PRIVACY POLICY
Version: 1.0v Effective from August 5, 2026
WE VALUE YOUR PRIVACY AND TAKE PROTECTING IT SERIOUSLY!
Please read this Privacy Policy carefully before providing any of Your Personal information and/or using the Website!
HereSure LLC, registration number: 10627005, having its registered address at 1521 Concord Pike, Suite 201, Wilmington, Delaware 19803, USA («HereSure», «Company», «We», «Us» or «Our»), understands that Your privacy is important to You and is committed to being transparent about the technologies it uses and the ways in which it Processes Your Personal information.
This Privacy Policy (the «Privacy Policy», or «Policy») describes how the Personal information You provide to Us is collected, used, disclosed, stored, and protected, as well as the ways in which You may access information regarding Your Personal Information and exercise other rights and choices available to You.
The main purpose of the Privacy Policy is to help You understand how We Process and protect Your Personal Information when You use the website https://heresureprotect.com/, including the webpages operated by HereSure that link to this Privacy Policy (collectively, the «Website»), contact or communicate with Us, or provide Personal Information in connection with an inquiry, employment application, engagement as an insurance agent or independent contractor, or another professional opportunity offered by HereSure.
By accessing and using the Website through any mobile phone, tablet, computer, laptop, or other device, or by providing any of Your Personal information to Us, including through a contact form, recruitment application form, CV submission, or another available communication channel, You, as a visitor, applicant, or other person interacting with the Website («User»,«You», «Your» or «Yourself»), confirm that:
- You have read and understood this Privacy Policy;
- the Personal information You provide to Us is accurate and relates to You or is otherwise lawfully provided by You; and
- You have reached the age at which the laws applicable to You permit You to provide Your Personal information and, where required, Consent to its Processing. In any event, You must be at least 18 years old to submit an application for employment, engagement as an insurance agent or independent contractor, or another professional opportunity through the Website.
This Privacy Policy should be read together with Our Terms & Conditions (the «Terms»), which govern Your access to and use of the Website.
As We encourage You to read this document attentively before using the Website, We assume that all Users have done so and agreed to its provisions. If You do not agree or cannot confirm the above, You must immediately stop using the Website. In this case, You must (a) contact Us and request the deletion of Your Personal information; (b) leave the Website and not use it.
TABLE OF CONTENTS:
1. DEFINITIONS
2. SCOPE OF THE PRIVACY POLICY
3. TYPES OF PERSONAL INFORMATION THAT WE PROCESS
4. RECRUITMENT AND CANDIDATE SELECTION
5. LEGAL BASIS WE RELY ON TO PROCESS YOUR PERSONAL INFORMATION
6. PURPOSES OF PERSONAL INFORMATION PROCESSING
7. PRIVACY RIGHTS OF USERS
8. INFORMATION SECURITY
9. STORING AND DELETION OF PERSONAL INFORMATION
10. PERMITTED DISCLOSURE
11. RIGHT TO APPEAL
12. CHILDREN’S PRIVACY
13. COOKIES AND OTHER TRACKING TECHNOLOGIES
14. PERSONAL INFORMATION THAT WE SHARE, SELL, OR USE FOR TARGETED ADVERTISING
15. CONTROLS FOR DO-NOT-TRACK FEATURES
16. ADDITIONAL U.S. DISCLOSURES
17. MARKETING AND INFORMATIONAL COMMUNICATIONS
18. CHANGES TO THE PRIVACY POLICY
19. CONTACT US
1. DEFINITIONS
For the purposes of the Privacy Policy, the capitalized words shall have the meanings ascribed to them under the following conditions. Any use of the following definitions in the singular or plural, capitalized form shall be deemed interchangeable and, accordingly, to mean the same thing.
1.1. «Applicant» means an individual who submits an application through the Careers section of the Website for employment, engagement as an insurance agent or independent contractor, or another professional opportunity offered by HereSure.
1.2. «Consent» means any freely given, specific, informed, and unambiguous indication by which You agree to a particular Processing activity, where such Consent is required under applicable law.
1.3. «Controller» means the person or entity that, alone or jointly with others, determines the purposes and means of Processing Personal Information. With respect to the Personal Information covered by this Privacy Policy, HereSure acts as the Controller to the extent this term is recognized under applicable law.
1.4. «Personal Information» means any information that identifies, relates to, describes, or is linked or reasonably linkable to an identified or identifiable individual and, where applicable under relevant law, a household. Personal Information does not include information that is lawfully considered publicly available, aggregated, or deidentified under applicable law.
1.5. «Processor» means the Company or any other entity or individual that Processes Personal information on behalf of the Controller according to the Controller’s instructions, without determining the purposes or means of the Processing.
1.6. «Processing» means any operation or set of operations that are performed on Personal information or on sets of Personal information, whether or not by automated means. The terms «Process», «Processes», and «Processed» will be construed accordingly.
1.7. «Third Party» means any entity or individual, other than the User, Controller, or Processor, that receives or interacts with Personal information for purposes not directly governed by the Controller’s instructions.
1.8. «Website» means https://heresureprotect.com/, including any webpages operated by HereSure that link to this Privacy Policy.
1.9. Any capitalized terms used in this Privacy Policy that are not expressly defined herein shall have the meanings assigned to them in the Terms & Conditions of the Company.
2. SCOPE OF THE PRIVACY POLICY
2.1. This Privacy Policy describes the Processing of Personal Information provided or collected through the Website.
2.2. The Privacy Policy applies solely to the Personal Information collected through the Website. Once You are redirected to a Third-Party website, platform, software, or service, the Privacy Policy no longer governs the collection, use, or disclosure of Your Personal Information. We do not have control over, nor are We responsible for, the privacy practices or content of any Third-Party websites or services. We encourage You to review the applicable privacy policies before providing Personal Information to or otherwise interacting with any Third Party.
