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Specialty Program Group LLC Privacy Statement

(Updated September 1, 2022)

Information Collection

We are generally unable to perform insurance brokerage or other insurance industry services on your behalf without collecting, using or disclosing your personal information. Typically, you will provide this required information to us directly within insurance applications or in connection with other communications or indirectly depending on your relationship with us – whether as an individual client, agent, broker, claimant, employee of our corporate, program or association clients, family member of any of such employees or other person who SPG employs or with whom we may do business. For example, 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.


We generally collect the amount and types of personal information that are required for us to perform 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. This and other information may 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;
  • 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;
  • your account activity and premium payment history;
  • 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;
  • details about your business and status as an insurance agent, broker or other intermediary; and
  • passive tracking information from our website or the Internet, including information obtained through the use of internet “cookies.”

Sharing of Information

We generally share your personal information to perform services on your behalf and provide you with the insurance products and services you expect from us. Information technology and other support service providers with which we maintain an arrangement may also have access to your personal information to allow us to operate our business and to provide you with our services. We do not sell your personal information to third parties, other than 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 share 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 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 (or for whom the information was provided); to obtain insurance (or similar products) on your behalf (or for whom the information was provided) 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; 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; 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 marketing purposes so that we may offer you our products and services, including through the use of targeted or similar advertising on the internet.
  • 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’ or non-affiliates’ marketing purposes so that they may offer you their products and services.
  • for other purposes as may be permitted by law.

To Limit Our Sharing of Information

To limit our sharing 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:

  • Calling us at 908-790-6749.
  • Emailing us at eli.orozco@specialtyprogramgroup.com and indicating your full name, email, zip code and whether you want to limit any or all of the following:
    • Sharing of information about your creditworthiness with our affiliates for their everyday business purposes
    • Allowing of our affiliates to use your personal information to market to me
    • Sharing of my personal information with nonaffiliates to market their products and services to me

Other Important Website Information

Our website may contain links to third party sites that are not sites of SPG affiliates or divisions. 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 policy of those other websites carefully. We are not responsible for those third party sites. Links to outside sites do not constitute or imply endorsement by us of the linked site or any material displayed on those sites.

Our website is not intended for children under 13 years of age. No one under age 13 may provide any information through our website, and we do not knowingly collect personal information from children under 13. If you are under 13, 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 user name you may use. If we learn we have collected or received personal information from a child under 13 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 13, please contact us at the mailing address shown beneath the heading “Your Right to Review Your Information”.

Information Security Purposes

We maintain technical and organizational security measures reasonably designed to protect the security of your personal information against loss, misuse, unauthorized access, disclosure or alteration. 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 contact information set forth in this statement. In the event of a breach impacting your personal information, we intend to provide you with notification to the extent required by applicable law.

Updates To Statement

From time to time we may change our privacy practices. The latest version of this statement will be posted on our website at the page it has historically appeared. Sometimes there may be a material change to this statement that we wish to apply retroactively. If so, we will notify you and obtain your consent to the extent required by law. Your continued use of our website following the posting of changes constitutes your acceptance of such changes with respect to your use of our website.

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 statement, you can write us at:


Chief Legal Officer
Specialty Program Group LLC
150 N Riverside Plaza, 17th Floor
Chicago, IL 60606


Please include your name, address, telephone number and email address whenever you contact us, including by email. This helps us handle your request correctly.

Privacy Statement Organizations

Each of the Specialty Program Group LLC Privacy Statement and Privacy Notice for California Residents is provided on behalf of Specialty Program Group LLC and the following organizations (as well as its and their divisions):
• Avant, LLC
• The Advantage Association, LLC
• Avant Brokerage, LLC
• Avant Care, LLC
• Avant Leasing Services, LLC
• Avant Specialty Claims, LLC
• Avant Underwriters, LLC
• CS Risk Healthcare, LLC
• Independent Contractor Specialty Group, LLC
• Independent Contractor Service Providers Association, LLC
• National Association of Independent Contractor Professionals, LLC
• SafeHerb, LLC
• HDOL LLC
• MGU of the West Insurance Services, Inc.
• SBR Administrative Services, LLC
• SBR Services, LLC
• SBR Analytics, LLC
• American Medical Professional Alliance, Inc.
• Biz Choice Last Mile Logistics Purchasing Group
• Boater Rewards Association, PBC
• National CPA Risk Purchasing Group, Inc.
• SPG Crane & Boom Truck Risk Purchasing Group, Inc.
• SHEL Risk Purchasing Group Association

