Duncan & Stoker
Commercial Insurance Solutions Inc.

Effective Date

September 18, 2025

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We value your privacy and are committed to protecting your personal information. Duncan & Stoker Commercial Insurance Solutions Inc. (“we,” “our,” or “us”) does not sell or share your information except as described in this policy. This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you use our website, services, or interact with us (collectively, our “Services”), including SMS communications.

This policy complies with applicable data protection laws, including the California Consumer Privacy Act (CCPA) as amended by the California Privacy Rights Act (CPRA), the General Data Protection Regulation (GDPR), other U.S. state privacy laws (e.g., Virginia Consumer Data Protection Act, Colorado Privacy Act), the Telephone Consumer Protection Act (TCPA), and the CAN-SPAM Act.

Information We Collect

We collect the following types of information to provide, maintain, and improve our Services:

• Personal Information: Information you provide, such as name, email address, phone number, mailing address, payment details (e.g., credit card information), insurance policy details, and other data submitted through forms, applications, or communications.

• Usage Data: Automatically collected data about your interactions with our Services, including IP address, browser type, device information (e.g., operating system, unique device identifiers), pages visited, time and date of visits, and browsing behavior.

• Cookies and Tracking Technologies: Data collected via cookies, web beacons, pixels, and similar technologies to enhance user experience, analyze trends, and administer the site. We use session cookies (temporary) and persistent cookies (stored on your device) for essential functions, analytics, and personalization. You can manage cookies through your browser settings or our cookie consent tool (if applicable).

• Sensitive Information: For insurance services, we may collect sensitive data such as financial account details, health-related data (if relevant to policies), or government-issued identifiers (e.g., Social Security Number), only with your explicit consent or as required for service delivery.

• SMS-Specific Information: If you opt in to receive SMS communications, we collect your phone number and related metadata (e.g., time of opt-in, opt-out status) to manage text messaging services.

We collect only the information necessary for the purposes outlined in this policy.

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How We Use Your Information

We use your information to:

• Provide, operate, maintain, and improve our Services, including processing insurance quotes, policies, claims, and customer support.

• Process payments, fulfill transactions, and manage billing through secure payment processors.

• Communicate with you via email, phone, or SMS, including:

  • Updates on policy information, payments, coverages, and renewals.

  • Marketing messages (with your explicit consent, where required).

  • SMS notifications about policy updates, renewals, or promotions (only with your prior express written consent per TCPA requirements).

• Analyze usage patterns to improve our website and Services.

• Detect, prevent, and address fraud, security breaches, or technical issues.

• Comply with legal and regulatory requirements, including insurance regulations, tax obligations, TCPA, CAN-SPAM Act, and court orders.

• Conduct internal business activities, such as auditing, research, and data analysis.

We do not use your information for automated decision-making or profiling that produces legal effects or significant impacts without human oversight or your consent.

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SMS Communications

If you opt in to SMS communications, we may send you text messages for:

• Policy updates, renewals, or claims notifications.

• Marketing or promotional offers (with your prior express written consent).

• Transactional messages (e.g., payment confirmations).

Consent and Opt-Out:

• You must provide express written consent before receiving SMS messages. Consent is obtained via clear opt-in mechanisms (e.g., website forms, text-to-join keywords).

• You may opt out of SMS communications at any time by replying “STOP” to any message or contacting us directly. After opting out, you will receive a confirmation message and no further texts unless you opt in again.

• Message frequency varies based on your interactions and preferences. Standard message and data rates may apply, as determined by your mobile carrier.

• We comply with TCPA and carrier requirements to ensure transparent and consensual SMS communications.

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Data Sharing and Disclosure

We Do Not Sell Your Data: We do not sell your personal information for monetary or other valuable consideration, as defined under CCPA/CPRA or similar laws.

Sharing with Service Providers: We share your information only as necessary with trusted third-party service providers, such as:

• Payment processors (e.g., Stripe, PayPal) for transaction handling.

• Cloud storage providers (e.g., AWS) for data hosting.

• Analytics tools (e.g., Google Analytics) for usage insights.

• Insurance carriers or underwriters for policy issuance.

• SMS service providers (e.g., Twilio) for text messaging services.

These providers are contractually bound to use your data only for the services they provide to us and to implement appropriate security measures.

