1. If we are not provided with covered person(s) and organization(s)’s personal information we will be unable to accomplish certain necessary tasks and may be unable to communicate with and may deny the first-named insured’s insurance application because we are unable to assess the risks involved, therefore we must collect and maintain, with the first-named insured’s consent, the first-named insured’s personal information, including, but not limited to:
   1. Identifying information and contact data, including but not limited to:
      1. Legal name, signature, date of birth,
      2. Residential and mailing address, email address, online identifiers, phone number;
      3. Passwords and system credentials,
      4. Activity records, driving history, photographs
      5. Employment history, professional qualifications, licenses, affiliations;
      6. Relationship to insured parties or claimants;
      7. Time or cause of death, injury, or disability, if applicable
      8. Global positioning data, internet protocol address;
      9. Motor vehicle records, loss history records;
      10. Biometric information;
   2. Government issued identification, including but not limited to:
      1. Social Security Number, national insurance number;
      2. Passport number, tax identification number;
      3. Government issued identification numbers including but not limited military identification or driver’s license;
   3. Financial and account information, including but not limited to:
      1. Payment card details, bank account numbers, financial account identifiers;
      2. Credit history, credit score, and income data;
      3. Investment, asset, or home valuation data;
   4. Medical and health related information, including but not limited to:
      1. Medical and health history;
      2. Details of injury, health, disability, or medical procedures;
      3. Lifestyle habits including but not limited to smoking, alcohol, or other recreational drug use;
   5. Sensitive personal information:
      1. Information provided via third party marketing partners affiliated with professional, trade, religious, political, or community organizations
      2. Criminal history or civil litigation records for fraud prevention and investigation;
      3. Sanctions;
   6. Demographic data, including but not limited to:
      1. Physical characteristics, descriptions, or education level;
      2. Age, race or color, national origin, citizenship, religion or cred, marital status, medical condition, physical or mental disability, sex, gender, pregnancy status, sexual orientation, or veteran or military status;
      3. Marital status;
      4. Familial status, family members and their relation to you;
   7. Professional or employment information, including but not limited to:
      1. Previous and current employer;
      2. Job title;
      3. Salary;
      4. Employment benefit option;
      5. Professional licenses;
      6. Educational or professional qualifications;
      7. Professional and trade association membership and standing;
   8. Commercial information;
      1. Commercial website and public social media information;
      2. Public customer reviews;
   9. Claims related information, including but not limited to:
      1. Previous and current claims information;
      2. Insurance policy numbers;
      3. Medical or health inforamion;
      4. Health insurance information;
      5. Information received from anti-fraud databases concerning you;
      6. Third-party appraisals, engineering, adjustment, expert opinion or other reports
   10. Telephonic communications, including but not limited to audio recordings of inbound and outbound telephone interactions with customer service representatives and call center personnel;
   11. Visual media;
       1. Photographic and video content captured or received in the course of insurance-related activities, including but not limited to:
          1. Claims assessment, investigations, processing; or
          2. Settlement, dispute resolution, and other legally permissible purposes;
   12. Crime prevention and investigative data;
       1. Information obtained and shared with industry partners and regulatory bodies for the purpose of detecting, investigating, and preventing criminal activity;
       2. Including but not limited to historical data on prior claims, policyholder behavior, and other relevant interactions;
   13. Marketing and engagement data, including but not limited to;
       1. User-submitted preferences regarding marketing communications;
       2. Responses to promotional campaigns, contests, and surveys;
       3. Feedback provided through customer satisfaction initiatives; 
   14. Any information you voluntarily share with us when you contact our customer service or otherwise engage with us;

