I. Introduction

Creisoft, Inc. (“we,” “us,” or “our”) respects your privacy and is committed to protecting it through our compliance with this Policy.  This Policy describes the types of information we may collect from you or that you may provide to us, including when you visit our website at www.obieinsurance.com and any successor or affiliated website or subdomain thereof (collectively, our “Website”), and our practices for collecting, using, maintaining, protecting, and disclosing that information. 

This Policy covers us and each of our affiliates, including Obie Insurance Services, LLC (our “Affiliates”).  When we use the terms “we,” “us,” and “our” in this Policy, such terms refer to us and our Affiliates collectively.

This Policy applies to any information we collect through our Website, including any information you submit to us through web forms, e-mails or other electronic messages between you and our Website, and any information about you transferred to our Website from other websites or third parties.  This Policy also applies to any information we collect about you when you e-mail, text or exchange other electronic messages with us or when you interact with messages you receive from us and any information we collect about you offline but that will be processed by automated means using our Website or other services.  This Policy does not apply to any other information we collect by any other means.

Please read this 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, you can choose not to use our Website.  By accessing or using our Website or by otherwise sharing information with us, you agree to this Policy.  This Policy may change from time to time.  When we make changes to this Policy, we will post the updated Policy on our Website and update the Policy’s “last modified” date.  We will also provide notice of any material changes as explained in the section below titled “Changes to Our Privacy Policy.”  Your continued use of our Website after we make changes is deemed to be acceptance of those changes. 

II. Information Collected About You and How It Is Collected

Information We Collect

We collect several types of information from and about users of our Website, including information by which such individuals may be personally identified or information about such individuals that is maintained in a personally identifiable form (collectively, “Personal Information”).  Specifically, we collect:

1. Identifiers, such as your name, postal address, e-mail address, IP address or mobile device ID, account name, and phone number.  
2. Information regarding the property you seek to insure and the owner of such property.
3. Payment information, such as credit card or debit card information, security codes, zip codes (for verification purposes) and other financial information used to process transactions related to products or services obtained through our Website.
4. Geolocation data for purposes of confirming your address information. 

Technical Information

As you navigate through and interact with our Website, we collect certain traffic data, mouse movements and clicks, usage information, and other information about your device and your visit to our Website, such as your device’s operating system and browser type, file information, time-stamped logs regarding access times and duration of visits, the pages of our Website that you visit, text inputs and other interactions you have with our Website (collectively, “Technical Information”).  The technologies we use for this data collection include third-party software, cookies that are stored on your browser or device, small embedded electronic files known as web beacons (also referred to as clear gifs, pixel tags and single-pixel gifs) and other types of embedded code.  We collect Technical Information to manage our content and to improve users’ use of our Website; to count and review the number of visitors to our Website and their usage patterns and interactions with our Website; to track key performance indicators such as pages accessed, frequency of access and other statistical information related to our Website (for example, verifying system and server integrity); to recognize if a visitor is a return visitor to our Website; to store information about a user’s visits; and to remember a user’s preferences.  You can set your browser to refuse all or some browser cookies.  If you choose not to accept cookies, you may be unable to access certain parts or pages of our Website, or certain parts or features of our Website may not function properly.  To learn more about cookies and how to disallow or manage them, go to: www.allaboutcookies.org/. 

How We Collect Information

We primarily collect information, including Personal Information, directly from you when you create an account on our Website, request a quote or complete an application for insurance products, complete a transaction through our Website, register to receive marketing or informational materials from us, correspond with us via e-mail, text message, or telephone or through our Website or request additional services from us (such as customer support services).  We also collect certain information as you use our Website or interact with the e-mails and other electronic messages we send to you (see section above titled “Technical Information”).

In addition, we may obtain certain Personal Information from third parties if we are required to verify information (e.g., for legal or regulatory compliance purposes) or if we need additional information in order to execute transactions or perform services on your behalf.  These third parties may include your financial institution and credit reporting agencies.  

III. How We Use Your Information

Generally

We use the information we collect about you or that you provide to us, including Personal Information, to: 

1. Provide to you, and to improve, our Website and related services and products and their contents.
2. Provide you with information, products or services you request from us.
3. Process your requests, purchases, transactions, and payments, including by transmitting certain of your Personal Information to the third-party payment processor that we use for securely processing payment card purchases, and to prevent transactional fraud.
4. Create, maintain, customize, and secure your account with us.
5. Verify identity and to determine appropriate insurance products.
6. Contact you regarding your account, policies, coverages and other products and services obtained through the Website. 
7. Provide you with support and to respond to your inquiries and customer service and support requests, including to investigate and address your concerns and to monitor and improve our responses.
8. Help maintain the safety, security, and integrity of our Website, databases and other technology assets and our business.
9. Update and maintain customer or e-mail lists.
10. Notify you about changes to our Website, products and services and to contact you about issues you may be having with our Website, products and services. 
11. With respect to Technical Information, fulfill the purposes described in the section above titled “Technical Information.”
12. Respond to lawful requests for information through court orders, subpoenas, warrants and other legal processes or obligations.
13. Enforce any contracts between you and us, including for billing and collection, or for the establishment, exercise or defense of legal claims.
14. 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 a bankruptcy, liquidation, or similar proceeding.
15. Fulfill any other purpose for which you provide the information.
16. Serve any other purpose that we describe when you provide the information and for any other purpose with your consent. 

