We are charter-care, LLC (“charter-care”, “we”, “us” and “our”).Among other things, we are a marketing and communications platformto generate interested consumers for products and services offeredby our clients. The Services include a marketing platform forproviding interested consumers for insurance carriers, agents,brokers and related entities, (collectively, the “Services”).

Each person or entity who uses our Services is referred to as a“user” or “you” or “your”. If you subscribe to any of ourServices, we will refer to you as a “registered user”. If youdon’t register with us, we will refer to you as an “unregistereduser”. This Privacy Statement and our Terms of Service (“Terms”)apply to each user.

This document is our statement of our privacy practices (“PrivacyStatement”). Among other things, it explains how we and some ofthe companies we work with collect, use, share and protect theinformation you provide to us (“your Content” or “User Content”).The User Content may include any personally-identifiableinformation, including without limitation name, address, telephonenumbers, electronic mail and postal addresses, personal financialinformation, and other sensitive information that identifies or isuniquely associated with an individual (collectively, “PersonalData”). This Privacy Statement also discusses your choices aboutthe collection, storage and use of your Personal Data.

Any Content that is not Personal Data is referred to as“Non-Personal Data.” Non-Personal Data includes information abouthow users use the Services, what Services users select, how usersrespond to service offerings, how users share information withothers, what users say they like and dislike, all of which weaggregate into larger data sets that do not identify individuals(“Behavioral Data”).

Among other services, charter-care connects users with otherusers, and with companies who provide goods or services which mayhave value to our users (collectively, “Partners”). This PrivacyStatement does not apply to any Partners or to any other websites,mobile applications, or businesses. This Privacy Statement doesnot apply to any Personal Data or other Content collected via anymeans other than the Services.

By using our Services, you consent to the collection, transfer,analysis, transformation, storage, disclosure and other uses ofyour Content, including your Personal Data, as described in thisPrivacy Statement.

1. Information We Collect

As noted above, we collect Content from you while providing theServices. Some of the Content is Personal Data that we use tocontact you and connect you with other users, and which isnecessary to provide the Services. Other Content we collect fromyou, Behavioral Data and other Non-Personal Data that weaggregate, share, and use to improve our Services, and others inthe industry. We collect many different types of information fromyou, both directly and indirectly.

Information you provide us directly

Registration information. When you create or modify an account, orsubscribe to our Services, you provide Personal Data to us, suchas your user name, password, postal address and email address.

Payment information. Except for particular cases where we obtain awritten credit card authorization (and subject to the terms of thewritten authorization), we use a third-party payment processor(“Processor”) to process your payments, so we do not store yourcredit card numbers or other payment information. Please note thatour Processor does store and process your credit card numbers andother payment information in accordance with the Processor’sprivacy policy and subject to applicable law.

Profile information. You may provide us with additional profileinformation that you choose to make public or share with otherusers. You may also provide information to customize your account,such as a telephone number for the delivery of short messagesystem (“SMS”) or text messages. We may use your contactinformation to send you information about our Services, events forwhich you’ve registered, any orders you place, or to market toyou. You may use your account settings to customize notificationsfrom us. If you email us, we may keep your message, email addressand contact information to respond to your request.

Location Information. We may ask for your postal address or yourgeographic location information, especially if you place an orderfor Services with us. When you post User Content to our website orto social media, you may provide your location information,including global positioning system (“GPS”) data or other locationinformation embedded in or accompanying the User Content (e.g., intags or captions).

Communications between you and charter-care: We may send youemails, SMS or text messages, and other electronic communicationsfor sales and delivery, account verification, notices ofchanges/updates to features of the Services, technical andsecurity notices, and for other purposes. We may collect and storethese communications.

Information we gather from your use of our Services

We collect and may save private emails sent to us by users, and wemay share your emails with any third parties or other users. Anypublic posts on the Services may be viewed by any user and arepublic to anyone who visits the Services. You may elect todisclose certain Personal Data and Non-Personal Data. Theinformation you submit in any public forums is not confidential orprivate, and charter-care does not protect it. All information youchoose to provide publicly, including information that identifiesyou or others, can be read, collected, or used by other users andby other third parties, and could be used to send you unsolicitedmessages and for other purposes.