1. Hudson Bailey Insurance Services, Inc. retains Personal Information only for as long as necessary to fulfill the purposes for which it was collected, or as required by applicable legal, regulatory, or contractual obligations. 
   1. Retention periods vary depending on the nature of the data and the context of its collection for example:
      1. Claims and policy data will be retained for a minimum of 7 years post-policy expiration or claim resolution, in accordance with insurance regulatory requirements;
      2. Financial records will be retained for 7–10 years to comply with tax, audit, and financial reporting obligations;
      3. Telephonic and visual recordings may be retained for up to 2 years, unless extended for legal or compliance purposes;
      4. Marketing and engagement data will be retained until consent is withdrawn or the data is deemed no longer relevant, subject to periodic review; and
      5. Sensitive personal information will be retained only as long as necessary for the specific purpose for which it was collected, and securely deleted thereafter.
   2. Upon expiration of the applicable retention period, Personal Information is securely deleted, anonymized, or otherwise rendered inaccessible, in accordance with industry best practices and applicable data protection laws.

Hudson Bailey Insurance Services, Inc. utilizes Personal Information for the following operational, legal, and strategic purposes:

1. Customer and Stakeholder Communication
   1. Responding to inquiries and service requests
   2. Disseminating updates regarding policy changes, terms of service, and administrative notices
2. Product and Service Delivery
   1. Underwriting, eligibility assessment, and claims management
   2. Dispute resolution and customer support
3. Operational Optimization
   1. Enhancing product and service quality
   2. Staff training and performance monitoring
   3. Ensuring cybersecurity and data integrity
4. Financial Transactions
   1. Payment processing, billing, and collections
   2. Evaluation of financing and installment eligibility
5. Risk Management and Compliance
   1. Fraud detection and prevention
   2. Commercial risk analysis
   3. Compliance with anti-money laundering and anti-terrorism regulations
6. Research and Analytics
   1. Customer segmentation and behavioral analysis
   2. Business intelligence and strategic planning
7. Marketing and Personalization
   1. Delivery of targeted marketing communications
   2. Customization of user experience across digital platforms
8. Social and Promotional Engagement
   1. Administration of contests, sweepstakes, and promotional events
   2. Enabling social sharing features
9. Infrastructure and Governance
   1. IT systems management, data hosting, and business continuity planning
   2. Internal audits, financial reporting, and document management
10. Legal and Regulatory Obligations
    1. Responding to lawful requests from authorities
    2. Establishing and defending legal claims
    3. Protecting corporate assets, personnel, and stakeholders
11. Artificial Intelligence (AI) Utilization
    1. AI technologies may be employed by Hudson Bailey Insurance Services, Inc. or its authorized service providers to process Personal Information for the purposes outlined above, including risk assessment, fraud detection, customer support, and personalization.

1. International personal information storage and transmission
   1. Given the global scope of Hudson Bailey Insurance Services, Inc.'s operations, Personal Information may be transferred across international borders to facilitate the purposes outlined in this Privacy Policy. 
   2. Such transfers may be necessary for:
      1. Processing international insurance claims (e.g., travel or expatriate policies)
      2. Delivering emergency medical assistance services abroad
      3. Supporting cross-border business operations and customer service
      4. Engaging with affiliated entities, third-party service providers, and business partners
      5. Complying with legal obligations and responding to requests from governmental or regulatory authorities
   3. These transfers may involve jurisdictions that do not offer data protection standards equivalent to those in the country of your residence. 
      1. By submitting Personal Information to Hudson Bailey Insurance Services, Inc.—whether via our Online Services, direct communications, or email correspondence to any "@hudsonbaileyins.com" address;
      2. You acknowledge and consent to the collection, processing, disclosure, and international transfer of your data to and within the United States and other applicable jurisdictions.
   4. All email communications directed to "@hudsonbaileyins.com" addresses are routed through infrastructure located in the United States, and may be subject to U.S. laws and regulations.
   5. Hudson Bailey Insurance Services, Inc. implements appropriate safeguards to ensure that international data transfers comply with applicable legal requirements, including but not limited to:
      1. Standard Contractual Clauses (SCCs) approved by relevant regulatory authorities
      2. Data Processing Agreements (DPAs) with third-party processors
      3. Binding Corporate Rules (BCRs) where applicable
      4. Risk assessments and due diligence on cross-border data flows

