Privacy and Security Policies

E-COMP, A Division of Granite Insurance Brokers, Granite Insurance Brokers (“Company,” “we,” “us” or “our”) respect your privacy and are committed to protecting it through our compliance with the Privacy Policy.

This Policy describes the type of information we may collect from you or that you may provide when you visit the websites www.ecompnow.com and www.graniteins.com (collectively, the “website”) and our practices for collecting, using, maintaining, protecting, and disclosing that information.

This policy applies to information we may collect:

• On this Website.
• In email, text, and other electronic messages between you and this Website.
• Through mobile and desktop applications you download from this Website, which provides dedicated non-browser-based interaction between you and this Website.
• When you interact with our advertising and applications on third-party websites and services if those applications or advertising include links to this policy.
• And any other sources.

Please read this policy carefully to understand our policies and practices regarding your information and how we will treat it. If you do not agree with our policies and practices, your choice is not to use our website. By accessing or using this Website, you agree to this Privacy Policy. This policy may change from time to time. Your continued use of this Website after we make changes is deemed to be acceptance of those changes, so please check the policy periodically for updates.

Our website is not intended for visitors who are under eighteen (18) years of age. No one under age eighteen (18) may provide any information to or on the website. We do not knowingly collect personal information from children under eighteen (18). If you are under eighteen (18), do not use or provide any information on this website or through any of its features, register on the Website, or provide any information about yourself to us, including your name, address, telephone number, email address, or any screen name or username you may use.

1 – Information we collect about you and how we collect it

We collect several types of information from and about users of our website, including information:

• That may allow you to be personally identified, such as name, postal address, email address, telephone number, and social security number (“personal information“).
• Relates to your business, such as the number of employees that work at your company, your company’s average income, and your company’s Federal Employer ID Number (FEIN).
• Payment account information, such as your credit card number, security code, and expiration date, your bank routing number and bank account number, if you elect to purchase products or services (the “Service”) through the Website.
• That is about you but individually does not identify you, such as automatically recorded times and dates of visit to the Website; and/or
• About your internet connection, the equipment you use to access our website, and usage details.

We collect this information:

• Directly from you when you provide it to us when you access or use the Service, use the “chat” feature to communicate with one of our service representatives, submit a request for an insurance quote or application for insurance, or otherwise submit a request for information about the products or services that we offer;
• Automatically as you navigate through the site. Information collected automatically may include usage details, unique IDs, IP addresses, and information collected through cookies, web beacons, and other tracking technologies; and
• From third parties, for example, our business partners.

2 – Information we collect through automatic data collection techniques

As you navigate through and interact with our website, we may use automatic data collection technologies to collect certain information about your equipment, browsing actions, and patterns, including:

• Details of your visits to our website, including the pages you visit within the Website, the date and time of your visit, the amount of time you spend using the Website, location data, logs, and other communication data and the resources that you access and use on the Website.
• Information about your computer and internet connection, including your IP address, operating system, and browser type.

We also may use these technologies to collect information about your online activities over time and across third-party websites or other online services (behavioral tracking).

The information we collect automatically is only statistical data and does not include personal information, but we may maintain it or associate it with personal information we collect in other ways or receive from third parties. It helps us to improve our website and to deliver a better and more personalized service, including by enabling us to:

• Estimate our audience size and usage patterns.
• Store information about your preferences, allowing us to customize our website according to your individual interests.
• Speed up your searches.
• Recognize you when you return to our website.

The technologies we use for this automatic data collection may include:

• Cookies (or browser cookies). A cookie is a small file placed on the hard drive of your computer. You may refuse to accept browser cookies by activating the appropriate setting on your browser. However, if you select this setting, you may be unable to access certain parts of our website. Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies when you direct your browser to our website.

• Web beacons. Pages of the Website and our e-mails may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit the Company, for example, to count users who have visited those pages or opened an email and for other related website statistics (for example, recording the popularity of certain website content and verifying system and server integrity).

3 – Third-party use of cookies and other tracking technologies

Some content or applications, including advertisements, on the Website are served by third parties, including advertisers, ad networks and servers, content providers, and application providers. These third parties may use cookies alone or in conjunction with web beacons or other tracking technologies to collect information about you when you use our website. The information they collect may be associated with your personal information or they may collect information, including personal information, about your online activities over time and across different websites and other online services. They may use this information to provide you with interest-based (behavioral) advertising or other targeted content.