Social Media. In addition to media that we control, you may postcomments, photographs, drawings and other User Content on thirdparty social media, such as Facebook, Instagram and Twitter, eachof which enforces its own terms of use and privacy policy for itsservice. As noted in the Terms and our other online documents, wemay use and copy the User Content you post. More to the point,your User Content may contain Personal Data about you and otherpeople in the form of names, email addresses, and locationinformation. You should also be aware that a photograph or drawingof a person may be Personal Data to the extent the person may berecognized in and identified by the photograph or drawing. We maycollect and use User Content and the Personal Data contained inthe User Content to market our Services.

We use third-party analytics tools to help us measure traffic andusage trends and other Non-Personal Data for the Services. Thesetools collect information sent by your device or our Services,including the web pages you visit, add-ons, and other informationthat assists us in improving our Services. We collect and combinethis analytics information with analytics information from otherusers so that it cannot be used to identify any particularindividual user. One of the analytics tools we use is GoogleAnalytics. For more information and steps you can take to controlGoogle’s collection and use of your data, please visit Google’spage, “How Google uses data when you use our partners’ sites orapps”;https://www.google.com/policies/privacy/partners. Google also provides an opt-out plugin for web browsers,available here;https://tools.google.com/dlpage/gaoptout/

Metadata is usually technical data that is associated with otherdata, including User Content. For example, metadata can describehow, when and by whom an item of User Content was collected andhow that User Content is formatted. charter-care may collect andstore metadata, including about each user’s public posts on theServices.

charter-care may keep track of how you interact with links acrossour Services, including our email notifications and third-partyServices by redirecting clicks or through other means. We do thisto help improve our Services, to provide more relevant local data,and to be able to share aggregate click statistics such as howmany times a particular link was clicked on.

Device Identifiers. We may access, collect, monitor, store on yourdevice, or remotely store one or more “device identifiers.” Deviceidentifiers are small data files or similar data structures storedon or associated with your computer, phone or other device, whichuniquely identifies your device. A device identifier may be datastored in connection with the device hardware, data stored inconnection with the device’s operating system or other software,or data sent to the device by charter-care. A device identifiermay deliver information to us or to a third-party partner abouthow you browse and use the Services and may help us or othersprovide reports or personalized Content and ads. Some features ofthe Services may not function properly if use or availability ofdevice identifiers is impaired or disabled.

Log Data. Our servers automatically record information (“LogData”) created by your use of the Services. Log Data may includeinformation such as your Internet Protocol (“IP”) address, browsertype, operating system, the referring web page, pages visited,location, your mobile carrier, device and application IDs, searchterms, and cookie information. We receive log data when youinteract with our Services, for example, when you visit ourwebsite, sign into our Services or interact with our emailnotifications. charter-care uses log data to review how we provideour Services and to measure, customize, and improve the Services.

2. How We Store Your Information

We currently provide the Services from within the United States,and we store all User Content, including Personal Data, that wecurrently collect and retain on servers inside the United States.

In the future, we may store Personal Data and other User Contenton servers located outside the United States.

Certain types of User Content you submit to us might reveal yourgender, ethnic origin, nationality, age, religion, sexualorientation, or other Personal Data about you or others.

By using our Services, or by submitting your personal Informationto us, you consent to the collection, storage, processing andonward transfer of your personal Information as stated in thecurrent version of this Privacy Statement and the current versionof our other online documents, including the Terms of Service.

