Privacy Policy

Last Modified: March 5, 2025

Brightway Insurance and its subsidiaries, affiliates, and franchisees (collectively, "Brightway" "we," "us," or "our") developed this Privacy Policy ("Privacy Policy" or "Policy") to provide individuals in the United States with information concerning our Personal Information practices, including our collection, usage, and disclosure practices, as well as our privacy and security practices. This Privacy Policy does not apply to workforce-related Personal Information collected from employees or similar individuals.

For purposes of this Privacy Policy, the term "Personal Information" means information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household. The terms "you" and "your" refer to the person reading this Privacy Policy, which may include Brightway customers, potential customers, and subcontractors, as well as individuals working for Brightway's customers, potential customers, and subcontractors; Brightway's job applicants; and individuals that visit our websites.

I. Categories of Personal Information We Collect We have collected the following categories of Personal Information within the last twelve (12) months and/or reasonably anticipate collecting the following categories of Personal Information moving forward:

• Identifiers, such as a real name, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, driver's license number, Social Security Number, or other similar identifiers.

• Personal Information Categories Listed in California Customer Records Statute, such as a name, signature, driver's license or state identification number, address, telephone number, education, employment, employment history, bank account number, credit card number, debit card number, insurance policy number, or other insurance or financial information. Some Personal Information included in this category may overlap with other categories.

• Characteristics of Protected Classifications under California or Federal Law, such as age, veteran or military status, or sex/gender. Some Personal Information included in this category may overlap with other categories.

• Commercial Information, such as records of products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.

• Internet or Other Similar Network Activity Information, such as browsing history, search history, location data, or information on your interaction with a website, application, or advertisement.

• Geolocation Data, such as physical location.

• Professional or Employment-Related Information, such as occupation or current or past job history or performance evaluations.

• Education Information as Defined in the Family Education Rights and Privacy Act, such as student transcripts, GPA, academic evaluations, or other education information.

• Sensitive Personal Information, such as Personal Information that reveals your driver's license, state identification card, Social Security Number, or passport number; your account log-in, financial account, debit card, or credit card number in combination with any required security or access code, password or credentials allowing access to an account. Brightway does not use or disclose Sensitive Personal Information for purposes other than those specified in Section 7027(m) of the CCPA Regulations.

II. Categories of Sources of Personal Information We Collect We may collect the above-described categories of Personal Information from one or more of the following sources:

• You. We collect Personal Information that you provide to us, such as when you contact us by phone, email, or when you fill out Start a Quote Form; subscribe to a marketing email, or other publication; engage us on a transaction; create an online portal account on our websites; or apply for a job.

• Our Automated Information Collection Technologies. We use automated data collection technologies for reporting and analysis purposes. For example, we consider metrics such as how you and others interact with our website and applications, ease of website navigation, and the performance of our marketing efforts. For additional information, see the Cookies & Similar Technologies section, below.

• Your Employer. Your employer may provide us with your Personal Information if (1) your employer is our customer; (2) your employer is our subcontractor; or (3) if you are a job applicant, and we contact your current or former employer in connection with your job application.

• Social Media Platforms and Networks. If you connect or interact with us on social media platforms and networks such as LinkedIn, Facebook, or Instagram ("Social Media Platforms"), for example, by liking our page or sharing something we post, such Social Media Platforms may provide us with information concerning you, such as your name and other Personal Information. In addition, the Social Media Platforms will have access to information about you and your use of the Social Media Platforms. The information that we collect relating to your connections or interactions with us on Social Media Platforms is subject to this Privacy Policy. The information collected by the Social Media Platforms remains subject to the Social Media Platforms' privacy practices.

• State Agencies and Organizations that Make Personal Information Publicly Available. We may collect information about you from state agencies and organizations providing publicly available information.

• Brightway's Third-Party Service Providers and Partners. We may receive information about you from our third-party service providers and partners, including but not limited to our affinity partners, vendors, website hosting providers, website analytics service providers, website content management service providers, and other third parties who enable us to provide you with requested services.

• Insurance Carriers. We may receive information about you from our insurance carrier and broker partners whose insurance products and services we offer to you in our role as an insurance agent.

III. Purposes for Collecting Personal Information

• To respond to inquiries and questions about our services and products.

• To provide you with an insurance quote or related information.

• To provide our insurance carrier partners with information necessary to bind an insurance policy.

• To receive job applications; communicate with job applicants about the status of their applications; verify job applicant identity, qualifications, and experience; evaluate job applicant qualifications and experience; and determine whether applicants are a good fit for the position they are interested in.

• To evaluate our success in pursuing our goal to be an equal opportunity employer.

• To control access to and protect the security of Brightway's offices, parking structures, and other spaces.