We do not control these third parties’ tracking technologies or how they may be used. If you have any questions about an advertisement or other targeted content, you should contact the responsible provider directly. For information about how you can opt out of receiving targeted advertising

4 – How we use your information

We use information that we collect about you or that you provide to us, including any personal information:

• To fulfill or meet the reason you provided the information. For example, if you share your name and contact information to request a price quote or ask a question about our products or services, we will use that personal information to respond to your inquiry. If you provide your personal information to purchase a product or service, we will use that information to process your payment and facilitate delivery. We may also save your information to facilitate new product orders or process returns.
• To create, maintain, customize, and secure your account with us.
• To tell you about our service updates.
• To process your requests, purchases, transactions, and payments and prevent transactional fraud.
• To provide you with support and to respond to your inquiries, including to investigate and address your concerns and monitor and improve our responses.
• To personalize your website experience and to deliver content and product and service offerings relevant to your interests, including targeted offers and ads through our website, third-party sites, and via email or text message (with your consent, where required by law).
• To notify you about changes to our website or any products or services we offer or provide though it.
• To help maintain the safety, security, and integrity of our website, products and services, databases and other technology assets, and business.
• For testing, research, analysis, and product development, including to develop and improve our website, products, and services.
• To fulfill any other purpose for which you provide it.
• To carry out our obligations and enforce our rights arising from any contracts entered between you and us, including for billing and collection.
• To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.
• To resolve disputes, troubleshoot problems and respond to your customer service inquiries; prevent, detect, and investigate potentially prohibited or illegal activities, and enforce the Terms of Use.
• To keep a record of our transactions and communications with you; and provide you with other services requested by you as described when we collect the information.
• In combination with the information of other users so that we can generally assess users’ preferences or to otherwise improve the service.
• In any other way we may describe when you provide the information.
• For any other purpose with your consent.

5 – How we disclose your information

We will not sell your information to third parties after obtaining your consent. We may also exchange your information with third-party partners without first obtaining your express consent. We may also share your information with the following third parties:

• To fulfill the purpose for which you provide it: If you request an insurance quote through the Service, or otherwise use the Service to purchase insurance coverage, we may share the information you provide through the Service with insurance companies. We will only share your information with insurance companies as necessary to provide you with the products or services you have requested through the Service. If you elect to proceed with purchasing insurance from a particular insurance company, that insurance company may seek additional information about you, including by contacting you directly by email, postal mail or telephone or running a credit check on you. We will obtain your prior consent if an insurance company intends to conduct a credit check on you. Insurance companies are only permitted to contact you directly to provide you with the products or services you have requested through the Service.
• Third-party marketing partners: We may, from time to time, share your name, email address and postal mailing address with a few carefully selected third-party insurance partners that we believe offer products or services that may be of interest to you. We contractually require these third parties to keep personal information confidential and use it only for the purposes for which we disclose it to them.
• Our service providers: We may share your information with contractors, service providers, and other third parties who provide certain services to us or on our behalf, such as operating and supporting the service. These service providers will only have access to the information needed to perform these limited functions on our behalf and are required to provide your information with at least the same level of protection and security as we use regarding your information and use your information only for the purposes for which we disclose it to them.
• Our affiliates: We may share some or all your information with our subsidiaries and corporate affiliates, joint ventures, or other companies under common control with us. We will require these entities to comply with the terms of this Privacy Policy regarding their use of your information.
• Companies that acquire our business or assets: If our company or our assets are acquired by, transferred to or merged with another company, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, that company may acquire the information about you collected by us. We will require the applicable company to assume the rights and obligations that are applicable to your information at the time of the acquisition, transfer, or merger.
• For any other purpose disclosed by us when you provide the information
• With your consent.

We may also disclose your personal information:

• To comply with any court order, law, or legal process, including to respond to any government or regulatory request.
• To enforce or apply our Terms of Use and other agreements, including for billing and collection purposes.
• If we believe disclosure is necessary or appropriate to protect the right, property, or safety of us, our customers, or others. This may include exchanging information with other companies and organizations for the purposes of fraud protection and credit risk protection.

6 – Choices about how we use and disclose your information

We strive to provide you with choices regarding the personal information you provide to us. We have created mechanisms to provide you with the following control over your information:

• Tracking technologies and advertising. You can set your browser to refuse all or some browser cookies, or to alert you when cookies are being sent. To learn how you can manage your Flash cookie settings, visit the Flash player settings page on Adobe’s website. If you disable or refuse cookies, please note that some parts of this site may then be inaccessible or not function properly.

• Disclosure of your information for third-party advertising. If you do not want us to share your personal information with unaffiliated or non-agent third parties for promotional purposes, you may opt out by emailing us at [email protected] or calling us at (888) 493-2667.

• Promotional offers from the Company. If you do not wish to have your contact information used by the Company to promote our own or third parties’ products or services, you can opt-out by either following the link provided in the applicable email communication or contacting us at [email protected].

We do not control third parties’ collection or use of your information to serve interest-based advertising. However, these third parties may provide you with ways to choose not to have your information collected or used in this way. You can opt out of receiving targeted ads from members of the Network Advertising Initiative (“NAI”) on the NAI’s website.

California residents may have additional personal information rights and choices. Please see your California Privacy Rights for more information.

Nevada residents who wish to exercise their sale opt-out rights under Nevada Revised Statutes Chapter 603A may submit a request to this designated address: [email protected] or by telephone at (888) 493-2667.

7 – Your California privacy rights

If you are a California resident, California law may provide you with additional rights regarding our use of your personal information.

