Privacy Policy — Ingot Capital Insurance Inc.

INGOTINSURANCE.COM

Ingot Capital Insurance Inc. ("Ingot Capital," "we," "us," or "our") is committed to protecting your privacy. This Privacy Policy explains how we collect, use, disclose, and safeguard your personal information when you visit ingotinsurance.com, use our mobile applications, or engage with our insurance services (collectively, the "Platform").

This Privacy Policy applies to all users of the Platform and is incorporated into our Terms of Use. Please read this policy carefully. By using the Platform, you agree to the practices described herein. If you do not agree, please discontinue use of the Platform.

This Privacy Policy is intended to comply with applicable federal and state privacy laws, including but not limited to: the Gramm-Leach-Bliley Act (GLBA); the California Consumer Privacy Act (CCPA) and California Privacy Rights Act (CPRA) (for California residents); the Telephone Consumer Protection Act (TCPA); applicable state insurance privacy regulations; and the CAN-SPAM Act.

1. Information We Collect

We collect personal information in the following categories:

1.1 Information You Provide Directly

Identity & Contact Information: Full name, date of birth, Social Security number (where required for underwriting), mailing address, email address, and phone number(s).
Insurance Application Data: Driving history, claims history, medical information (for health/life products), property details, vehicle information, and other information necessary to obtain quotes or issue policies.
Financial Information: Payment card information, bank account details (processed securely through PCI-DSS compliant payment processors), and billing address.
Account Credentials: Username, password, and security question responses.
Communications: Messages, emails, chat transcripts, and other communications you send us.

1.2 Information Collected Automatically

Device & Technical Data: IP address, browser type and version, operating system, device identifiers, and time zone.
Usage Data: Pages visited, links clicked, session duration, referring URLs, and navigation paths within the Platform.
Location Data: General geographic location derived from IP address; precise location only with your express consent.
Cookies & Tracking Technologies: Please see Section 9 (Cookies and Tracking Technologies) for full details.

1.3 Information From Third Parties

Insurance Carriers & Partners: Policy status, underwriting data, and claims information from carriers with whom we place coverage.
Consumer Reporting Agencies: Credit reports, motor vehicle reports (MVRs), CLUE reports, and other consumer reports permissible under the Fair Credit Reporting Act (FCRA) for insurance purposes.
Data Brokers & Marketing Partners: Demographic and interest data used to improve our services and communications, subject to applicable law.
Public Sources: Publicly available information, including property records and court records, as permitted by law.

2. How We Use Your Information

We use the personal information we collect for the following purposes:

2.1 Insurance Services

Processing insurance quotes, applications, and policy issuance;
Facilitating claims reporting, investigation, and resolution;
Verifying your identity and eligibility for insurance products;
Communicating with you about your policies, renewals, and coverage changes;
Complying with legal and regulatory obligations as a licensed insurance agency.

2.2 Platform Operations

Operating, maintaining, and improving the Platform;
Authenticating users and managing accounts;
Detecting, preventing, and investigating fraud, security incidents, and other prohibited activities;
Analyzing usage patterns and Platform performance.

2.3 Communications & Marketing

Sending transactional communications (policy documents, billing statements, claims updates);
Sending marketing and promotional materials, subject to your consent and applicable law;
Conducting surveys and collecting feedback;
Communicating via email, phone call, or SMS/text message in accordance with Section 5 (TCPA Compliance) of this Policy.

2.4 Legal & Compliance

Complying with applicable laws, regulations, and legal process;
Responding to lawful requests from regulatory and law enforcement authorities;
Enforcing our Terms of Use and other agreements;
Protecting the rights, property, and safety of Ingot Capital Insurance, our users, and the public.

3. How We Share Your Information

We do not sell your personal information to unaffiliated third parties for their own marketing purposes. We may share your information in the following circumstances:

3.1 Insurance Carriers and Agents

We share your information with licensed insurance carriers, underwriters, managing general agents (MGAs), and other insurance professionals as necessary to obtain quotes, bind coverage, issue policies, and service your account. These parties receive your information for insurance transaction purposes only.

3.2 Service Providers

We engage third-party service providers that perform services on our behalf, including IT and platform infrastructure, payment processing, data analytics, customer support, email communications, and marketing services. These providers are contractually obligated to use your information only as directed by us and in accordance with applicable privacy law.

3.3 Affiliates

We may share information with our corporate affiliates for purposes consistent with this Privacy Policy. All affiliated entities are bound by the same privacy standards we apply.

3.4 Business Transfers

In the event of a merger, acquisition, reorganization, or sale of all or substantially all of our assets, your information may be transferred to the acquiring entity, subject to the same privacy protections described in this Policy. We will provide notice of such a transfer as required by applicable law.