1. Hudson Bailey Insurance Services, Inc. may disclose Personal Information to internal and external entities in accordance with applicable legal, regulatory, and contractual obligations. 
   1. Those entities include but are not limited to:
      1. Affiliated Entities
         1. Personal Information may be shared with Hudson Bailey Insurance Services, Inc. group companies for operational, administrative, and compliance purposes.
      2. Insurance Ecosystem Participants
         1. Disclosures may be made to:
         2. Insurers, reinsurers, brokers, intermediaries, and agents
         3. Appointed representatives and distribution partners
         4. Financial institutions and securities firms
      3. External Service Providers
         1. Personal Information may be shared with:
            1. Medical professionals, emergency service providers
            2. Legal, actuarial, audit, and consulting firms
            3. IT infrastructure and software vendors
            4. Call center and customer support providers
            5. Marketing and analytics firms
            6. Financial institutions and payment processors
            7. Claims administrators, adjusters, and investigators
            8. Engineering, construction, and forensic consultants
            9. Translation and document management providers
      4. Social Media and Connected Accounts
         1. If you link your Hudson Bailey Insurance Services, Inc. Online Services account with third-party social media platforms, Personal Information may be shared with:
         2. Social media account providers
         3. Other users of the platform
         4. Individuals within your social network
      5. Technology and Device Ecosystem Providers
         1. Personal Information submitted via our mobile applications may be shared with providers of internet-connected devices, operating systems, and associated software.
      6. Governmental and Legal Entities
         1. Disclosures may be made to:
            1. Governmental, regulatory, and law enforcement authorities
            2. Courts and legal representatives
            3. Civil and criminal legal process participants
      7. Other Third Parties
         1. Personal Information may also be shared with:
         2. Emergency responders
         3. Retailers, travel carriers, and medical networks
         4. Credit bureaus and reporting agencies
         5. Individuals involved in insurance-related incidents
         6. Prospective buyers or partners in corporate transactions
      8. Public Forums and User-Generated Content
         1. Information voluntarily disclosed via public forums may become publicly accessible. 
         2. Users are advised to exercise discretion when posting Personal Information.

1. Hudson Bailey Insurance Services, Inc. implements a comprehensive set of technical, physical, legal, and organizational safeguards designed to protect Personal Information against unauthorized access, disclosure, alteration, and destruction. 
2. These measures are aligned with applicable data protection laws, cybersecurity standards, and industry best practices.
3. Security Controls Include:
   1. Technical Measures: Encryption, secure access protocols, intrusion detection systems, endpoint protection, and vulnerability management.
   2. Organizational Measures: Role-based access controls, employee training, incident response protocols, and data governance policies.
   3. Physical Measures: Secure data centers, access-controlled facilities, and environmental safeguards.
   4. Legal Measures: Binding contractual obligations with third parties, including Data Processing Agreements and confidentiality clauses.
4. Despite these efforts, no data transmission over public networks or electronic storage systems can be guaranteed to be 100% secure. 
   1. Users are advised to exercise caution when transmitting sensitive information electronically.
5. If you suspect that your interaction with Hudson Bailey Insurance Services, Inc. is no longer secure—such as a potential compromise of your Personal Information—please notify us immediately. 
   1. Refer to the “Who to Contact About Your Personal Information” section for contact details.
6. Security Incident Notification
   1. In the event Hudson Bailey Insurance Services, Inc. determines that the security of Personal Information in its possession or control may have been compromised, we will:
      1. Assess the scope and impact of the incident
      2. Notify affected individuals as promptly as possible, consistent with legal and regulatory obligations
      3. Use available contact information (e.g., email) to communicate breach notifications, where appropriate
7. Personal Information of Third Parties
8. If you provide Personal Information to Hudson Bailey Insurance Services, Inc. about other individuals (e.g., dependents, employees, or business associates), you are responsible for:
   1. Informing those individuals of the contents of this Privacy Policy and any applicable Hudson Bailey Insurance Services, Inc. Privacy Notices
   2. Obtaining any legally required consent for the collection, use, and disclosure of their Personal Information in accordance with this Privacy Policy

