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PRIVACY POLICY

Last Revised December 19, 2019

Your privacy is valued and respected by Armfield, Harrison & Thomas, Inc. and its subsidiaries (“we” or “our” or “us”). This Privacy Policy (“Privacy Policy”) describes the types of information, including personal information, that we gather from you, including when you use our website (www.ahtins.com) (the “Site”) or that you may provide to us through means other than the Site, as well as your choices regarding use and disclosure of your personal information. This notice is intended to comply with privacy laws that may apply to you, including without limitation the California Consumer Privacy Act of 2018 (“CCPA”) and other California privacy laws.  Any terms defined in the CCPA have the same meaning when used in this notice.

YOUR AGREEMENT TO THE PRIVACY POLICY

By accessing the Site, you agree to be bound by this Privacy Policy. If you do not agree to the terms of this Privacy Policy, please do not use our Site.

We reserve the right to update or modify this Privacy Policy from time to time. We will notify you of any changes by revising the “Effective Date” at the top of this Privacy Policy. If we make any material changes to this Privacy Policy or the way we use, share or collect personal information, we will post an announcement of the changes on our Site, prior to the new policy taking effect. In all cases, your continued use of our Site or our products and services constitutes consideration and your binding acceptance to any such changes. We encourage you to review this Privacy Policy regularly to ensure that you are familiar with ahtins.com’s current practices.

INFORMATION WE COLLECT

We collect information that identifies, relates to, describes, references, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or device (“personal information”).

This includes personal information collected from the use of our Site or other means, such as documents or other materials or information that you may provide to us.  As to the Site, it collects information (i) that users knowingly and voluntarily provide (such as through forms or profile screens) including registration information, and (ii) that we are able to collect from users’ web browsers, cookies and other similar technologies.  As for information that you voluntarily provide to the Site, (such as through web forms or profile screens), such information includes registration information, and profile details. We primarily use this information to fulfill your transaction requests. You can choose not to provide us with certain personal information , but then you may not be able to take advantage of the Site or other available features we offer.

In addition, information submitted to the Site via a “contact us” or other similar function may not necessarily receive a response. We will not use the information provided via these functions for any business purpose not disclosed in this Policy (See “Use of personal information” below) unless we disclose otherwise at the time you submit your request.

With respect to non-personal information, we collect standard information about Ahtins.com users such as IP addresses, browser type, operating system, device used, what you searched for, referring and exit pages, the dates and times of visits, and other Site usage behavior (“Site Visitation Data”). Site Visitation Data is used to administer the Site and provide general statistics regarding the use of the Ahtins.com website. We may also use Site Visitation Data to display advertising or send targeted email marketing messages you may find interesting and to suppress advertising that might not interest you.

When you visit our Site we may store information about your web session and assign you one or more cookies. Your browser will store these cookies on your computer in a small text file, and if you return to the Site the cookie may be read. Cookies are not linked to your personal information.

We may also use web beacons, clear gif technology, or action tags as mechanisms to collect aggregate Site Visitation Data by tracking how users navigate to and through our website. We may also use this technology to track the delivery of HTML email messages. Data collected through this mechanism is not linked to personal information.

Permanent cookie files remain on your computer’s hard drive until you delete them manually using your browser or operating system software. You can set your browser to refuse cookies, but doing so may disable access to some services and tools that we offer.

Please be advised that we have collected the following categories of personal information from consumers within the last twelve (12) months:

 

Category Examples
A. Identifiers. A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, Social Security number, driver’s license number, passport number, or other similar identifiers.
B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)). A name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver’s license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information. Some personal information included in this category may overlap with other categories.
C. Protected classification characteristics under California or federal law. Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information).
D. Commercial information. Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.
E. Internet or other similar network activity. Browsing history, search history, information on a consumer’s interaction with a website, application, or advertisement.
F. Professional or employment-related information. Current or past job history or performance evaluations.

 

We obtain the categories of personal information listed above from the following categories of sources:

  • Directly from our clients or their agents. For example, from documents that our clients provide to us related to the services for which they engage us.
  • Indirectly from our clients or their agents. For example, through information we collect from our clients in the course of providing services to them.
  • Directly and indirectly from activity on our website (www.ahtins.com). For example, from submissions through our website or website usage details collected automatically.
  • From third-parties that interact with us in connection with the services we perform.

USE OF PERSONAL INFORMATION

We may use or disclose the personal information we collect for one or more of the following business purposes:

  • To fulfill or meet the reason for which the information is provided.
  • To provide you with information, products or services that you request from us.
  • To provide you with email alerts, event registrations and other notices concerning our products or services, or events or news, that may be of interest to you, whether or not related to any initial request for information from us.
  • To carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collections.
  • To improve our website and present its contents to you.
  • For testing, research, analysis and product or service development.
  • As necessary or appropriate to protect the rights, property or safety of us, our clients or others.
  • To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.
  • As described to you when collecting your personal information or as otherwise set forth in applicable law.
  • To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by us is among the assets transferred.

