VIU by HUB LLC U.S. Privacy Policy

Effective Date: August 1, 2024

This U.S. Privacy Policy (this “Policy”) describes how VIU by HUB LLC (“VIU”) VIU”) uses your “Personal Information” (as defined below) both during and after our direct (or indirect) business relationship with you. This Policy applies to your Personal Information that we may from time to time collect, use and disclose in the course of (1) performing insurance brokerage or other insurance or financial industry services on your behalf, (2) making available our mobile applications and websites, including viubyhub.com, and (3) visiting a VIU location or website, attending a VIU event or using other services that link to this Policy. This Policy may be supplemented by additional privacy policies, terms, and notices relevant to the service. We take very seriously our privacy responsibilities to you, and we are committed to treating your Personal Information in a manner that is consistent with applicable law and this Policy. Please read this Policy carefully.

Updates to Policy, Accessibility of Policy, and Regional Differences

Updates to Policy. From time to time, we may change our privacy practices which will require changes to this Policy. The latest version of this Policy will be posted on our websites and the date it is effective will be displayed. We encourage you to look for updates and changes to this Policy when you access our websites.

Your continued use of our websites and mobile applications following the posting of changes constitutes your acceptance of such changes with respect to your use of our websites and mobile applications

Accessibility. If you have special needs with regard to accessing the content of this Policy, we recommend that you or someone on your behalf, contact us at: privacy.compliance@hubinternational.com. Please include the words “Accessibility Issue” in your subject line.

Notice to California Residents. If you are a California resident, you may have additional privacy rights. Due to the detailed requirements under California privacy laws, please review the VIU Privacy Notice for California Residents for information about these additional rights in addition to this Policy.

Certain other jurisdictions provide enhanced personal information rights to residents depending on the jurisdiction and the reason VIU is processing your information. For example, certain privacy rights may not apply to personal information that is already subject to certain federal and state laws regulating insurance or health information. While these rights may differ based on the data collected, the type of product or service you choose, you can submit a personal information rights request by visiting the VIU Consumer Privacy Request Portal.

Notice to Residents of Colorado, Connecticut, Montana, Oregon, Texas, Utah, Virginia. If you are a resident of Colorado, Connecticut, Montana, Oregon, Texas, Utah or Virginia, you may also have additional rights such as (a) rights to know, access, correct, data portability, or restrict processing, (b) right to opt out of sale, (c) right to opt-out of automated decision making and (d) right to delete certain Personal Information, or (e) otherwise described below in this Policy. These rights can be asserted by visiting the VIU Consumer Privacy Request Portal.

Residents of Connecticut, Virginia, Texas, and Oregon have the right to appeal the outcome of a rights request to access, review, delete or correct personal information. Assertions of these appeal rights can be made to: privacy.compliance@hubinternational.com. Please include “Appeal of Outcome” and your state name in the subject line of your email message to initiate the appeal request.

Definition and Exclusions of Personal Information at VIU by HUB LLC

Generally, “Personal Information” means information that identifies (whether directly or indirectly) you, such as your name, postal address, email address, and telephone number. Due to the nature of our business as described under “Information Collection” below, Personal Information we collect may also include:

• your name, Social Security Number, driver’s license, or other government-issued identification;
• assets and income, occupation, and employment status, dependent information, and other relevant financial information;
• information relating to any of your past claims, driving history, certifications, license details, previous insurance policy details, previous accident and claims history including any driving convictions;
• information from reporting agencies and state and federal government agencies, such as state motor vehicle departments;
• information from other sources, such as medical or health care providers and other third parties with which you or we maintain a relationship including credit reference agencies, vetting and data validation agencies, advisory service providers, insurers, underwriters, reinsurers, other insurance brokers, business partners;
• your account activity and premium payment history;
• benefits information such as benefits elections, pension entitlement information, date of retirement and any relevant matters impacting your benefits;
• information about your interest in and attendance at VIU sponsored events, including feedback responses;
• information from social media interactions with VIU’s social media presence, feedback forms or surveys;
• credit card, bank account or other account information as may be required to facilitate your payment of insurance premium or similar amounts, which payment generally is made through systems maintained by third parties, such as insurance carriers;
• passive tracking information from our website or the Internet, including information obtained through the use of internet “cookies” as detailed in the “Cookie Notice and Notice of Other Web Technologies” section below; and
• inferences drawn from other Personal Information, precise geolocation data, and sensory data such as audio or visual information.