• To connect visitors to their Brightway hosts when they arrive, document visits, and enable employees to easily identify visitors in our offices.

• To manage relationships with our customers, franchisees, affinity partners, carriers, and subcontractors.

• To provide requested services and products to our customers; communicate with customers regarding services, and products; collaborate with customers; and invoice customers for services, products, and other expenses.

• To request services and products from our subcontractors; assess the risks, qualifications, and capacity of our subcontractors; collaborate with our subcontractors; and pay our subcontractors for services and products provided.

• To help ensure security and integrity to the extent the use of your Personal Information is reasonably necessary for these purposes.

• To debug, specifically to identify and repair errors that impair existing intended functionality.

• To perform additional services, including maintaining or servicing accounts, providing customer service, processing transactions, verifying customer information, processing customer payments, providing financing, providing analytic services, or providing other services on behalf of Brightway.

• To advertise and market products and services to you.

• To undertake internal research for technological development and demonstration.

• To undertake activities to verify or maintain the quality or safety of a service or device that is owned, manufactured for, or controlled by Brightway, and to improve, upgrade, or enhance the service or device that is owned, manufactured for, or controlled by Brightway.

• To meet our regulatory reporting requirements and comply with our legal and regulatory obligations, including those that require employers and insurance agents/brokers to maintain specified records.

• To respond to law enforcement requests, meet our obligations in legal proceedings and government investigations, and otherwise comply with applicable laws, court orders, and government regulations.

• To investigate any instances of property damage, theft, and other crimes on or near our offices, parking structures, and other spaces, and to assist law enforcement agencies in their investigations of the same.

• To provide information pertinent to an actual or potential merger, acquisition, or other reorganization.

• As necessary or appropriate to protect the rights, property, or safety of Brightway, our customers, or others.

• As otherwise described by Brightway to an individual at or before the time that Brightway collects the individual's Personal Information.

IV. Purposes for Collecting Personal Information

• To respond to inquiries and questions about our services and products.

• To provide you with an insurance quote or related information.

• To provide our insurance carrier partners with information necessary to bind an insurance policy.

• To receive job applications; communicate with job applicants about the status of their applications; verify job applicant identity, qualifications, and experience; evaluate job applicant qualifications and experience; and determine whether applicants are a good fit for the position they are interested in.

• To evaluate our success in pursuing our goal to be an equal opportunity employer.

• To control access to and protect the security of Brightway's offices, parking structures, and other spaces.

• To connect visitors to their Brightway hosts when they arrive, document visits, and enable employees to easily identify visitors in our offices.

• To manage relationships with our customers, franchisees, affinity partners, carriers, and subcontractors.

• To provide requested services and products to our customers; communicate with customers regarding services, and products; collaborate with customers; and invoice customers for services, products, and other expenses.

• To request services and products from our subcontractors; assess the risks, qualifications, and capacity of our subcontractors; collaborate with our subcontractors; and pay our subcontractors for services and products provided.

• To help ensure security and integrity to the extent the use of your Personal Information is reasonably necessary for these purposes.

• To debug, specifically to identify and repair errors that impair existing intended functionality.

• To perform additional services, including maintaining or servicing accounts, providing customer service, processing transactions, verifying customer information, processing customer payments, providing financing, providing analytic services, or providing other services on behalf of Brightway.

• To advertise and market products and services to you.

• To undertake internal research for technological development and demonstration.

• To undertake activities to verify or maintain the quality or safety of a service or device that is owned, manufactured for, or controlled by Brightway, and to improve, upgrade, or enhance the service or device that is owned, manufactured for, or controlled by Brightway.

• To meet our regulatory reporting requirements and comply with our legal and regulatory obligations, including those that require employers and insurance agents/brokers to maintain specified records.

• To respond to law enforcement requests, meet our obligations in legal proceedings and government investigations, and otherwise comply with applicable laws, court orders, and government regulations.

• To investigate any instances of property damage, theft, and other crimes on or near our offices, parking structures, and other spaces, and to assist law enforcement agencies in their investigations of the same.

• To provide information pertinent to an actual or potential merger, acquisition, or other reorganization.

• As necessary or appropriate to protect the rights, property, or safety of Brightway, our customers, or others.

• As otherwise described by Brightway to an individual at or before the time that Brightway collects the individual's Personal Information.

V. Categories of Third Parties to Whom Personal Information is Disclosed

• Data Analytics Providers. We may disclose your Personal Information to third-party analytics service providers who collect and analyze information about your interaction with our website.

• Operating Systems and Platforms. We may disclose your Personal Information to software companies that provide us with operating systems and platforms.

• Social Media Platforms. We may disclose your Personal Information to websites and applications that enable users to participate in content sharing and social networking (e.g., Facebook or LinkedIn).

