PRIVACY POLICY

Last updated October 02, 2024

This Privacy Notice for Terrapin Insurance Group, LLC. ("we," "us," or "our"), describes how and why we might access, collect, store, use, and/or share ("process") your personal information when you use our services ("Services"), including when you: Visit our website at http://www.terrapininsurance.com, or any website of ours that links to this Privacy Notice. Engage with us in other related ways, including any sales, marketing, or events.

Questions or concerns? Reading this Privacy Notice will help you understand your privacy rights and choices. We are responsible for making decisions about how your personal information is processed. If you do not agree with our policies and practices, please do not use our Services. If you still have any questions or concerns, please contact us at info@terrapininsurance.com.

SUMMARY OF KEY POINTS

This summary provides key points from our Privacy Notice, but you can find out more details about any of these topics by clicking the link following each key point or by using our table of contents below to find the section you are looking for. What personal information do we process? When you visit, use, or navigate our Services, we may process personal information depending on how you interact with us and the Services, the choices you make, and the products and features you use. Learn more about personal information you disclose to us. Do we process any sensitive personal information? Some of the information may be considered "special" or "sensitive" in certain jurisdictions, for example your racial or ethnic origins, sexual orientation, and religious beliefs. We may process sensitive personal information when necessary with your consent or as otherwise permitted by applicable law. Learn more about sensitive information we process. Do we collect any information from third parties? We do not collect any information from third parties. How do we process your information? We process your information to provide, improve, and administer our Services, communicate with you, for security and fraud prevention, and to comply with law. We may also process your information for other purposes with your consent. We process your information only when we have a valid legal reason to do so. Learn more about how we process your information. In what situations and with which parties do we share personal information? We may share information in specific situations and with specific third parties. Learn more about when and with whom we share your personal information. How do we keep your information safe? We have adequate organizational and technical processes and procedures in place to protect your personal information. However, no electronic transmission over the internet or information storage technology can be guaranteed to be 100% secure, so we cannot promise or guarantee that hackers, cybercriminals, or other unauthorized third parties will not be able to defeat our security and improperly collect, access, steal, or modify your information. Learn more about how we keep your information safe.

What are your rights? Depending on where you are located geographically, the applicable privacy law may mean you have certain rights regarding your personal information. Learn more about your privacy rights. How do you exercise your rights? The easiest way to exercise your rights is by visiting https://www.terrapininsurance.com/contact-us, or by contacting us. We will consider and act upon any request in accordance with applicable data protection laws.

Want to learn more about what we do with any information we collect? Review the Privacy Notice in full.

TABLE OF CONTENTS

1. WHAT INFORMATION DO WE COLLECT?

2. HOW DO WE PROCESS YOUR INFORMATION?

3. WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL

INFORMATION?

4. HOW LONG DO WE KEEP YOUR INFORMATION?

5. HOW DO WE KEEP YOUR INFORMATION SAFE?

6. DO WE COLLECT INFORMATION FROM MINORS?

7. WHAT ARE YOUR PRIVACY RIGHTS?

8. CONTROLS FOR DO-NOT-TRACK FEATURES

9. DO UNITED STATES RESIDENTS HAVE SPECIFIC PRIVACY

RIGHTS?

10. DO WE MAKE UPDATES TO THIS NOTICE?

11. HOW CAN YOU CONTACT US ABOUT THIS NOTICE?

12. HOW CAN YOU REVIEW, UPDATE, OR DELETE THE DATA WE

COLLECT FROM YOU?

1. WHAT INFORMATION DO WE COLLECT?

Personal information you disclose to us In Short: We collect personal information that you provide to us. We collect personal information that you voluntarily provide to us when you express an interest in obtaining information about us or our products and Services, when you participate in activities on the Services, or otherwise when you contact us. Personal Information Provided by You. The personal information that we collect depends on the context of your interactions with us and the Services, the choices you make, and the products and features you use.

The personal information we collect may include the following:

. phone numbers

. email addresses

. mailing addresses

. contact preferences

. billing addresses

Sensitive Information. When necessary, with your consent or as otherwise permitted by applicable law, we process the following categories of sensitive information:

. biometric data

. social security numbers or other government identifiers

All personal information that you provide to us must be true, complete, and accurate, and you must notify us of any changes to such personal information.

2. HOW DO WE PROCESS YOUR INFORMATION?

In Short: We process your information to provide, improve, and administer our Services, communicate with you, for security and fraud prevention, and to comply with law. We may also process your information for other purposes with your consent. We process your personal information for a variety of reasons, depending on how you interact with our Services, including:

To respond to user inquiries/offer support to users. We may process your information to respond to your inquiries and solve any potential issues you might have with the requested service. To evaluate and improve our Services, products, marketing, and your experience. We may process your information when we believe it is necessary to identify usage trends, determine the effectiveness of our promotional campaigns, and to evaluate and improve our Services, products, marketing, and your experience.

