1. General.

This customer portal privacy policy (“Privacy Policy”) governs how AssuranceSD, Inc. and its affiliated entities and subsidiaries (collectively, the “Company,” “We,” or “Us”) uses and processes personally identifiable information data we learn when you use the customer portal system (the “Customer Portal”) where this Privacy Policy is posted.

2. Children Under the Age of 13.

The Customer Portal is not intended for use by children under 13 years of age, nor are children the intended audience of the Customer Portal. We do not knowingly collect personal information from children under 13, and all personal information concerning such children is collected from their parent(s) or legal guardian(s). No one under age 13 may provide any personal information to or on the Customer Portal. If we learn we have collected or received personal information from a child under age 13 without verification of parental consent, we will promptly delete that information. If you believe we might have any information provided by a child under age 13, please contact us at the contact information provided below.

3. Information Collected.

We collect several types of information about you, including: (a) information by which users, accessors of the Customer Portal or beneficiaries of the Customer Portal account owners may be personally identified; (b) information that is about such users or beneficiaries of the Customer Portal but individually does not identify you; and/or (c) information about a user’s internet connection, equipment a user uses to access the Customer Portal, and usage details.

4. How We Collect Personally Identifiable Information.

We collect information about you in three ways:

Information You Provide: When you create a user account registered with the Company (your “Account”) or log into the Customer Portal, you may have the option of providing personally identifiable information about yourself, including your name, contact details (e.g., address, telephone number, facsimile number, email address, etc.) and username and password (collectively, your “Customer Data”). Customer Data includes such data, in any form or medium, that is collected, downloaded, or otherwise received by the Company directly or indirectly in connection with your use of the Customer Portal and in connection with the services offered to you or clients of the Company. Subject to your consent, in addition to your Customer Data, we may also collect, use, store, and process certain sensitive or health data provided by you or by clients of the Company or their authorized third party agents, including but not limited to your personal identification documents or information, government identification data or copies of such documents, medical history, or other health-related information, records, or copies thereof (collectively, “Sensitive Personal Information”). When you sign into your Account to log into the Customer Portal, we may show you your Customer Data (including Sensitive Personal Information) so that you can view your own information.

Information from Third Parties and Other Sources: Third parties may provide us with information on you, such as details with respect to social media accounts. We may also obtain additional commercially available information from third parties.

Information from Your Use of the Customer Portal: We may collect information about the pages that you visit on the Customer Portal, the content that you provide or view, and how you react to such content. This information includes:

· Log Information: When you use our Customer Portal or view content provided in the mobile app, we may automatically collect and store certain information in server logs, including with respect to your usage of our Customer Portal, pages you visited, the content you viewed, errors experienced, and the websites you visited before or after you visit our Customer Portal.

· Location Information: We may collect and process information about your actual location, including GPS signals sent by a mobile device and IP address. We may also use various technologies to determine location, such as sensor data from your device that may, for example, provide information on nearby Wi-Fi access points and cell towers.

· Unique Application Numbers: Certain services include a unique application number. This number and information about your installation (for example, the operating system type and application version number) may be sent to Company when you install or uninstall that service or when that service periodically contacts our servers, such as for automatic updates.

5. How We Use Your Customer Data.

Company and its affiliates collect, store, and use your Customer Data (including Sensitive Personal Information) for the following purposes:

· To present our Customer Portal and its contents to you.

· To display your Customer Data or Sensitive Personal Information to you when you log into the Customer Portal.

· To provide you with information, products, or services that you request from us.

· To fulfill any other purpose for which you provide your Customer Data or Sensitive Personal Information.

· To notify you about changes to our Customer Portal, or any products or services we offer or provide through the same.

· To allow you to participate in interactive features on our Customer Portal.

· To improve our Customer Portal and troubleshoot problems with our services.

· To generate aggregated statistics and conduct research which may be used in marketing our services to you or third parties.

· To provide any legitimate business service or product.

· For any other purpose with your consent.

6. Cookies and Other Technologies. We use various technologies to collect and store your Customer Data, and this may include sending one or more cookies or anonymous identifiers to your device, including “web beacons”, clear GIFs, pixel tags and other means. Cookies help us in many ways to make your use of our Customer Portal more enjoyable and meaningful to you. Cookies are text information files that your web browser places on your computer and/or mobile device when you visit a website. Pixel tags are not visible to the user of a website and consist of a few lines of computer coding delivered with the web pages accessed. Company may use such technologies to obtain non-personal information from you as an online visitor. You may refuse to accept browser cookies by activating the appropriate setting on your browser. 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 Customer Portal. Please note that if you refuse to accept browser cookies, the Customer Portal may not work properly and as a result, you may not be able to take full advantage of all the features of our Customer Portal. However, even if you elect to disable cookies, we will still receive basic information (such as last URL visited) when you navigate to the Customer Portal. The Customer Portal does not respond to browser do-not-track signals.

