Privacy Policy

1. Introduction

Nexus Lead Solutions ("Nexus," "we," "our," or "us"), a service operated by PM Groups LLC, a Florida Limited Liability Company, is committed to protecting your privacy. This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you use our lead generation platform ("Platform") and related services.

This Privacy Policy applies to:

• Insurance Agents ("Agents") who register for and use our Platform to purchase leads
• Consumers ("Leads") whose information is collected through our lead generation activities
• Website Visitors who browse our website

By using our Platform or providing your information to us, you consent to the practices described in this Privacy Policy. If you do not agree with this Privacy Policy, please do not use our services.

2. Information We Collect

2.1 Information from Insurance Agents

When you register as an Agent, we collect:

• Full legal name, email address, phone number, and mailing address
• National Producer Number (NPN) and insurance license information
• Licensed states and lines of authority
• Agency name and business information
• Payment and billing information (processed by our payment processor)
• Account credentials and authentication data
• Transaction history and lead purchase records
• Communications with our support team
• IP address, device information, and browser type

2.2 Information from Consumers (Leads)

Through our lead generation activities, we may collect:

• Name, email address, phone number, and mailing address
• Date of birth and age
• Insurance needs and preferences (health, life, Medicare, ACA, etc.)
• Current insurance coverage information
• Household information and number of dependents
• Income range and employment status
• Health-related information relevant to insurance quotes
• Consent records and opt-in timestamps
• IP address and device information

2.3 Information Collected Automatically

When you visit our Platform, we automatically collect:

• IP address and geolocation data
• Browser type, version, and settings
• Device type, operating system, and unique device identifiers
• Referring URLs and exit pages
• Pages viewed, time spent, and clickstream data
• Cookies and similar tracking technologies (see Section 9)

3. How We Use Your Information

3.1 For Insurance Agents

• Create and manage your account
• Verify your identity and NPN/licensing status
• Process lead purchases and payments
• Provide customer support and respond to inquiries
• Send transactional emails (receipts, account updates, lead notifications)
• Send marketing communications (with your consent)
• Improve our Platform and develop new features
• Detect and prevent fraud, abuse, and security incidents
• Comply with legal obligations and enforce our Terms of Service

3.2 For Consumers (Leads)

• Match you with licensed insurance agents who can serve your needs
• Facilitate insurance quotes and policy information
• Verify the accuracy of information provided
• Comply with applicable laws and regulations
• Maintain records of consent as required by law

4. Legal Bases for Processing

We process personal information based on the following legal grounds:

• Consent: When you provide affirmative consent for us to collect and share your information (e.g., lead form submissions)
• Contract Performance: To fulfill our obligations under our Terms of Service with Agents
• Legitimate Interests: For fraud prevention, security, improving our services, and direct marketing to existing customers
• Legal Compliance: To comply with applicable laws, regulations, and legal processes

5. How We Share Your Information

5.1 Consumer Lead Information

We share consumer lead information with licensed insurance agents who purchase leads through our Platform. This sharing is based on the consumer's consent to be contacted about insurance products.

5.2 Service Providers

We share information with third-party service providers who assist us with:

• Payment processing (e.g., Stripe)
• Cloud hosting and data storage (e.g., Amazon Web Services)
• Email delivery services
• Analytics and performance monitoring
• Customer support tools
• Identity and license verification services

These service providers are contractually obligated to protect your information and may only use it for the specific services they provide to us.

5.3 Legal and Safety Disclosures

We may disclose information when we believe it is necessary to:

• Comply with applicable laws, regulations, or legal processes
• Respond to lawful requests from government authorities
• Enforce our Terms of Service and other agreements
• Protect the rights, property, or safety of Nexus, our users, or others
• Detect, prevent, or address fraud, security, or technical issues

5.4 Business Transfers

If Nexus is involved in a merger, acquisition, sale of assets, or bankruptcy, your information may be transferred as part of that transaction. We will notify you of any change in ownership or use of your personal information.

5.5 Information We Do Not Sell

We do not sell Agent personal information to third parties for their own marketing purposes. The sharing of consumer lead information with insurance agents is the core service we provide and is conducted with consumer consent.

6. Data Security

We implement appropriate technical and organizational measures to protect your personal information, including:

• Encryption of data in transit (TLS/SSL) and at rest
• Secure authentication mechanisms including password hashing
• Access controls limiting employee access to personal data
• Regular security assessments and vulnerability testing
• Employee training on data protection and security practices
• Incident response procedures for potential data breaches

While we strive to protect your information, no method of transmission over the Internet or electronic storage is 100% secure. We cannot guarantee absolute security.

7. Data Retention

We retain personal information for as long as necessary to fulfill the purposes for which it was collected, including:

• Agent Accounts: For the duration of your account plus 7 years for legal and tax purposes
• Lead Information: For 7 years from the date of collection for compliance and legal purposes
• Transaction Records: For 7 years as required by financial regulations
• Consent Records: For 7 years or as required by TCPA and other regulations
• Communication Records: For 3 years or as required for dispute resolution

After the retention period, we will securely delete or anonymize your information unless longer retention is required by law.

8. Your Privacy Rights

8.1 Rights for All Users

Depending on your location, you may have the following rights:

• Access: Request a copy of the personal information we hold about you
• Correction: Request that we correct inaccurate or incomplete information
• Deletion: Request that we delete your personal information (subject to legal retention requirements)
• Portability: Request your data in a structured, commonly used format
• Opt-Out: Opt out of marketing communications at any time
• Withdraw Consent: Withdraw consent where processing is based on consent

8.2 How to Exercise Your Rights

To exercise your privacy rights, you may:

• Email us at legal@nexusleadsolutions.com
• Use the account settings in your Agent dashboard
• Contact us using the information in Section 16

We will respond to your request within 30 days (or sooner if required by applicable law). We may need to verify your identity before processing your request.