1. Hudson Bailey Insurance Services, Inc. provides data subjects with clear and recurring opportunities to manage their marketing communication preferences in accordance with applicable data protection regulations (e.g., GDPR, CCPA).
2. Preference Management: Individuals may specify, update, or revoke their marketing preferences through the following mechanisms:
3. Email Communications: Each marketing-related email includes a standardized “unsubscribe” hyperlink, enabling recipients to opt out of future marketing communications.
4. Direct Requests: Preferences may be submitted or updated by contacting our Privacy Office via email at Privacy@hudsonbaileyins.com.
5. We endeavor to process opt-out requests within a commercially reasonable timeframe, typically within 10 business days of receipt. During this period, users may continue to receive marketing communications initiated prior to the completion of the opt-out process.
6. Limitations of Opt-Out: Please note:
   1. Opting out of Hudson Bailey Insurance Services, Inc. marketing communications does not affect the delivery of transactional or administrative messages, such as policy updates, billing notices, or service-related alerts, which are necessary for the operation of our services and cannot be disabled.
   2. Opt-out requests apply prospectively. We are unable to retroactively remove Personal Information from the databases of third parties to whom data has already been lawfully disclosed prior to the opt-out request.

1. Hudson Bailey Insurance Services, Inc. maintains a strict data classification and handling policy for Social Security Numbers (SSNs), recognizing them as highly sensitive personal identifiers. 
   1. SSNs collected in the course of business operations—whether related to customers, employees, or third parties—are treated as confidential data and are subject to enhanced safeguards, including:
   2. Access Controls: SSNs are accessible only to authorized personnel with a legitimate business need, governed by role-based access policies.
   3. Technical Safeguards: SSNs are protected using encryption, secure transmission protocols, and secure storage mechanisms.
   4. Physical Security: Paper records containing SSNs are stored in access-controlled environments and disposed of securely.
   5. Disclosure Restrictions: SSNs are not disclosed to third parties except where legally required or expressly permitted under applicable federal, state, or international laws and regulations.
2. Hudson Bailey Insurance Services, Inc. also requires all third-party service providers who may process SSNs on its behalf to adhere to equivalent security and confidentiality standards, as defined in applicable Data Processing Agreements (DPAs).
3. Questions, Concerns, and Data Subject Requests
   1. For inquiries regarding the processing of Personal Information, including SSNs, or to exercise your rights under applicable data protection laws (e.g., access, correction, deletion, restriction, objection), please contact us using the details provided in the “Who to Contact About Your Personal Information” section of this Privacy Policy.
   2. We are committed to responding to all legitimate requests and concerns in a timely and compliant manner, consistent with our internal data governance protocols and applicable regulatory requirements.

1. In addition to Personal Information, Hudson Bailey Insurance Services, Inc. collects and processes Other Information through its Online Services. 
2. “Other Information” refers to data that does not, on its own, directly identify a specific individual. 
3. This includes, but is not limited to:
   1. Device and Browser Metadata: IP address, device type, operating system and version, screen resolution, browser type and version, language settings, and time zone.
   2. Application Usage Metrics: Timestamps of access, session duration, feature interactions, and download activity.
   3. Tracking Technologies: Data collected via cookies, pixel tags, web beacons, and similar technologies.
   4. Demographic and Preference Data: Non-identifiable information voluntarily provided by users (e.g., age range, interests, preferred language).
4. Aggregated Analytics: Statistical summaries derived from multiple users that do not contain identifiable data.
   1. Methods of Collection: Hudson Bailey Insurance Services, Inc. and its authorized third-party service providers may collect Other Information through the following mechanisms:
   2. Browser and Device Interactions
   3. Information is automatically collected when users access our Online Services via web browsers or connected devices. This includes:
   4. IP address and geolocation approximation
   5. Device manufacturer and model
   6. Operating system and browser specifications
   7. Access timestamps and navigation patterns
   8. This data is used to ensure compatibility, optimize performance, and enhance user experience across platforms.
5. Mobile Application Usage: when users download and interact with Hudson Bailey Insurance Services, Inc. mobile applications, we may collect:
   1. Device identifiers and operating system details
   2. Application usage logs
   3. Server access timestamps
   4. Downloaded content and feature utilization
6. This information supports application functionality, diagnostics, and user experience optimization.

