Sterling Bridge Insurance Agency, Inc. ("Company," "we", "us," "our,") provides online and mobile services, including but not limited to, the Company website ("Pivot.com”or the "Site") widgets, computer programs and mobile applications hosted by or on behalf of Company (collectively, the "Service" or the “Platform”) intended to enhance your use of the products offered by Company (the "Company Products"). We are committed to respecting and protecting your privacy, and it is our policy to comply with all applicable laws relating to privacy. This Privacy Policy ("Policy") explains how we protect personal information we collect in connection with your use of the Service and how we use and, in some cases, disclose that information. "Personal information" for purposes of this Policy means information that identifies you, such as your name, address, phone number, or email address. In addition, in this Policy you will find further information on these areas:

• What information we collect.
• How we may use the information.
• How we may share the information.
• What types of security procedures are in place to protect the information.
• How users can correct inaccuracies in the information.
• What choices are available to users regarding collection, use and distribution of the information.
• How to contact us.

Important note: Our websites may contain links to other parties’ sites. Although we take efforts to ensure that we only share information with third-parties who have sound privacy policies, we are not responsible for the privacy practices of such other sites. We encourage you to read the privacy statements of each and every Website that collects personally identifiable information.


Information We Collect

Information you provide. When you use any service or promotion that requires registration, we ask you for Personal Information (e.g., your name, email address, an account password). We may combine the information you submit under your account with information from our other services or third parties in order to fulfill your request, to provide you with a better experience, or to improve the quality of our services. For certain services, we may give you the opportunity to opt out of combining such information.
 

Cookies and other Technologies.

The Company Site and Service may use "cookies" and other technologies such as pixel tags and web beacons.

Cookies are alphanumeric identifiers in the form of text files that are inserted and stored by your Web browser on your computer's hard drive. These technologies tell us which parts of our website you have visited, limit the number of times you see a Company offer, or help us better determine which Company offers you may like to see or to alert you to software compatibility issues. They are also used to analyze and improve our Service's design and functionality.

If you choose to delete cookies from your device or block them from being stored on your device, please note that the full functionality of the Service may not be available to you.

"Web beacons" are images embedded in a Web page or email for the purpose of measuring and analyzing Site usage and activity. Company, or third-party service providers acting on our behalf, may use Web beacons to help us analyze Site usage and improve the Service.

We may use third party service providers to help us analyze certain online activities and improve our products and the Service. For example, these service providers may help us measure the performance of our online campaigns or analyze visitor activity on Company.com. We may permit these service providers to use cookies and other technologies to perform these services for Company. We do not share any personal information about our customers with these third-party service providers, and these service providers do not collect such information on our behalf. Our third party service providers are required to comply fully with this Policy.

Log-file information. When you access our services, our servers may automatically record information that your browser sends whenever you visit any website. These server logs may include information such as your web request, IP address, browser type, browser language, the date and time of your request and one or more cookies that may uniquely identify your browser.

Communications If you send us messages, we may retain those in order to process your inquiries, respond to your requests and improve our services.


Use of Information
 

Company uses your personal information to:

• Provide you with the Service;
• Analyze Site usage and improve the Service;
• Deliver to you any administrative notices and communications relevant to your use of the Company Products and Service;
• Provide you with updates regarding Company Products and Services;
• Perform internal market research, project planning, troubleshooting problems, and to detect and protect against error, fraud or other criminal activity.

Legal Basis

We rely on a number of legal bases to use your information in the ways indicated above. These legal bases include where:

• necessary to perform the contractual obligations in our agreement with you or your employer and provide services to you;
• you have consented to the processing, which you can revoke at any time;
• necessary to comply with a legal obligation, a court order, or to exercise or defend legal claims;
• necessary for the purposes of our legitimate interests; and
• you have expressly made the information public.
   

Where we process your information on the basis of legitimate interests, we do so as it is necessary to pursue our legitimate interests of providing and improving our services for our customers. The Company has a legitimate interest in understanding how our services are being used. We also pursue our legitimate interests of improving our services, efficiency, and determining the level of interest in services for customers by obtaining insights into usage patterns of the services.

We may also use your information to maintain a secure site, including sharing of your information for such purposes, because it is necessary to pursue our legitimate interests in ensuring the security of our services, including enhancing protection of our site, intellectual property infringement and security risks of all kind. We may also process and share your personal information with a third party in response to lawful requests by public authorities, including to meet legitimate national security or law enforcement requirements; defend against legal claims, to comply with a subpoena, court order, legal process, or other legal requirement; or when we believe in good faith that such disclosure is reasonably necessary to comply with the law.

We may use the information to provide you with the Service, to communicate with you, or for other lawful purposes within the limits of this policy. Unless your jurisdiction prohibits it, we will retain copies of Personal Information in a form that permits identification for as long as we deem necessary in connection with the purposes set out in this Privacy Policy, unless applicable law or regulation requires us to preserve this information for a longer or shorter period. We will retain and use your information as necessary to comply with our legal and/or regulatory obligations, resolve disputes, and enforce our agreements.


Communications from Us

Initial Account Confirmation.  We may send you a welcoming email for your information, and if applicable, to confirm your user ID and/or password.

Newsletter, Products & Services.  We may send a newsletter to users of certain services. If a user wishes to subscribe to our newsletter, we ask for contact information such as name and email address. We may also occasionally send you information on products or services. Out of respect for our users’ privacy, we provide a way to opt-out of these communications (see Opt-Out, below).