To exercise the right to opt-out, you (or your authorized representative) may submit a request to us by filling out this form.

8 – Links to other websites. The Service may contain links to websites that are not owned or operated by Granite/E-COMP. Please be aware that we are not responsible for the privacy practices of these websites. If you visit these websites or provide any information directly to parties other than Granite/E-COMP (even if those websites display the Granite/E-COMP brand), different policies may apply to the collection and use of your information. We encourage you to investigate and ask questions before accessing third-party websites or disclosing information to third parties.

9 – Third-party advertisers. The Service may include third-party advertising, links to advertiser websites, and other content from third-party businesses. These third-party sites, businesses, and advertisers may use web beacons and cookies to measure the effectiveness of their ads, personalize or optimize advertising content and to track users who click on the links made available through the Service. We do not have access to or control over web beacons or cookies that these third parties may use. We are not responsible for the privacy practices of these third parties. We encourage you to review their privacy policies.

10 – Privacy protection for children. In compliance with the Children’s Online Privacy Protection Act (COPPA), we will not knowingly collect information from persons under the age of thirteen (13). If we later learn that an individual under the age of thirteen (13) has provided information through the Service, we will take appropriate steps to remove that individual’s information from our database and restrict that individual from future access to the Service.

11 – Use of information outside your country of residence

The Service is directed to users located in those states in the United States in which the Company or any of its affiliates are licensed insurance agents or brokers. The Service is not intended as a solicitation for insurance in any state where the Company or any of its affiliates are not licensed. If you are located outside of the United States and choose to use the Service or provide your information to us, your information will be transferred, processed, and stored in the United States. U.S. privacy laws may not be as protective as those in your jurisdiction. Your agreement to the terms of this Privacy Policy followed by your submission of information represents your agreement to this practice. If you do not want your information transferred to or processed or stored in the United States, you should not use the Service.

12 – Our security procedures

We have implemented technical and administrative security measures to protect your personal information from accidental loss and from unauthorized access, use, alteration, and disclosure. To guard against unauthorized disclosure of your information, information that is passed between your browser and us is encrypted with the Secure Sockets Layer (SSL) system. We also use industry-standard practices such as encrypted storage, firewalls, and password protection systems to safeguard the confidentiality of your information. Each of our employees who has access to your information is aware of our security policies, and your information is only available to those employees who need it to perform their jobs.

The safety and security of your information also depends on you. Where we have given you (or where you have chosen) a password for access to certain parts of our website, you are responsible for keeping this password confidential. We ask you not to share your password with anyone.

Unfortunately, the transmission of information via the internet is not completely secure. Although we do our best to protect your personal information, we cannot guarantee the absolute security of your information. Any transmission of personal information is at your own risk. We assume no responsibility or liability if any information relating to you is intercepted and/or used by an unintended recipient.

13 – How we retain your information

We retain information for active accounts as long as it is necessary and relevant for our operations and as required by the Department of Insurance. In addition, we may retain information from closed accounts to comply with the law, prevent fraud, collect any fees owed, resolve disputes, troubleshoot problems, assist with any investigation, enforce the Terms of Use, and take other actions permitted by law. The information we retain about you will be handled in accordance with this Privacy Policy.

14 – How we notify you of changes to our policy

It is our policy to post any changes we make to our privacy policy on this page. We will notify you of material changes to this Privacy Policy by posting the amended terms on the Site at least thirty (30) days before the effective date of the changes. You may cancel your account prior to the end of the applicable thirty (30) day period by contacting us using the contact information in Section 13 below. If you choose to cancel your account within this thirty (30) day period, you will not be bound by the policy. The date the Privacy Policy was last revised is identified at the bottom of the page. You are responsible for periodically visiting our Website and this Privacy Policy to check for any changes.

15 – Practices related to Platform

This section of our Policy describes how we handle information that you provide to us as an employee, agent, or representative of an entity that uses the E-COMP NOW Platform (a “Platform Customer”). The other sections of this Policy do not apply to such information, except as provided below. Note that we do not control how Platform Customers use personal information that they access from the E-COMP NOW Platform.

Information that Platform Customers provide. We will collect your name, contact information, and information associated with your Platform Customer account.

How we use this information. We use information that you provide to deliver services to the Platform Customer that you represent, e.g., gathering price quotes from insurance carriers on the Customer’s behalf. We also may aggregate information about the use of the E-COMP NOW Platform to provide statistical information to Platform Customers. We do not sell this information.

How we share information from Platform Customers. We may share the information that you provide with:

• Our service providers, to help us to provide E-COMP NOW Platform services;
• Your employer in its capacity as a Platform Customer, to the extent required to fulfill our contractual obligations;
• Courts, regulators, enforcement authorities, and other third parties in response to lawful demands or in the context of legal proceedings.

Data Security. The security measures described in section 10 of this Policy apply to the information that we collect under this section 13.

16 – How you can contact us

If you have any questions about this Privacy Policy, you may contact us by email at [email protected] or by telephone at (888) 493-2667.

Last modified: 2/16/2022