1. Hudson Bailey Insurance Services, Inc. employs various client-side tracking technologies—including pixel tags, web beacons, clear GIFs, and similar mechanisms—across its online services and HTML-formatted email communications. 
2. These technologies serve multiple analytical and operational purposes, including:
   1. Monitoring user interactions across multiple devices
   2. Measuring the effectiveness of digital marketing campaigns
   3. Collecting statistical data on service usage and email engagement (e.g., open rates, click-through rates)
   4. In certain cases, data collected via these technologies may be linked to personally identifiable information (PII) to enhance personalization, improve service delivery, and support internal analytics.
3. Adobe Omniture Analytics
   1. We utilize Adobe’s Omniture analytics platform, which integrates cookies and web beacons to provide detailed insights into user behavior on our website.
   2.  This includes:
      1. Tracking page views, navigation paths, and interaction patterns
      2. Identifying trends in content consumption and feature usage
      3. Supporting continuous improvement of site performance and user experience
   3. Adobe is contractually prohibited from using the data collected on our behalf for any purpose other than providing analytics services to Hudson Bailey Insurance Services, Inc. 
      1. Users who wish to opt out of Adobe Omniture tracking may do so by visiting the Omniture Privacy Policy and Opt-Out Page.

1. Hudson Bailey Insurance Services, Inc. may engage interest-based advertising service providers to deliver, customize, and measure the performance of advertisements across websites and mobile applications. 
2. These services may be informed by:
   1. Your interactions with Hudson Bailey Insurance Services, Inc. both online and offline
   2. Behavioral data collected across multiple devices (e.g., desktop, mobile, tablet)
   3. Third-party data sources
3. To facilitate this, service providers may deploy cookies, pixel tags, web beacons, and other tracking technologies to collect usage data from both Hudson Bailey Insurance Services, Inc. online services and third-party platforms. 
   1. These technologies may also be used to recognize users across devices, enabling consistent ad targeting and frequency capping.
   2. In some cases, service providers may match personal information (e.g., email address or customer ID) provided by Hudson Bailey Insurance Services, Inc. with your IP address to deliver targeted advertisements across the web. 
   3. This process helps ensure that Hudson Bailey Insurance Services, Inc. advertisements are relevant and aligned with user interests.
4. Opt-Out Mechanisms: Users who wish to opt out of interest-based advertising and cross-device tracking may do so via the following industry-standard platforms:
   1. Desktop and Mobile Web Browsers:
      1. Visit www.aboutads.info/choices or www.networkadvertising.org/managing/opt_out.asp to opt out on the specific device and browser used to access the opt-out page.
   2. Mobile Applications:
      1. Download the AppChoices app from www.aboutads.info/appchoices to manage opt-out preferences within mobile apps.