Service Announcements.  On very rare occasions it may be necessary to send out a strictly service-related announcement, For instance, if our service experiences a significant outage. Generally, users may not opt-out of these communications, though they can deactivate their account. However, these communications are not promotional in nature.

Customer Service.  We communicate with users on a regular basis to provide requested services and in regard to issues relating to their specific account; we may communicate via email, mail, or phone.

Surveys. Depending upon which of our services you use and which of our sites you access, you may be permitted and/or invited to provide us with information and/or your opinions. Participation in these surveys is completely voluntary, but the information collected may be used consistent with this privacy policy. In the event we elect to use an intermediary to conduct these surveys, the intermediary will be prohibited from using personally identifiable information for any secondary purposes.


Additional Information We May Collect

Profile. We may store information that we collect through cookies, log files and/or third parties to create a profile of our users. A profile is stored information that we keep on individual users that details their viewing preferences. Consequently, collected information is tied to the users personally identifiable information to provide offers and improve the content of the site for the user. This profile is used to tailor a user’s visit to our website and to direct pertinent information to users. We do not share your profile with third parties, except as otherwise described herein.

Tell-A-Friend. We reserve the right to start a referral service. If you elect to use this referral service to tell a friend about our site, we’ll ask you for the friend’s name and email address. We will automatically send the friend a one-time email inviting him or her to visit the site. We store this information for the sole purpose of sending this one-time email and tracking the success of our referral program. The friend may contact our privacy officer (see contact information below) to remove this information from our database.


Sharing of Information

Aggregate Information (non-personally identifiable).  We may share aggregated demographic information about our user base with others. This information does not identify individual users. In doing this, we do not link aggregate user data with personally identifiable information.

Personally identifiable information. We may share personally identifiable information with third parties in several instances:

1) When the service you are requesting inherently requires it, as when we submit your application for insurance to an insurance company;

2) When you expressly authorize and/or direct it;

3) In response to subpoenas, court orders, or legal process, or to establish or exercise our legal rights or defend against legal claims; and

4) When we believe that disclosure is necessary to protect our rights or to comply with a judicial proceeding, court order, legal process, or as otherwise required by law.

Business Transitions.  In the event we go through a business transition, such as a merger, acquisition by another company, or sale of all or a portion of our assets, the information we have collected will likely be among the assets transferred. You will be notified via notice on our website of any such change in ownership or control of your personal information.


Security

We subscribe to industry standards for the protection of personal information submitted to us, both during transmission and once we receive it. When you enter sensitive information (such as a credit card number and/or social security number) through our website, we encrypt that information using secure socket layer technology (SSL). Once received, information that is retained by us is (1) kept in a firewalled and intrusion-protected storage environment, (2) accessed only by privacy-trained staff authorized to access it to fulfill your requests or otherwise perform our business functions, and (3) periodically reviewed for deletion in accordance with applicable law, contract requirements, and our internal data-retention guidelines.
 

Even though we have taken reasonable commercial steps and efforts to prevent Personal Information and other information covered by this Privacy Policy from being accessed, used, intercepted, or disclosed by unauthorized individuals, you should know and you acknowledge that we cannot fully eliminate risks associated with Personal Information. By providing to or allowing access by us to personal information as a result of your use of the Platform and/or Services, you acknowledge and agree that we are not liable for (i) any special, indirect, consequential, incidental or punitive damages, costs, or liabilities whatsoever arising out of or resulting from your use of the Platform or Services, including from uploading, posting, providing, storing, using, analyzing, transmitting, sharing, and/or allowing access to Personal Information and other information and content; or (ii) any loss, disclosure, or use of Personal Information or other information and content.

Opt-out and Corrections

If you wish to opt-out of certain features of your account, if your personally identifiable information changes (such as zip code, phone, email or postal address), or if you no longer wish to use our service, we provide a way to correct, update or delete/deactivate personally identifiable information. This can usually be done online, or alternatively by emailing us at the contact email address below.

If you choose to close your Account or your account is terminated with us, we will continue to adhere to the privacy policies and practices outlined here. If you maintain an Account with us that you access through our Platform, you are responsible for protecting and maintaining the confidentiality of your Account and password and restricting access to your computer. While we follow generally accepted standards to protect the Personal Information submitted to us, both during transmission and once we receive it, no method of transmission over the Internet, or method of electronic storage, is 100% secure and we cannot guarantee its absolute security.

We may delete Personal Information when we no longer need it for the purposes we described earlier. However, any information that you have made public may continue to be displayed unless you remove it. Additionally, We retain Personal Information as permitted by law to resolve disputes and enforce our policies.

International Users

The Company's Services are hosted and operated entirely in the United States and are subject to United States law. Any personal information that you provide to Company is being provided to Company solely in the United States and will be hosted on United States servers. You consent to the transfer of your personal information to the United States. If you are accessing the Company Services from outside the United States, please be advised that United States law may not offer the same privacy protections as the law of your jurisdiction.

Changes in this Privacy Statement

We reserve the right to modify this privacy statement at any time, so please review it frequently. If we make material changes to this policy, we will notify you here, by email, or by means of a notice on our home page.


Contact Us

This privacy policy covers websites owned and operated by Sterling Bridge Insurance Agency, Inc. and its subsidiaries, including Small Business Service Bureau, Inc., and divisions thereof, including Pivot.com. To reach us regarding this privacy policy, please contact us at:

Email: privacy-officer@carroll-ent.com
or mail us at
Privacy Officer
Sterling Bridge Insurance Agency, Inc.
38 Austin Street

Worcester, MA 01609