Privacy Policy

SIAA, Inc. and SIAA’s subsidiaries and affiliates “SIAA” processes information that identifies individuals or is identifiable to individuals, which is referred to as “Personal Information.” SIAA’s processing of Personal Information is governed by this Privacy Policy as well as the laws and regulations that govern our processing of Personal Information, which are referred to as “Data Privacy Laws.” This Policy does not apply to SIAA’s processing of Personal Information for employment, or to the processing of Personal Information that is otherwise excluded from Data Privacy Laws.

Personal Information

As an alliance of independent insurance agencies, SIAA provides a wide variety of goods and services, including access to insurance carriers, access to insurance programs and insurance-related products, participation in negotiated arrangements with strategic partners, business consulting, training, educational programs designed to grow and evolve the independent agency, and other similar services and benefits, which are referred to as “Services.” We provide Services to a broad range of businesses, which are referred to as “Businesses.”

In the course of providing Services and conducting Operations (as that term is defined below), we interact with a broad range of individuals, including the following: employees of Clients; owners, shareholders, members, managers, directors, officers, employees, associates, contractors, customers, vendors, service providers, agents, representatives, insurers, attorneys, and affiliates of Clients; individuals who attend SIAA events, use the SIAA website and other SIAA technology systems, receive information from SIAA, and otherwise interact with employees and other representatives of SIAA; and SIAA vendors, service providers, contractors, agents and representatives. All individuals with whom we interact in the course of providing Services or conducting Operations are referred to as “Individuals.” For the purposes of this Policy, Individuals and Businesses are collectively referred to as “Clients.”

Due to the broad range of our Services and Operations, SIAA processes a broad range of Personal Information. While it would be imprudent to attempt to list every type of Personal Information we process, the following lists some common categories, including Personal Information that we have processed in the preceding 12 months.

  • Name and Contact Information. Current and previous first, middle, and last names, signature, residential and business addresses, phone numbers, email, and other personal identifiers.
  • Financial Numbers. Bank, checking, savings, credit, debit, online, other financial, insurance and tax documentation, Social Security numbers and W-9 documentation and cardholder data.
  • Technological Information. Internet Protocol or IP address, Media Access Control or MAC address, browsing activity, use of SIAA’s website and technology systems, and other technological information.
  • Security Information. Information relating to access to and use of SIAA’s physical facilities and technology systems, and other security information.
  • Billing Information. Information about the Services we provide to Clients, the fees we charge for those Services, our invoicing for Services, and other billing information.
  • Client Information. Information that we process related to or in the course of providing Services to or for a Client.
  • Insurance and Underwriting Information. Information related to insurance policies and insurance-related transactions, including policyholder information, applications, submissions, quotes, coverage details, limits, endorsements, premiums, commissions, underwriting data, risk characteristics, claims information (including types of claims and claim amounts), loss history, and similar insurance-related data.
  • Transaction and Placement Information. Information processed in connection with insurance placement, servicing, and related activities, including communications with carriers, managing general agents, wholesalers, and other market participants.
  • Operations Information. Information that SIAA processes to conduct our own operations, including administration, accounting, finance, marketing, technology, cybersecurity, privacy, management of vendors and services providers, human resources, records management, facilities management, and other types of operations, which are referred to as “Operations.”
  • Analytics Information. Information derived from Personal Information, including aggregated, de-identified, or analytical data used for reporting, product development, and business intelligence.

We collect Personal Information in connection with our Services from various sources, including: (1) when you fill out a form on our website, apply for or inquire about our Services; (2) referrals from partner programs; (3) when you otherwise interact with us; (4) visitors to our website or offices; and (5) other sources such as public databases, joint marketing partners, affiliate programs, and data providers. In addition, we collect and receive Personal Information from our Clients and their systems, including agency management systems, third-party platforms, integrations, and other data sources that Clients use in their operations. This may include Personal Information about individuals who do not directly interact with SIAA, such as customers, insureds, claimants, and other third parties.

If you provide Personal Information to SIAA about any Individual other than yourself, we ask and expect that you have the authority to do so or consent to do so from that Individual.

Sensitive Personal Information and Information about Children

SIAA may receive and process certain categories of Personal Information that may be considered sensitive under applicable Data Privacy Laws in connection with providing Services to Clients, which is referred to as “Sensitive Personal Information.” The Sensitive Personal Information we collect may include, for example, identifiers such as Social Security numbers and certain taxpayer identification information, financial account and payment information, insurance-related information, and other Personal Information contained within insurance applications, policies, claims, and related records, which is referred to as “Sensitive Personal Information.” For purposes of this Policy, Sensitive Personal Information is a sub-category of Personal Information.

Except as otherwise stated in this Privacy Policy, we do not intentionally collect Personal Information about individuals who are minors in the jurisdictions where they reside, who are referred to as “Children.” Additionally, except as otherwise stated in the Privacy Policy, we also do not collect protected health information and other health related information, information about race, ethnicity, national origin, citizenship, immigration status, gender and sexual orientation and identification, religion or religious belief, political affiliation, union membership, criminal and credit matters, biometric information, and specific geolocation. To the extent we receive any such information, whether inadvertently or otherwise, we reserve the right to delete or otherwise remove such information from our systems without notice.

Purposes and Bases for Processing Personal Information

Due to the broad range of our Services and Operations, SIAA may process Personal Information for a broad range of purposes and bases. While it would be imprudent to attempt to list every such purpose or basis, the following lists some of the more common purposes and bases for which we process Personal Information.

  • Consent and Direction. Based on consent and direction given to us by Clients and third parties about whom the Personal Information pertains or who otherwise have authority or consent to provide such consent or direction.
  • Provide Services. Activities related to providing Services to or for Clients, and improving the Services that we offer and provide.
  • Business Relationships. Interact with Clients, and third parties with respect to SIAA’s or their business activities and interests.
  • Compliance, safety, claims, and website. To comply with applicable laws and regulations, including Data Privacy Laws; to ensure safety and protect SIAA, our personnel, Clients, third parties, and SIAA’s physical facilities and technology systems; to establish, enforce, and exercise our rights and defend against claims; and to monitor, develop and maintain the operation, security and integrity of our website and technology systems.
  • Analytics and Product Development. To analyze, aggregate, deidentify, and otherwise process Personal Information and insurance information to develop insights, reporting, analytics, products, programs, market opportunities, and other business initiatives, and to improve and expand SIAA’s Services, technologies, and strategic relationships.
  • Operations. Activities related to SIAA’s Operations.
Disclosure of Personal Information

SIAA may disclose Personal Information under the following circumstances.

  • Consent and Direction. Based on consent and direction given to us by Clients and third parties about whom the Personal Information pertains or who otherwise have authority or consent to provide such consent or direction.
  • Provide Services. As necessary or appropriate to provide Services to or for Clients, and to support analytics, product development, market access facilitation, program administration, and other business purposes related to SIAA’s Services and Operations.
  • Agents of Clients, Individuals and SIAA. To owners, shareholders, members, managers, directors, officers, employees, associates, contractors, customers, vendors, service providers, agents, representatives, insurers, and attorneys of SIAA, or Clients as necessary or appropriate to provide Services to Clients or support our Operations.
  • Business Partners. We may share Personal Information that we collect, including names, business contact details, email addresses, phone numbers, and other relevant information, with trusted third parties and business partners for legitimate business purposes. These third parties may include, but are not limited to, affiliates, insurance carriers, wholesalers, technology vendors, service providers, sponsors, co-sponsors, trade associations, and other strategic business partners. We share this information to deliver products, services, and program benefits to our Clients, improve operational efficiency, support marketing, analytics, and event-related activities, negotiate and administer member programs, assess potential partnerships, and enable such partners to introduce and market additional Services, including their own products and services, to Clients. Some of these partners may use this information to contact Clients directly. Where required or appropriate, we disclose this information under confidentiality or non-disclosure agreements.
  • Compliance, safety, claims and legal process. To comply with applicable laws and regulations, including Data Privacy Laws; to ensure safety and protect SIAA, our personnel, Clients, Individuals, third parties, and SIAA’s physical facilities and technology systems; to establish, enforce, and exercise our rights and defend against claims; and to comply with a valid subpoena or other legal process or lawful request by governmental, regulatory, and law enforcement authorities.
  • Business Transfers. In anticipation of or the course of an acquisition, merger, consolidation, restructuring, sale of ownership interests, assets or both, or other such corporate change.
Privacy Rights

