Privacy Policy
Last Modified: October 11, 2024
Summary
We have written this Privacy Policy to disclose what information we collect online and how this data may be used. If you have questions about this Privacy Policy, please contact compliance@brightway.com.
This Privacy Policy describes the types of information we may collect from you or that you may provide when you visit any Brightway Insurance website using the domain brightway.com or brightwaydifference.com (our "Website") and our practices for collecting, using, maintaining, protecting, and disclosing that information.
Scope of Privacy Policy
This policy applies to information we collect on this Website, and in any email, text, and other electronic messages between you and this Website. It does not apply to information collected by us offline or through any other means, including on any other website operated by Brightway Insurance or any third party (including our affiliates and subsidiaries). The Brightway Insurance website may contain links to other websites. We are not responsible for the content, privacy policy or practices of these third-party websites. Be advised, the links on the Brightway Insurance website to other websites are provided solely as a convenience to users of this site, and you should use them at your own risk. SMS/MMS consent or phone numbers for the purpose of SMS/MMS is not shared with third parties other than Brightway Insurance’s affiliates or its franchisees (and if you are an existing customer of a Brightway Insurance franchisee, consent will only be shared with that franchisee and not with any other franchisee).
Please read this Privacy Policy carefully to understand our policies and practices regarding your information and how we will treat it. If you do not agree with our policies and practices, your choice is not to use our Website. By accessing or using this Website, you agree to this Privacy Policy. This Privacy Policy may change from time to time. It is our policy to post any changes we make to our Privacy Policy on this page. Your continued use of this Website after we make changes is deemed to be acceptance of those changes, so please check this page periodically for updates. The date the Privacy Policy was last revised is identified at the top of the page.
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
Our Website collects 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. We may also collect personal information that you input onto the Website, or that we are able to obtain independently. However, we will use any data that we collect for our internal business purposes and not to sell or provide such information to third parties.
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, without limitation:
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 you, 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 to you.
The technologies we use for this automatic data collection may include cookies. A cookie is a small file placed on the hard drive of your computer. 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 Website. 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. We may also use third party services, such as Google Analytics, to automatically collect data regarding usage of 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 also communicate with you via SMS/MMS if you opt-in to our text messaging program. The terms of use can be found at brightway.com/sms-terms, including information about how to opt-out.
We may disclose aggregated information about our users, and information that does not identify any individual, without restriction.
We may disclose personal information that we collect or you provide as described in this Privacy Policy:
To our subsidiaries and affiliates.
To franchisees, affinity partners, carriers, 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, carriers, 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:
Tracking Technologies and Advertising. You can set your browser to refuse all or some browser cookies, or to alert you when cookies are being sent. If you disable or refuse cookies, please note that some parts of this site may then be inaccessible or not function properly.
Your California Privacy Rights
If you are a California resident, California law may provide you with additional rights regarding our use of your personal information. The California Consumer Privacy Act (CCPA) grants California consumers certain rights with respect to personal information that is held by a business. This Section of the Privacy Policy applies solely to all visitors, users, and others who reside in the State of California. Any terms defined in the CCPA have the same meaning when used in this Section of the Privacy Policy.
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.
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: -identifiers, such as: your real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, Social Security number, driver’s license number, or passport number; -biographical information, such as: age, race, educational records, marital status, sex, and military status; -information related to your insurance policy, including: your policy number, and records of personal property, products or services purchased or considered; and -payment information, including your bank account number, credit card number, debit card number or other financial information We reserve the right to disclose all of the nonpublic personal information about consumers that we collect. When you are no longer our customer, we continue to share certain of your information with third parties, as described in this notice. |
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: |
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For our everyday business purposes, such as: -to process, effectuate or enforce transactions you have authorized; -to coordinate with insurance carriers and between franchisees and home office; -to find replacement coverage if a carrier declines to renew your policy; -to maintain your account(s); -to comply with state and federal regulations; -to verify, correct and store your policy information; and -to respond to court orders and legal investigations. |
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 | |
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Who is providing this notice? | Brightway Insurance, LLC 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 franchise@brightway.com to request a copy of our most recent FDD. |
What we do | |
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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: compliance@brightway.com. |
How does Brightway collect my personal information? | We collect your personal information, for example, when you: - request a quote or purchase a policy; - pay your bills; - renew, cancel or make changes to a policy; or - use your credit or debit card Brightway and Brightway Franchisees collect personal information from one another to carry out the purposes described in this Notice. We also collect your personal information from other companies. |
Why can’t I limit all sharing? | Federal law gives you the right to limit only: - sharing for affiliates’ everyday business purposes—information about your creditworthiness - affiliates from using your information to market to you; and - sharing for nonaffiliates to market to you State laws and individual companies may give you additional rights to limit sharing. |
Definitions | |
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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, LLC and the Brightway Franchisees. |
Affiliates Companies related by common ownership or control. Currently, our only affiliate is First City Insurers, LLC. All franchisees are not affiliates but instead are independent contractors that have entered into an agreement with us. See above. | Currently, our only affiliate is First City Insurers, LLC. All franchisees are not affiliates but instead are independent contractors that have entered into an agreement with us. See above. |
Nonaffiliates Companies not related by common ownership or control. | Brightway Franchisees (see above). Customer service outsourcing companies, including staffing companies and their designees, such as Patra; Brightway customer service center support companies; 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; Independent contractors providing consultation and management services; and Insurance carriers and managing general agents; and Other third-party vendors that assist us in marketing or providing other services to customers, Brightway Franchisees, or prospective customers or franchisees. 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). |
Joint marketing 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. We may also engage in joint marketing with Brightway Franchisees or with our insurance carriers. |
The chart below describes the categories of personal information Brightway has or may collect from a consumer.
Categories of personal information collected | Examples | Collected |
Personal Identifiers | A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, Social Security number, driver’s license number, passport number, or other similar identifiers. | Yes |
Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)) | A name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver’s license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information. Some personal information included in this category may overlap with other categories. | Yes |
Characteristics of protected class | Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information). | Yes |
Commercial information | Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies. | Yes |
Biometric information | Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as, fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data. | No |
Internet or other similar network activity | Browsing history, search history, information on a consumer’s interaction with a website, application, or advertisement. | Yes |
Geolocation data | Physical location or movements. | No |
Multimedia Sensory data | Audio, electronic, visual, thermal, olfactory, or similar information. | No |
Employment information | Current or past job history or performance evaluations. | Yes |
Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)) | Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records. | Yes |
Inferences drawn from other personal information. | Profile reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes. | No |
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 call us at 844-533-1149 or email to compliance@brightway.com.
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.
Non-Discrimination
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.
Data Security
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.
Our servers are maintained in the United States of America ("USA"). By using the Website, you freely and specifically give us your consent to export your personal information to the USA and to store and use it in the USA as specified in this Privacy Policy. You understand that data stored in the USA may be subject to lawful requests by the courts or law enforcement authorities in the USA.
Privacy Policy Changes
We have the sole discretion to change, modify, add, or remove portions of this Privacy Policy from time to time. New versions of this Privacy Policy will be posted here. Our collection, use and disclosure of your information will be governed by the version of this Privacy Policy in effect at the time of such collection, use or disclosure. Your continued use of the Website following the posting of any changes to this Privacy Policy means that you accept such changes.
Contact Us
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.