We may also use third-party tools such as Google Analytics to track and monitor use of our Customer Portal. Google Analytics is a web analytics service offered by Google that collects information related to how you use our Customer Portal. This information may be shared with other Google services, and Google may use such information to contextualize and personalize the ads of its own advertising network. We encourage you to review Google’s policy for safeguarding your information. For more information on the privacy practices of Google, please visit the Google Privacy Terms webpage: https://policies.google.com/privacy. To learn more about Google Analytics and how to opt out, please visit https://tools.google.com/dlpage/gaoptout. In addition, you can click the following link in order to find out more information about your options with respect to Google Analytics and other Google services: https://policies.google.com/technologies/partner-sites.

7. Sharing and Transfer of Customer Data.

Third-Party Disclosures. Subject to your consent and authorization, Company may disclose your Customer Data or Sensitive Personal Information to its third-party vendors and/or licensors in order to facilitate and enable the Customer Portal services offered by Company. The Company may share your Customer Data or Sensitive Personal Information with its own affiliates to improve the Company’s services and with government entities or affiliated organizations to facilitate the performance of the services specific to a user or Company client in connection with the services for such individual. Company will not trade, sell, or share your personal information for use by any third party except in the following circumstances:

· You consent to the disclosure. For example, when you establish or register your Account, we may ask your consent to share your Customer Data with organizations, entities, or persons you authorize or third parties that provide similar products that you elect to engage with;

· With Your Third-Party Service Providers. If your Account is managed for you by a third-party service provider, then such service providers will have access to your Account information and certain Customer Data (including your email and other data);

· We may provide your Customer Data or Sensitive Personal Information with your consent to our affiliates and other trusted businesses or persons that provide services to us in connection with our business activities, based on our instructions and in compliance with this Privacy Policy and under binding contractual obligations of confidentiality and security. These third parties are authorized to use your personal information only as necessary to provide such services to us;

· To a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of the Company’s assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by the Company about our users is among the assets transferred;

· To fulfil the purposes for which users provide it;

· The disclosure is required by applicable law or regulation; or

· The disclosure is required pursuant to a valid warrant or subpoena issued by a court of competent jurisdiction.

Notwithstanding the foregoing, we may share aggregated, de-identified, non-personally identifiable information on the Customer Portal or with companies or financial institutions that perform marketing services on our behalf or with other financial institutions with which we have joint marketing arrangements. For example, we may share information publicly to show trends about the general use of our services. We may combine information collected about you, and share it, in an aggregated, non-personally identifiable manner, with third parties.

8. Data Security.

Company shall use a reasonable standard of care to store, transmit, and protect Customer Data and Sensitive Personal Information from unauthorized disclosures. Company has implemented measures designed to secure Customer Data and Sensitive Personal Information from accidental loss and from unauthorized access, use, alteration, and disclosure. To the extent data encryption technology is utilized by us on a given page of our Customer Portal, you may be unable to use certain account or customization features of the Customer Portal unless your web browser software supports SSL encryption. Your Customer Data and Sensitive Personal Information will generally be stored on behalf of Company by us or a third-party service provider and will be granted the protections and will be subject to the security procedures utilized by such service provider, whose data protection and privacy protections may not afford the same level of protection as required by laws of certain countries, such as the member nations of the European Union. If you wish to receive information about such third-party service providers, you may make such request using the contact information set forth at the end of this document, including the phrase “Third Party Service Providers” in the subject line, and providing us with your name, address and email address. We will respond to you within thirty days of receiving such a request. We make no claims that our Customer Portal or mobile app, or any of their respective contents are appropriate or may be downloaded or accessed outside of the United States. If you access our Customer Portal or mobile app from outside the United States, you do so at your own risk and are responsible for compliance with the laws of your country. You may not use or export any content of the Company’s Customer Portal in violation of U.S. export laws and regulations.

Please note that the servers containing your information may become accessible in the event of a security breach. Also, transmissions of information via the Internet and mobile networks are never completely private or secure. Although we do our best to protect Customer Data and Sensitive Personal Information, we cannot guarantee the security of data transmitted via the Customer Portal. You understand that any transmission of your Customer Data and Sensitive Personal Information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on the Customer Portal. If you have any questions about the security of your Customer Data or Sensitive Personal Information, please contact us at the contact information below.

Breach Procedures. In the event of unauthorized access to, acquisition of, or disclosure of your Customer Data or Sensitive Personal Information, Company shall (i) investigate the incident without unreasonable delay, take all necessary steps to contain and remediate the breach, and document findings; and (ii) provide written notice to the Personal Representative as soon as practicable, and in no event later than the earlier of (a) the timeframe required by applicable law or (b) 30 days after discovery of the breach. Such notice shall include, to the extent known at the time, a general description of the incident, the types of data affected, the steps taken to secure and mitigate the breach, available protective measures You may take, and contact information for further inquiries. Where required by law, Company shall also notify appropriate regulatory authorities and any other state or federal agencies with jurisdiction.

9. Data Retention Policy.

Retention Schedule. As a general matter, we only keep information for as long as necessary to fulfill the purposes for which it was collected, as stated in our retention policies, and permitted or required by law, such as to comply with recordkeeping and other legal obligations. There may also be residual information that will remain within our backup files, databases, and other records, which will not be removed or changed, except in accordance with retention policies. Company will retain Customer Data and Sensitive Personal Information no longer than the maximum allowable time authorized by law after receiving written request for destruction.

Destruction Policy. Upon receipt of your written destruction request, Company will permanently destroy your Customer Data and Sensitive Personal Information registered to your Account in accordance with applicable law. Destruction of such data will be conducted by Company using methods that render the data permanently unreadable and unrecoverable. A record of destruction (including date and method) will be retained by Company for the minimum duration required by law.

10. Accessing and Correcting Your Customer Data.

You may contact us at the contact information below if you wish to (a) update or delete your Customer Data or Sensitive Personal Information; (b) close your Account; (c) request we cease sending you promotional or other information via mail or email; (d) request that we cease any further or future online collection of your Customer Data or Sensitive Personal Information. We will comply with requests for deletion of information subject to applicable state and federal law.

11. Your State Privacy Rights.

State consumer privacy laws may provide their residents with additional rights regarding our use of Customer Data and Sensitive Personal Information. Certain state laws may permit users or our Customer Portal and mobile apps to request certain information regarding our disclosure of Customer Data and Sensitive Personal Information to third parties.

California Residents. California consumers have the following privacy rights: to request additional information about our data collection, use, and disclosure practices in connection with the consumer’s Customer Data and Sensitive Personal Information; to request access to the specific Customer Data and Sensitive Personal Information collected about the consumer; to request the deletion of the consumer’s Customer Data and Sensitive Personal Information; to request a restriction on certain processing of personal information; and to request correction of inaccurate Customer Data and Sensitive Personal Information. Also, California consumers have the right not to receive discriminatory treatment if they exercise the rights listed above. To learn more about California’s “Shine the Light” law and California residents’ privacy rights, visit cppa.ca.gov.

Sensitive Personal Information may include sensitive personal information as defined by California law. We collect and use your Sensitive Personal Information solely for the lawful purposes described herein. You have the right to direct us to limit our use of your Sensitive Personal Information to what is necessary to perform the services you have requested.

You may be able to use the Customer Portal to access and update the Customer Data or Sensitive Personal Information that you have provided to us through your use of the Customer Portal or otherwise. If you would like to request access to such information or that we update, correct, or delete any such information, you may email us at the contact information below. We will comply with requests you submit as required by applicable law.

Colorado Residents. Colorado consumers have the following privacy rights: to request additional information about our data collection, use, and disclosure practices in connection with the consumer’s Customer Data and Sensitive Personal Information; to request access to the specific Customer Data and Sensitive Personal Information collected about the consumer; to request the deletion of the consumer’s Customer Data or Sensitive Personal Information; and to request correction of inaccurate Customer Data or Sensitive Personal Information. Also, Colorado consumers have the right not to receive discriminatory treatment if they exercise the rights listed above.

You may be able to use the Customer Portal to access and update the Customer Data and Sensitive Personal Information that you have provided to us through your use of the Customer Portal or otherwise. If you would like to request access to such information or that we update, correct, or delete any such information, you may email us at the contact information below. We will comply with requests you submit as required by applicable law.

12. Choice and Opt-Out Preference; Termination.

If you wish to request we no longer use your Customer Data or Sensitive Personal Information to provide you services, please contact us at the contact information provided below.

13. Updates.

We may update or modify this Privacy Policy at any time and without prior notice to you. Unless otherwise stated, any changes will be effective immediately upon posting on the Customer Portal. Your continued use of the Customer Portal following the posting of any changes constitutes acceptance of such changes. We encourage you to review the Privacy Policy regularly.

14. Questions or Comments.

Questions or comments about this Privacy Policy should be directed to: mysdhub@loriknappchoice.com.

Last updated: October 18, 2025.