3.5 Legal Compliance and Protection

We may disclose your information where required by law, court order, or government regulation; to enforce our agreements; or to protect the rights, safety, and property of Ingot Capital Insurance, our users, or the public.

3.6 With Your Consent

We may share your information with any third party when you have given us your explicit consent to do so.

4. Data Retention and Inactive Account Deletion

180-DAY INACTIVE DATA DELETION POLICY: We automatically delete personal data associated with inactive user accounts after 180 consecutive days of inactivity, subject to the exceptions described below.

4.1 General Retention Periods

We retain your personal information for as long as necessary to fulfill the purposes described in this Privacy Policy, to maintain your active insurance policies, and to comply with our legal and regulatory obligations. Specific retention periods include:

Active Account Data: Retained for the duration of your account and any active insurance policy period.
Policy Records: Retained for a minimum of seven (7) years following policy expiration or cancellation, as required by applicable insurance regulations.
Claims Records: Retained for a minimum of seven (7) years following claim closure, or longer as required by applicable law or regulation.
Financial Transaction Records: Retained for a minimum of seven (7) years in accordance with applicable tax and financial recordkeeping requirements.
Consumer Reports (FCRA): Retained and disposed of in accordance with FCRA requirements, including proper disposal standards.

4.2 Inactive Account Data Deletion

An account is considered "inactive" when the account holder has not logged in, accessed the Platform, made a payment, filed a claim, or otherwise engaged with the Platform for a continuous period of one hundred eighty (180) calendar days.

Upon reaching 180 days of inactivity, the following process applies:

Day 150 of Inactivity: We will send an email notification to your registered email address advising that your account data is scheduled for deletion and providing instructions to reactivate your account.
Day 170 of Inactivity: A final reminder notice will be sent to your registered email address.
Day 180 of Inactivity: Your account and associated personal data will be permanently deleted from our active systems, subject to the exceptions in Section 4.3 below.

4.3 Exceptions to the 180-Day Deletion Policy

Notwithstanding the 180-day deletion policy, we will retain data as required by:

Active or recently expired insurance policies (data retained through the minimum regulatory retention period);
Open or unresolved insurance claims;
Pending or ongoing litigation, regulatory investigation, or legal hold;
Applicable state or federal law, including insurance recordkeeping regulations;
Contractual obligations with insurance carriers;
Fraud prevention records where retention is required to protect our users and business.

Data retained pursuant to these exceptions will be held in restricted-access archives and will not be used for marketing or non-compliance purposes.

4.4 Account Reactivation

You may reactivate your account at any time before the 180-day deletion period elapses by logging in to the Platform or contacting us at Info@IngotInsurance.com. Reactivation resets the inactivity clock. Data that has already been permanently deleted cannot be recovered.

5. Telephone Consumer Protection Act (TCPA) Compliance

TCPA NOTICE: We are committed to full compliance with the Telephone Consumer Protection Act (TCPA), 47 U.S.C. § 227, and its implementing regulations. We will never contact you via autodialed call, prerecorded message, or text/SMS without your prior express written consent where required by law.

5.1 Scope of TCPA Coverage

The TCPA governs how we may contact you using:

Automated telephone dialing systems (autodialers) for calls or texts to your mobile phone;
Prerecorded or artificial voice messages delivered to mobile or residential phones;
SMS/MMS text messages sent to mobile phones using automated systems;
Fax transmissions (where applicable).

5.2 Consent Requirements

We obtain consent as follows, consistent with FCC regulations and applicable TCPA standards:

Transactional / Informational Calls and Texts:

For calls and texts that are directly related to your insurance account or policy (e.g., payment reminders, policy renewal notices, claims status updates), we may contact you based on the contact information you provide. You have the right to opt out of these communications at any time.

Marketing / Promotional Calls and Texts:

For marketing or promotional calls and texts to your mobile phone using an autodialer or prerecorded message, we obtain your "prior express written consent" as required by the TCPA. Such consent is documented, timestamped, and retained. You may revoke marketing communications consent at any time.

Manual Calls:

Live, manually dialed calls to mobile or residential phones for non-marketing purposes may be made based on the contact information in your account without additional TCPA consent, though we respect all do-not-call preferences.

5.3 How to Provide TCPA Consent

You may provide your consent to receive autodialed or prerecorded calls and text messages in any of the following ways:

Checking the TCPA consent checkbox during account registration or policy application;
Replying to a consent confirmation text message with the keyword START or YES;
Verbally providing consent during a recorded call with a licensed agent (which we will confirm in writing);
Submitting a signed electronic consent form through the Platform.