Personal Information does not include aggregated or anonymous information which does not identify and cannot reasonably be used to identify you. It also does not include other categories of information excluded by state or federal law.

Information Collection

We are generally unable to perform insurance brokerage or other insurance or financial industry services on your behalf without collecting, using, or disclosing your Personal Information. Typically, you will provide your Personal Information directly to us as your broker, or indirectly to us via another broker representing you, as part of a written application for insurance coverage. Other times, we may receive this and other Personal Information from third parties, including insurance carriers and other industry service providers, and other third parties with which you maintain a relationship (for example, your employer or financial service or medical or health providers). We may also develop this information over time based on your direct or indirect interactions with us, such as through the use of cookies on our websites.

Please keep in mind that when you provide information to us on a third-party site or platform, the information you provide may be separately collected by the third-party site or platform. We encourage you to read the privacy policies of other sites and mobile applications that may collect your Personal Information.

We generally collect the amount and types of Personal Information that are required for us to perform or support services on your behalf, whether directly or indirectly. This includes information that may be required by an insurance carrier or an industry service provider in the course of providing you with insurance coverage or related services. If you use our websites, we may collect information about your device, browser and other information regarding your web usage using tracking tools described in this Policy. Such information collection could include relevant market research designed to make our products and services better. This and other information may include the Personal Information as defined above.

Cookie Notice and Notice of Other Web Technologies

We may use cookies and other technologies such as web beacons on our websites and mobile applications. Cookies are files which can store information in your computer hard drive or other devices and help us and our service partners to better understand user behavior. This information is collected for security and fraud prevention purposes, to identify which parts of our websites people have visited, and to facilitate and measure the effectiveness of advertisements and web searches. These technologies can also help to improve user experiences with the performance of websites and mobile applications.

We may combine information derived from cookies or web technologies with information provided directly by you as described in the “Information Collection” section above. We may use several different categories of cookies:

• Strictly Necessary Cookies. These cookies are necessary for the website or application to function. They are set as required to provide a specific feature or service that you have accessed or requested and that cannot be provided without the use of such cookies.
• Performance or Analytical Cookies. These cookies allow measurement of website activity by tracking user visits, the location of users and the volume of users. We use these cookies to help us to analyze data.
• Functional Cookies. These cookies enable the website to provide enhanced functionality and personalization. They may be set by us or by third party service providers. Disallowing these cookies may impact the ease with which the website or application functions for users.
• Targeting Cookies. These cookies are used to understand how visitors interact with our websites and online services, including by helping us to assess the effectiveness of web searches and so we can provide you with a more customized experience. Targeting cookies can include marketing cookies, which are used to provide you with personalized, relevant product offerings and advertisements. Another type of targeting cookie is a social media cookie. Social media cookies may result in the sharing of information you have provided to social networks’ websites by those websites, subject to those websites’ privacy policies and user consents.

Cookie Choices and Opt-Out

VIUVIU generally gives you choices to opt-out of the categories of cookies as described above, except for those that are essential to the services of the websites or tools you are accessing. This option is typically presented when you first visit our websites.

Your computers or devices also have tools within their browser settings that allow you to manage your acceptance of cookies. These can include the ability to disable or block non-essential cookies, remove cookies, automatically accept cookies or to notify you when a cookie is received. Refer to “How To Manage Cookies” for detailed explanations by browser (e.g., Google Chrome). Generally, disabling or rejecting cookies can impact your user experience.

Certain features of our website may not be available if all cookies are disabled, and therefore, disabling, particularly of strictly necessary cookies, may not be available.

VIU uses both Adobe and Google as website service providers. To learn about Adobe Analytics privacy practices or to opt-out of Adobe cookies which are used to facilitate reporting, visit Adobe Privacy Center. To learn more about Google’s privacy practices, visit the Google Privacy Center. To access and use the Google Analytics Opt-out Browser Add-on, visit Google Opt-out.

Sales of Personal Information

In the preceding twelve (12) months, we have shared information for advertising purposes which might be considered a “sale” of Personal Information as defined by some state laws. This is described herein and in our Cookie Notice and Notice of Other Web Technologies in our U.S. Privacy Policy in relation to sharing personal information for cross-contextual behavioral advertising or targeted advertising purposes.

Global Privacy Control (GPC) Signal

You have the right to opt out of the use of your personal information for targeted advertising purposes. You may download one of the supported browsers or extensions to send the Global Privacy Control (“GPC”) signal, which will transmit your request to opt-out of targeted advertising automatically. A list of GPC enabled available browsers or extensions is available here: https://globalprivacycontrol.org/#download.

Use of Automation for Insurance Quoting

VIU’s online formats may utilize certain types of automation which assist carrier partners with their underwriting of insurance. Such automation may result in the use of your personal information by the insurer to create predictions about insurance products and premium pricing, and information about insurance carrier market categories that would be appropriate for you. The goal of such an interaction would be for you to receive one or more insurance quotations or estimations of premium and coverage details. Each insurer will have methodologies, including underwriting algorithms, to help with making underwriting decisions. Insurers’ underwriting decisions for insurance coverage, and the use of data for making those decisions, are each subject to the applicable privacy policy and privacy rights request process of that insurer. Your personal information is protected and is utilized consistently with the purposes and categories of this Policy and the intention of our use of this technology is that it operates without improper biases. Based on applicable law, you may have the right to opt out of automated technology which produces a legal effect. If available in your area, this right can be exercised through the VIU Consumer Privacy Request Portal.

Use and Disclosure of Personal Information

We generally only disclose your Personal Information to perform services on your behalf and provide you with the insurance products and services you expect from us. In addition, in order to operate our business and provide you with the services you request from us, information technology and other support service providers with which we maintain an arrangement may also have access to your Personal Information. Your Personal Information may be disclosed to third parties in connection with a merger, sale, or other transfer of organizational assets where Personal Information held by us about our clients is among the assets transferred.

We may from time to time disclose your Personal Information for the following reasons:

• to fulfill or meet the reason you provided the information and for our everyday business purposes, such as to obtain initial and renewal quotations for insurance or other insurance or financial industry services (including those procured proactively and/or in connection with the movement of a book of business from one provider to another) on your behalf; to obtain insurance (or similar products) on your behalf or to facilitate the performance of related services by other industry service providers; to maintain or service your account or insurance, including by reporting claims of loss to other industry service providers, such as insurance carriers and adjusters; to evaluate our performance or offerings; to allow risk management or actuarial evaluation of prospective or existing placements; to confer with medical professionals if necessary regarding a relevant claim; and to make reports to credit bureaus. We may also save your information to facilitate new quotations or placements.
• for legal reasons, such as to make required or advisable reports to insurance regulatory, law enforcement or other similarly situated authorities including government authorities; to respond to and comply with court orders, applicable law, and other legal requirements; and to defend ourselves against claims and to enforce our rights or protect our employees or property.
• for our own marketing purposes, so that we may offer you our products and services, including through the use of targeted or similar advertising on the internet. You will be given the opportunity to opt out of direct marketing from VIU, and you can change your marketing preferences by contacting VIU as set forth in this Policy.
• for joint marketing purposes, so that we and any third-party product or service provider may together offer you products and services.
• for our affiliates’ everyday business purposes, such as to process or service transactions or to provide or receive shared organizational services.
• for our affiliates’ marketing purposes, so that they may offer you their products and services.
• for our and our affiliates’ fraud prevention purposes, where necessary to prevent and detect fraud.
• for non-affiliated third parties, whenever you consent to such sharing, when the information cannot reasonably identify you, when business partners or third-party companies play a related or expected role in an insurance transaction, or as needed for VIU to participate in insurance support organizations.
• for our internal and external auditors, where necessary for company audits, complaint investigation or investigation of a security threat.
• for other purposes, as may be permitted by law.
• to evaluate, negotiate or effect a business transaction (e.g., a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets), in which Personal Information held by us about our consumers or website users is among the assets evaluated or transferred.

To Limit Our Disclosure or Sharing of Information

To limit our disclosure of your Personal Information with affiliates or non-affiliates for marketing purposes (and for any other purpose which applicable law provides you a right to require us to limit our sharing of your Personal Information), you may at any time submit a request to us by:

• Visiting the: VIU Consumer Privacy Request Portal.
• Emailing us at: privacy.compliance@hubinternational.com.

California Residents: Refer to the VIU Privacy Notice for California Residents.

Retention of Your Information

VIU retains certain records of your personal information as necessary to operate our business and comply with our legal and regulatory obligations. Such records are retained for legally defined retention periods that may extend beyond the period for which we provide services to you or on your behalf. We have implemented appropriate measures to confirm that private information is securely disposed of when no longer required.

Other Important Website and Mobile Application Information

Our website contains links to third party sites. If you click on one of those links, you will be taken to websites we do not control. This Policy does not apply to the information practices of those sites. You should read the privacy policies of those other websites carefully. We are not responsible for those third-party sites. Links to third party sites do not constitute or imply endorsement by us of the linked site or any material displayed on those sites.

To the extent that VIU provides mobile application access for your use, please note that your Personal Information may be collected. In addition to being subject to this Policy, your use of a downloaded application provided by VIUis also subject to the privacy terms and conditions of the providers and developers of the application. VIU may have access to and utilize certain data collected by such providers or developers. VIU may utilize such data to better service your account, as well as to improve the performance of the application. Please refer to the “Cookie Notice and Notice of Other Web Technologies,” as well as the “Cookie Choices and Opt-Out” sections for more information.

VIU websites are not intended for children under 13 years of age. No one under age 13 may provide any information through our websites, and we do not knowingly collect Personal Information from children under thirteen. If you are under thirteen, do not use or provide any information on this website or otherwise provide any information about yourself to us, including your name, address, telephone number, email address, or any screen or username you may use. If we learn we have collected or received Personal Information from a child under thirteen without verification of parental consent, we will use commercially reasonable efforts to delete that information. If you believe we might have any information from or about a child under thirteen without parental consent, please contact us at the mailing address shown beneath the heading “Your Right to Review Your Information.”

Information Security Practices

We maintain technical and organizational security measures reasonably designed to protect the security of your Personal Information against loss, misuse, and unauthorized access, disclosure, or alteration. VIU by HUB LLC and its affiliates take steps to secure your Personal Information with appropriate levels of security around storage and use. Despite this, the security of information cannot be guaranteed. If you have reason to believe that your Personal Information maintained by us is no longer secure, please immediately notify us utilizing the contact information set forth below. In the event of a breach impacting your Personal Information, we intend to provide you with notification to the extent required by applicable law.

Your Right to Review Your Information

You may have the right to review your Personal Information that we could reasonably locate and retrieve, and to request that we correct, amend, or delete any inaccurate information. To make a related request, or to ask any question concerning this Policy:

• Visit the: VIU Consumer Privacy Request Portal.
• Email us at: privacy.compliance@hubinternational.com.
• Call us at 866-415-2207
• Write us at:

Chief Legal Officer
VIU by HUB LLC
150 N Riverside Plaza, 17^th Floor
Chicago, IL 60606

Please include your name, address, telephone number and email address whenever you contact us, including by email. Please include “Personal Information Rights Request” in your subject line. This helps us handle your request correctly and allows us to verify your identity to protect your information. Depending upon the type of information request, we may require additional verification information.

Situations Where Rights Cannot Be Granted. There may be situations where we cannot grant a particular request — for example, if you ask us to delete your transaction data but we are legally obligated to keep a record of that transaction to comply with law or if we are unable to verify your identity through standard and reasonable means. We may also decline to grant a request where doing so would undermine our legitimate use of data for antifraud and security purposes, such as when you request deletion of an account that is being investigated for security concerns. Other reasons your privacy request may be denied could be that granting the request would jeopardize the privacy of others; that the request is substantively frivolous or vexatious; or that granting the request would be highly impractical in the context of our legitimate business purposes. If we are unable to fulfill your request to access, review, delete or correct your personal information; and, where required, we will respond with an explanation.