Depending on the Personal Information SIAA processes about an Individual, and the manner in which we process such Personal Information, an Individual may have the following rights with respect to our processing of Personal Information about that Individual.

  • Scope of Processing. Disclosure about how we process Personal Information, the categories of Personal Information we process, and the categories of sources from which such Personal Information was obtained.
  • Access. Access or receipt of a copy of Personal Information, including (if appropriate) in a portable, machine-readable, and commonly used format.
  • Correction. Rectify or correct inaccurate or incomplete Personal Information.
  • Deletion. Deletion or erasure of Personal Information.
  • Withdraw Consent. Withdraw consent if we rely on consent as a basis for processing Personal Information, provided that such withdrawal will not affect the lawfulness of our processing of Personal Information before such withdrawal or the continued processing of it after withdrawal for a purpose or basis other than consent.
  • Selling, Profiling, and Targeted Advertising. Disclosure about whether SIAA sells, shares, trades, exchanges, or brokers Personal Information with or to a third party for the purpose of that or any other third party using the Personal Information to market on their own behalf, which is referred to as “Selling”; disclosure about whether SIAA uses automated decision making to evaluate, analyze or predict personal aspects related to an individual’s economic situation, health, personal preferences, interests, reliability, behavior, location, or movements, which is referred to as “Profiling.”; disclosure about whether SIAA targets advertising to individuals based on their activities on unaffiliated third party websites, which is referred to as “Targeted Advertising”; and to object or opt-out of such Selling, Profiling and Targeted Advertising.

To make a request concerning these rights, please complete and submit the Privacy Rights Request Form on our website. SIAA will respond to all complete requests within 45 days, subject to extension of that period. Also, there may be a delay in processing a request while we verify that the request is valid and originates from a person authorized to make it.

There may be valid reasons that require or permit us to decline to honor a request, in whole or in part, including legal and regulatory requirements that we retain and process certain information. Also, honoring certain requests may limit or prevent us from providing Services to the Individual about whom the request is made. In those situations, we will notify you in writing within 45 days, subject to extension of that period. You may also contact one of our Privacy Officers for information about and help with those situations.

SIAA will not discriminate against an Individual for exercising these rights or any other rights under Data Privacy Laws, including by not denying Services to that Individual, not providing a different level or quality of Services to that Individual, and not suggesting that Individual will receive a different level or quality of Services.

Selling, Profiling, and Targeted Advertising

SIAA does not engage in Selling, Profiling, or Targeted Advertising, except with respect to tracking technologies as discussed below.

Marketing and TCPA Compliance

From time to time, SIAA may disclose some of your Personal Information to our service providers and/or subcontractors to assist us in our marketing activities. Our service providers and/or subcontractors do not have any right to use the Personal Information we share with them beyond what is necessary to assist us in providing Services to you. If and to the extent we send you any marketing communications via text messages, we do so in compliance with the Telephone Consumer Protection Act (TCPA) and based on your prior express consent (if and to the extent required by TCPA). You may revoke this consent at any time by opting-out of receiving any marketing-related communication via text messages by completing and submitting the Privacy Rights Request Form on our website. You can also change your preferences for receiving our marketing communications from us at any time by following the instructions to unsubscribe specified in our marketing emails. SIAA does not send marketing-related text-messages to any telephone number registered with the National Do Not Call Registry (Registry). For additional information on the Registry, or to register your telephone number(s) with the Registry, please see Federal Trade Commission’s National Do Not Call Registry webpage, which can be found here. Please note that not all of our communications sent via text messages or email are for marketing purposes, and you may continue to receive service messages for our Services (like bills, transactional notices, customer service, etc.) despite you opting-out of receiving marketing-relating communications from SIAA.

