Our Website is not intended for children under 16 years of age. No one under age 16 should provide any information to the Website. We do not knowingly collect personal information from children under 16. If you are under 16, do not provide any information on this Website or provide any information about yourself to us, including your name, address, telephone number, or email address.
Information We Collect and How We Collect It
You may visit the Website on the Internet without providing us with any personal information. However, our Website does collect traffic information such as domains that come to our site, time spent on site, etc. This information is aggregated to provide us with statistics and demographics. Brightway Insurance only collects personal information if you choose to provide that information to us.
For example, the Brightway Insurance Website includes a Start a Quote Form that you may use to provide your contact information (such as name, email address, phone number, address and state) to request more information about becoming a Brightway customer or getting a customized quote. You are under no obligation to provide information via the Start a Quote Form. Should you choose to use the form, we will use the information you supply to provide you with information about a quote or contact from Brightway.
The information we collect on or through our Website may include:
- Information that you provide by filling in forms on our Website, such as the Start a Quote Form described above.
- Records and copies of your correspondence (including email addresses), if you contact us.
- Details of transactions you carry out through our Website.
You also may provide information either on the Website or on another related site (such as a Google listing for a Brightway Insurance agency) that will be posted on public areas of the Website, or transmitted to other users of the Website or third parties (collectively, "User Contributions"). Your User Contributions are posted on and transmitted to others at your own risk, and please be aware that no security measures are perfect or impenetrable. Additionally, we cannot control the actions of other users of the Website with whom you may choose to share your User Contributions. Therefore, we cannot and do not guarantee that your User Contributions will not be viewed by unauthorized persons.
As you navigate through and interact with our Website, we may use automatic data collection technologies to collect certain information about your equipment, browsing actions, and patterns, including:
- Details of your visits to our Website, including traffic data, location data, logs, and other communication data and the resources that you access and use on the Website.
- Information about your computer and internet connection, including your IP address, operating system, and browser type.
The information we collect automatically is only statistical data and does not include personal information, but we may maintain it or associate it with personal information we collect in other ways or receive from third parties. It helps us to improve our Website and to deliver a better and more personalized service, including by enabling us to:
- Estimate our audience size and usage patterns.
- Store information about your preferences, allowing us to customize our Website according to your individual interests.
- Recognize you when you return to our Website.
How We Use Your Information
We use information that we collect about you or that you provide to us, including any personal information:
- To present our Website and its contents to you.
- To provide you with information, products, or services that you request from us.
- To fulfill any other purpose for which you provide it.
- To notify you about changes to our Website or any products or services we offer or provide though it.
- In any other way we may describe when you provide the information.
- For any other purpose with your consent.
We may also use your information to contact you about our own and third-parties' goods and services that may be of interest to you. We will communicate with you via email, and if you do not want us to use your information in this way, please use the opt-out mechanism in the email communication.
We may disclose aggregated information about our users, and information that does not identify any individual, without restriction.
- To our subsidiaries and affiliates.
- To franchisees, affinity partners, and third parties (such as vendors) we use to support our business and who are bound by contractual obligations to keep personal information confidential.
- To a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of Brightway Insurance's assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by Brightway Insurance about our Website users is among the assets transferred.
- To third parties to market their products or services to you if you have consented to these disclosures.
- To fulfill the purpose for which you provide it (such as to obtain an insurance quote).
- For any other purpose disclosed by us when you provide the information.
- With your consent.
We may also disclose your personal information:
- To comply with any court order, law, or legal process, including to respond to any government or regulatory request.
- If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of Brightway Insurance, our customers, franchisees, affinity partners or others. This includes exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction.
We strive to provide you with choices regarding the personal information you provide to us. We have created mechanisms to provide you with the following control over your information:
Your California Privacy Rights
Personal Information Collection & Disclosure
We collect information that identifies, relates to, describes, references, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer, household, or device ("personal information"). Personal information does not include publicly available information from government records, deidentified or aggregated consumer information, or other information excluded from the CCPA's scope.
The chart below describes the categories of personal information Brightway has or may collect from a consumer.
|FACTS||WHAT DO BRIGHTWAY AND BRIGHTWAY FRANCHISEES DO WITH YOUR PERSONAL INFORMATION?|
|Why?||Companies in the insurance industry may choose or be required to share certain information personal to you. 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:
|How?||All insurance companies need to share customers’ personal information to run their everyday business. In the section below we list the reasons Brightway chooses or is required to share this information, and whether you can limit this sharing.|
|Reasons we share your personal information:|
|For our everyday business purposes, such as:
|For our marketing purposes—
to offer our products and services to you
|To Nonaffiliates as permitted by law|
|For joint marketing with other financial/insurance companies, including Nonaffiliated affinity partners|
|For our affiliates’ everyday business purposes—
to assist our affiliate First City Insurers to perform its responsibilities as managing general agent (MGA) for certain of our customers
|Questions?||Call (844) 533-1149 or email CustomerRequest@brightway.com|
|Who we are|
|Who is providing this notice?||Brightway Insurance, Inc. and the franchisees operating in the Brightway Insurance franchise system and under the BRIGHTWAY INSURANCE proprietary marks. A complete list of all franchisees is included in our annual Franchise Disclosure Document (“FDD”), a copy of which will be provided to you upon request. Contact email@example.com to request a copy of our most recent FDD.|
|What we do|
|How do Brightway and Brightway Franchisees protect my personal information?||To protect your personal information from unauthorized access and use, we use security measures that comply with federal law. These measures include computer safeguards and secured files and buildings. More information regarding our personal information security policies is contained in our Cybersecurity Policy, which you may request via email at: firstname.lastname@example.org|
|How does Brightway collect my personal information?||We collect your personal information, for example, when you:
|Why can’t I limit all sharing?||Federal law gives you the right to limit only:
|Brightway Franchisees||All franchisees are independent contractors that have entered into an agreement with us, pursuant to which our franchisees operate under our marks and in accordance with our operating standards and procedures. See “Who We Are” section above. All references to “we” or “us” in this Notice are made by or in reference to both Brightway Insurance, Inc. and the Brightway Franchisees.|
Companies related by common ownership or control.