3. How We Use Your Information

We share and use your Personal Data in the followingcircumstances:

Partners and Affiliates of charter-care. We may share yourPersonal Data with Partners and with our charter-care affiliates(meaning entities controlled by, controlling or under commoncontrol with charter-care) as necessary to sell and provide theServices. However, any Personal Data stored in one country orjurisdiction would not be forwarded to another country orjurisdiction, except in compliance with applicable laws andregulations. If you wish to opt out please Email us [email protected]

Cookies. Cookies are unique identifiers that we transfer to yourdevice to enable our systems to recognize your device and toprovide features and remember your personalization choices. We usecookies to make it easier to access and use our Services. The helpfeature on most browsers will tell you how to prevent your browserfrom accepting new cookies, how to have the browser notify youwhen you receive a new cookie, or how to disable cookiesaltogether. Additionally, you can disable or delete similar dataused by browser add-ons, by changing the add-on’s settings orvisiting the website of its manufacturer. Because cookies allowyou to take advantage of some of the Service’s essential features,we recommend that you leave them turned on. Cookies are also usedto display particular Content and to set session identifiers forvisitors who voluntarily join user areas.

Do Not Track. We make reasonable efforts to honor the “do nottrack” settings on users’ devices.

Opt-out Email or Postal Address. If you supply us with your postalor email address you may receive periodic mailings from us withinformation on new products and services or upcoming events. Ifyou do not want to receive such mailings, please let us know bysending an email to us at the “opt-out” address, below. We willremove your name from the list we use internally. Opting-out ofthese emails does not mean we remove your email from our systementirely, because we still retain your email addresses for otherpurposes.

Service Providers. We employ third party companies and individualsto facilitate our Services (e.g., payment processing, maintenance,analysis, audit, marketing and development, or to ensure that weare complying with the laws and requirements of variousjurisdictions while providing the Services). These third partiesmay have limited access to your Personal Data only to performthese tasks on our behalf and are obligated to charter-care not todisclose or use your Personal Data for other purposes.

Required by Law. We may access, preserve and share your PersonalData in response to a legal request (like a search warrant, courtorder or subpoena). We may also access, preserve and sharePersonal Data when we have a good faith belief it is necessary to:detect, prevent and address fraud and other illegal activity; toprotect ourselves, you and others, including as part ofinvestigations; and to prevent death or imminent bodily harm.Information we receive about you may be accessed, processed andretained for an extended period of time when it is the subject ofa legal request or obligation, governmental investigation, orinvestigations concerning possible violations of our terms orpolicies, or otherwise to prevent harm.

National Security and Intelligence Activities. We may release yourPersonal Data to authorized federal officials for intelligence,counterintelligence and other national security activities whenrequired by law. For example, under current law in the UnitedStates, certain federal officials may require that we providePersonal Data and other Content in response to a national securityletter, subpoena, demand, or court order. In some cases, we wouldbe required not to tell you that we complied with that letter,subpoena, demand, or court order. Where permitted by applicablelaw, we reserve the right to comply with, or to fight or quash,any such letter, subpoena, demand, or court order.

Change of Control. If we sell or otherwise transfer part or thewhole of charter-care or our assets to another organization (e.g.,a merger, acquisition, or reorganization), your Personal Data suchas user name and email address, User Content and any otherinformation collected through the Services may be among the itemssold or transferred.

Non-Personal Data. We may share Non-Personal Data publicly andwith publishers, researchers or connected sites. For example, wemay share aggregated Non-Personal Data publicly to show trendsabout the general use of our Services. Non-Personal Data includesaggregated or collective information about multiple users thatdoes not reflect or reference an individually-identifiable user.

In addition to some of the specific uses of information wedescribe in this Privacy Statement above, we may use Personal Datathat we receive to:

• help you efficiently access your information after you sign in;
• remember information so you will not have to re-enter it during your visit or the next time you visit the Services;
• provide personalized Content and information to you and others, which, in the future, could include online ads or other forms of marketing;
• provide, improve, test, and monitor the effectiveness of our Services. develop and test new products and features;
• monitor metrics such as total number of visitors, traffic, and demographic patterns. diagnose or fix technology problems;
  or
• Implement display ads from Google; for more information on Google AdWords; (see https://marketingplatform.google.com/about/analytics/terms/us/ ).