2.3. The Privacy Policy applies to the following people:
a. Users who visit, browse, access, or otherwise interact with the Website;
b. individuals who submit an inquiry or contact form through the Website;
c. individuals who contact, provide feedback, submit a complaint, or otherwise communicate with Us by email, telephone, or another available communication channel;
d. Applicants who submit an application for employment, engagement as an insurance agent or independent contractor, or another professional opportunity offered by HereSure;
2.4. This Privacy Policy has been prepared with regard to applicable U.S. privacy laws. We are committed to protecting Personal Information and Processing it in accordance with the applicable legal and regulatory requirements governing data protection and privacy. If You access the Website from a jurisdiction outside the United States, additional data protection or privacy requirements may apply to the Processing of Your Personal Information. Where required by applicable law, We may include separate sections or supplementary notices describing the specific rights available to You and the corresponding obligations applicable to HereSure. We encourage You to review any such additional provisions together with this Privacy Policy.
3. TYPES OF PERSONAL INFORMATION THAT WE PROCESS
3.1. Personal Information You provide to Us personally:
3.1.1. Contact and correspondence information. When You submit a Сontact form, contact Us by email or telephone, or otherwise communicate with Us, We may Process:
- Your first and last name;
- email address;
- telephone number, where provided;
- the content and subject matter of Your inquiry or message; and
- any other information You voluntarily provide in connection with Your communication.
The contact form and general communication channels available through the Website are intended solely for general inquiries and correspondence with HereSure. Unless We expressly request otherwise and provide an appropriate method for submitting such information, You should not disclose medical or health information, Social Security numbers, financial account or payment card information, government-issued identification numbers, or other sensitive Personal Information through these channels.
3.1.2. Applicant information. When You submit an application through the Careers section of the Website, We may Process:
- Your first and last name;
- email address;
- telephone number;
- the position or professional opportunity for which You apply;
- Your resume or CV; and
- any information contained in or submitted together with Your application, including information about Your employment history, education, professional experience, skills, qualifications, certifications, or licences.
In connection with the recruitment and candidate-selection process, We may also Process information provided or generated during interviews, assessments, test assignments, and other selection activities, including:
- information provided during interviews and other recruitment communications;
- test assignments, assessment responses, questionnaires, work samples, presentations, and other materials submitted by You;
- assessment results, scores, interview notes, evaluator feedback, and other records created in connection with the evaluation of Your application;
- records relating to the scheduling and administration of interviews, assessments, and other selection activities; and
- communications and decisions relating to Your application.
Applicants should provide only the Personal Information that is reasonably relevant to the applicable professional opportunity and should not include Sensitive Personal Information unless it has been expressly requested by HereSure for a legitimate recruitment, licensing, or compliance purpose.
Applicants should take reasonable care to ensure that the information and materials submitted in connection with an application are accurate, complete, current, and not materially misleading.
Applicants should not submit confidential, proprietary, trade secret, or Personal Information belonging to a current or former employer, client, customer, or other Third Party, or any materials that they are not legally authorized to use or disclose.
Where HereSure provides specific instructions concerning a test assignment or assessment, including instructions regarding independent completion, external assistance, Third-Party materials, or the use of artificial intelligence or other automated tools, Applicants must comply with those instructions and make any required disclosures.
Consistent with Title II of the Genetic Information Nondiscrimination Act of 2008 and other applicable laws, HereSure does not request or intentionally collect genetic information for recruitment or employment decision-making purposes. Applicants should not include genetic test results, family medical history, information concerning genetic services, or genetic information relating to family members in any application, resume or CV, cover letter, message, or other materials submitted through the Website.
If We inadvertently receive genetic information, We will not use it in making recruitment, employment, or engagement decisions and will handle such information confidentially in accordance with applicable law. We may delete or restrict the Processing of such information where it is not reasonably necessary or legally required to be retained.
3.2. Personal Information automatically collected. When You access or use the Website, certain Personal information may be collected automatically by the Company. This includes:
- Your IP address;
- browser type and version;
- operating system;
- device type;
- referring URL, meaning the webpage or online source from which You accessed the Website;
- date and time of access;
- cookie information, including cookie identifiers and records of Your cookie preferences; and
- approximate location derived from Your IP address.
3.3. Sensitive information. The Website and the communication channels available through it are not intended for the collection of Sensitive Personal Information unless such information is expressly requested by HereSure for a specific and legitimate purpose. Depending on applicable law, Sensitive Personal Information may include Social Security numbers and other government-issued identification numbers, financial account or payment card information, precise geolocation information, racial or ethnic origin, religious or philosophical beliefs, health, medical, genetic or biometric information, sexual orientation, and other information classified as sensitive under applicable law.
3.3.1. You should not include Sensitive Personal Information in a contact form, application, CV, or other communication submitted through the Website unless We have expressly requested such information and provided an appropriate method for its submission. If You voluntarily provide Sensitive Personal Information that We have not requested, We may delete it or restrict its Processing where it is not reasonably necessary for the purpose of Your communication or application.
3.3.2. Where We request Sensitive Personal Information for a specific licensing, compliance, reasonable accommodation, or other lawful purpose, We will inform You of the relevant purpose and provide an appropriate method for submitting such information. We will obtain Your Consent or authorization where required by applicable law.