|First City Insurers, LLC|
Companies not related by common ownership or control.
|Customer service outsourcing companies, such as CXIS;
Brightway customer service center support companies, such as Envision;
Data governance and regulatory compliance companies, such as Campaign Monitor;
Insurance policy transaction technology companies, such as DocuSign and Microsoft
Insurance quoters and raters, such as EZLynx
All disclosures currently made to Nonaffiliates are authorized under §§ 248.14 and 248.15 (17 CFR PART 248). We reserve the right to disclose your personal information to Nonaffiliates in the future for reasons other than those authorized under §§ 248.14 and 248.15. These future disclosures may include any categories of information described under the “What?” heading of this Notice, and these disclosures may be made to Nonaffiliates falling within one of the categories described in this section (though not necessarily to a company specifically named herein).
A formal agreement between nonaffiliated companies that together market financial/insurance products or services to you.
|Currently, we have a comprehensive agreement with Vystar, an affinity partner, which includes provisions authorizing certain joint marketing activities.|
Sale of Information
Brightway Insurance does not sell your information. In the event we later decide to sell your personal information, we will implement a procedure for you to opt-out of the sale of your personal information.
Your Rights and Choices
The CCPA provides California residents with specific rights regarding their personal information. This section describes your CCPA rights and explains how to exercise those rights.
Access to Specific Information and Data Portability Rights
You have the right to request that we disclose certain information to you about our collection and use of your personal information over the past 12 months. Once we receive and confirm your verifiable consumer request, we will disclose to you:
- The categories of personal information we collected about you.
- The categories of sources for the personal information we collected about you.
- Our business or commercial purpose for collecting or selling that personal information.
- The categories of third parties with whom we share that personal information.
- The specific pieces of personal information we collected about you (also called a data portability request).
- If we sold or disclosed your personal information for a business purpose, two separate lists disclosing:
- sales, identifying the personal information categories that each category of recipient purchased; and
- disclosures for a business purpose, identifying the personal information categories that each category of recipient obtained.
Deletion Request Rights
You have the right to request that we delete any of your personal information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request, we will delete (and direct our service providers to delete) your personal information from our records, unless an exception applies. We may deny your deletion request if retaining the information is necessary for us or our service providers to:
- Complete the transaction for which we collected the personal information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, fulfill the terms of a written warranty or product recall conducted in accordance with federal law, or otherwise perform our contract with you.
- Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
- Debug products to identify and repair errors that impair existing intended functionality.
- Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
- Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et. seq.).
- Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information's deletion may likely render impossible or seriously impair the research's achievement, if you previously provided informed consent.
- Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
- Comply with a legal obligation.
- Make other internal and lawful uses of that information that are compatible with the context in which you provided it.
Exercising Your Rights
If you are a California consumer and would like to submit a verifiable consumer request in respect to the rights outlined above, please contact us at TBD CCPA phone number/TBD CCPA email address.
Only you, or someone legally authorized to act on your behalf, may make a verifiable consumer request related to your personal information. You may also make a verifiable consumer request on behalf of your minor child.
You may only make a verifiable consumer request for access or data portability twice within a 12-month period. The verifiable consumer request must:
- Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative.
- Describe the request with sufficient detail that allows us to properly understand, evaluate, and respond to it.
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. 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.
We endeavor to respond to a verifiable consumer request within 45 days of its receipt. If we require more time (up to 90 days), we will inform you of the reason and extension period in writing. We will deliver our written response by mail or electronically, at your option.
Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request's receipt. The response we provide will also explain the reasons we cannot comply with a request, if applicable.
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.
Brightway will not discriminate against a consumer because the choice was made to exercise a right granted within the provisions of the California Consumer Privacy Act (CCPA). This includes:
- Denying goods or services.
- Charging different prices or rates for goods or services, including the use of discounts or other benefits or imposing penalties.
- Providing a different level or quality of goods or services to the consumer
- Suggesting that the consumer will receive a different price or rate for goods or services or a different level or quality of services.
We have implemented measures designed to secure your personal information from accidental loss and from unauthorized access, use, alteration, and disclosure.
To ensure that your data remains secure, we enforce several security protocols, including:
- SSL and AES encryption
- Industry-standard virus and intrusion prevention/detection technology
- A distributed-hosting strategy, including public and private cloud
- Our partners and data centers use PCI/DSS, SSAE 16/ISAE, SOC 1 Type 2, SOC 2 Type 2, and SOC 3 Type 2 compliance
Unfortunately, the transmission of information via the Internet is not completely secure. Although we do our best to protect your personal information, we cannot guarantee the security of your personal information transmitted to our Website. Any transmission of personal information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on the Website.
Servers in the U.S.A.
If you are a California consumer and would like to submit a request in respect to the rights outlined in the California Consumer Privacy Act (CCPA) contact us at (844) 533-1149 or CCPARequest@brightway.com.