• Other Third-Party Service Providers, Partners, and Subcontractors that Perform Services on our Behalf. We may disclose Personal Information to other third-party service providers and subcontractors that perform services on our behalf, including but not limited to technology development, marketing, project management, customer service, data storage, security, fraud prevention, recruitment, security camera surveillance and badging, website hosting and website content management, customer relationship management, talent management and recruitment, and other legal and business-related services.

• Insurance Carriers. We disclose Personal Information to our insurance carrier and broker partners whose insurance products and services we offer to you in our role as an insurance agent.

• Governmental Entities and Third Parties in Connection with Legal and Regulatory Matters. We may disclose Personal Information to governmental entities, such as regulatory agencies, law enforcement, and judicial authorities, as well as other third parties providing assistance to us or to other parties in relevant legal and regulatory matters (e.g., attorneys and e-discovery service providers), under any of the following conditions: (a) if we have your consent to do so; (b) to comply with a valid subpoena, legal order, court order, warrant, legal process, or other legal obligation; (c) to enforce or apply any of our terms and conditions, other agreements, or policies; (d) to exchange information with other companies and organizations for the purposes of fraud protection and credit risk reduction; (e) as necessary to pursue available legal remedies or defend legal claims; or (f) as necessary to comply with legal and regulatory requirements.

• Third Parties in Connection with a Potential Reorganization. We may disclose Personal Information to any prospective seller, any prospective buyer, and/or to any third-party service provider assisting Brightway or any prospective seller or buyer in connection with any type of potential reorganization (e.g., a law firm assisting Brightway) in the event of any potential reorganization, including a merger, sale, joint venture, assignment, transfer, or other disposition of all or any portion of Brightway's assets including, without limitation, in connection with any bankruptcy or similar proceeding.

VI. Cookies and Other Similar Technologies As you interact with our websites and applications, we, with assistance from third-party analytics service providers, collect Personal Information pertaining to your use of Brightway's website and applications and the devices and programs from which you access our website and applications ("Usage Data") using cookies and similar technologies.

A. What are Cookies and Other Similar Technologies? Cookies are small computer files sent or accessed from your browser or our applications on the hard drive of your computer, mobile device, or tablet that contain information about your device, such as your user ID, user settings, browsing history, and activities conducted while browsing websites and applications.

B. How do We Use Cookies and Other Similar Technologies? Cookies are essential for the effective operation of our website and applications and help you to navigate our website and applications.

The primary purposes for which cookies are used are: (1) For the effective operation of our website and applications, especially in connection with website and application navigation and online communications; (2) To monitor and improve the quality and user-friendliness of our websites and applications; (3) To monitor the success of our advertising campaigns and marketing-related activities and to conduct additional advertising campaigns and marketing-related activities; and (4) To assist Brightway in detecting and preventing fraud, denial of services attacks, and other malicious activity directed at our websites or through our applications.

C. How Can You Manage Cookies and Other Similar Technologies? If you do not want Usage Data collected through the use of cookies and other similar technologies, there is a procedure in most browsers that allows you to automatically decline many of these technologies, or to be given the choice of declining or accepting them. Cookies that are required to enable core site functionality cannot be disabled without causing substantial website or application functionality issues. To assist in controlling website or application-specific cookies, check the privacy and cookie setting in your preferred browser.

We neither have access to, nor does this Privacy Policy govern, the use of cookies and similar technologies that may be placed on your device by third parties when you access our websites or applications.

VII. Third-Party Privacy Practice Our website and/or applications may provide links to other third-party internet websites as a service to you. We are not responsible for the privacy practices of such other third-party websites. If you link to such a website through our website or applications, you should always review any privacy notice that is available for that website.

VIII. Children's Privacy Our website is not directed to individuals under the age of 13. We do not knowingly collect any Personal Information from users under 13 years of age. No Personal Information should be submitted to our website by any website users under 13 years of age. If we learn that we have collected Personal Information from someone under 13, we will take steps to delete the Personal Information as soon as possible.

IX. Protection of Your Personal Information

We implement technical and organizational measures designed to assist in maintaining the security and confidentiality of Personal Information; safeguarding against anticipated threats to the confidentiality, integrity, and availability of Personal Information; and protecting your Personal Information against accidental or unlawful destruction, loss, alteration, and unauthorized access or disclosure.

However, whenever Personal Information is processed, there is a risk that such data could be lost, misused, modified, hacked, breached, and/or otherwise accessed by an unauthorized third party. No system or online transmission of data is completely secure. In addition to the technical and organizational measures that Brightway has in place to protect your Personal Information, you should use appropriate security measures to protect your Personal Information. If you believe that any Personal Information you provided to us is no longer secure, please notify us immediately at compliance@brightway.com.