Use of Personal Information for Marketing Purposes

We use your Personal Information to provide you with marketing and promotional information about our Website and related insurance products and services.  If you do not wish to have your Personal Information used by us to contact you for marketing purposes, you can opt out by sending us an e-mail with your request to support@obieinsurance.com or by clicking on the “Unsubscribe” or similar link in the most recent e-mail you received from us and by following the prompts that appear.  This opt-out does not apply to information provided as a result of an insurance product purchase, product service experience or other transactions (e.g., a purchase confirmation).  

Tracking and “Do Not Track” 

Tracking involves the use of cookies, web beacons, or other embedded code or tracking technologies to collect, analyze and store information on a user’s behavior over time on multiple sites, including information on the sites visited, products viewed, products purchased and other online interactions.  Tracking information can be used to enable companies to make interest-based (behavioral) advertising available to users on multiple sites that they visit.  

We may collect Personal Information about your online activities over time and across third-party sites for tracking purposes when you use our Website. In addition, other parties, including third-party advertisers, ad networks, ad servers, internet providers and mobile device providers, may use cookies, web beacons, or other embedded code or tracking technologies to collect Personal Information about your online activities over time and across third-party sites when you use our Website.  We do not control these third parties’ tracking technologies or how they may be used. If you have any questions about an advertisement, you should contact the responsible advertiser directly.

Our Website does not respond to any “do not track” signals sent by your computer, browser or mobile device, and if your computer, browser or mobile device sends a “do not track” signal to our Website, our Website will not treat you differently from users who do not send such signals.   

Google Analytics

We use Google Analytics to track and analyze certain traffic and usage statistics regarding the use of our Website, such as the number of visitors to our Website, how visitors are navigating to our Website, visitors’ general geographic region information, how long individuals are visiting our Website, and information about the equipment individuals are using to access our Website (e.g., browser version and operating system).  Google Analytics may use a Google Analytics cookie and may collect your IP address or mobile device ID as part of this service (but neither we nor Google Analytics otherwise collects or processes any of your Personal Information in connection with our use of the Google Analytics services).  We use this traffic and usage information to gauge, internally, the effectiveness of our advertising efforts and to make improvements to our Website and our marketing and promotional efforts.

In addition, from time to time we may use one or more of the following Google Analytics Advertising Features: 

1. Remarketing 
2. Google Display Network Impression Reporting
3. Google Analytics Demographics and Interest Reporting
4. Google Ads (an integrated service with Google Analytics)

By enabling these features, we permit Google to collect certain additional traffic and usage data using a Google Advertising cookie and other identifiers not tied to your Personal Information.  This information includes demographic information about our Website visitors and general information about our visitors’ interests, but does not identify our visitors individually.  In fact, we are prohibited by Google policy from using this information to try to identify individual users and from merging non-personally identifiable information obtained from Google with Personal Information we otherwise have about you without obtaining your separate consent.  The purpose of these features is to segment our audience and to better target our advertising and marketing efforts.

For more information, please review the following:

1. Information about Google’s use of cookies: www.policies.google.com/technologies/types 
2. Information about Google’s use of information from sites or apps that use Google’s services: www.policies.google.com/technologies/partner-sites

You can opt out of our use of certain Google Analytics features by updating the “Ads Settings” in your browser (www.adssettings.google.com/authenticated) or mobile device (www.support.google.com/ads/answer/1660762#mob), by visiting the Network Advertising Initiative’s Consumer Opt-Out page at www.optout.networkadvertising.org/, or by visiting Google’s currently available opt-outs over the web at www.tools.google.com/dlpage/gaoptout/.

IV. Disclosure of Your Information

In general, we may disclose Personal Information to our contractors and service providers who need to know such information to provide services or products that we request to support our permitted uses of your Personal Information.  For example, we may disclose certain of your Personal Information in connection with our use of Google Analytics (see the section above titled “Google Analytics”), we may use a third-party cloud-hosting service provider to store certain of your Personal Information securely, and we use a third-party payment processor to process in a secure manner any transactions you make through our Website.  We give these third-party service providers only the information they need to perform the specific services we have requested.  Although we use reasonable precautions to ensure these service providers protect your Personal Information, we cannot guarantee they will protect your Personal Information to the same extent as us. 

In addition, we may disclose Personal Information to insurance companies and other third parties for purposes of obtaining an insurance quote or insurance products and processing and performing other functions related to your insurance transactions.  