Legal and Compliance Disclosures: We may disclose information if required by law, such as in response to subpoenas, court orders, or regulatory inquiries, including compliance with TCPA and CAN-SPAM Act requirements. We may also share data to protect our rights, safety, or property, or that of our users or others.

Business Transfers: In the event of a merger, acquisition, or sale of assets, your information may be transferred, subject to equivalent privacy protections.

With Your Consent: We may share information in other ways with your explicit consent.

We do not share sensitive personal information or SMS data without your consent, except as permitted by law.

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International Data Transfers

If you are located outside the United States, your information may be transferred to and processed in the U.S. or other countries where our service providers operate. We implement safeguards, such as Standard Contractual Clauses (under GDPR) or equivalent measures, to protect your data during transfers.

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Data Retention

We retain your information only as long as necessary to fulfill the purposes outlined in this policy or comply with legal obligations:

• Account and policy information is retained for the duration of your relationship with us and up to 7 years thereafter for tax, insurance, and regulatory compliance.

• Usage data is retained for up to 2 years for analytics.

• Payment details are retained only until the transaction is complete, unless required for ongoing billing.

• SMS-related data (e.g., phone numbers, opt-in records) is retained for the duration of your consent or as required by TCPA and carrier regulations.

After the retention period, we securely delete or anonymize your data. You may request deletion earlier, subject to legal exceptions.

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Your Rights

Depending on your location and applicable laws, you have the following rights:

• Access: Request a copy of your personal information.

• Correction: Update or correct inaccurate or incomplete data.

• Deletion: Request deletion of your data, subject to legal retention requirements.

• Opt-Out of Sale/Sharing: Opt out of targeted advertising or data sharing for analytics (if applicable). We do not sell data, as defined by CCPA/CPRA.

• Restriction/Objection: Object to or restrict certain processing, such as marketing or SMS communications.

• Portability: Receive your data in a structured, machine-readable format (under GDPR or CCPA).

• Withdraw Consent: Revoke consent for processing (e.g., SMS or marketing communications).

• Non-Discrimination: We will not discriminate against you for exercising your rights.

SMS-Specific Rights:

• Opt out of SMS communications by replying “STOP” or contacting us.

• Request access to or deletion of your SMS-related data.

For CCPA/CPRA residents: You may designate an authorized agent to make requests on your behalf. We respond to verifiable requests within 45 days (extendable to 90 days). EU residents may lodge complaints with their local data protection authority.

To exercise your rights, contact us using the details below. We may require identity verification.

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Data Security

We implement reasonable administrative, technical, and physical security measures, including encryption (e.g., SSL/TLS for data in transit), access controls, firewalls, and regular security audits. SMS communications are sent via secure platforms compliant with carrier requirements. No method of transmission or storage is 100% secure, and we cannot guarantee absolute security. In the event of a data breach, we will notify affected individuals as required by law.

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Third-Party Links and Services

Our Services may include links to third-party websites, applications, or services (e.g., insurance partners, payment gateways, SMS providers). We are not responsible for their privacy practices. Review their privacy policies before engaging.

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Children’s Privacy

Our Services are not directed to children under 13 (or 16 under GDPR). We do not knowingly collect personal information from children under 13 without verifiable parental consent, per the Children’s Online Privacy Protection Act (COPPA). If we learn we have collected such data without consent, we will delete it promptly. Parents or guardians may contact us to review or delete their child’s information.

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Changes to This Policy

We may update this Privacy Policy to reflect changes in our practices, technology, or legal requirements. We will notify you of material changes via email, SMS (if applicable), or a prominent notice on our website at least 30 days before they take effect (where required). Your continued use of our Services after the effective date constitutes acceptance of the updated policy.

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Contact Us

For questions, concerns, or to exercise your rights, contact our Data Privacy Officer:

• Email: Customercare@dsinssolutions.com

• Phone: 425-620-1445

• Mailing Address: Duncan & Stoker Commercial Insurance Solutions, PO Box 29197, Bellingham, WA 98228

• Location Address: 5989 Everson Goshen Rd, Bellingham, WA 98226

To opt out of SMS communications, reply “STOP” to any message or contact us directly.

By using our Services, you acknowledge that you have read, understood, and agree to this Privacy Policy. If you do not agree, please do not use our Services.