3.3.3. Sensitive Personal Information provided for an accommodation, licensing, verification, or compliance purpose will not be used for an unrelated recruitment or employment decision where such use is prohibited by applicable law. HereSure does not request genetic information for recruitment or employment decision-making purposes, except where its collection is expressly permitted by applicable law.
4. RECRUITMENT AND CANDIDATE SELECTION
4.1. Candidate assessment. Depending on the relevant position or professional opportunity, the recruitment process may include interviews, test assignments, work samples, questionnaires, practical exercises, or other assessments intended to evaluate an Applicant’s qualifications, experience, skills, and suitability for the relevant opportunity.
4.1.1. In connection with such activities, HereSure may process interview responses, test assignments, work samples, assessment results, interview notes, evaluator feedback, and related recruitment records.
4.1.2. Where required by applicable law, HereSure will administer recruitment assessments and other selection procedures in a manner consistent with applicable equal employment opportunity requirements and will consider reasonable accommodations necessary for an Applicant to participate in the application, interview, or assessment process.
4.2. Accuracy and submitted materials. Applicants should take reasonable care to ensure that the information and materials submitted in connection with an application are accurate, complete, current, and not materially misleading.
4.2.1. Applicants should not submit confidential, proprietary, or trade-secret information belonging to a current or former employer, client, or other Third Party, or any materials that they are not legally authorized to use or disclose.
4.2.2. Where HereSure provides specific instructions concerning a test assignment, including instructions regarding independent completion, external assistance, Third-Party materials, or the use of artificial intelligence or other automated tools, Applicants must comply with those instructions and make any required disclosures.
4.2.3. Material misrepresentations, falsified information, or failure to comply with the applicable assessment instructions may result in discontinuation of the recruitment process or withdrawal of an offer, subject to applicable law.
4.3. Genetic information. Consistent with the Genetic Information Nondiscrimination Act of 2008 and other applicable laws, HereSure does not request or intentionally collect genetic information for recruitment or employment decision-making purposes. If HereSure inadvertently receives genetic information, it will not use such information in making recruitment, employment, or engagement decisions and will handle it confidentially in accordance with applicable law.
4.4. Employment-related verification. Where relevant to the applicable professional opportunity, permitted by law, and separately disclosed to the Applicant, HereSure may take reasonable steps to verify information provided in connection with an application. If HereSure obtains a background report from a consumer reporting agency for employment purposes, HereSure will provide any separate disclosure, obtain any authorization, and follow any additional procedures required under the Fair Credit Reporting Act and applicable state or local law. This Privacy Policy does not replace any separate disclosure or authorization required for such a background check.
5. LEGAL BASIS WE RELY ON TO PROCESS YOUR PERSONAL INFORMATION
5.1. The Company Processes Personal information in accordance with applicable laws and relies on the following legal bases to ensure lawful and transparent data handling practices:
5.1.1. Taking steps at Your request. We may Process Personal Information where necessary to perform Our obligations and exercise Our rights under the Terms & Conditions governing Your use of the Website, or to take steps at Your request before entering into an employment, agency, independent contractor, or other professional relationship with HereSure. This includes responding to inquiries, receiving and reviewing applications, communicating with Applicants, and administering the recruitment and candidate-selection process.
5.1.2. Legitimate business purposes. We may Process Personal Information where reasonably necessary to operate and secure the Website, respond to inquiries, administer recruitment, evaluate Applicants, maintain appropriate business and recruitment records, improve Website functionality, measure Website performance, prevent fraud or misuse, resolve disputes, and establish, exercise, or defend legal claims, except where applicable law requires Consent or otherwise restricts such Processing.
5.1.3. Compliance with legal obligations. We may Process Personal Information where necessary to comply with applicable federal, state, or local laws, regulations, court orders, legal processes, licensing requirements, recordkeeping obligations, or lawful requests from public authorities. This may include obligations relating to equal employment opportunity, reasonable accommodation, genetic information, professional licensing, recruitment records, and other employment or regulatory requirements.
5.1.4. Consent or authorization. We rely on Your Consent or authorization where required by applicable law, including, where applicable, for non-essential Cookies and similar technologies, marketing communications, certain uses of Sensitive Personal Information, or other Processing activities requiring an affirmative choice.
Where HereSure obtains an employment-related Consumer Report from a consumer reporting agency, any disclosure and authorization required under the Fair Credit Reporting Act will be provided and obtained separately. Submission of an application or acknowledgment of this Privacy Policy does not constitute authorization for a background check.
Where We rely on Consent, You may withdraw it at any time by contacting HereSure using the contact details specified in this Privacy Policy. Withdrawal of Consent does not affect the lawfulness of Processing carried out before the withdrawal and may not affect Processing that is permitted or required on another legal ground.
6. PURPOSES OF PERSONAL INFORMATION PROCESSING
6.1. We Process Personal Information only for the purposes described in this Privacy Policy and as otherwise permitted or required by applicable law. The specific purposes depend on how You interact with the Website and the context in which Your Personal Information is collected.