Use of Artificial Intelligence

SIAA uses artificial intelligence or AI to process Personal Information and for other purposes, including for the purposes and bases described above and with respect to our Services and Operations. While it would be imprudent to attempt to list every such use of AI, particularly since it is an evolving technology, the following lists some ways that SIAA uses AI to process Personal Information and for other purposes: organize, summarize, analyze, recognize patterns, and identify specific aspects of information; create records, documents, text, images, communications, and similar content generated by AI based on information and prompts input into AI; conduct research; use notetakers and transcribers for meetings, video conferences, and SIAA events; and perform other discrete aspects of our Services and Operations. As a result, the Services provided by SIAA and the information generated by SIAA may be based, in whole or in part, on output from AI.

Video and Audio Recording

SIAA uses technology to facilitate meetings, video conferences, and other SIAA events, including technology that captures video, images, and audio, such as recording devices and AI notetakers and transcribers. By participating in SIAA meetings, video conferences, and events, you consent to SIAA’s recording and processing of video, images, and audio collected during such meetings, video conferences, and events.

Website, Cookies, Tracking Technology, and Third Party Tools

SIAA may collect and generate information about you when you interact with our website, which may include name and contact information (as described above), information about the device you use to interact with our website, and information about your interaction with our website (such as content you view, features you access, sites you view immediately before and after you access our website, content you view on our website, search terms you use on our website, and content in which you have indicated interest).

When you visit SIAA’s website, we may place a cookie (a text file containing a randomly assigned number) or a similar technology on your device so we have the ability to customize the look and feel of the website for you. Cookies remember information about you, your preferences, and your device for a better user experience when visiting the website. Using cookies, we may also collect other information about your use of the website, including your Internet Protocol or IP address, username, session, browser, web pages you view and referring web pages, when you access the website, and general online behavior for performance and marketing purposes.

SIAA may use third-party analytics tracking technologies and tools to collect information about how you use our website, such as the frequency of visits, pages viewed, traffic data, location, referring and exit pages, and error information. These tools may also collect device-specific data, including your IP address, operating system, browser type, and Internet connection details. These tools examine website activities to prepare usage reports, and this information helps us improve our website and enhance user experience. Tracking information will be shared with the third-party analytics provider, which may use that information for its own purposes, potentially including marketing or advertising. While the tracking information we collect through such tools is not sufficient on its own for SIAA to identify you, the third-party analytics provider may be able to combine it with other data it has to identify you.

If you would like to limit the ability of cookies or tracking technologies and tools to track your activity on our website, you can either configure your preferences for cookie settings on our website, or disable cookies in your Internet browser settings, although doing so may impact the performance and effectiveness of our website or other websites.

SIAA may use third party tools to provide Services and for other purposes, and our website may contain links to third party websites. We have no control over the policies and practices of such third-party tools and websites. Please review the applicable policies of such third parties for information regarding their processing of Personal Information.

Duration of Retention

Because the Services that SIAA provides to Client’s vary significantly, the duration we retain Personal Information varies significantly, depending on the types of Services that SIAA provides to particular Client’s, the duration and depth of SIAA’s relationship with the particular Client, and the nature of Personal Information in question. SIAA endeavors to retain Personal Information that it receives from or collects for only as long as is necessary or appropriate to achieve the purposes for which such information was collected, unless a longer retention period is required or permitted by law (such as tax, accounting, or other legal requirements).

Automated Decision Making

SIAA does not use automated decision making or profiling in the Processing of Personal Information and does not make decisions that affect you based on automated decision making or profiling using Personal Information.

Changes to Policy

SIAA reserves the right to change or amend this Privacy Policy at any time and for any reason.

Questions or Concerns

For questions or concerns, please contact our Chief Data Officer as follows.

Names: Anurag Shah

Address: 234 Lafayette Rd, Hampton, NH 03842

Phone: (603) 430-0055

Email: [email protected]

Last Updated: May 5, 2026

 

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