We are Breachway Media Group, LLC (“Breachway Media Group”, “we”, “us” and “our”). Among other things, we are a marketing and communications platform to generate interested consumers for products and services offered by our clients. The Services include a marketing platform for providing interested consumers for insurance carriers, agents, brokers and related entities, among others (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 our Services, we will refer to you as a “registered user”. If you don’t register with us, we will refer to you as an “unregistered user”. This Privacy Statement and our Terms of Service (“Terms”) apply to each user.

This document is our statement of our privacy practices (“Privacy Statement”). Among other things, it explains how we and some of the companies we work with collect, use, share and protect the information you provide to us (“your Content” or “User Content”). The User Content may include any personally-identifiable information, including without limitation name, address, telephone numbers, electronic mail and postal addresses, personal financial information, and other sensitive information that identifies or is uniquely associated with an individual (collectively, “Personal Data”). This Privacy Statement also discusses your choices about the 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 about how users use the Services, what Services users select, how users respond to service offerings, how users share information with others, what users say they like and dislike, all of which we aggregate into larger data sets that do not identify individuals (“Behavioral Data”).

Among other services, Breachway Media Group connects users with other users, and with companies who provide goods or services which may have value to our users (collectively, “Partners”). This Privacy Statement does not apply to any Partners or to any other websites, mobile applications, or businesses. This Privacy Statement does not apply to any Personal Data or other Content collected via any means other than the Services.

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

1. Information We Collect

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

Information you provide us directly

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

Profile information. You may provide us with additional profile information that you choose to make public or share with other users. You may also provide information to customize your account, such as a telephone number for the delivery of short message system (“SMS”) or text messages. We may use your contact information to send you information about our Services or to market to you. You may use your account settings to customize notifications from us. If you email us, we may keep your message, email address and contact information to respond to your request.

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

Communications between you and Breachway Media Group: We may send you emails, SMS or text messages, and other electronic communications for sales and delivery, account verification, notices of changes/updates to features of the Services, technical and security notices, and for other purposes. We may collect and store these communications.

Information we gather from your use of our Services

We collect and may save private emails sent to us by users, and we may share your emails with any third parties or other users. Any public posts on the Services may be viewed by any user and are public to anyone who visits the Services. You may elect to disclose certain Personal Data and Non-Personal Data. The information you submit in any public forums is not confidential or private, and Breachway Media Group does not protect it. All information you choose to provide publicly, including information that identifies you or others, can be read, collected, or used by other users and by other third parties, and could be used to send you unsolicited messages and for other purposes.

Social Media. In addition to media that we control, you may post comments, photographs, drawings and other User Content on third party social media, such as Facebook, Instagram and Twitter (X), each of which enforces its own terms of use and privacy policy for its service. As noted in the Terms and our other online documents, we may use and copy the User Content you post. More to the point, your User Content may contain Personal Data about you and other people in the form of names, email addresses, and location information. You should also be aware that a photograph or drawing of a person may be Personal Data to the extent the person may be recognized in and identified by the photograph or drawing. We may collect and use User Content and the Personal Data contained in the User Content to market our Services.

We use third-party analytics tools to help us measure traffic and usage trends and other Non-Personal Data for the Services. These tools collect information sent by your device or our Services, including the web pages you visit, add-ons, and other information that assists us in improving our Services. We collect and combine this analytics information with analytics information from other users so that it cannot be used to identify any particular individual user. One of the analytics tools we use is Google Analytics. For more information and steps you can take to control Google’s collection and use of your data, please visit Google’s page, “How Google uses data when you use our partners’ sites or apps”; 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 other data, including User Content. For example, metadata can describe how, when and by whom an item of User Content was collected and how that User Content is formatted. Breachway Media Group may collect and store metadata, including about each user’s public posts on the Services.

Breachway Media Group may keep track of how you interact with links across our Services, including our email notifications and third-party Services by redirecting clicks or through other means. We do this to help improve our Services, to provide more relevant local data, and to be able to share aggregate click statistics such as how many times a particular link was clicked on.

