Last Modified: March 19, 2025

Kendra Gray and her affiliates and subsidiaries (collectively, “Kendra Gray,” “we,” “us,” or “our”) respect and value your privacy.

This Privacy Policy explains our online and offline information practices, the kinds of information we may collect, how we use and share that information, and how you can opt out of certain uses or correct or change your information.

This Privacy Policy is incorporated by reference into our Website Terms of Service and any applicable Platform or Service Terms of Service (collectively, the “Terms of Service”).

Scope

This Privacy Policy applies to information that we process from or regarding our current, prospective, and former customers, users, visitors, guests,

business partners (including members, agents, agencies, providers, and carriers), and applicants, in the course of our business, including:

Our website(s)

Forms and applications

Technology platforms and CRM systems

Phone calls, text messages, and in-person meetings

Any other online offerings that link to this Privacy Policy
(collectively, the “Services”).

This Privacy Policy does not apply to information collected by third parties, including through any application or content (including advertising), that may link to or be accessible from the Services but operate under separate privacy policies.

Applicability of HIPAA

Because we facilitate the sale and management of a diverse range of insurance products, including health-related coverage,

some information processing may fall under state or federal regulatory frameworks, including the Health Insurance Portability and Accountability Act (“HIPAA”) and related state laws.

We may act as a Business Associate (as defined by HIPAA) if we receive Protected Health Information (“PHI”)

on behalf of a third party that is a Covered Entity (such as a health plan or insurance carrier).

In our role as a Business Associate:

We collect, use, and disclose PHI only as permitted under HIPAA.

PHI is handled according to agreements with Covered Entities.

This Privacy Policy does not apply to personal information covered exclusively by HIPAA.

For additional information regarding PHI, please review the applicable carrier or Covered Entity’s Notice of Privacy Practices.

Information We Collect About You

The types of information we collect depend on our relationship with you and applicable law.

For purposes of this Privacy Policy, the categories below are referred to collectively as “personal information.”

Categories of Personal Information

Identifiers

Real name

Alias

Account name

Social Security number

Driver’s license number

Insurance agent license numbers

National Producer Numbers (NPN)

Contact Information

Postal address

Email address

Phone number

Demographic Information

Age

Race

Marital status

Mental or physical disability

Sex or gender

Commercial Information

Insurance products purchased

Type of coverage

Policy numbers

Carrier name

Financial information

Internet or Network Activity

Browsing history

Search history

Interaction with Services

Usage data

Geolocation Data

General location information derived from IP or device

Sensory Data

Audio recordings

Electronic or visual information

Professional or Employment Information

Employment history

Income and salary details

Performance-related information (if applicable)

Education Information

Education or credentialing details

Account Information

Usernames

Account numbers

Communications

Mail

Email

Text messages

Communications directed to agents, carriers, providers, or members

Health Information

Medical history

Prescriptions

Health conditions

Coverage details

Inferences

Preferences

Characteristics

Behavioral trends

Attitudes

Predispositions

Some categories may be considered “sensitive personal information” under state law.

Exclusions

Personal information does not include:

Publicly available information from government records

De-identified or aggregated information

Pseudonymized information not reasonably linkable to an individual

How We Collect Information

Direct Collection

We collect personal information when you:

Complete forms

Apply for coverage

Contact us by phone, email, text, or in person

Use our website or Services

Apply for employment

Information may also be provided by a spouse or family member.

We may lawfully obtain information from public sources and third-party service providers.

Indirect Collection

We may collect personal information from:

Insurance agents and agencies

Carriers and providers

Business partners

Lead generation partners

Members using our Services

When agents or agencies use our systems, they may upload or provide personal information (“Your Content”).

We process such information under contractual agreements and only as necessary to provide Services or comply with law.

Automatic Collection

We use automatic technologies to collect:

Traffic data

Usage logs

Device data

Interaction data

Behavioral tracking information

This may include:

IP address

Browser type

ISP

Access times

Referring URLs

Files viewed

Technologies Used

Browser cookies

Web beacons

Pixel tags

Flash cookies

Analytics tools (e.g., Google Analytics)

You may manage cookies through browser settings. Disabling cookies may limit functionality.

We do not currently respond to Do Not Track (DNT) signals.

Third-Party Tracking

Third-party advertisers, ad networks, service providers, and application providers may use tracking technologies. We do not control their tracking methods.

To opt out of targeted advertising from NAI members, visit the Network Advertising Initiative website.

SMS Preferences

By opting into SMS communications, you agree to receive messages related to:

Contracting

Support

Enrollment

General service inquiries

You may opt out by replying STOP.
Reply HELP for assistance.
Message frequency varies.
Message and data rates may apply.

SMS opt-in data and consent will not be shared with third parties.

Mobile Information Protection

Mobile phone numbers and SMS consent data will not be sold, rented, or shared with third parties for marketing or promotional purposes.

Your mobile information is used solely to communicate regarding services you have requested and for customer support purposes.

How We Use Your Information

We use personal information to:

Provide Services

Process enrollments

Improve Services

Develop new products

Diagnose technical issues

Prevent fraud

Fulfill contractual obligations

Conduct marketing (where permitted)

Protect rights and property

Comply with law

Facilitate mergers or asset transfers

Carry out HR or employment functions

Any purpose with your consent

Disclosure of Personal Information

We may disclose personal information to:

Insurance agents

Insurance carriers and health plans

Health care providers

Subsidiaries and affiliates

Contractors and service providers

Co-branded business partners

Successors in business transactions

Government agencies

Third parties with your consent

We do not sell or share SMS opt-in data.

Your Choices

You may:

Disable cookies

Opt out of promotional emails

Contact us to update or correct information

Request deletion (subject to legal retention requirements)

You cannot opt out of transactional communications related to active services.

Additional State Privacy Rights

Residents of California, Colorado, Connecticut, Montana, Oregon, Texas, Utah, Virginia, and other applicable states may have rights to:

Access personal information

Correct inaccuracies

Delete personal information

Opt out of targeted advertising

Opt out of sale/sharing (we do not sell personal information)

Limit use of sensitive personal information

Appeal denial of a request

Be free from discrimination

We verify identity before processing requests.

Authorized agents may submit requests with proper documentation.

We respond within legally required timeframes (generally 45 days, with possible extension).

California-Specific Rights (CCPA / CPRA)

California residents may request:

Categories collected

Sources

Business purposes

Categories of third parties disclosed to

Specific pieces of personal information

Correction or deletion

Restriction of sensitive data use

We do not sell or share personal information for cross-context behavioral advertising without consent.

We will not discriminate for exercising rights.

Shine the Light Law (CA Civil Code §1798.83)

We do not disclose personal information to third parties for direct marketing unless you request it.

Data Security We implement:

Secure server environments

Encryption at rest (where applicable)

Physical, technical, and organizational safeguards

Access controls

However, no transmission is completely secure. Use of Services is at your own risk.

You are responsible for maintaining password confidentiality.

Data Retention

We retain personal information:

As long as necessary to fulfill purposes collected

As required by law

For tax, audit, or regulatory compliance

To resolve disputes

Children Under 18

Our Services are not intended for individuals under 18. We do not knowingly collect data from minors.

Changes to This Privacy Policy

We may update this Privacy Policy at any time. Updates will be posted with a revised “Last Modified” date.

Continued use of Services constitutes acceptance of changes.

Contact Information

If you have questions or wish to exercise privacy rights, contact:

Kendra Gray
ClarVia Benefits Group LLC

(725)712-5122 or

(725)777-2338

[email protected]