To comply with our legal obligations. We may process your information to comply with our legal obligations, respond to legal requests, and exercise, establish, or defend our legal rights.

3. WHEN AND WITH WHOM DO WE SHARE YOUR

PERSONAL INFORMATION?

In Short: We may share information in specific situations described in this section and/or with the following third parties.

We may need to share your personal information in the following situations:

. Business Transfers. We may share or transfer your information in

connection with, or during negotiations of, any merger, sale of

company assets, financing, or acquisition of all or a portion of our

business to another company.

. Affiliates. We may share your information with our affiliates, in

which case we will require those affiliates to honor this Privacy

Notice. Affiliates include our parent company and any subsidiaries,

joint venture partners, or other companies that we control or that are

under common control with us.

. Business Partners. We may share your information with our

business partners to offer you certain products, services, or

promotions.

4. HOW LONG DO WE KEEP YOUR INFORMATION?

In Short: We keep your information for as long as necessary to fulfill the

purposes outlined in this Privacy Notice unless otherwise required by law.

We will only keep your personal information for as long as it is necessary

for the purposes set out in this Privacy Notice, unless a longer retention

period is required or permitted by law (such as tax, accounting, or other

legal requirements).

When we have no ongoing legitimate business need to process your

personal information, we will either delete or anonymize such information,

or, if this is not possible (for example, because your personal information

has been stored in backup archives), then we will securely store your

personal information and isolate it from any further processing until deletion

is possible.

5. HOW DO WE KEEP YOUR INFORMATION SAFE?

In Short: We aim to protect your personal information through a system of

organizational and technical security measures.

We have implemented appropriate and reasonable technical and

organizational security measures designed to protect the security of any

personal information we process. However, despite our safeguards and

efforts to secure your information, no electronic transmission over the

Internet or information storage technology can be guaranteed to be 100%

secure, so we cannot promise or guarantee that hackers, cybercriminals, or

other unauthorized third parties will not be able to defeat our security and

improperly collect, access, steal, or modify your information. Although we

will do our best to protect your personal information, transmission of

personal information to and from our Services is at your own risk. You

should only access the Services within a secure environment.

6. DO WE COLLECT INFORMATION FROM

MINORS?

In Short: We do not knowingly collect data from or market to children

under 18 years of age.

We do not knowingly collect, solicit data from, or market to children under

18 years of age, nor do we knowingly sell such personal information. By

using the Services, you represent that you are at least 18 or that you are

the parent or guardian of such a minor and consent to such minor

dependent's use of the Services. If we learn that personal information from

users less than 18 years of age has been collected, we will deactivate the

account and take reasonable measures to promptly delete such data from

our records. If you become aware of any data we may have collected from

children under age 18, please contact us at info@terrapininsurance.com.

7. WHAT ARE YOUR PRIVACY RIGHTS?

In Short: You may review, change, or terminate your account at any time,

depending on your country, province, or state of residence.

Withdrawing your consent: If we are relying on your consent to process

your personal information, which may be express and/or implied consent

depending on the applicable law, you have the right to withdraw your

consent at any time. You can withdraw your consent at any time by

contacting us by using the contact details provided in the section "HOW

CAN YOU CONTACT US ABOUT THIS NOTICE?" below.

However, please note that this will not affect the lawfulness of the

processing before its withdrawal nor, when applicable law allows, will it

affect the processing of your personal information conducted in reliance on

lawful processing grounds other than consent.

Opting out of marketing and promotional communications: You can

unsubscribe from our marketing and promotional communications at any

time by clicking on the unsubscribe link in the emails that we send, replying

"STOP" or "UNSUBSCRIBE" to the SMS messages that we send, or by

contacting us using the details provided in the section "HOW CAN YOU

CONTACT US ABOUT THIS NOTICE?" below. You will then be removed

from the marketing lists. However, we may still communicate with you -

for example, to send you service-related messages that are necessary for

the administration and use of your account, to respond to service requests,

or for other non-marketing purposes.

If you have questions or comments about your privacy rights, you may

email us at info@terrapininsurance.com.

8. CONTROLS FOR DO-NOT-TRACK FEATURES

Most web browsers and some mobile operating systems and mobile

applications include a Do-Not-Track ("DNT") feature or setting you can

activate to signal your privacy preference not to have data about your

online browsing activities monitored and collected. At this stage, no uniform

technology standard for recognizing and implementing DNT signals has

been finalized. As such, we do not currently respond to DNT browser

signals or any other mechanism that automatically communicates your

choice not to be tracked online. If a standard for online tracking is adopted

that we must follow in the future, we will inform you about that practice in a

revised version of this Privacy Notice.

California law requires us to let you know how we respond to web browser

DNT signals. Because there currently is not an industry or legal standard

for recognizing or honoring DNT signals, we do not respond to them at this

time.

9. DO UNITED STATES RESIDENTS HAVE SPECIFIC

PRIVACY RIGHTS?

In Short: If you are a resident of California, Colorado, Connecticut,

Delaware, Florida, Indiana, lowa, Kentucky, Montana, New Hampshire,

New Jersey, Oregon, Tennessee, Texas, Utah, or Virginia, you may have

the right to request access to and receive details about the personal

information we maintain about you and how we have processed it, correct

inaccuracies, get a copy of, or delete your personal information. You may

also have the right to withdraw your consent to our processing of your

personal information. These rights may be limited in some circumstances

by applicable law. More information is provided below.

Categories of Personal Information We Collect

We have collected the following categories of personal information in the

past twelve (12) months:

Category

A. Identifiers

YES

B. Personal information

as defined in the

California Customer

Records statute

C. Protected

classification

characteristics under

state or federal law

D. Commercial

information

Examples

Contact details, such as real name,

alias, postal address, telephone or

mobile contact number, unique

personal identifier, online identifier,

Internet Protocol address, email

address, and account name

Name, contact information,

education, employment, employment

history, and financial information

Collected

YES

YES

NO

NO

F. Internet or other

similar network activity

Gender, age, date of birth, race and

ethnicity, national origin, marital

status, and other demographic data

Transaction information, purchase

history, financial details, and payment

information

E. Biometric information Fingerprints and voiceprints

Browsing history, search history,

online behavior, interest data, and

interactions with our and other

websites, applications, systems, and

advertisements

NO

G. Geolocation data

H. Audio, electronic,

sensory, or similar

information

Device location

NO

NO

Professional or

employment-related

information

NO

J. Education Information

NO

K. Inferences drawn

information

NO

.. Sensitive personal

Information

Images and audio, video or call

recordings created in connection with

our business activities

Business contact details in order to

provide you our Services at a

business level or job title, work

history, and professional

qualifications if you apply for a job

with us

Student records and directory

information

Inferences drawn from any of the

collected personal information listed

from collected personal | above to create a profile or summary

about, for example, an individual's

preferences and characteristics

Drivers' licenses, debit or credit card

numbers, social security numbers

and state id card numbers

We only collect sensitive personal information, as defined by applicable

privacy laws or the purposes allowed by law or with your consent. Sensitive

personal information may be used, or disclosed to a service provider or

contractor, for additional, specified purposes. You may have the right to

limit the use or disclosure of your sensitive personal information. We do not

collect or process sensitive personal information for the purpose of inferring

characteristics about you.

We may also collect other personal information outside of these categories

through instances where you interact with us in person, online, or by phone

or mail in the context of:

. Receiving help through our customer support channels;

. Participation in customer surveys or contests; and

. Facilitation in the delivery of our Services and to respond to your

inquiries.

YES
We only collect sensitive personal information, as defined by applicable

privacy laws or the purposes allowed by law or with your consent. Sensitive

personal information may be used, or disclosed to a service provider or

contractor, for additional, specified purposes. You may have the right to

limit the use or disclosure of your sensitive personal information. We do not

collect or process sensitive personal information for the purpose of inferring

characteristics about you.

We may also collect other personal information outside of these categories

through instances where you interact with us in person, online, or by phone

or mail in the context of:

. Receiving help through our customer support channels;

. Participation in customer surveys or contests; and

. Facilitation in the delivery of our Services and to respond to your

inquiries.

We will use and retain the collected personal information as needed to

provide the Services or for:

. Category A - As long as the user has an account with us

. Category B - As long as the user has an account with us

. Category C - As long as the user has an account with us

. Category H - As long as the user has an account with us

. Category L - As long as the user has an account with us

Sources of Personal Information

Learn more about the sources of personal information we collect in "WHAT

INFORMATION DO WE COLLECT?"

How We Use and Share Personal Information

Learn about how we use your personal information in the section, "HOW

DO WE PROCESS YOUR INFORMATION?"

Will your information be shared with anyone else?

We may disclose your personal information with our service providers

pursuant to a written contract between us and each service provider. Learn

more about how we disclose personal information to in the section, "WHEN

AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?"

We may use your personal information for our own business purposes,

such as for undertaking internal research for technological development

and demonstration. This is not considered to be "selling" of your personal

information.