6.2. The following table describes the categories of Personal Information We may Process, the purposes for which We Process such information, the legal bases upon which We may rely where applicable law requires a legal basis, and the categories of Third Parties to which the information may be disclosed.
| Category of Personal Information | Purpose of Processing | Legal Basis | Third Parties |
|---|---|---|---|
| Contact and correspondence data (first and last name, email address, phone number, message content, and other information voluntarily provided through the Website) | To receive, review, and respond to contact inquiries; communicate with Users and Applicants by telephone, email, or SMS; provide information about HereSure and available Professional Opportunities; schedule interviews, assessments, and other recruitment activities; respond to requests for reasonable accommodation; maintain records of communications; send marketing or informational communications in accordance with User preferences; protect Our rights and resolve complaints or disputes; and comply with applicable legal obligations. | Consent; legitimate interests; taking steps at the User’s request; compliance with legal obligations, where applicable. | Service Providers supporting Website forms, CRM functionality, email and other communications, cloud storage, recruitment administration, and related operational functions, including GoHighLevel and Google Drive / Google Cloud, where applicable Service Providers supporting website operation, forms, email, communications, cloud storage, and other operational functions. |
| Professional or work-related data (resume or CV, position, work history, experience, qualifications, and other information included in an application) | To receive and review applications; to evaluate Applicants; to communicate with Applicants; and to administer the recruitment and candidate-selection process. | Consent; legitimate interests; taking steps at the Applicant’s request before entering into a contract; compliance with legal obligations, where applicable | Service Providers supporting recruitment, website forms, communications, and cloud storage, including GoHighLevel / LeadConnector and Google Drive (Google Cloud), where applicable |
| Automatically collected data (IP address, browser type and version, operating system, device type, referring URL, date and time of access, cookie information, and approximate location derived from the IP address) | To support the technical operation of the Website and its integrations; to operate Website forms, maintain sessions, and save form progress; to remember cookie-consent and advertising opt-out preferences; to measure Website traffic, visitor behavior, and Website performance; to generate statistical reports; to measure and optimize advertising campaigns; to perform campaign attribution and conversion measurement; to create advertising and remarketing audiences; and to display targeted or behavioral advertising, where applicable | Legitimate interests; Consent, where required; compliance with legal obligations, where applicable | Analytics Partners, including Google Analytics and Microsoft Clarity; Advertising Partners, including Google Ads, Meta, Microsoft Advertising, TikTok Ads, LinkedIn Ads, Taboola, and Outbrain; Website and form technology providers, including GoHighLevel/LeadConnector |
6.3. Additional purposes of processing Applicant Personal Information. In addition to the purposes described in the table above, HereSure may Process Applicant Personal Information to:
- receive, review, and administer applications;
- communicate with Applicants and organize interviews, test assignments, assessments, or other stages of the recruitment process;
- evaluate an Applicant’s experience, qualifications, skills, and suitability for the relevant professional opportunity;
- verify information provided by an Applicant, where relevant and permitted by law;
- administer reasonable accommodation requests;
- comply with applicable employment, licensing, regulatory, and recordkeeping requirements; and
- protect HereSure’s rights, prevent fraud or material misrepresentation, and resolve recruitment-related disputes.
The specific purposes applicable to an Applicant will depend on the relevant professional opportunity and the stages of the recruitment process in which the Applicant participates.
Where relevant, permitted by law, and separately disclosed to the Applicant, HereSure may also Process Applicant Information for employment-related verification or background screening.
7. PRIVACY RIGHTS OF USERS
7.1. Residents of the United States may have specific privacy rights depending on the state in which they reside. These rights are established by state-specific privacy laws, which grant individuals certain control over their Personal Information. The scope of these rights, as well as the procedures for exercising them, vary by state.
State Privacy Rights Table
| Right | Description | State(s) |
|---|---|---|
| Right to access | You have a right to confirm whether We Process Your Personal information and to request an explanation of the Processing of Your Personal information. | California; Virginia; Colorado; Connecticut; Utah; Florida; Oregon; Texas; Montana; Iowa; Delaware; Nebraska; New Hampshire; New Jersey; Tennessee; Minnesota; Maryland; Indiana; Kentucky; Rhode Island. |
| Right to correct | You have the right to request the change of the Personal information if it is inaccurate or incomplete. | California; Virginia; Colorado; Connecticut; Florida; Oregon; Texas; Montana; Delaware; Nebraska; New Hampshire; New Jersey; Tennessee; Minnesota; Maryland; Indiana; Kentucky; Rhode Island. |
| Right to delete | You can send Us a request to delete Your Personal information from Our systems. | California; Virginia; Colorado; Connecticut; Utah; Florida; Oregon; Texas; Montana; Iowa; Delaware; Nebraska; New Hampshire; New Jersey; Tennessee; Minnesota; Maryland; Indiana; Kentucky; Rhode Island. |
| Right to data portability | You may have the right to receive all Personal information about You from the Company in a structured, commonly used and machine-readable format, and also to require Us to transmit it to another entity (Controller) where this is technically feasible. | California; Virginia; Colorado; Connecticut; Utah; Florida; Oregon; Texas; Montana; Iowa; Delaware; Nebraska; New Hampshire; New Jersey; Tennessee; Minnesota; Maryland; Indiana; Kentucky; Rhode Island. |
| Right to opt out of sales | You have the right to opt out of the sale of Personal information to Third Parties. | California; Virginia; Colorado; Connecticut; Utah; Florida; Oregon; Texas; Montana; Iowa; Delaware; Nevada; Nebraska; New Hampshire; New Jersey; Tennessee; Minnesota; Maryland; Indiana; Kentucky; Rhode Island. |
| Right to opt out of certain purposes | You have the right to opt-out of Processing for profiling / targeted advertising purposes. | California; Virginia; Colorado; Connecticut; Utah; Florida; Oregon; Texas; Montana; Iowa; Delaware; Nebraska; New Hampshire; New Jersey; Tennessee; Minnesota; Maryland; Indiana; Kentucky; Rhode Island. |
| Right to opt out of / limit Processing of sensitive data or revoke Consent | You have the right to opt-out of / limit Processing of sensitive Personal information. | California; Connecticut; Utah; Florida; Oregon; Montana; Iowa; Delaware; New Hampshire; New Jersey; Minnesota; Rhode Island. |
| Right to opt in for sensitive data Processing | The right to opt in before Processing of sensitive Personal information. | Virginia; Colorado; Connecticut; Florida; Oregon; Texas; Montana; Delaware; Nebraska; New Hampshire; New Jersey; Tennessee; Minnesota; Indiana; Kentucky; Rhode Island. |
| Right to obtain a list of the categories of Third Parties to which the Controller has disclosed Your Personal information | You have the right to request and obtain a list of the categories of Third Parties with whom the Company has disclosed Your Personal information. | Delaware; Maryland. |
| Right to obtain a list of specific Third Parties to which the Controller has disclosed Your Personal information | You have the right to request and obtain a detailed list of specific Third Parties to whom the Company has disclosed Your Personal information. | Minnesota. |
| Right to question the results of profiling and review the Personal information used | If Your Personal information is subject to profiling that leads to decisions with legal or similarly significant effects, You have the right to question the outcome. You may request to be informed of the reasons for the decision, actions You could have taken to secure a different outcome, and what steps You can take in the future to influence similar decisions. Additionally, You have the right to review the Personal information used in the profiling, and if the information is found to be inaccurate, You may request its correction and have the decision reevaluated based on the corrected data. | Minnesota. |
| Private right of action | The right to seek civil damages from a controller for violations of a statute. | California. |
Please note! Some states do not have privacy laws. The rights of residents of such states are governed by U.S. federal law.
