Date last updated: 05/24/2023

‍
OVERVIEW

This Privacy Policy describes the collection, use, and disclosure practices with respect to Hightower Holdings (“we,” “us”, “our,” or the “Company”) and its website, www.hightower-holdings.com, and any other websites or platforms that the Company may create in the future (the “Platform”).

The purpose of the Platform is to provide information and tools to licensed insurance agents and prospective insurance agents (“Agents”). We also receive information about individuals who are interested in insurance or financial products (“Consumers”) and make such information available to licensed insurance agents who assist individuals with the purchase of the products. We may also work with “Lead Vendors” – companies that collect inquiries from Consumers and pass such inquiries to Agents and Company representatives. Lead Vendors must obtain appropriate consent from Consumers to be contacted regarding specific products before providing us with such Consumers’ information.

This Privacy Policy uses the term “Personal Information” to describe 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.

HIPAA
Because we facilitate the sale of a diverse range of insurance products, our processing of some information on behalf of our agents may fall under the Health Insurance Portability and Accountability Act (“HIPAA”). Specifically, we act as a Business Associate (as defined by HIPAA) when we receive Protected Health Information (“PHI”) from you(including your name, contact information, date of birth, sex, street address, Medicare number, information about current Medicare policy, ethnicity and race, and other information) in the course of your application to a health plan carrier. For more information about how PHI is used and disclosed, please review the applicable health plan’s Notice of Privacy Practices.

This Privacy Policy applies to personal information that is not covered by HIPAA.

INFORMATION COLLECTED FOR TEXTING PROGRAM
Any information that we collect when you opt into receiving SMS and MMS text messages from us is used solely for the management of such texting communications program. We do not disclose such information to any entities other than our subsidiaries. We also do not transfer your consent to be contacted via the texting program to any other entity. The applicable terms for your participation in the texting program are available here.

PERSONAL INFORMATION WE COLLECT
The table below details the categories of Personal Information that we collect or obtain through the operation of the Platform. The Personal Information described below may be collected about your spouse as well, if you provide such information to us.

CATEGORY EXAMPLES AND SOURCES

• Contact information: We collect your name, phone number, postal address, and email address when you submit a form requesting to be contacted or when you submit an application for enrollment in an insurance product.
• Login credentials: This includes username and password* if you choose to create a profile with us.
• Health Information: We collect supplemental information about your health and healthcare, such as the medication you take, your preferred pharmacy, and your preferred clinician, when you provide such information to us on the Platform. This information is used to identify appropriate Medicare plans for you.
• Internet or other similar network activity: Automatically-collected information on your interaction with the Platform. This may include your browsing history (including the site you came from before visiting our website and the site you went to after leaving our website), duration of browsing session, device ID, and IP address.
• Audio, electronic, or visual information: We may have access to video snippets of users’ online activity, such as clicks and scrolling, that show how users provide consent to be contacted or interact with our Platform. We may also have audio recordings of your conversations with our customer service, sales, or other Company representatives in connection to your inquiries about the Platform.
• Geolocation data: We collect geolocation* from users to ensure the security and integrity of the Platform and provide our services.
• Commercial information: We collect information about the products and services that may interest you or are requested by you.
• Professional or employment-related information: We collect information about your employment when you provide it to us in the course of submitting an application for enrollment in an insurance product.

Types of Personal Information marked with an asterisk (*) may be considered “sensitive” personal information according to some state laws.

We do not collect biometric information.

We intend to keep the above categories of Personal Information for as long as reasonably necessary to achieve the business purposes for which they were collected.

USE OF PERSONAL INFORMATION
We may use or disclose the Personal Information that we collect for one or more of the following purposes:Operate the Platform, including finding appropriate insurance plans and processing your plan enrollment requests;

• Operate the Platform, including finding appropriate insurance plans and processing your plan enrollment requests;
• Communicate with you regarding the Platform;
  
• Connect you with a licensed agent at your request;
  
• Address your inquiries;
  
• Process transactions;
  
• Tailor the content and information that we may send or display to you;
  
• Analyze use of our products and services;
  
• Develop new products and services;
  
• Comply with legal obligations;
  
• Protect our rights, property, and safety or the rights, property, and safety of others;
• Evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by us about our customers is among the assets transferred. You hereby consent to such transfers and we may assign and transfer all of the rights, benefits, duties, and obligations of this Privacy Policy, under the circumstances described in this paragraph.

From time to time, we may contact you via personal phone call, email, and mail, for the purpose of providing announcements, promotional offers, alerts, confirmations, surveys, and/or other general communication. If you would like to stop receiving marketing or promotional communications via email or mail from us, you may opt out of such communications by contacting us at the toll-free number or email address listed below.

We may also contact you via text if you provide your consent to receive text communications on a texting consent page.

SHARING PERSONAL INFORMATION
We may disclose all categories of Personal Information described above in “Personal Information We Collect” to the third parties listed below for the purpose of facilitating the sale of insurance products to individuals who are interested in purchasing such products.

• With Our Service Providers. We may share Personal Information about you with third parties who perform services for us or on our behalf. For example, this may include payment processors or other operating systems or platforms that help us run our services.
• With Our Business Partners. We may share Personal Information (but not Personal Information that you provide when opting into text messaging communications) with the independent licensed agents who are contracted to sell insurance policies with the same carriers as us, and business partners that assist us with analytics, marketing, and advertising.
• With Law Enforcement, Government Agencies, or Parties to a Legal Proceeding. We may share Personal Information with such entities to comply with the law or assist in law enforcement.
• With Our Independent Agents and Advisors. Agents and advisors have access to Personal Information that is provided by you when you request information regarding insurance products.
• With Data Analytics Providers and Advertising Service Providers. Third-party data analytics providers may collect Personal Information about users over time and across different websites, applications, and devices for the purposes of targeted advertising. These providers may collect Personal Information, specifically internet or other similar network activity information, social media information, and/or commercial information in this manner on our Platform. For more information on these third parties, please see the below “Cookie Policy.”
  