Your consent is specific to the phone number provided at the time of consent. If you change your phone number, a new consent may be required.

5.4 Opt-Out Rights — How to Stop Texts and Calls

You may revoke your consent to receive autodialed or prerecorded calls and text/SMS messages at any time using any of the following methods:

Text-Based Opt-Out: Reply STOP, QUIT, CANCEL, END, or UNSUBSCRIBE to any text message you receive from us. You will receive a single confirmation text and no further marketing texts will be sent.
Call-Based Opt-Out: Tell the representative during any call that you wish to be removed from our call list, or call us at the number listed in Section 17 (Contact Information) of our Terms of Use.
Email Opt-Out: Send an email to Info@IngotInsurance.com with the subject line "TCPA Opt-Out" and include your name and phone number(s) you wish to remove.
Written Opt-Out: Submit a written request to our mailing address listed in Section 15 of this Policy.

We will process all opt-out requests within ten (10) business days. Opting out of marketing communications will not affect your receipt of legally required or transactional communications necessary to service your insurance account.

5.5 National Do Not Call Registry

We honor the National Do Not Call (DNC) Registry maintained by the Federal Trade Commission. If your number is registered on the National DNC Registry and you have not provided us with prior express written consent to contact you for marketing purposes, we will not make telemarketing calls to that number.

You may also register your internal do-not-call preference directly with us by contacting Info@IngotInsurance.com. We maintain an internal DNC list and will honor requests within thirty (30) days.

5.6 Text Messaging Program Disclosures

If you enroll in our SMS/text messaging program, the following terms apply:

Message Frequency: Message frequency varies based on your account activity and preferences. You may receive up to [8] messages per month.
Message and Data Rates: Standard message and data rates may apply depending on your mobile carrier and plan.
Supported Carriers: Our text messaging program is available on most major U.S. carriers. We are not liable for delayed or undelivered messages.
Help: Text HELP to any message for assistance, or email Info@IngotInsurance.com.
Stop: Text STOP at any time to cancel. You will receive a one-time opt-out confirmation message.

No mobile information will be shared with third parties or affiliates for marketing or promotional purposes. All the above categories exclude text messaging originator opt-in data and consent; this information will not be shared with any third parties.

5.7 Calling Hours

We make telephone calls for marketing or solicitation purposes only between 8:00 a.m. and 9:00 p.m. in the called party's local time zone, consistent with TCPA and FTC Telemarketing Sales Rule (TSR) requirements.

6. Non-Public Personal Information (GLBA)

As a licensed insurance services company, we are subject to the privacy requirements of the Gramm-Leach-Bliley Act (GLBA) and applicable state insurance privacy regulations. This section supplements the remainder of this Privacy Policy with disclosures required by the GLBA.

We collect nonpublic personal information ("NPPI") about you from: (a) information you provide on applications and other forms; (b) information about your transactions with us, our affiliates, or others; and (c) information we receive from consumer reporting agencies.

We do not disclose NPPI to nonaffiliated third parties except as permitted or required by law, including for the purpose of processing insurance transactions you have requested, to comply with legal requirements, to prevent fraud, and as otherwise described in this Privacy Policy.

You have the right to opt out of certain disclosures of NPPI to nonaffiliated third parties. To exercise this right, please contact us at Info@IngotInsurance.com.

We restrict access to NPPI about you to those employees, agents, and service providers who need to know that information to service your account. We maintain physical, electronic, and procedural safeguards designed to protect your NPPI.

7. Your Privacy Rights

7.1 Rights Available to All Users

Subject to applicable law, you have the following rights with respect to your personal information:

Access: The right to request a copy of the personal information we hold about you.
Correction: The right to request correction of inaccurate or incomplete personal information.
Deletion: The right to request deletion of your personal information, subject to exceptions for legal compliance, active policies, and claims.
Portability: The right to receive your personal information in a structured, machine-readable format where technically feasible.
Opt-Out of Marketing: The right to opt out of marketing communications at any time (see Section 5.4 for TCPA opt-out and Section 8 for email opt-out).

7.2 California Residents (CCPA/CPRA)

California residents have additional rights under the California Consumer Privacy Act (CCPA) as amended by the California Privacy Rights Act (CPRA):

Right to Know: The right to know what personal information we collect, use, disclose, and sell.
Right to Delete: The right to request deletion of your personal information, subject to certain exceptions.
Right to Correct: The right to correct inaccurate personal information.
Right to Opt-Out of Sale/Sharing: We do not sell personal information. However, to the extent any of our practices constitute "sharing" under the CPRA, you have the right to opt out.
Right to Limit Use of Sensitive Personal Information: You have the right to limit our use of sensitive personal information to purposes authorized by the CPRA.
Right to Non-Discrimination: We will not discriminate against you for exercising your privacy rights.