1. Hudson Bailey Insurance Services, Inc. may collect the physical location of your device through various technologies, including but not limited to GPS (Global Positioning System), cellular network triangulation, and Wi-Fi signal analysis. 
   1. This geolocation data may be used for the following purposes:
   2. To deliver personalized, location-based services and content
   3. To enhance user experience by tailoring offerings based on geographic context
   4. To support marketing initiatives, including sharing location data—combined with advertising interaction data and other collected information—with authorized marketing partners for the purpose of delivering targeted content and evaluating campaign effectiveness
   5. In certain scenarios, users may be given the option to enable or disable the collection and/or sharing of location data. However, opting out may limit the availability or functionality of location-dependent services and content.
2. Additionally, when users engage with Hudson Bailey Insurance Services, Inc. mobile applications, we may collect precise geolocation data to facilitate services such as:
   1. Travel assistance
   2. Emergency support
   3. Other client-specific service offerings
3. This precise location data may also be shared with insurance clients and affiliated entities for purposes including:
   1. Delivery of contracted services
   2. Enhancement of actuarial modeling and pricing tools
   3. Development of risk management programs for commercial insurance clients
4. Opt-Out Options: users may opt out of the collection and sharing of precise geolocation data by:
   1. Uninstalling the mobile application
   2. Disabling location permissions via the device’s operating system settings
   3. Following opt-out instructions provided in the privacy notice within the mobile application

1. Voluntary Information Submission
   1. Hudson Bailey Insurance Services, Inc. may collect certain types of information—such as your geographic location or preferred communication method—when you voluntarily provide it through interactions with our online services. 
   2. Unless this data is combined with personally identifiable information (PII), it is treated as non-identifiable and does not individually identify you.
2. Aggregated Data Usage
   1. We may aggregate non-identifiable data for analytical and operational purposes. 
   2. For example, we may calculate the percentage of users associated with a specific telephone area code or analyze usage trends across demographic segments. 
   3. Aggregated data is used to improve service delivery, optimize user experience, and support strategic decision-making.
3. Use and Disclosure of Other Information
   1. Unless restricted by applicable law, Hudson Bailey Insurance Services, Inc. may use and disclose Other Information (i.e., information that does not individually identify you) for any lawful purpose. 
   2. If applicable law requires us to treat Other Information as Personal Information, or if we combine Other Information with Personal Information, then such data will be handled in accordance with the standards and practices outlined for Personal Information, including those described in the “Other Information We Collect” section.

1. This Privacy Policy applies solely to the data collection and processing activities of Hudson Bailey Insurance Services, Inc. and does not extend to the privacy practices of third parties. 
   1. We are not responsible for the privacy, data handling, or security policies of any third-party entities, including those operating websites or services that may be linked from Hudson Bailey Insurance Services, Inc. online platforms. 
   2. The presence of such links does not constitute an endorsement of the third-party site or its content by Hudson Bailey Insurance Services, Inc. or its affiliated entities.
2. Furthermore, we disclaim responsibility for the data collection, usage, and disclosure practices—including security protocols—of external organizations such as:
   1. Social media platforms (e.g., Facebook)
   2. Operating system providers (e.g., Apple, Google, Microsoft, RIM)
   3. Wireless service providers
   4. Device manufacturers
   5. Software application developers
3. This includes any Personal Information you may choose to share with these entities through interactions with our mobile applications or social media pages. 
   1. Users are encouraged to review the privacy policies of these third parties to understand how their data may be handled.

1. Hudson Bailey Insurance Services, Inc. online services are not intended for individuals under the age of eighteen (18). 
2. We do not knowingly collect, process, or store Personal Information from individuals in this age group. 
3. If you are under 18 years of age, you are requested not to submit any Personal Information through any Hudson Bailey Insurance Services, Inc. digital platform or service.

1. Hudson Bailey Insurance Services, Inc. reviews and updates this Privacy Policy on a regular basis to reflect changes in business operations, legal requirements, and data processing practices. 
2. We reserve the right to modify this Privacy Policy at any time.
3. Any updates will be posted to our website, and we encourage users to review the policy periodically to stay informed about how we protect and use personal information.
4. To determine when this Privacy Policy was last revised, please refer to the “LAST UPDATED” date indicated at the top of the document.

California privacy rights: