This Privacy Policy describes how Ulti Brands LLC (“Ulti Brands,” “we,” “us,” or “our”) collects, uses, discloses, and protects information in connection with our websites, insurance lead and inbound-call marketplace, buyer and supplier relationships, technology, analytics, and related services.
01 Scope
This Policy applies to visitors to our websites and marketplace, business buyers and suppliers, representatives of those businesses, and consumer information processed through insurance lead-generation, lead-distribution, inbound-call, live-transfer, call-routing, and related marketplace activities. It does not replace privacy notices independently provided by insurance carriers, agencies, publishers, call centers, or other third parties.
02 Information We Collect
We may collect business account and contact information; billing and transaction information; marketplace preferences; technical and device information; communications; lead and campaign performance data; and consumer lead or call information received from publishers, marketing partners, buyers, websites, forms, call-routing providers, telephony platforms, and other authorized sources.
03 Consumer Lead Information
Consumer lead information may include name, telephone number, email address, postal address, state, ZIP code, insurance product interest, age or age range, household or coverage-related responses, form responses, source information, timestamps, IP address, consent records, TrustedForm or Jornaya identifiers, and other campaign-specific information. We process only information reasonably related to marketplace and campaign operations.
04 Inbound Calls, Live Transfers, and Call Data
For inbound-call and live-transfer campaigns, we may collect or receive telephone numbers, caller or routing information, call start and end times, call duration, routing destination, campaign and source identifiers, IVR responses, qualification responses, disposition information, and call recordings where recording is permitted and implemented. Calls may be monitored or recorded by Ulti Brands, a supplier, a buyer, or a telephony provider where legally permitted and subject to applicable notice or consent requirements. Call data may be used for routing, billing, quality assurance, fraud prevention, dispute resolution, compliance, analytics, and campaign optimization.
05 How We Use Information
We use information to operate and secure the marketplace; create and administer accounts; process orders and payments; match, route, deliver, and validate leads and calls; apply state, schedule, product, qualification, and buyer filters; provide customer support; investigate returns and call disputes; detect fraud and abuse; maintain consent and source records; generate analytics; score and optimize sources; improve products and services; comply with law; and enforce agreements.
06 Marketplace Sharing and Disclosure
Ulti Brands operates a marketplace in which consumer inquiries and calls may be transmitted, routed, sold, licensed, or otherwise provided to authorized business buyers for the insurance-related purpose associated with the applicable consumer interaction and consent. We may also receive consumer information from publishers, lead generators, call generators, marketing partners, and other suppliers. The specific recipients and permitted uses may depend on the applicable campaign, consumer disclosure, consent language, and legal requirements.
07 Service Providers and Business Partners
We may disclose information to service providers and partners that support hosting, CRM, payment processing, telephony, call routing, analytics, fraud prevention, identity or phone validation, consent certification, customer support, security, accounting, legal, compliance, and other business operations. These parties may process information on our behalf or under their own applicable legal obligations.
08 Buyers and Suppliers
Business buyers may receive consumer lead or call information to contact consumers regarding the applicable insurance inquiry. Suppliers may provide consumer lead or call information and supporting source or consent records to Ulti Brands. Buyers and suppliers are responsible for their own independent legal obligations, privacy notices, downstream communications, licensing, data security, and use of information.
09 LeadsIQ and Performance Data
Where enabled, we may receive and analyze buyer dispositions and campaign outcomes, including contact attempts, call outcomes, appointments, applications, sales, policies, call duration, quality indicators, and other performance data. We use this information to measure lead and call quality, identify fraud or underperforming sources, improve routing and allocation, generate reporting, and optimize marketplace performance.
10 Cookies and Online Technologies
We and our service providers may use cookies, pixels, analytics tools, session technologies, and similar technologies to operate the website, maintain sessions, remember preferences, understand usage, measure marketing, detect fraud, and improve marketplace performance. Browser and device controls may allow users to limit certain technologies.
11 Payments
Payment information may be collected and processed by third-party payment processors. Ulti Brands may receive transaction status, billing details, payment identifiers, and limited payment-related information necessary to administer orders, refunds, disputes, and accounting.
12 Legal and Compliance Disclosures
We may disclose information when reasonably necessary to comply with law, legal process, regulatory requests, insurance or telemarketing compliance obligations, subpoenas, court orders, investigations, law enforcement requests, or to protect consumers, Ulti Brands, buyers, suppliers, or others from fraud, abuse, security threats, or unlawful conduct.
13 Business Transfers
Information may be transferred in connection with a merger, financing, acquisition, reorganization, bankruptcy, sale of assets, or similar corporate transaction, subject to applicable law.
14 Data Retention
We retain information for as long as reasonably necessary for marketplace operations, contractual obligations, billing, dispute resolution, analytics, fraud prevention, compliance, litigation holds, and legal requirements. Consent, source, lead, and call records may be retained for periods appropriate to applicable laws, contracts, and regulatory risk.
15 Data Security
We use reasonable administrative, technical, and physical safeguards designed to protect information. No system or transmission method can be guaranteed completely secure. Buyers, suppliers, and users are responsible for protecting their own credentials, systems, and copies of marketplace data.
16 Privacy Rights
Depending on residency and applicable law, individuals may have rights to request access, correction, deletion, or information about certain disclosures or uses of personal information, and may have rights to opt out of certain processing. Rights are subject to legal exceptions, identity verification, and the scope of applicable law. Requests may be submitted through the privacy request method identified on the Ulti Brands website.
17 Marketing and Communication Choices
Recipients may opt out of Ulti Brands marketing emails by using the unsubscribe mechanism provided in those communications. Consumers seeking to stop calls, texts, or emails from a particular insurance buyer should also communicate that request directly to the applicable buyer. Ulti Brands will honor legally applicable requests directed to Ulti Brands.
18 Children
The marketplace is not directed to children under 18, and Ulti Brands does not knowingly offer marketplace accounts to children.
19 Third-Party Sites and Services
Our services may link to or integrate with third-party websites, CRMs, telephony providers, payment processors, compliance tools, or other services. Their privacy practices are governed by their own policies.
20 Changes to This Policy
We may update this Privacy Policy periodically. The Effective Date identifies the current version. Material changes may be communicated through the website, marketplace, email, or another reasonable method.
21 Contact
Privacy questions and requests may be submitted through the privacy request or contact method identified on the Ulti Brands website. No individual executive’s personal contact information is required to exercise privacy rights.