We have not disclosed, sold, or shared any personal information to third

parties for a business or commercial purpose in the preceding twelve (12)

months. We will not sell or share personal information in the future

belonging to website visitors, users, and other consumers.

Your Rights

You have rights under certain US state data protection laws. However,

these rights are not absolute, and in certain cases, we may decline your

request as permitted by law. These rights include:

. Right to know whether or not we are processing your personal data

. Right to access your personal data

. Right to correct inaccuracies in your personal data

. Right to request the deletion of your personal data

. Right to obtain a copy of the personal data you previously shared

with us

. Right to non-discrimination for exercising your rights

. Right to opt out of the processing of your personal data if it is used

for targeted advertising (or sharing as defined under California's

privacy law), the sale of personal data, or profiling in furtherance of

decisions that produce legal or similarly significant effects

("profiling")

Depending upon the state where you live, you may also have the following

rights:

. Right to obtain a list of the categories of third parties to which we

have disclosed personal data (as permitted by applicable law,

including California's and Delaware's privacy law)

. Right to obtain a list of specific third parties to which we have

disclosed personal data (as permitted by applicable law, including

Oregon's privacy law)

. Right to limit use and disclosure of sensitive personal data (as

permitted by applicable law, including California's privacy law)

. Right to opt out of the collection of sensitive data and personal data

collected through the operation of a voice or facial recognition

feature (as permitted by applicable law, including Florida's privacy

law)

How to Exercise Your Rights

To exercise these rights, you can contact us by visiting

https://www.terrapininsurance.com/contact-us, by emailing us at

info@terrapininsurance.com, by calling toll-free at 240-243-0042, by

visiting https://www.terrapininsurance.com/contact-us, or by referring to the

contact details at the bottom of this document.

We will honor your opt-out preferences if you enact the Global Privacy

Control (GPC) opt-out signal on your browser.

Under certain US state data protection laws, you can designate an

authorized agent to make a request on your behalf. We may deny a

request from an authorized agent that does not submit proof that they have

been validly authorized to act on your behalf in accordance with applicable

laws.

Request Verification

Upon receiving your request, we will need to verify your identity to

determine you are the same person about whom we have the information

in our system. We will only use personal information provided in your

request to verify your identity or authority to make the request. However, if

we cannot verify your identity from the information already maintained by

us, we may request that you provide additional information for the purposes

of verifying your identity and for security or fraud-prevention purposes.

If you submit the request through an authorized agent, we may need to

collect additional information to verify your identity before processing your

request and the agent will need to provide a written and signed permission

from you to submit such request on your behalf.

Appeals

Under certain US state data protection laws, if we decline to take action

regarding your request, you may appeal our decision by emailing us at

info@terrapininsurance.com. We will inform you in writing of any action

taken or not taken in response to the appeal, including a written

explanation of the reasons for the decisions. If your appeal is denied, you

may submit a complaint to your state attorney general.

California "Shine The Light" Law

California Civil Code Section 1798.83, also known as the "Shine The Light"

law, permits our users who are California residents to request and obtain

from us, once a year and free of charge, information about categories of

personal information (if any) we disclosed to third parties for direct

marketing purposes and the names and addresses of all third parties with

which we shared personal information in the immediately preceding

calendar year. If you are a California resident and would like to make such

a request, please submit your request in writing to us by using the contact

details provided in the section "HOW CAN YOU CONTACT US ABOUT

THIS NOTICE?"

10. DO WE MAKE UPDATES TO THIS NOTICE?

In Short: Yes, we will update this notice as necessary to stay compliant

with relevant laws.

We may update this Privacy Notice from time to time. The updated version

will be indicated by an updated "Revised" date at the top of this Privacy

Notice. If we make material changes to this Privacy Notice, we may notify

you either by prominently posting a notice of such changes or by directly

sending you a notification. We encourage you to review this Privacy Notice

frequently to be informed of how we are protecting your information.

11. HOW CAN YOU CONTACT US ABOUT THIS

NOTICE?

If you have questions or comments about this notice, you may email us at

info@terrapininsurance.com or contact us by post at:

Terrapin Insurance Group, LLC.

1300 PICCARD DR STE 204

Rockville, MD 20850-4375

United States

12. HOW CAN YOU REVIEW, UPDATE, OR DELETE

THE DATA WE COLLECT FROM YOU?

You have the right to request access to the personal information we collect

from you, details about how we have processed it, correct inaccuracies, or

delete your personal information. You may also have the right to withdraw

your consent to our processing of your personal information. These rights

may be limited in some circumstances by applicable law. To request to

review, update, or delete your personal information, please visit:

https://www.terrapininsurance.com/contact-us.