7.2. Employment-Related Personal Information. Certain U.S. state privacy laws grant the rights described above only to individuals acting in an individual or household context and expressly exclude individuals acting in an employment or commercial context. This may include application materials, resumes or CVs, interview and assessment records, recruitment communications, information used to evaluate an Applicant, and records relating to an employment or other professional relationship. Accordingly, depending on the applicable state law, some rights identified in the State Privacy Rights Table may not apply to Personal Information We Process solely in connection with an individual’s application for employment or engagement, or their current or former employment, agency, or independent contractor relationship with HereSure. This limitation does not affect any rights available under other applicable laws. In particular, where the California Consumer Privacy Act applies to HereSure, California residents who are Applicants, employees, or independent contractors may exercise the rights available to them under that law.
7.3. To exercise any applicable privacy right, please contact Us at info@heresureprotect.com. Your request should include Your name, email address, state of residence, a description of the right You wish to exercise, and sufficient information to identify the Personal Information to which Your request relates.
7.4. We may request additional information where reasonably necessary to verify Your identity or authority to submit the request. The verification method will depend on the nature of the request, the sensitivity of the Personal Information involved, and the risk associated with unauthorized access, correction, or deletion. We may be unable to fulfil Your request if We cannot reasonably verify Your identity or authority to make it.
7.5. Where permitted by applicable law, We may decline to act on requests that are manifestly unfounded, excessive, repetitive, fraudulent, or otherwise not required to be fulfilled. If We decline to act on Your request, We will explain the reasons for Our decision and provide information about any available appeal procedure, where required by applicable law.
7.6. We will not unlawfully discriminate or retaliate against You for exercising any privacy right granted under applicable law. We will not deny You access to the Website, provide a different level of Website functionality, or otherwise treat You adversely solely because You submitted a valid privacy request. However, exercising certain rights, including requesting the deletion of information necessary to respond to an inquiry or administer an application, may affect Our ability to continue the relevant interaction with You.
7.7. As a general rule, the Company will respond to Your request within 45 (forty-five) days from the date of receiving the request. In cases where additional time is needed to process the request, the response period may be extended by an additional 45 (forty-five) days, with the User being notified of the extension and the reasons for the delay. However, the following states have specific response time requirements for certain types of requests:
7.7.1. Iowa: the Company will respond to Your request within 90 (ninety) days from the date of receipt. If necessary, this period may be extended by an additional 45 (forty-five) days, with the User being notified of the delay.
7.7.2. New Jersey: in cases where the request pertains to Personal information shared with Third Parties, the Company will respond within 60 (sixty) days regarding all transfers that occurred in the past 12 (twelve) months. For all other types of requests, the Company will respond within 45 (forty-five) days from the date of receipt. If additional time is required, the response period may be extended by an additional 45 (forty-five) days, provided that the User is notified of the extension and the reasons for the delay, in accordance with applicable laws.
7.8. Please note that response times for opt-out requests may differ from the general timelines mentioned above. For specific details regarding opt-out requests, please refer to the relevant section of the Privacy Policy.
8. INFORMATION SECURITY
8.1. We take the protection of Your Personal Information very seriously. We take commercially reasonable measures designed to prevent unauthorized access to Your Personal Information. We strive to protect Your Personal Information by various means in order to preserve its confidentiality and integrity, prevent its unauthorized use or disclosure, and protect it against loss, misuse, alteration, and / or destruction. We strive to follow generally accepted and commonly used industry standards in maintaining technical, physical, and administrative security measures.
8.2. We are committed to providing reasonable protection for Personal Information provided to Us, both during transmission and once We receive it. When We or Our contractors Process Your Personal Information, We make reasonable efforts to ensure that it is reasonably protected against unauthorized access, misuse, corruption, loss, manipulation, destruction, or unauthorized disclosure through appropriate measures.
8.3. By using the Website or providing Personal Information to Us, You acknowledge that no method of transmission over the Internet or method of electronic storage is completely secure. We use reasonable efforts to protect Your Personal Information, but We cannot guarantee or provide any warranty or representation that the Personal Information You provide to Us will remain absolutely secure.
8.4. We apply a variety of security measures appropriate to the possible risks. Access to Personal Information is limited to authorized personnel on a need-to-know basis and according to each person’s role and responsibilities. Personnel with access to Personal Information are expected to maintain its confidentiality and comply with applicable privacy and information security requirements.
9. STORING AND DELETION OF PERSONAL INFORMATION
9.1. We will store Your Personal Information only for as long as reasonably necessary for the purposes set out in this Privacy Policy, unless a longer retention period is required or permitted by applicable law.
9.2. Personal Information collected through the Website is stored and processed within the United States, including through Google Drive and Google Cloud services.
9.3. The applicable retention period may depend on the nature of the Personal Information, the purpose for which it was collected, the nature of Our interaction with You, and any applicable legal or regulatory requirements.
9.4. When We no longer have an ongoing legitimate business or legal need to Process Your Personal Information, We will take reasonable steps to delete or anonymize it. Where immediate deletion is not technically possible, We will restrict further Processing of the relevant Personal Information until deletion becomes possible, except where continued Processing is required or permitted by applicable law.
9.5. You may request the deletion of Your Personal Information by contacting Us using the contact details specified in this Privacy Policy. Any such request will be reviewed and processed in accordance with applicable law.
9.6. Information that has been anonymized or aggregated so that it can no longer reasonably be linked to You may be retained and used for statistical, analytical, or other lawful business purposes.
10. PERMITTED DISCLOSURE
10.1. The Company may share Your Personal information with Third Parties in limited and specific circumstances, as outlined in this section. The Company does not sell, license, or otherwise transfer Your Personal information to Third Parties in exchange for monetary or other valuable consideration. Insurance inquiries are processed by the Company’s licensed insurance agents and are not sold or transferred to independent external agents. However, the Company does use, and plans to continue using, Your Personal information, online identifiers, Cookies, pixels, conversion events, and related advertising technologies for campaign attribution, conversion measurement, audience creation, remarketing, and targeted or behavioural advertising through advertising and analytics platforms, as further described in the Cookies and Other Tracking Technologies section and the Personal Information That We “Share”, “Sell”, or Use for “Targeted Advertising” section below. All sharing of Personal information is conducted in accordance with applicable laws and is subject to appropriate contractual and security measures to protect Your data.
10.2. Service Providers. We use Service Providers to operate the Website, receive and manage inquiries and applications, store Personal Information, communicate with Users and Applicants, analyze Website activity, and measure and manage advertising campaigns. Service Providers may Process Personal Information only as reasonably necessary to perform services on Our behalf and comply with applicable legal obligations. Where applicable, Our relationships with such providers are governed by contractual, confidentiality, and data-security requirements.
| Name of Service Provider | Category / Purpose of Processing | Personal information Processed | Location of Processing | Additional Information / Privacy Policy |
|---|---|---|---|---|
| GoHighLevel (HighLevel Inc.) | CRM, lead management, form hosting, and Platform hosting | Name, email address, telephone number, resume or CV, form submissions, communications, and session data | United States (hosted on Amazon Web Services (AWS) and Google Cloud Platform (GCP)) | GoHighLevel Privacy Policy |
| Google LLC | Cloud services, storage, email, analytics | Contact information, Applicant Information and submitted documents, communications, online identifiers, and Website-usage data | United States and other jurisdictions | Google Privacy Policy; Opt-out of analytics via Google Analytics Opt-out |
| Meta | Advertising campaign management, conversion tracking, audience creation, remarketing, and targeted advertising | Online identifiers, device/browser information, advertising interaction data | United States | Meta Privacy Policy |
10.3. Corporate Transactions. If We enter or intend to enter a transaction that modifies the structure of Our business, such as a reorganization, merger, sale, joint venture, assignment, transfer, change of control, or other disposition of all or part of Our business, assets, or stock, We may share Personal information with Third Parties in connection with such transaction. Any other entity that buys Us or part of Our business will have the right to continue to use Your Personal information, but subject to the terms of the Privacy Policy.
10.4. Compliance and Harm Prevention. We share Personal information when We believe it is necessary to comply with applicable law; enforce Our contractual rights (Terms & Conditions); secure and protect the Website, rights, privacy, safety, and property of the Company, You, and others, including against malicious or fraudulent activity; and to respond to valid legal requests from courts, law enforcement agencies, regulatory agencies, and other public and government authorities, which may include authorities outside Your country of residence.
10.5. Personnel and Advisors. Personal Information may be accessed by authorized personnel who require it to perform their responsibilities. Depending on their role, this may include human resources and recruitment personnel, management personnel, customer service or administrative personnel, technical personnel, and legal or compliance personnel, where applicable.
Access is granted on a need-to-know basis and is limited to the Personal Information reasonably necessary for each person to perform their duties.
10.6. With Your Consent. We may disclose Your Personal Data publicly or with another Third Party with Your prior authorization.
11. RIGHT TO APPEAL
11.1. Where applicable law grants You the right to appeal Our refusal to act on a privacy request, You may submit an appeal by contacting Us through the same method used to submit the original request.
11.2. Your appeal should identify the original privacy request, the decision You wish to appeal, and any additional information You believe is relevant to Our review.
11.3. We will review Your appeal and notify You in writing of any action taken or not taken in response, including the reasons for Our decision, within the period required by applicable law. Where required, We will respond within sixty (60) days after receiving the appeal. In jurisdictions that prescribe a shorter period, including Oregon, We will respond within the applicable statutory period.
11.4. If We deny Your appeal, We will provide information about how You may submit a complaint to the Attorney General, Department of Justice, or other competent authority in Your state, where required by applicable law.
11.5. Where applicable law does not provide a right to appeal, You may still contact Us to request clarification regarding Our decision on Your privacy request.
12. CHILDREN’S PRIVACY
12.1. Ensuring the privacy and safety of children online is a top priority for Us. We are committed to complying with the privacy laws, particularly concerning the protection of children's Personal Information.
12.2. We do not knowingly collect, solicit, or maintain Personal Information from anyone under the age of 18 (eighteen) (or the age of majority in your jurisdiction, if higher), and We also do not offer them to use the Website.By agreeing to this Privacy Policy, You represent and warrant that You are at least 18 (eighteen) years old (or You have reached the age of majority in your jurisdiction, if higher). Please do not send any Personal Information about Yourself to Us if You are under the age of 18 (eighteen) (or the age of majority in your jurisdiction, if higher).
12.3. If We become aware that We have collected Personal Information from an individual under the age of 18 (or below the age of majority in your jurisdiction, if higher), We will take steps to delete such information promptly. If You believe We might have any information from or about a child under 18 (or below the age of majority in your jurisdiction, if higher), please contact Us at info@heresureprotect.com.
12.4. We also recommend that parents monitor their children’s Internet activities and use appropriate tools to help ensure a safe online experience.
13. COOKIES AND OTHER TRACKING TECHNOLOGIES
13.1. We and Our Third-Party partners automatically collect certain types of usage information when You visit the Website, read Our emails, or otherwise engage with Us. We typically collect this information through a variety of tracking technologies, including Cookies (collectively, «Tracking Technologies»). Some of these technologies store data in the browser or on Your device.
13.2. We use Strictly Necessary and Functional Cookies and similar technologies to operate contact and application forms, maintain user sessions, save form progress, process inquiries and applications, and support Our CRM and Website integrations; Preference Cookies to remember Cookie-consent choices and advertising opt-out preferences; Statistics and Analytics technologies, including Google Analytics and Microsoft Clarity, to measure Website traffic, analyze visitor interactions, understand Website performance, and generate aggregated statistical reports; and Marketing and Tracking technologies, including technologies provided by Google Ads, Meta, Microsoft Advertising, TikTok Ads, LinkedIn Ads, Taboola, and Outbrain, for campaign attribution, conversion measurement, audience creation, remarketing, and targeted or behavioural advertising.
13.3. We use both session and persistent Cookies and similar technologies. Their retention periods vary depending on the specific Cookie, technology, and provider.
| Cookie Name | Purpose | Category | Domain (Company/Third-Party) | Provider | Retention Period |
|---|---|---|---|---|---|
| _ _Secure-STRP | Supports secure functionality and helps prevent abuse | Strictly Necessary / Functional | Third-Party | Persistent, approximately until July 2026 | |
| NID | Supports Google service functionality and remembers certain user preferences | Strictly Necessary / Functional | Third-Party | Persistent, approximately 6 months |
14. PERSONAL INFORMATION THAT WE SHARE, SELL, OR USE FOR TARGETED ADVERTISING
14.1. Certain U.S. states provide residents, or in some cases their authorized agents, with the right to opt out of the «selling» or «sharing» of their Personal information, or of «targeted advertising» based on their Personal information.
14.2. While We don’t sell or share directly identifying information like Your name, phone number or email address, We may share Your technical identifiers to provide more relevant Services, content, and ads to You. This may be deemed by applicable state laws as «targeted advertising», or a «sale» or «sharing» of Personal information.
14.3. To submit a request to opt out of targeted advertising, or the sale or sharing of Your Personal information, You may use any of the following methods: (a) by email at info@heresureprotect.com; (b) by replying to any SMS message You receive from Us; or (c) during a phone conversation with Us, or by contacting Us by phone at +1 (732) 278-1858. Please ensure that Your request includes sufficient information to verify Your identity and specify the nature of the opt-out request. Once Your request is received, We will process it in accordance with applicable laws and update Our systems to reflect Your preferences.
14.4. Where applicable regulations require Us, We honor the opt-out signals You send to Us by universal opt-out mechanisms, such as Global Privacy Control. Universal opt-out mechanisms are tools designed to give You more control over Your online privacy by simplifying the process of opting out of data collection and sharing practices. Certain browsers and browser extensions support Global Privacy Control, which sends a signal to websites indicating Your choice to opt-out of the use of Your Personal Information for targeted advertising and «sales» or «shares» as defined under applicable law. We honor the GPC and, where required by law, similar user-initiated browser-based opt-out preference signals. To set up GPC, You can visit the Global Privacy Control page. You can set Your preferences through Your browser, and once it sends Your opt-out preferences to Us, We will honor Your request.
14.5. Please note that Your opt-out choice is specific to the device and browser You are using. If You are using other devices or browsers, You will need to make a separate election for each. Also, if You clear Your Cookies on Your browser or use another browser or device, You may need to opt out again.
14.6. The Company is committed to addressing all opt-out requests promptly and without unnecessary delay, in accordance with applicable legal requirements. While We strive to respond as quickly as possible, the response time will be within the timeframes specified by the relevant laws of each jurisdiction. We will respond within the timeframes required under applicable state law, generally within 45 days (15 days in California, 60 days in Nevada, 30 days in Maryland). If permitted by law, We may extend Our response period and will notify You of the extension and the reason for it.
14.7. If no specific response time for opt-out requests is provided under the applicable law in Your state, the Company will adhere to the general response timeframes outlined for User requests, as specified in the relevant section of the Privacy Policy.
14.8. We will make every effort to comply with these timeframes and provide timely responses to Your requests. If further information or clarification is needed, or if there are any delays, We will promptly notify You and provide an explanation. Should You have any questions or concerns regarding Your opt-out request, please use any of the three methods specified in clause 14.3 above.