X. Retention of Personal Information

Brightway will retain your Personal Information for the time period necessary to fulfill the purposes for which your Personal Information was originally collected or received and to meet our legal or regulatory obligations.

XI. California Notice A. Third-Party Disclosures

We have disclosed the following categories of Personal Information for business purposes within the past twelve (12) months and/or reasonably anticipate disclosing the following categories of Personal Information for business purposes (i.e., the purposes listed in the CCPA and its regulations definition of "business purpose").

We do not currently "sell" or "share" the Personal Information of consumers (i.e., California residents) as those terms are defined in the CCPA. Additionally, Brightway currently has no actual knowledge of selling or sharing the Personal Information of consumers under 16 years of age.

B. CCPA Privacy Rights California residents have certain rights under California privacy law, including but not limited to the California Consumer Privacy Act ("CCPA"), which gives California residents ("consumers" or "you") certain rights and control over their Personal Information. If you are a California resident, you have the following privacy rights under the CCPA:

• Right to Know. You have the right to request that we disclose the Personal Information we have collected about you, including the categories of Personal Information; the categories of sources from which the Personal Information was collected; the business or commercial purposes for collecting, selling, or sharing Personal Information; the categories of third parties to whom we disclose Personal Information; and the specific pieces of Personal Information we have collected about you.

• Right to Request Deletion. You have the right to request deletion of Personal Information about you that we have collected, subject to certain exceptions.

• Right to Request Correction. You have the right to request correction of inaccurate Personal Information that we maintain about you.

• Right to Non-Discrimination. You have the right to not receive discriminatory treatment by a business for exercising your rights under the CCPA.

C. Shine the Light Privacy Rights Under California's "Shine the Light" law, California residents can annually request certain information about the Personal Information, if any, we shared with third parties for their direct marketing purposes in the immediately preceding twelve (12) months. You may request this information by contacting us by email at compliance@brightway.com or by writing us at the following address: 3733 University Blvd. W., Suite 100, Jacksonville, FL 32217, Attn: Compliance Department.

XII. Other Personal Information Rights If you reside in other parts of the world, you may have privacy rights under law(s) applicable to your Personal Information. Please reach out to us if you have any questions about Personal Information rights using the contact information provided in the How to Contact Us Section.

XIII. How to Exercise Privacy Rights

A. General Methods for Submitting Requests

To exercise any of your other rights described in this Privacy Policy, please submit a verifiable consumer request to us through one of the following methods: Submission Methods:

• Emailing us at compliance@brightway.com or

• Calling us at (904) 539-3719.

B. Identity Verification If you are submitting a request pursuant to the CCPA or any other data protection law(s), we will contact you to confirm receipt of your request and request any additional information necessary to verify your request (which may include verification of the requestor's identity ourselves or using a third party service). We verify requests by matching information provided in connection with your request to information contained in our records. Depending on the sensitivity of the request and the varying levels of risk in responding to such request (for example, the risk of responding to a fraudulent or malicious request), we may request further information in order to verify your request. We also reserve the right to verify your request through a third-party verification service. You may designate an authorized agent to make a request under the CCPA on your behalf, provided that you satisfy certain requirements set forth in the CCPA for such authorized agent to make a request on your behalf. We may verify such authorized person's identity using the procedures above.

XIV. Disability Assistance We are committed to taking steps to ensure that this Policy is accessible to everyone. Individuals with difficulty accessing information in this Policy are encouraged to contact us by email at compliance@brightway.com or by calling us at (904) 539-3719.

XV. Do Not Track and Other Similar Technologies We will respond to "do not track" signals or other similar technologies. Although we do not track your online activities over time and across third-party websites or other online services, our website may place analytic or advertising cookies originating from third parties that may be used for such tracking on your computers and devices. These third parties may collect Personal Information relating to your online activities over time and across different websites and applications when you use our websites in order for us to provide you with content that is likely to be of interest to you.

XVI. Privacy Policy Updates We may update this Privacy Policy from time to time. It is our policy to post any changes we make to our Privacy Policy on our website. Any changes will become effective thirty (30) days after our posting of the revised Privacy Policy on our website. The date this Privacy Policy was last updated is identified at the top of the first page. If we make material changes to how we treat the Personal Information that falls within the scope of this Privacy Policy, we will notify you by email or through a prominent notice on the homepage of our website.

XVII. How To Contact Us If you have questions, complaints, or any need for assistance relating to your Personal Information, you may contact our Compliance Department by email at compliance@brightway.com, by phone at: (904) 539-3719, or by writing us at the following address:

3733 University Blvd. W., Suite 100 Jacksonville, FL 32217