  We partner with these third parties to tailor and customize our advertising to Users. The practice of targeted advertising may be considered a “sale” of Personal Information under some state laws. For more information about your choices related to this practice, please see “Rights Regarding Personal Information,” below.
  

COOKIE POLICY
The website on which the Platform is hosted may use cookies, pixel tags, web beacons, and similar technologies to track and enhance user experience. Users’ web browser places cookies on their hard drive for record-keeping purposes and sometimes to track information about them. Cookies can also enable us to track and target the interests of our users to enhance their experience on our website. We may use the following types of cookies: advertising and analytics and social media.

Users may choose to set their web browser to refuse cookies or to alert you when cookies are being sent. If they do so, note that some parts of the Platform may not function properly. Our website does not recognize “Do Not Track” signals, however it may recognize other opt-out preference signals, such as the Global Privacy Control (“GPC”). You may set such a signal through your browser or browser extension.

CHILDREN UNDER THE AGE OF 16
The Platform is not intended for children under 16 years of age. We do not collect information about individuals under the age of 16. No one under age 16 may provide any information through the Platform. We do not knowingly collect personal information from children under 16. If you are under 16, do not use or provide any information through the Platform. If we learn we have collected or received personal information from a child under 16 without verification of parental consent, we will delete that information. If you believe we might have any information from or about a child under 16, please contact us.

RIGHTS REGARDING PERSONAL INFORMATION
You may have the following rights (“Data Subject Rights”) with respect to the Personal Information that we collect or process about you. These rights differ depending on where you live (including specifically in California, Virginia, Colorado, Connecticut, and Utah), but we will endeavor to respect these rights regardless of your place of residence. Please note that we reserve the right to honor your Data Subject Rights as required by applicable law.

• Right to Access and Obtain a Copy: If you ask us, we will confirm whether we are processing your Personal Information and, if so, provide you with a copy of all Personal information you are lawfully entitled to receive along with certain other details. In addition, you may request to know the types of third parties with whom we share your Personal Information, and the categories of Personal Information we share with them.
• Right to Amend: If you believe your Personal Information is inaccurate or incomplete, you are entitled to request that we correct or complete it. If you ask us, and where possible and lawful to do so, we will also tell you with whom we shared your Personal Information so you can contact them directly.
• Right to Delete: You may request that we delete or remove your Personal Information. If we shared your Personal Information with others, we will tell them about the erasure as directed by law.
• Right to Restrict Processing: You may ask us to restrict or ‘block’ the processing of your Personal Information in certain circumstances, such as if we process Personal Information that is considered “sensitive” under applicable state laws or engage in automated decision-making.
• Right to Opt Out of Targeted Advertising: Targeted advertising is the practice of serving you tailored advertisements based your Personal Information gathered across other businesses, websites, applications, or services. You have the right to opt out of this practice.
• Right to Opt Out of sales: Some states consider targeted adverting a “sale” of Personal Information. You may request that we not “sell” your Personal Information.
• Right to Non-discrimination: We will not discriminate against you for exercising these rights, but we may charge a reasonable fee as permitted by law in fulfilling these rights, such as if you request multiple copies of your Personal Information.

If you or your authorized agent wish to exercise any of these Data Subject Rights, please use the following form. Before responding to your request to exercise Data Subject Rights, we may require additional information from you to verify your identity or clarify your specific request. We will try to comply with your request as soon as reasonably practicable and in compliance with applicable law. Where appropriate, we will work with third parties in order to fulfil your request. If we deny any of the above rights, you may have the right to appeal the decision with us by submitting an appeal request to us using the contact information listed below. Additionally, you may have the ability to contact your state’s attorney general if you have concerns about the results of the appeal.

ADDITIONAL NOTICE TO CALIFORNIA RESIDENTS
The following disclosures are made in compliance with the California Consumer Privacy Act (CCPA), as amended. In the past 12 months, we have collected the Personal Information described above, and disclosed it to the third parties listed under the section “Sharing Personal Information.” This information falls into the following categories of Personal Information under the CCPA:

• Identifiers
• Characteristics of protected classifications under California or federal law
• Commercial information
• Geolocation information
• Internet or electronic network activity information
• Employment information
• Sensitive personal information (health information, account log-in credentials, and precise geolocation)
• Categories of Personal Information described in section 1798.80(e) of the California civil code

Because we engage in targeted advertising, we may “sell” Users’ Personal Information identified above (but not any information collected for text campaigns) as defined under some state laws, including California. In the last 12 months, we may have “sold” or “shared” some or all of the above categories of your Personal Information with advertising networks, data analytics vendors, and insurance agents or their representatives. If you wish to opt out of this use of your information email us at managment@Hightower-holdings.com, subject line ”Do Not Sell or Share My Personal Information.”
‍
We do not use or disclose “sensitive” Personal Information, listed above, for purposes other than those specified in Cal. Code Regs. tit. 11, § 7027(m).

ADDITIONAL NOTICE TO NEVADA RESIDENTS
Nevada law permits Nevada residents to request that we not sell their personal information. We do not sell personal information as defined by Nevada law. If you are a resident of Nevada and would like to request that we not sell your information in the future, please contact us by following the steps below in ‘Contact Information.’

CONTACT INFORMATION
If you have any questions or comments about this notice, or the ways in which we collect and use your personal information, please do not hesitate to contact us at:

‍Email: managment@Hightower-holdings.com

‍Address:  8 The Green, Ste 16194, Dover, DE 19901