your Information may be shared if it is made anonymous and aggregated, as in such circumstances the information will cease to be Personal Information. We may aggregate the Personal Information that we collect about you and other individuals by removing any Personal Information that directly identifies a user and by combining this Personal Information. This aggregated information may be used for marketing, research, and the development of and contribution to market knowledge, and financial or operational analysis and planning, and it may be shared with third parties, including business partners and group companies to, for example, carry out analyses and to enhance and improve the quality and delivery of our products and Services.
• Business Purposes. To fulfill our everyday business purposes;
• With Your Consent. We may share Personal Information consistent with this Privacy Policy with your consent.
• Lawful Purpose. For other purposes permitted by law.

VIII. CHILDREN’S PERSONAL INFORMATION

Our Services, including our website and any mobile applications, are intended only for users over the age of eighteen (18). Contact Us if you believe that we have mistakenly or unintentionally collected Personal Information from a child under the age of eighteen (18).

IX. SECURITY OF YOUR PERSONAL INFORMATION

We use commercially reasonable measures to provide our Services. However, you should assume that no data transmitted over the internet or stored or maintained by us or our third-party service providers can be 100% secure. Therefore, although we believe the measures implemented by us reduce the likelihood of security problems to a level appropriate to the type of data involved, we do not promise or guarantee, and you should not expect, that your Personal Information or private communications will always remain private or secure. We do not guarantee that your Personal Information will not be misused by third parties.

We are not responsible for the circumvention of any privacy settings or security features. You agree that we will not have any liability for misuse, access, acquisition, deletion, or disclosure of your Personal Information.

It is your responsibility to maintain the confidentiality of your log-in credentials and unique identifiers used to access the Services.

If you believe that your Personal Information has been accessed or acquired by an unauthorized person, you shall promptly Contact Us so that necessary measures can quickly be taken.

X. THIRD PARTY WEBSITE LINKS

We may occasionally provide links to other websites or online services that are operated by parties other than us who are not under our control or maintained by us (“Third-Party Websites”).

Such Third-Party Websites links do not constitute an endorsement by us of those other websites, the content displayed therein, or the persons or entities associated therewith.  

This Privacy Policy only applies to Personal Information collected by us. You should refer to such Third-Party Websites’ privacy policies and terms of use on their websites and in any other disclosures to determine their respective privacy practices. We are not responsible for the privacy and security practices of those other Third-Party Websites or social media platforms or the Personal Information they may collect (which may include IP address).

XI. DATA RETENTION & DISPOSAL

We will retain your Personal Information for as long as needed to provide you Services. You are also responsible for ensuring the accuracy of the Personal Information you submit to us. Submitting inaccurate Personal Information or failing to maintain the accuracy of Personal Information that changes (for example, a change of email address) may disrupt your ability to use our Services, may affect the information you receive from us, and may impact our ability to contact you. Contact Us if you believe your Personal Information requires correction or updating.

We will also retain and use your Personal Information as necessary to comply with our legal obligations, including any applicable rules on statute of limitations, any relevant litigation, or regulatory investigations, to enable us to defend or bring potential legal claims, resolve disputes, enforce our agreements, and in accordance with our routine record keeping that considers the duration of your use of our Services. We are under no obligation to store such Personal Information indefinitely. We disclaim any liability arising out of, or related to, the disposal of your Personal Information.

XII. DATA STORAGE & TRANSFERS

We operate in the United States and so your Personal Information is stored and retained in the United States.

Your Personal Information may be transferred to and processed in any country where we have offices or in which we engage service providers. These countries may be outside the United States and may have different data protection laws than in the United States.

Thus, we transfer your Personal Information to third parties as in this Privacy Policy, some of these parties may be located in countries other than your own, whose privacy and data protection laws may not be equivalent to those in your country of residence.  When we transfer your Personal Information to other countries we take steps to apply appropriate safeguards, to protect your Personal Information and comply with applicable laws.  

If you have questions about how we transfer your Personal Information, please Contact Us.