Device Identifiers. We may access, collect, monitor, store on your device, or remotely store one or more “device identifiers.” Device identifiers are small data files or similar data structures stored on or associated with your computer, phone or other device, which uniquely identifies your device. A device identifier may be data stored in connection with the device hardware, data stored in connection with the device’s operating system or other software, or data sent to the device by Breachway Media Group. A device identifier may deliver information to us or to a third-party partner about how you browse and use the Services and may help us or others provide reports or personalized Content and ads. Some features of the Services may not function properly if use or availability of device identifiers is impaired or disabled.

Log Data. Our servers automatically record information (“Log Data”) created by your use of the Services. Log Data may include information such as your Internet Protocol (“IP”) address, browser type, operating system, the referring web page, pages visited, location, your mobile carrier, device and application IDs, search terms, and cookie information. We receive log data when you interact with our Services, for example, when you visit our website, sign into our Services or interact with our email notifications. Breachway Media Group uses log data to review how we provide our 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 we currently collect and retain on servers inside the United States.

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

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

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

3. How We Use Your Information

We share and use your Personal Data in the following circumstances:

Partners and Affiliates of Breachway Media Group. We may share your Personal Data with Partners and with our Breachway Media Group affiliates (meaning entities controlled by, controlling or under common control with Breachway Media Group) as necessary to sell and provide the Services. However, any Personal Data stored in one country or jurisdiction would not be forwarded to another country or jurisdiction, except in compliance with applicable laws and regulations. If you wish to opt out please Email us at contact@BreachwayMedia.com

Cookies. Cookies are unique identifiers that we transfer to your device to enable our systems to recognize your device and to provide features and remember your personalization choices. We use cookies to make it easier to access and use our Services. The help feature on most browsers will tell you how to prevent your browser from accepting new cookies, how to have the browser notify you when you receive a new cookie, or how to disable cookies altogether. Additionally, you can disable or delete similar data used by browser add-ons, by changing the add-on’s settings or visiting the website of its manufacturer. Because cookies allow you to take advantage of some of the Service’s essential features, we recommend that you leave them turned on. Cookies are also used to display particular Content and to set session identifiers for visitors who voluntarily join user areas.

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

Opt-out Email or Postal Address. If you supply us with your postal or email address you may receive periodic mailings from us with information on new products and services or upcoming events. If you do not want to receive such mailings, please let us know by sending an email to us at the “opt-out” address, below. We will remove your name from the list we use internally. Opting-out of these emails does not mean we remove your email from our system entirely, because we still retain your email addresses for other purposes.

Service Providers. We employ third party companies and individuals to facilitate our Services (e.g., payment processing, maintenance, analysis, audit, marketing and development, or to ensure that we are complying with the laws and requirements of various jurisdictions while providing the Services). These third parties may have limited access to your Personal Data only to perform these tasks on our behalf and are obligated to Breachway Media Group not to disclose or use your Personal Data for other purposes.

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

National Security and Intelligence Activities. We may release your Personal Data to authorized federal officials for intelligence, counterintelligence and other national security activities when required by law. For example, under current law in the United States, certain federal officials may require that we provide Personal Data and other Content in response to a national security letter, subpoena, demand, or court order. In some cases, we would be required not to tell you that we complied with that letter, subpoena, demand, or court order. Where permitted by applicable law, 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 the whole of Breachway Media Group or our assets to another organization (e.g., a merger, acquisition, or reorganization), your Personal Data such as user name and email address, User Content and any other information collected through the Services may be among the items sold or transferred.

Non-Personal Data. We may share Non-Personal Data publicly and with publishers, researchers or connected sites. For example, we may share aggregated Non-Personal Data publicly to show trends about the general use of our Services. Non-Personal Data includes aggregated or collective information about multiple users that does not reflect or reference an individually-identifiable user.

In addition to some of the specific uses of information we describe in this Privacy Statement above, we may use Personal Data that 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 at https://policies.google.com/technologies/partner-sites

4. Your Right to Review, Request Changes, and Disclose Personal Data

Subject to applicable laws and regulations, each user may inspect and receive a copy of his or her Personal Data as stored in the Services. In rare circumstances, we may deny a request, and we may provide you with an explanation. If we deny your request, you may request a review by another professional, who will be chosen by Breachway Media Group, and we will comply with the outcome of the review.