You can find more information on Google privacy policy site athttps://policies.google.com/technologies/partner-sites

4. Your Right to Review, Request Changes, and Disclose PersonalData

Subject to applicable laws and regulations, each user may inspectand receive a copy of his or her Personal Data as stored in theServices. In rare circumstances, we may deny a request, and we mayprovide you with an explanation. If we deny your request, you mayrequest a review by another professional, who will be chosen bycharter-care, and we will comply with the outcome of the review.

Subject to applicable laws and regulations, the Personal Data youprovide to us remains completely under your control. If youbelieve the Personal Data we have is incorrect or incomplete, youmay in writing request an amendment to your Personal Data. We willapprove or deny each request, and notify you of our decision. Ifapproved, we will amend the Personal Data. We will also make areasonable effort to notify people to whom the Personal Data wasreleased. In the case of a denial, we will provide the reason forthe denial and instructions on how to appeal.

Any information or User Content that you voluntarily disclose foruse of the Services, such as your user name, your Personal Data oryour User Content, may become available to the public if yourelease it to other users or to the general public. Once you haveshared your Personal Data or your User Content with other people,or otherwise made it public, that Personal Data and your UserContent may be re-shared by others.

5. Children

Our Services are not directed to persons under age 18. If you arethe parent or guardian of a person under 18, and you become awarethat your young person has provided us with Personal Data or UserContent without your express consent, please contact us [email protected] and we will remove the information or UserContent, and we will terminate the young person’s account.

6. Changes to this Privacy Statement

We may modify our Privacy Statement from time to time on priorwritten notice sent to the email address we have for you. For anyuser who has not provided us with an email address, the revisedPrivacy Statement will become effective no less than ten (10)calendar days after posting on the Services. If you choose not tobe subject to a revised version of this Privacy Statement, thenyou may terminate your account with us, and the unrevised versionof the Privacy Statement will apply.

7. Different Locations, Different Laws

The laws and regulations that address privacy rights andresponsibilities (collectively, “Laws”) are different from one toanother. Indeed, some of the Laws do or do not apply depending ondifferent factors, including:

• Location or residence of the user;
• Location or residence of the individual that is the subject of the Personal Data (“Data Subject”);
• Location or residence of the person or organization that employs or contracts with the Data Subject;
• Location of each server or other machine where the Personal Data is received, stored, processed or forwarded to; or
• Location of the relevant office of charter-care.

Several of the Laws that concern unregistered users, registeredusers, and charter-care are discussed in this Section, but theseare not all of the Laws that may apply. In addition, if there isany conflict or ambiguity between the statements made in thisPrivacy Statement and an applicable Law, then the Law willcontrol.

a. United States Federal Laws

Several of the federal Laws in the United States may apply to thePersonal Data collected by us.

Currently, all Personal Data of users resident in the UnitedStates is stored on servers and other machines physically locatedwithin the United States.

b. Children’s Online Privacy Protection Act (“COPPA”)

Currently, COPPA does not apply to the Services. Each registereduser and other user must be 18 years of age or older. As noted inthis Privacy Statement, if we learn of any registered user or useris under the age of 18, or if any parent or guardian contacts us,we will close that person’s account and remove all informationprovided by the individual from our Services.

c. State Laws in the United States

Individual states in the United States have passed and enforceinformation privacy and security laws.

d. Your California Privacy Rights

This section supplement the information contained elsewhere in ourprivacy statement and applies to all visitors, users, and otherswho reside in the State of California (”consumers” or “you”). Thisnotice of privacy rights has been adopted in order to comply withthe California Consumer Privacy Act of 2018 (“CCPA”), and anyterms defined in the CCPA have the same meaning when used in thisnotice. For further information about your rights underCalifornia’s privacy laws, see California’s “Privacy Laws” website athttps://oag.ca.gov/privacy/.

You have the right under the California Consumer Privacy Act of2018 (CCPA) and certain other privacy and data protection laws, asapplicable, to exercise these rights free of charge:

i. Disclosure of Personal Data We Collect About You You have theright to know:

• The categories of Personal Data we have collected about you;
• The categories of sources from which the Personal Data is collected;
• Our business or commercial purpose for collecting or selling Personal Data;
• The categories of third parties with whom we share Personal Data, if any; and
• The specific pieces of Personal Data we have collected about you.