We may also disclose your Personal Information to our affiliates or to a buyer or other successor to our business in the event of a sale of equity or assets, reorganization, merger, divestiture or a similar corporate transaction, and in connection with any due diligence review with respect to any of the foregoing transactions.  And we may disclose your Personal Information to comply with a court order or other legal process, including to meet law enforcement requirements or to respond to any government or regulatory request or audit, or to enforce or apply any contracts you have entered into with us, or if we believe disclosure is necessary or appropriate to protect the rights, property, or safety of our customers or others.  

Finally, we may disclose your Personal Information for any other purpose disclosed when the information is provided and for any other purpose with your consent.

V. Users Outside of the United States

 Our Website is hosted in the United States and is provided from the United States.  It is possible that certain information will be stored on servers in multiple other countries on the “cloud” or other similar distributed hosting platforms.  If you are a resident of any country other than the United States, please note that by providing your Personal Information to us, you are consenting to the transfer of your Personal Information to the United States and other jurisdictions and to our use and disclosure of your Personal Information in accordance with this Policy.

VI. California “Shine The Light” Disclosure

The California Civil Code permits California residents with whom we have an established business relationship to request that we provide a list of certain categories of Personal Information that we have disclosed to third parties for their direct marketing purposes during the preceding calendar year.  To make such a request, please send an e-mail to legal@obieinsurance.com or otherwise contact us using the information set forth below.  Please mention that you are making a “California Shine the Light” inquiry.  Please note, however, that we do not currently disclose Personal Information to third parties for their direct marketing purposes.

VII. Nevada Residents

Nevada residents who wish to exercise their sale opt-out rights under Nevada Revised Statutes Chapter 603A may submit a request by contacting us at legal@obieinsurance.com.  Please note, however, that we do not currently sell any Personal Information to third parties within the meaning of such statute.  

VIII. Third-Party Websites

Our Website may include links to blogs, social media and third-party websites.  These third-party sites have their own privacy policies and terms of use and are not controlled by this Policy. You should carefully review any terms, conditions and policies of such third-party sites before visiting them or supplying them with any personal information.  If you follow a link on our Website to any third-party site, any information you provide to that site will be governed by its own terms of use and privacy policy and not this Policy. 

We are not responsible for the privacy or security of any information you provide to a third-party website or the information practices used by any third-party site, including links to any third-party site from our Website.  We make no representations, express or implied, concerning the accuracy, privacy, safety, security, or information practices of any third-party site.  The inclusion of a link to a third-party site on our Website does not constitute any type of endorsement of the linked site by us.  We are not responsible for any loss or damage you may sustain resulting from your use of any third-party website or any information you share with a third-party website.

IX. Individuals Under the Age of 18

Our Website is not intended for individuals under 18 years of age, and no one under the age of 18 may provide any information to us or others on or using our Website.  We do not knowingly collect Personal Information from individuals under the age of 18.  If you are under 18 years of age, do not use our Website or provide any information about yourself to us, including your name, address, telephone number, email address, IP address or mobile device ID, or any username you may use.  If we learn we have collected or received Personal Information from an individual under 18 years of age, we will delete that information.  If you believe we might have any information from or about an individual under the age of 18, please contact us at legal@obieinsurance.com.

X. Data Security

We have implemented measures designed to secure your Personal Information from accidental loss and from unauthorized access, use, alteration and disclosure, including device safeguards and secured files and buildings.  The safety and security of your information also depends on you.  When we have given you (or when you have chosen) a password for access to certain parts of our Website, you are responsible for keeping that password confidential.  We ask you not to share your password with anyone.  

Unfortunately, the transmission of information over the Internet is not completely secure.  Although we have implemented security measures that we think are adequate, we cannot guarantee the security of your Personal Information transmitted to or using our Website.  Any transmission of Personal Information is at your own risk. We are not responsible for the circumvention of any privacy settings or security measures contained on our Website. 

XI. Reviewing and Updating Your Information‍

Keeping your policy and account information up-to-date is very important.  You may review and/or update certain policy and account information by visiting your account page on our Website.  You may review and update other policy and account information by contacting us as provided below.

XII. Changes to Our Privacy Policy

We post any changes we make to our Policy on this page.  If we make material changes to how we collect and use Personal Information, we will notify you by e-mail to the primary e-mail address specified in your account and/or through a notice on the Website home page.  

The date this Policy was last revised is identified at the top of the page.  You are responsible for periodically visiting our Website and this Policy to check for any changes. 

‍XIII. Contact Information‍

We are Creisoft, Inc. and Obie Insurance Services, LLC, collectively.  To ask questions or to submit comments about this Policy and our privacy practices, you may contact us: 

1. Via E-mail: legal@obieinsurance.com
2. Via Telephone: (773) 820-7132
3. Via Postal Mail: Obie Insurance Services, LLC, 167 N Green St, Suite 1360, Chicago, IL 60607, Attn: Legal Department