9. Cookies and Tracking Technologies

We use cookies and similar technologies to enhance your experience on our Platform:

9.1 Types of Cookies We Use

• Essential Cookies: Required for the Platform to function properly (authentication, security)
• Functional Cookies: Remember your preferences and settings
• Analytics Cookies: Help us understand how users interact with the Platform
• Marketing Cookies: Used to deliver relevant advertisements (with consent)

9.2 Managing Cookies

You can control cookies through your browser settings. Note that disabling certain cookies may affect the functionality of the Platform. Most browsers allow you to:

• View and delete cookies
• Block third-party cookies
• Block all cookies
• Clear cookies when you close your browser

10. California Privacy Rights (CCPA/CPRA)

If you are a California resident, you have additional rights under the California Consumer Privacy Act (CCPA) as amended by the California Privacy Rights Act (CPRA):

• Right to Know: Request information about the categories and specific pieces of personal information we have collected, the sources, purposes, and third parties with whom we share it
• Right to Delete: Request deletion of your personal information, subject to exceptions
• Right to Correct: Request correction of inaccurate personal information
• Right to Opt-Out of Sale/Sharing: Opt out of the "sale" or "sharing" of personal information
• Right to Limit Use of Sensitive Personal Information: Limit how we use sensitive personal information
• Right to Non-Discrimination: We will not discriminate against you for exercising your rights

To submit a request, contact us at legal@nexusleadsolutions.com or call [Your Phone Number]. You may designate an authorized agent to make requests on your behalf.

California "Shine the Light" Law

California Civil Code Section 1798.83 permits California residents to request information about our disclosure of personal information to third parties for direct marketing purposes. To make such a request, contact us using the information below.

11. Virginia Consumer Data Protection Act (VCDPA)

If you are a Virginia resident, you have the following rights under the VCDPA:

• Right to confirm whether we are processing your personal data
• Right to access your personal data
• Right to correct inaccuracies
• Right to delete your personal data
• Right to obtain a portable copy of your data
• Right to opt out of targeted advertising, sale of data, or profiling

You may appeal our decision on your request by contacting us at legal@nexusleadsolutions.com.

12. Colorado Privacy Act (CPA)

Colorado residents have similar rights under the Colorado Privacy Act, including rights to access, correct, delete, and port their data, as well as opt out of targeted advertising, sale of personal data, and profiling.

13. Connecticut Data Privacy Act (CTDPA)

Connecticut residents have rights similar to those described for Virginia and Colorado residents, including the right to access, correct, delete, and obtain a copy of their personal data.

14. Florida Digital Bill of Rights

As a Florida-based company, we comply with the Florida Digital Bill of Rights (effective July 1, 2024) for qualifying Florida residents. This includes:

• Right to confirm whether we are processing your personal data
• Right to access your personal data
• Right to correct inaccuracies
• Right to delete your personal data
• Right to obtain a copy of your personal data
• Right to opt out of targeted advertising and sale of personal data

15. Gramm-Leach-Bliley Act (GLBA) Notice

As a company that facilitates insurance-related services, we are committed to compliance with the Gramm-Leach-Bliley Act (GLBA) privacy provisions:

• We collect nonpublic personal information from consumers who request insurance quotes
• We share this information with licensed insurance agents for the purpose of providing requested insurance services
• We do not share nonpublic personal information with non-affiliated third parties except as permitted by law
• We maintain administrative, technical, and physical safeguards to protect your information

16. TCPA Consent and Compliance

When consumers submit their information through our lead generation forms, they provide consent to be contacted by telephone, including via automated systems and prerecorded messages. We maintain records of this consent as required by the Telephone Consumer Protection Act (TCPA).

Consumers may revoke their consent at any time by contacting us or the agent who contacts them.

17. Children's Privacy

Our Platform is not intended for individuals under 18 years of age. We do not knowingly collect personal information from children under 18. If we become aware that we have collected personal information from a child under 18, we will take steps to delete that information promptly. If you believe we have collected information from a child under 18, please contact us immediately.

18. Data Breach Notification

In the event of a data breach involving your personal information, we will notify you and relevant authorities as required by the Florida Information Protection Act (FIPA) and other applicable state and federal laws. Florida law requires notification within 30 days of discovery of a breach affecting 500 or more Florida residents.

19. Third-Party Links

Our Platform may contain links to third-party websites or services. We are not responsible for the privacy practices of these third parties. We encourage you to review the privacy policies of any third-party sites you visit.

20. International Users

Our Platform is operated in the United States. If you are accessing our Platform from outside the United States, please be aware that your information may be transferred to, stored, and processed in the United States. By using our Platform, you consent to this transfer.

21. Changes to This Privacy Policy

We may update this Privacy Policy from time to time. We will notify you of material changes by posting the updated policy on our Platform and updating the "Last updated" date. For significant changes, we may also notify you by email. Your continued use of the Platform after changes become effective constitutes your acceptance of the updated Privacy Policy.

22. Contact Us

If you have questions, concerns, or requests regarding this Privacy Policy or our data practices, please contact us:

For California residents, you may also contact the California Attorney General at oag.ca.gov if you believe your privacy rights have been violated.