To exercise your California privacy rights, please submit a verifiable consumer request to Info@IngotInsurance.com or call us at the number listed in Section 15 of this Policy. We will respond within 45 days as required by the CPRA.

7.3 How to Submit a Privacy Request

To exercise any of the rights described above, you may:

Email us at Info@IngotInsurance.com with the subject line "Privacy Rights Request";
Mail a written request to the address in Section 15 of this Policy;
Use the Privacy Request form available at ingotinsurance.com/privacy-request.

We may need to verify your identity before processing your request. We will not charge a fee for reasonable requests but reserve the right to charge a reasonable fee for excessive or repetitive requests as permitted by law.

8. Email Communications and CAN-SPAM Compliance

All commercial email communications from Ingot Capital Insurance comply with the CAN-SPAM Act. Each marketing email we send will:

Clearly identify Ingot Capital Insurance as the sender;
Include a valid physical postal address;
Include a clear and conspicuous opt-out mechanism;
Honor opt-out requests within ten (10) business days.

To unsubscribe from marketing emails, click the "Unsubscribe" link in any marketing email or contact us at Info@IngotInsurance.com. Unsubscribing from marketing emails does not affect transactional or policy-related communications.

9. Cookies and Tracking Technologies

We use cookies, web beacons, pixel tags, and similar tracking technologies to operate and improve the Platform. Types of cookies we use:

Strictly Necessary Cookies: Required for the Platform to function. These cannot be disabled.
Functional Cookies: Remember your preferences and settings to enhance your experience.
Analytics Cookies: Help us understand how users interact with the Platform (e.g., Google Analytics).
Marketing/Advertising Cookies: Used to deliver relevant advertisements and track campaign performance.

You can control most cookies through your browser settings or by using our cookie preference center available at ingotinsurance.com/cookie-settings. Please note that disabling certain cookies may affect Platform functionality.

We do not respond to Do Not Track (DNT) browser signals at this time, as no uniform standard has been established. California residents may exercise Global Privacy Control (GPC) rights where applicable.

10. Data Security

We implement administrative, technical, and physical safeguards designed to protect your personal information from unauthorized access, disclosure, alteration, and destruction. Our security measures include:

Encryption of data in transit using TLS/SSL protocols;
Encryption of sensitive data at rest;
Access controls and role-based permissions limiting data access to authorized personnel;
Multi-factor authentication for administrative systems;
Regular security assessments and vulnerability testing;
Employee training on data privacy and security practices;
Vendor security assessments for third-party service providers.

No method of electronic transmission or storage is 100% secure. While we strive to protect your personal information, we cannot guarantee absolute security. In the event of a data breach affecting your rights or freedoms, we will notify you as required by applicable state and federal breach notification laws.

11. Children's Privacy

The Platform is not directed to individuals under the age of 18. We do not knowingly collect personal information from children under 18. If we become aware that we have inadvertently collected personal information from a child under 18, we will promptly delete such information. If you believe we have collected information from a minor, please contact us immediately at Info@IngotInsurance.com.

12. Third-Party Links

The Platform may contain links to third-party websites, including insurance carrier portals, consumer reporting agency portals, and payment processors. This Privacy Policy does not apply to those third-party sites. We encourage you to review the privacy policies of any third-party sites you visit. We are not responsible for the privacy practices of third parties.

13. Interstate Data Transfers

Ingot Capital Insurance operates in the United States. If you are located outside of the United States, please be aware that your information will be transferred to, stored, and processed in the United States. By using the Platform, you consent to this transfer. We apply the protections described in this Privacy Policy regardless of where your data is processed.

14. Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our practices, technology, legal requirements, or other factors. When we make material changes, we will:

Post the updated Privacy Policy on the Platform with a new effective date;
Send an email notification to your registered email address; and/or
Display a prominent notice on the Platform.

Your continued use of the Platform after the effective date of the updated Privacy Policy constitutes your acceptance of the changes. We encourage you to review this Policy periodically.

15. Contact Us

For any questions, concerns, requests, or complaints regarding this Privacy Policy or our data practices, please contact our Privacy Team:

Ingot Capital Insurance Inc.
Attn: Privacy Compliance Officer
Website: ingotinsurance.com
Email: Info@IngotInsurance.com
SMS Help: Text HELP to any Ingot Capital Insurance text message

If you are a California resident and wish to submit a CCPA/CPRA request, please email Info@IngotInsurance.com with the subject line "California Privacy Request."

If you have an unresolved privacy concern that we have not addressed satisfactorily, you may contact your state's Department of Insurance or applicable data protection authority.