We will not collect additional categories of personal information or use the personal information we collected for materially different, unrelated, or incompatible purposes without providing you notice.

You can choose not to provide us with certain personal information , but then you may not be able to take advantage of our services or the Site or other available features we offer.

SHARING PERSONAL INFORMATION

We may disclose your personal information to a third party for a business purpose.  When we disclose personal information for a business purpose, we enter a contract that describes the purpose and requires the recipient to both keep that personal information confidential and not use it for any purpose except performing the contract.

In the preceding twelve (12) months, we have disclosed the following categories of personal information for a business purpose:

Category A:    Identifiers.
Category B:     Customer Records personal information categories.
Category C:     Protected classification characteristics under applicable state or federal law.
Category D:    Commercial information.
Category E:     Internet or other similar network activity.
Category F:     Professional or employment-related information.

We disclose your personal information for a business purpose to the following categories of third parties:

  • Our affiliates.
  • Service providers.
  • Third parties to whom you or your agents authorize us to disclose your personal information in connection with products or services we provide to you.

Examples of the foregoing may include:

Agents. We employ other companies and individuals to perform functions on our behalf. Examples of such functions include fulfilling orders, sending postal mail and e-mail, removing repetitive information from customer lists, analyzing data, providing technical support, providing marketing assistance, processing credit card payments, and providing customer service. We share our users’ personal information with these agents as we deem necessary for such third parties to perform their functions.

Employees. Only authorized employees have access to your personal information.

Advertisers. Please be aware that the information practices of third-party advertisers or platforms (if any) collecting data on our Site are not covered by this Privacy Policy.  We do not sell, rent, or otherwise disclose your personal information to third parties for their marketing and advertising purposes without your express consent.

Other Users. Please remember that any information you share in public areas of our Site, such as on message boards or feedback sections, becomes public and anyone may take and use that information. Public posts are not subject to this Privacy Policy. Please be careful about what you disclose in these portions of our Site and do not post any personal information that you expect to keep private. We strongly encourage you not to use any personal information in your username or password. If your personal information is posted on one of our community forums, you may contact us at marketing@ahtins.com to request that such information be removed. In some cases, we may not be able to remove your personal information, in which case we will let you know if we are unable to do so and why.

To Comply with Legal Process, Protect Ahtins.com, or Enforce our Rights. We may release your personal information when it is necessary to (a) conform to legal requirements or comply with legal process; (b) enforce or apply our terms of use and other agreements; (c) protect the rights, safety or property of Ahtins.com, our affiliates, service providers, our users or the public; or (d) prevent a crime or protect national security (including exchanging information with other companies and organizations for fraud protection and credit risk reduction).

As Part of a Merger or Sale of Business. We may disclose your personal information in connection with a substantial corporate transaction, such as the sale of our business, a divestiture, merger, consolidation, or asset sale, or in the unlikely event of bankruptcy.

Other Disclosures. We may also disclose your personal information as otherwise set forth in this Privacy Policy, as permitted by law, or with your consent.

In the preceding twelve (12) months, we have not sold any personal information.

 YOUR RIGHTS AND CHOICES

This section describes the specific rights that may apply to you regarding your personal information and explains how to exercise those rights.  Please note that the law may exempt or exclude some or all of such rights from applying to you, depending upon the context in which you provide personal information to us.  Accordingly, it is possible that some or all of the rights discussed in this section of the Policy may not apply to you.  To the extent such rights apply to you under applicable law, this section describes your rights and explains how to exercise those rights.

Access to Specific Information and Data Portability Rights

You have the right to request that we disclose certain information to you about our collection and use of your personal information over the past 12 months. Once we receive and confirm your verifiable consumer request, we will disclose to you:

  • The categories of personal information we collected about you.
  • The categories of sources for the personal information we collected about you.
  • Our business or commercial purpose for collecting or selling that personal information.
  • The categories of third parties with whom we share that personal information.
  • The specific pieces of personal information we collected about you (also called a data portability request).
  • If we sold or disclosed your personal information for a business purpose, two separate lists disclosing:
    • sales, identifying the personal information categories that each category of recipient purchased; and
    • disclosures for a business purpose, identifying the personal information categories that each category of recipient obtained.

Deletion Request Rights

You have the right to request that we delete any of your personal information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request, we will delete (and direct our service providers to delete) your personal information from our records, unless an exception applies.

We may deny your deletion request if retaining the information is necessary for us or our service providers to:

  1. Complete the transaction for which we collected the personal information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you.
  2. Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
  3. Debug products to identify and repair errors that impair existing intended functionality.
  4. Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
  5. Comply with the applicable state law, such as, for example, California Electronic Communications Privacy Act (Cal. Penal Code § 1546 seq.).
  6. 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 the information’s deletion may likely render impossible or seriously impair the research’s achievement, if you previously provided informed consent.
  7. Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
  8. Comply with a legal obligation.
  9. Make other internal and lawful uses of that information that are compatible with the context in which you provided it.