Privacy Notice for California Residents

Effective Date: February 7, 2020
Last Reviewed on: February 7, 2020

This Privacy Notice for California Residents (this “Notice”) supplements the information contained in the Specialty Program Group LLC International Privacy Statement (the “Statement”) and is provided on behalf of Specialty Program Group LLC and its subsidiaries listed here . We adopt this Notice to comply with the California Consumer Privacy Act of 2018 (the “CCPA”) and any terms defined in the CCPA have the same meaning when used in this Notice (unless separately defined in this Notice). This Notice applies solely to residents of the State of California who do business with us directly and/or visit our website (the “Website”). This Notice does not apply to employment-related personal information about our employees, job applicants, contractors or similarly situated individuals. This Notice also does not apply to personal information about employees, owners, directors, officers, or contractors of any of our commercial clients to the extent the information is collected in connection with our relationship with any commercial client (“B2B personal information”).

Information We Collect

We collect information that identifies, relates to, describes, references, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer, household, or device (“personal information”). Personal information does not include:

  • Publicly available information from government records.
  • Deidentified or aggregated consumer information.
  • Information excluded from the CCPA’s scope, like:
    • health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and the California Confidentiality of Medical Information Act (CMIA) or clinical trial data; and
    • personal information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FCRA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA) and the Driver’s Privacy Protection Act of 1994.
      In particular, we have collected the following categories of personal information from consumers within the last twelve (12) months:
CATEGORY
EXAMPLES
SELECTED
A. Identifiers
A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, Social Security number, driver's license number, passport number, or other similar identifiers.
YES
B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).
A name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver's license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information. Some personal information included in this category may overlap with other categories.
YES
C. Protected classification characteristics under California or federal law.
Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information).
YES
D. Commercial information.
Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.
YES
E. Biometric information.
Genetic, physiological, behavioral and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as, fingerprints, faceprints and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns and sleep, health, or exercise data.
NO
F. Internet or other similar network activity.
Browsing history, search history, information on a consumer's interaction with a website, application, or advertisement.
YES
G. Geolocation data.
Physical location or movements.
YES
H. Sensory data.
Audio, electronic, visual, thermal, or similar information.
NO
I. Professional or employment-related information.
Current or past job history.
YES
J. Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)).
Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records.
NO
K. Inferences drawn from other personal information.
Profile reflecting a person's preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities and aptitudes.
NO

We obtain the categories of personal information listed above from the following categories of sources:

  • Directly from you – for example, from insurance applications or in connection with your other communications with us.
  • From third parties – for example, from insurance carriers and other industry service providers, and other third parties with which you maintain a relationship, such as an employer, financial service or medical or health providers, or any industry provider from which we purchase or acquire industry assets or operations. This may occasionally include referral sources.
  • Indirectly from you – for example, from observing your actions on our Website, including through the use of “cookies” as described on our Website, or as may otherwise be developed over time based on your interactions with us.

Use of Personal Information

We may use or disclose the personal information we collect for one or more of the following purposes:

  • To fulfill or meet the reason you provided the information and for our everyday business purposes – for example, to obtain 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; and to make reports to credit bureaus. We may also save your information to facilitate new quotations or placements.
  • To comply with, or exercise rights under, applicable law – for example to make required or advisable reports to insurance regulatory, law enforcement or other similarly situated 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.
  • To market to you products and services, including through the use of targeted or similar advertising on the internet.
  • To provide or receive shared organizational services.
  • As described to you when collecting your personal information or as otherwise set forth in the CCPA.
  • To evaluate or effect 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 is among the assets evaluated or transferred.

Sharing of Personal Information

We generally share your personal information to perform services on your behalf and provide you with the insurance products and services you expect from us. We may disclose your personal information to a third party, including for any purpose identified within this Notice (see also “Use of Personal Information”). We share your personal information with the following categories of third parties:

  • Service providers.
  • Insurance carriers and other industry service providers.
  • Other third parties with which you or we maintain a relationship regarding your insurance.
  • Affiliates.

Disclosures of Personal Information for a Business Purpose

In the preceding twelve (12) months, we have disclosed the following categories of personal information for a business purpose:

Category A: Identifiers.
Category B: California Customer Records personal information categories.
Category C: Protected classification characteristics under California or federal law.
Category D: Commercial information.
Category F: Internet or other similar network activity.
Category G: Geolocation data.
Category H: Sensory data.
Category I: Professional or employment-related information.

We disclose your personal information for a business purpose to the following categories of third parties:

  • Service providers.
  • Insurance carriers and other industry service providers.
  • Other third parties with which you or we maintain a relationship regarding your insurance.

Sales of Personal Information

In the preceding twelve (12) months, we have not sold personal information.

Your Rights and Choices

The CCPA provides California residents with specific rights regarding their personal information. This section describes your CCPA rights and explains how to exercise those rights.

Access to Specific Information and Data Portability Rights

You have the right to request that we disclose certain information to you about our collection and use of your personal information over the past twelve (12) months. Once we receive and confirm your verifiable consumer request (see “Exercising Access, Data Portability and Deletion”), we will disclose to you:

  • The categories of personal information we collected about you.
  • The categories of sources for the personal information we collected about you.
  • Our business or commercial purpose for collecting or selling that personal information.
  • The categories of third parties with whom we share that personal information.
  • The specific pieces of personal information we collected about you (also called a data portability request).
  • If we sold or disclosed your personal information for a business purpose, two separate lists disclosing:
    • sales, identifying the personal information categories that each category of recipient purchased; and
    • disclosures for a business purpose, identifying the personal information categories that each category of recipient obtained.

We do not provide these access and data portability rights for B2B personal information.

Deletion Request Rights

You have the right to request that we delete any of your personal information that we collected from you and retained. Once we receive and confirm your verifiable consumer request (see “Exercising Access, Data Portability and Deletion”), we will delete your personal information from our records, unless an exception applies. We may deny your deletion request for other reasons described in the CCPA. We do not provide these deletion rights for B2B personal information.

Exercising Access, Data Portability and Deletion Rights

To exercise the access, data portability and deletion rights described above, please submit a verifiable consumer request to us by:

Only you, or someone legally authorized to act on your behalf, may make a verifiable consumer request related to your personal information. You may also make a verifiable consumer request on behalf of your minor child. To designate an authorized agent, please contact us by email at the email address shown above.
You may only make a verifiable consumer request for access or data portability twice within a 12-month period. The verifiable consumer request must:

  • Provide sufficient information as we may request that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative of such person, which may include personal and/or commercial identifiers, such as an insurance policy number. Depending on the sensitivity of the information you are requesting, we may ask for additional information to verify your identity.
  • Describe your request with sufficient detail that allows us to properly understand, evaluate and respond to it.

We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you. We will only use personal information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.

Response Timing and Format

We endeavor to respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time, we will inform you of the extension period.

Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request’s receipt. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your personal information that is readily useable and should allow you to transmit the information from one entity to another entity without significant hindrance.

We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.

Non-Discrimination

We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not:

  • Deny you goods or services.
  • Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.
  • Provide you a different level or quality of goods or services.
  • Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.

Other California Privacy Rights

California’s “Shine the Light” law (Civil Code Section § 1798.83) permits users of our Website who are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please write us at the mailing address shown beneath the heading “Contact Information”.

Changes to this Notice

We reserve the right to amend this Notice at our discretion and at any time. When we make changes to this Notice, we will post the updated notice on the Website and update the Notice’s effective date. Your continued use of our Website following the posting of changes constitutes your acceptance of such changes with respect to your use of the Website.

Contact Information

If you have any questions or comments about this Notice, the ways in which we collect and use your personal information described herein and in the Statement, your choices and rights regarding such use, or wish to exercise your rights under California law, please contact us at:

Phone: 908-790-6749
Website: specialtyprogramgroup.com
Email: christopher.lamitola@specialtyprogramgroup.com .

Postal Address:
Chief Legal Officer
Specialty Program Group LLC
150 N Riverside Plaza, 17th Floor
Chicago, IL 60606

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