15. CONTROLS FOR DO-NOT-TRACK FEATURES
15.1. Do Not Track («DNT») is a privacy preference that Users can set in certain web browsers. DNT is a way for Users to inform websites and services that they do not want certain information about their webpage visits collected over time and across websites or online services. We do not recognize or respond to browser-initiated DNT signals, as the Internet industry is currently still working toward defining exactly what DNT means, what it means to comply with DNT, and a common approach to responding to DNT.
16. ADDITIONAL U.S. DISCLOSURES
16.1. Categories of Personal information We collect.
16.1.1. We have collected the following categories of Personal information in the past 12 (twelve) months:
| Category | Examples as set forth by the CCPA | Collected |
|---|---|---|
| A. Identifiers | Contact details, such as real name, alias, postal address, telephone or mobile number, unique personal identifier, online identifier, Internet Protocol address, email address, and account name. | YES: name, email address, telephone or mobile number, IP address and other online identifiers |
| B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)) | Name, contact information, education, employment, employment history, and financial information. | YES: name, contact information, education, employment history, professional qualifications, and other information included in an application, resume, or CV |
| C. Protected classification characteristics under state or federal law | Age (40 years or older), race, color, ancestry, national origin, citizenship, religion, marital status, medical condition, disability, sex (including gender, gender identity/expression, pregnancy), sexual orientation, veteran or military status, genetic information. | NO, except where limited information is voluntarily provided or lawfully requested for a reasonable accommodation or another specific employment-related purpose |
| D. Commercial information | Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies. | NO |
| E. Biometric information | Genetic, physiological, behavioral, and biological characteristics. | NO |
| F. Internet or other similar network activity | Browsing history, search history, interactions with Our and other websites, apps, systems, and ads. | YES: cookies. |
| G. Geolocation Data | Physical location, approximate location derived from IP address or movements. | YES: approximate location derived from IP address. |
| H. Sensory Data | Audio, electronic, visual, thermal, olfactory, or similar information. | NO |
| I. Professional or employment-related information | Current or past job history or performance evaluations. | YES: resume or CV information, employment history, education, skills, qualifications, application materials, recruitment communications, interview information, test assignments, assessment results, and evaluator feedback |
| J. Non-public education information (per FERPA) | Education records maintained by an educational institution. | NO |
| K. Inferences drawn from collected Personal information | Profile reflecting preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, aptitudes. | YES: limited to usage preferences and interests inferred from interaction with the Platform. |
| L. Sensitive Personal Information | Government-issued identifiers, financial account details, precise geolocation, racial/ethnic origin, religious beliefs, union membership, biometric data, health data, sexual orientation/sex life. | NO |
16.2. Disclosures of Personal information for a Business Purpose.
16.2.1. We may disclose Your Personal information to a contractor or service provider for a business purpose. The types of Personal information We share for a business purpose vary, depending on the purpose and the function provided by the Third Party to whom We disclose such information. When We disclose Personal information for a business purpose, We enter a contract that describes the purpose and requires the recipient to both keep that Personal information confidential and not use it for any purpose except performing the contract. We further restrict the contractor and service provider from selling or sharing Your Personal information.
16.2.2. In the preceding 12 (twelve) months, We disclosed the following categories of Personal information for a business purpose:
| Category (corresponding with the table above) | Category of Recipient | Business Purpose |
|---|---|---|
| Category A (Identifiers) Category B (Customer Records info) Category F (Network activity data) Category G (Geolocation Data) Category I (Professional or employment-related information) | Cloud computing and storage vendors | Data storage, hosting, and infrastructure support |
| Category A (Identifiers) Category B (Customer Records info) Category I (Professional or employment-related information) | Customer support providers | Customer and technical support services |
| Category A (Identifiers) Category F (Network activity data) Category G (Geolocation) Category K (Inferences) | Analytics and marketing providers | Usage analytics, performance measurement, improving user experience |
17. MARKETING AND INFORMATIONAL COMMUNICATIONS
17.1. We may use Your email address or other contact details to send You marketing and promotional communications about HereSure, Our services, professional opportunities, updates, surveys, or other information that may be of interest to You, where permitted by applicable law.
17.2. We may also send You non-marketing communications related to Your inquiry, application, interview, recruitment process, or other interaction with HereSure, as well as notices concerning updates to this Privacy Policy or other information that We are required to provide by law.
17.3. You may opt out of receiving marketing communications at any time by using the unsubscribe link included in the relevant communication or by contacting Us using the details provided in this Privacy Policy. Your decision to opt out of marketing communications will not affect Our ability to respond to Your inquiry, communicate with You regarding Your application or professional relationship with HereSure, or send communications required by applicable law.
18. CHANGES TO THE PRIVACY POLICY
18.1. From time to time for any reason, We may make changes to the Privacy Policy by posting a new version of the Privacy Policy. Please check back periodically and review the Privacy Policy to keep Yourself always up-to-date on Our privacy practices.
18.2. A revised version of Our Privacy Policy will come into effect upon posting on the Website, unless a different effective date is explicitly specified.
19. CONTACT US
19.1. Please contact Us via Our customer support at info@heresureprotect.com to provide feedback or request to resolve any of Your questions, suggestions, or concerns. We will try to answer You as soon as possible, but no longer than within 30 (thirty) calendar days (unless the issue relates to the fulfillment of a request for which a shorter or longer period for fulfillment is provided by applicable law).
19.2. Notices relating to the Privacy Policy may be sent to You to the email address You provided. You expressly authorize Us to contact You via such email address in the event We (or Our affiliate) are required by law to notify You of a Data security incident or Data breach.