Please note that we are not required to:

• Retain any Personal Data about you that was collected for a single one-time transaction if, in the ordinary course of business, that information about you is not retained;
• Reidentify or otherwise link any data that, in the ordinary course of business, is not maintained in a manner that would be considered Personal Data; or
• Provide the Personal Data to you more than twice in a 12-month period.

ii. Disclosure of Personal Data Sold or Used for a BusinessPurpose

In connection with any Personal Data we may sell or disclose to athird party for a business purpose, you have the right to know:

• The categories of Personal Data about you that we sold and the categories of third parties to whom the Personal Data was sold; and
• The categories of Personal Data that we disclosed about you for a business purpose.

We have provided a table of this information herein.

iii. Disclosure of Personal Data to Third Party for DirectMarketing

If you are a California resident, California Civil Code Section1798.83 permits you to request information regarding thedisclosure of your Personal Data by us to third parties for thethird parties’ direct marketing purposes. To make such a request,see the section “How to Exercise Your Rights”, below.

Pursuant to California Civil Code Section 1798.83(c)(2), we areinforming you that we do share users’ Personal Data with affiliatecompanies or others outside charter-care for those parties’ directmarketing use, unless a user requests that we stop sharing theirdata.

iv. Right to Deletion

Subject to certain exceptions set out below, on receipt of averifiable request from you, we will:

• Delete your Personal Data from our records; and
• Direct any service providers to delete your Personal Data from their records.

Please note that we may not delete your Personal Data if it is necessary to:

• Complete the transaction for which the Personal Data was collected, provide a good or service requested by you, or reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform a contract between you and us;
• Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity; or prosecute those responsible for that activity;
• Debug to identify and repair errors that impair existing intended functionality; Exercise free speech, ensure the right of another consumer to exercise his or her right of free speech, or exercise another right provided for by law;
• Comply with the California Electronic Communications Privacy Act;
• Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when our deletion of the information is likely to render impossible or seriously impair the achievement of such research, provided we have obtained your informed consent;
• Enable solely internal uses that are reasonably aligned with your expectations based on your relationship with us;
• Comply with an existing legal obligation; or
• Otherwise use your Personal Data, internally, in a lawful manner that is compatible with the context in which you provided the information quality of goods or services.

​v. Protection Against Discrimination

You have the right to not be discriminated against by us becauseyou exercised any of your rights under the CCPA. This means wecannot, among other things:

• Deny goods or services to you;
• Charge different prices or rates for goods or services, including through the use of discounts or other benefits or imposing penalties;
• Provide a different level or quality of goods or services to you; or
• Suggest that you will receive a different price or rate for goods or services or a different level or quality of goods or services.
• Please note that we may charge a different price or rate, or provide a different level or quality of goods and/or services to you, if that difference is reasonably related to the value provided to you by your Personal Data.

vi. Categories of Information We Collect

The CCPA defines Personal Data as “information that identifies,relates to, describes, references, is capable of being associatedwith, or could reasonably be linked, directly or indirectly, witha particular consumer or device.” The Services collect PersonalData, Non-Personal Data, and Behavioral Data, which couldpotentially be combined to become Personal Data.

This list provides categories of Personal Data and indicateswhether we collect this data, the commercial or business purposebehind the collection, and whether the PI is shared with, or soldto, a third party.

vii. Why We Collect Your Personal Data

We use and/or sell your Personal Data for the following reasons:

• Auditing related to a current interaction with the consumer and concurrent transactions, including, but not limited to, counting ad impressions to unique visitors, verifying positioning and quality of ad impressions, and auditing compliance with this specification and other standards;
• Detecting security incidents, protecting against malicious, deceptive, fraudulent, or illegal activity, and prosecuting those responsible for that activity;
• Debugging to identify and repair errors that impair existing intended functionality; Short-term, transient use, provided the Personal Data that is not disclosed to another third party and is not used to build a profile about a consumer or otherwise alter an individual consumer’s experience outside the current interaction, including, but not limited to, the contextual customization of ads shown as part of the same interaction;
• Performing services on behalf of the business or service provider, including maintaining or servicing accounts, providing customer service, processing or fulfilling orders and transactions, verifying customer information, processing payments, providing financing, providing advertising or marketing services, providing analytic services, or providing similar services on behalf of the business or service provider;
• Undertaking internal research for technological development and demonstration; and
• Undertaking activities to verify or maintain the quality or safety of a service or device that is owned, manufactured, manufactured for, or controlled by the business, and to improve, upgrade, or enhance the service or device that is owned, manufactured, manufactured for, or controlled by the business.

viii. Parties With Whom We Share Your Personal Data

We routinely share Personal Data with:

• our affiliates;
• service providers we use to help deliver our products and/or services to you, such as payment service providers, warehouses and delivery companies;
• other third parties we use to help us run our business, such as marketing agencies or website hosts;
• third parties approved by you, including social media sites you choose to link your account to or third-party payment providers;
• credit reporting agencies;
• 3rd party marketing partners, for commercial use;
• our insurers and brokers; andour banks and other financial institutions.

e. Your Right to Opt-Out

If you are a California resident 16 years of age or older, you have the right to opt-out from the collection and sale of your Personal Data. As we’ve stated in the section titled “Children”, minors are not permitted to register to use our site; however, if you are the parent or guardian of a minor, please visit our homepage and click on the Do Not Sell My Personal Data link here: Do Not Sell My Personal Information (CCPA).

f. Rights of Minors

As stated in the section titled “Children”, minors are not permitted to register to use our site. However, if you are a California resident under the age of 18, and a registered user ofany site where this Privacy Statement is posted, California Business and Professions Code Section 22581 permits you to request and obtain removal of content or information you have publicly posted. To make such a request, please send an email or letter with a detailed description of the specific content or information to the addresses provided in the section below titled “How to Exercise Your Rights”. Please be aware that such a request doesnot ensure complete or comprehensive removal of the content or information you have posted and that there may be circumstances in which the law does not require or allow removal, even if requested.

By submitting any Personal Data or other User Content to us, orplacing any order with us, you consent to the storage, processing,use and onward transfer of your Personal Data and User Content tous in the United States.

g. How to Exercise Your Rights

If you would like to exercise any of your rights as described inthis Privacy Policy and Policy Statement, please:

• Call us, toll-free, at +18778380161 | TTY 711; or
• Email us at [email protected], ; or
• Write to us at “Attn: Privacy, charter-care LLC, 4801 Linton Blvd, Suite 11A, Delray Beach, FL 33445, USA.”

Please note that you may only make a data access or dataportability disclosure request twice within a 12-month period.

h. Verifying Your Identity

If you choose to contact us directly, you will need to provide uswith:

• Enough information to identify you (e.g., your full name, address and customer or matter reference number)
• Proof of your identity and address (e.g., a copy of your driving license or passport and a recent utility or credit card bill); and
• A description of what right you want to exercise and the information to which your request relates.

We are not obligated to make a data access or data portabilitydisclosure if we cannot verify that the person making the requestis the person about whom we collected information, or is someoneauthorized to act on such person’s behalf.

Any Personal Data we collect from you to verify your identity inconnection with you request will be used solely for the purposesof verification.

8. Use of Email Addresses and Other Contact Information

We collect the email addresses of those who voluntarily providethem to us, including unregistered users and registered users.

9. Contact Us

If you have questions or concerns about this Privacy Statement, please contact us online at [email protected], , or by postal mail addressed to:

Attn: Privacy, charter-care LLC, 4801 Linton Blvd, Suite 11A, Delray Beach, FL 33445, USA.

10. Revision Date and History

These Terms were last revised: May 25th, 2023. Prior versions of this Privacy Statement are listed below: August 31, 2020.