XIII. CHANGES TO THIS POLICY

We reserve the right to at any time update, modify, or amend this Privacy Policy to reflect company and customer feedback, changes in our Service offerings, accommodate new technologies, regulatory requirements, or other purposes. If we modify our Privacy Policy, we will update the “Effective Date” and such changes will be effective upon posting. AMGH encourages you to periodically review this Privacy Policy to be informed as it is your obligation to check our current Privacy Policy for any changes.

XIV. HOW WE MAY CONTACT YOU

To the extent permitted under law, you agree that we, our affiliates, and/or third-party service providers with whom we collaborate, and contract may communicate with you regarding our Services via electronic messages, including email, telephone, mobile device push notifications, mailers, and text messages. For example, send you Personal Information relating to our products and Services that we think may be of interest to you, communicate with you about offers, promotions, upcoming events, and other news about products and Services provided by or through us through permissible targeted advertisements offered by us, our subsidiaries, our affiliates, and other business partners.

You may opt out of receiving commercial emails from us by clicking on the opt-out or “unsubscribe” link included in the commercial e-mails you receive.  You may opt-out of receiving marketing text messages from us by replying “STOP.”  You may also opt out of receiving mobile push notifications by turning off push notifications through your device settings. In addition, if you would like to opt-out of receiving push notifications on all your devices, you must turn off the feature on each device.

Please note that opt-out requests may take some time to be effective.  Your opt-out requests will not apply to messages that you request or that are not commercial in nature.  For example, we may contact you concerning any purchases you have made with us, even if you opt out of receiving unsolicited commercial email messages.

You may also have choices available to you to opt out of the collection of your geolocation information, whether collected through location services, Bluetooth, or microphone access technology.  To understand your choices, please visit your device settings.

XV. CONTACT US

If you have any questions about this Privacy Policy, our Services, how we can contact you, or your Personal Information that we have collected about you, please contact us in the following ways:

• Email us: info@axisins.com
• Call us: 888-278-1571
• Write us: Axis Management Group Holdings, Inc.
  ATTN: Compliance Department
  795 Franklin Ave, Suite 210
  Franklin Lakes, NJ 07417

To exercise a privacy right you may also contact us at:

• Email us: info@axisins.com
• Call us: 888-278-1571
• Online: Request for Personal Information on Privacy Form located at:
  https://info.axisins.com/axis-request-for-information-on-privacy

AMGH employees should contact the Human Resources Department for a recent copy of the AMGH privacy policy as it relates to them.

Additional Disclosures Based On Where You Live

This section supplements our Privacy Policy and provides additional disclosures to residents of states that provide additional data privacy rights, which may include California, Virginia, Connecticut, Utah, and Colorado.

• Right to Know/Access: The right to request that we disclose to you the Personal Information we collect, use, or disclose, and information about our data practices.
• Right to Request Correction: The right to request that we correct inaccurate Personal Information that we maintain about you.
• Right to Request Deletion: The right to request that we delete your Personal Information that we have collected from or about you.
• Right to Opt Out: The right to opt out of the sale or sharing of Personal Information or opting out of processing of your Personal Information obtained from your activities on nonaffiliated websites or online applications for the purposes of targeted advertising.
• Right to Limit Use and Disclosure. The right to limit the use and disclosure of Personal Information, including do not sell or share Personal Information.
• Right to Data Portability: The right to receive the Personal Information collected in a format easily understandable and in a usable format.
• Right to Non-Discrimination: The right not to receive discriminatory treatment for exercising your privacy rights.

To exercise a privacy right, please Contact Usor submit your consumer privacy request at https://info.axisins.com/axis-request-for-information-on-privacy

Shine the Light Law

California Civil Code Section 1798.83 also known as the “Shine The Light” law permits California residents to request certain Personal Information and to opt out of the disclosure of your Personal Information by us to third parties for the third parties’ direct marketing purposes. Such residents may also request and obtain from us once a year, free of charge, information about the categories of Personal Information (as defined in the Shine the Light law), if any, that we disclosed in the preceding calendar year to third parties for those third parties’ direct marketing purposes. If you are a California resident and would like to make such a request, please Contact Us

Notice of Financial Incentive

We may offer you certain financial incentives for the collection of your Personal Information and as permitted by law. These incentives may result in different prices, rates, or quality levels. Any permitted financial incentive we offer will reasonably relate to your Personal Information’s value and contain written terms that describe the program’s material aspects. Participation in a financial incentive program requires your prior opt in consent, which you may revoke at any time. Details of the incentive, if applicable, including how to opt in or out and the basis for the value of the incentive, will be provided prior to or at the time of your participation.