Subject to applicable laws and regulations, the Personal Data you provide to us remains completely under your control. If you believe the Personal Data we have is incorrect or incomplete, you may in writing request an amendment to your Personal Data. We will approve or deny each request, and notify you of our decision. If approved, we will amend the Personal Data. We will also make a reasonable effort to notify people to whom the Personal Data was released. In the case of a denial, we will provide the reason for the denial and instructions on how to appeal.

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

5. Children

Our Services are not directed to persons under age 18. If you are the parent or guardian of a person under 18, and you become aware that your young person has provided us with Personal Data or User Content without your express consent, please contact us at contact@BreachwayMedia.com and we will remove the information or User Content, 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 prior written notice sent to the email address we have for you. For any user who has not provided us with an email address, the revised Privacy Statement will become effective no less than ten (10) calendar days after posting on the Services. If you choose not to be subject to a revised version of this Privacy Statement, then you may terminate your account with us, and the unrevised version of the Privacy Statement will apply.

7. Different Locations, Different Laws

The laws and regulations that address privacy rights and responsibilities (collectively, “Laws”) are different from one to another. Indeed, some of the Laws do or do not apply depending on different 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 Breachway Media Group.

Several of the Laws that concern unregistered users, registered users, and Breachway Media Group are discussed in this Section, but these are not all of the Laws that may apply. In addition, if there is any conflict or ambiguity between the statements made in this Privacy Statement and an applicable Law, then the Law will control.

a. United States Federal Laws

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

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

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

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

c. State Laws in the United States

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

d. Your California Privacy Rights

This section supplement the information contained elsewhere in our privacy statement and applies to all visitors, users, and others who reside in the State of California (”consumers” or “you”). This notice of privacy rights has been adopted in order to comply with the California Consumer Privacy Act of 2018 (“CCPA”), and any terms defined in the CCPA have the same meaning when used in this notice. For further information about your rights under California’s privacy laws, see California’s “Privacy Laws” website at https://oag.ca.gov/privacy/privacy-laws.

You have the right under the California Consumer Privacy Act of 2018 (CCPA) and certain other privacy and data protection laws, as applicable, to exercise these rights free of charge:

i. Disclosure of Personal Data We Collect About You

You have the right 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;

• Re-identify 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 Business Purpose

In connection with any Personal Data we may sell or disclose to a third 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 Direct Marketing

If you are a California resident, California Civil Code Section 1798.83 permits you to request information regarding the disclosure of your Personal Data by us to third parties for the third 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 are informing you that we do share users’ Personal Data with affiliate companies or others outside Breachway Media Group for those parties’ direct marketing use, unless a user requests that we stop sharing their data.

iv. Right to Deletion

Subject to certain exceptions set out below, on receipt of a verifiable 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 because you exercised any of your rights under the CCPA. This means we cannot, 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 associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or device.” The Services collect Personal Data, Non-Personal Data, and Behavioral Data, which could potentially be combined to become Personal Data.

This list provides categories of Personal Data and indicates whether we collect this data, the commercial or business purpose behind the collection, and whether the PI is shared with, or sold to, 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; and our 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 of any 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 does not 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, or placing any order with us, you consent to the storage, processing, use and onward transfer of your Personal Data and User Content to us in the United States.

g. How to Exercise Your Rights

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

• Email us at contact@BreachwayMedia.com or

• Write to us at “Attn: Privacy, Breachway Media Group, LLC, 8 Lewis Road, Marlborough, CT, 06447, USA.”

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

h. Verifying Your Identity

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

• 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 driver’s 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 portability disclosure if we cannot verify that the person making the request is the person about whom we collected information, or is someone authorized to act on such person’s behalf.

Any Personal Data we collect from you to verify your identity in connection with your request will be used solely for the purposes of verification.

8. Use of Email Addresses and Other Contact Information

We collect the email addresses of those who voluntarily provide them 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 contact@BreachwayMedia.com or by postal mail addressed to:

Attn: Privacy, Breachway Media Group, LLC, 8 Lewis Road, Marlborough, CT, 06447, USA.

10. Revision Date and History

These Terms were last revised: August 12th, 2024. Prior versions of this Privacy Statement are listed below: N/A.

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