Exercising Access, Data Portability, and Deletion Rights

To exercise the access, data portability, and deletion rights described above, please submit a verifiable consumer request to us by either:

Only you or a person authorized to act on your behalf and who is registered with the applicable Secretary of State of the relevant state, that you authorize to act on your behalf, may make a verifiable consumer request related to your personal information. You may also make a verifiable consumer request on behalf of your minor child.

You may only make a verifiable consumer request for access or data portability twice within a 12-month period. The verifiable consumer request must:

  • Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative.
  • Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you.  Making a verifiable consumer request does not require you to create an account with us.  We will only use personal information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.

Response Timing and Format

We endeavor to respond to a verifiable consumer request within 45 days of its receipt.  If we require more time (up to 90 days), we will inform you of the reason and extension period in writing.  If you have an online account with us, we will deliver our written response to that account.  If you do not have an online account with us, we will deliver our written response by mail or electronically, at your option.  Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request’s receipt.  The response we provide will also explain the reasons we cannot comply with a request, if applicable.  For data portability requests, we will select a format to provide your personal information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance.

We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded.  If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.

NON-DISCRIMINATION

We will not discriminate against you for exercising any of your rights. Unless permitted by applicable law, we will not:

  • Deny you goods or services.
  • Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.
  • Provide you a different level or quality of goods or services.
  • Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.

Children and Privacy

As a requirement to use our Site, you acknowledge that you have the appropriate consent(s) from any individual (or the parent of any child under the age of 18) to share their personal information with us.  We do not knowingly collect any personal information from children under the age of eighteen (18). We will delete any personal information collected that we later determine to be from an individual younger than the age of eighteen (18).

Third Party SiteS AND SERVICEs

Our Site contains links to third party websites, applications and services not operated by us. These links are provided as a service and do not imply any endorsement by Ahtins.com of the activities or content of these sites, applications or services nor any association with their operators. Additionally, our Site may include social media features, such as the Facebook “Like” button, and widgets, such as the “Share This” button or interactive mini-programs that run on our Site. We are not responsible for the privacy policies or practices of any third party including websites or services directly linked to our Site. We encourage you to review the privacy policies of any third party site that you visit.

Security, Storage & Retention

Security

The security of your personal information is important to us. We follow generally accepted standards to protect the personal information submitted to us, both during transmission and once we receive it. However, no method of transmission over the internet, or method of electronic storage is one hundred percent secure and we cannot guarantee its absolute security. Please contact us if you have any questions about security on our site.

Storage

The personal information that you provide to us is generally stored on servers located in the United States. If you are located in another jurisdiction, you explicitly ACKNOWLEDGE AND CONSENT that once your personal information is submitted through our Site, it will be transferred to our servers in the United States and that the United States currently does not have uniform data protection laws in place.  Further, the United States has not sought nor received a finding of “adequacy” from the European Union under Article 45 of the General Data Protection Regulation (“GDPR”) of the European Union.  For residents of the European Union, we rely on derogations for specific situations as set forth in Article 49 of the GDPR. In particular, we collect and transfer to the U.S. personal information of European Union residents only: with your consent; to perform a contract with you; or to fulfill a compelling legitimate interest of ours in a manner that does not outweigh your rights and freedoms.

Retention

We will retain your information for as long as your account is active or as needed to provide you with our services. If you wish to cancel your account or request that we no longer use your information to provide you service, contact us at marketing@ahtins.com. We will retain and use your information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.

DATA CONTROLLER

Armfield, Harrison & Thomas, Inc. your data controller.  A data controller makes decisions regarding and is responsible for the collection, use, disclosure, retention and protection of your personal information in accordance with this privacy notice, as well as any applicable national laws.  As your data controller, we may transfer data to our affiliates who agree to the obligations of this privacy notice.  We may process and retain your personal information on our servers in the U.S. and elsewhere in the world where our data centers are located.  If you have questions regarding your personal information, please contact us using the contact information set forth in the “Contact Information” section below.

CHANGES TO OUR PRIVACY NOTICE

We reserve the right to amend this privacy notice at our discretion and at any time. When we make changes to this privacy notice, we will notify you by email or through a notice on our website homepage.

CONTACT INFORMATION

If you have any questions or comments about this notice, our Privacy Statement, the ways in which we collect and use your personal information, your choices and rights regarding such use, or wish to exercise your rights under applicable law, please do not hesitate to contact us at:

Phone: 703 777 2341
Website:  ahtins.com

Email: marketing@ahtins.com

Postal Address: AHT Insurance, 20 S. King St., Leesburg, VA 20175

Attn: Kate Armfield, Chief Operating Officer

 

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