For example, we may offer you the opportunity to create an online account with us to be eligible for certain perks and benefits, such as rewards, offers, and discounts. Creating this online account is at no cost and any benefits to you for creating this account are also at no cost.

Metrics

In the last year, we have not received any valid requests under California law for the exercise of privacy rights.

California “Do Not Track” Disclosures

“Do Not Track” (DNT) is a privacy preference you can set in your browser if you do not want online services to collect and share certain kinds of Personal Information about your online activity from this party tracking services.  We respond to DNT signals and follow the W3C standard for responding to DNT signals.  If you would like to set your browser to signal that you would not like to be tracked, please check your browser’s documentation for how to enable those signals. For more information on Do Not Track, please visit allaboutdnt.com.

Process to Make Privacy Right Requests (also known as Data Subject Requests)

1. Number of Requests. You may only make a verifiable consumer request for access or data portability related to your Personal Information twice within a twelve (12) month period.
2. Verifying Requests.
   1. If you request access to or deletion of your Personal Information, we will take steps and may require you to provide certain Personal Information to verify your identity before granting you access to your Personal Information or complying with your request. In addition, if you ask us to provide you with specific pieces of Personal Information, we will require you to sign a declaration under penalty of perjury that you are the consumer whose Personal Information is the subject of the request. If you designate an authorized agent to make a request on your behalf, we may require you to provide the authorized agent written permission to do so and to verify your own identity directly with us (as described above).
   2. The verifiable consumer request must provide sufficient Personal Information that allows us to reasonably verify you are the person about whom we collected Personal Information or an authorized representative. This means that in making a request you may be required to: provide your email and phone number, customer Personal Information, and/or account sign-up authentication or other information needed to verify your identity depending on the sensitivity of the Personal Information that is the subject of the request.
   3. 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. If we are unable to verify your identity, we reserve the right to deny the request. Making a verifiable consumer request does not require you to create an account with us. We will only use Personal Information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.
3. Authorized Agent. You have the right to designate an authorized agent to make any of these requests on your behalf.  If you choose to use an authorized agent to submit a request to know or a request to delete your Personal Information, we may require that you: (1) provide the authorized agent written permission to do so; and (2) verify your own identity directly with us. We will not require these steps if we have received proof that you have provided the authorized agent with a power of attorney. We may deny a request from an agent that does not submit proof that they have been authorized by you to act on your behalf. We may also deny a request from an agent that does not meet the requirements for authorized agents under the law.
4. Once we have verified your identity (and your authorized agent, as applicable), we will respond to your request as appropriate. We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.
5. Response Timing. We use good faith efforts to respond to a verifiable consumer request within forty-five (45) days after its receipt. If we need more time (up to 90 days), we will inform you of the reason and the extension period needed in writing.
6. If you have an account with us, we will deliver our written response to that account. If you do not have an account with us, requests sent electronically through our request form, we will deliver our written response to the verified email associated with the request. If you did not submit the request with us via the online webform, we will deliver our written response by mail or electronically, at your option.
   1. Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request’s receipt.
   2. If we cannot comply with any portion of a request, the response we provide will also explain why, if applicable.
   3. For data portability requests, we will select a commercially reasonable format to provide your Personal Information that is commonly useable and should allow you to transmit the Personal Information from one entity to another entity without hindrance, but we do not guarantee that all formats are useable in all media.
7. Right to Appeal. If we do not act on your privacy request, we will inform you in writing of the reasons for not acting, as well as provide an explanation of any rights you have to appeal the decision.