Last updated: January 31, 2024

Introduction

This Privacy Policy explains how DIS, LLC, doing business as Independent Wholesale Advocates, collects, uses, and discloses your personal information. Please take a moment to familiarize yourself with our privacy practices and let us know if you have questions.

Table of Contents

Scope of this Policy

This Policy applies to personal information collected from your interaction with the Independent Wholesale Advocates website and Services, including requesting quotes. We treat any data that identifies you, or reasonably can be linked to you, as “Personal Information.” De-identified or aggregated data is not Personal Information. This Policy does not apply to information collected by third parties or information transmitted to insurance carrier partners at your request.

By accessing or using our Website or Services, you agree to this Policy and DIS, LLC’s Terms of Use. This Policy may change from time to time. If you do not agree with this Policy, then you should not use our Website or Services. Your continued use of our Website or Services after we make changes is deemed to be acceptance of those changes, so please check the Policy periodically for updates. 

Personal Information and Sensitive Personal Information (SPI) We Collect

We collect several types of Personal Information, including certain Sensitive Personal Information (“SPI”),* to provide you with our Website and Services, including:

  • Contact Information, such as name, postal address, e-mail address, and telephone number.
  • Personal Identifiers, such as social security number*, driver’s license* or state identification number, insurance policy number, date of birth, employment history or medical information* when you apply for Services.
  • Financial Information, such as your bank account number, credit card number, basic mortgage or leasing details or other financial information when you purchase Services.
  • Audio Information, such as call recordings of your phone interactions with us that are for training purposes.
  • Professional, Employment-related or Educational Information, which is collected to provide our Services.
  • Commercial Information, such as records of personal property, details relating to your personal property, and information relating to the Services you purchased and your purchasing habits, histories or tendencies.
  • Internet or Similar Network Activity, such as information about your internet connection, location, the equipment you use to access our Website, and usage details.
  • Location Information, which is collected when you access our Website.
  • Property Related Information, which we may collect when you use our Website or Services to research and view the subject property
  • Inference-Based Information, which is collected based on the above information to create a profile about your preferences and characteristics in order to offer or provide you with our Services.

How We Obtain Your Personal Information

  • From You: We obtain most of the Personal Information that we collect about you from you when you Interact with our Website or Services, including when you: (1) contact and communicate with us, including by providing information over the phone, or filling in forms on our Website; (2) request a cash offer for your home (3) respond to surveys that we might ask you to complete for research and quality control purposes; or (4) navigate through the site (e.g. usage details, IP addresses and information collected through cookies and other tracking technologies). 
  • From Public Data Sources: We may obtain information from public data sources regarding the property you are seeking a cash offer for.
  • From Service Providers: Third party service providers may supply us with information needed for core aspects of our Services, which allows us to provide a better service experience to our clients. These third-party service providers include, but may not be limited to, data processors & aggregators, and public record databases.
  • From Carrier Partners: Our carrier partners and other service providers may supply us with information in connection with our provision of Services. 

How We Use Your Information

We use Personal Information to: 

  • Provide our Services: We use Personal Information to (1) present our Website and its contents to you, (2) provide you with information regarding cash offers; (3)provide you with recommendations for product or service referrals that you request from us.
  • Communicate with You: We use Personal Information to respond to communications, contact you about your transactions, promote our Services, provide other relevant information and request information or feedback. We may also use your information for our direct marketing purposes, such as to contact you about additional insurance products that may be of interest to you. If you do not want us to use your information in this way, please contact us.  Note that you can always unsubscribe from our commercial or promotional email or text message campaigns by clicking unsubscribe in those email messages or by request or replying “STOP” to opt-out of those text messages.   
  • Personalize Your Experience: We utilize Personal Information regarding your use of our Website and Services to personalize and enhance your experiences.
  • Enable Security or Fraud Prevention: We use Personal Information to: (1) prevent, detect, protect against, or respond to security incidents, and (2) preserve the integrity or security of our systems.
  • Conduct Internal Research: We use Personal Information to conduct internal research to develop, improve or repair our products, services or technology. 
  • Maintain Legal Compliance: We may use Personal Information to comply with applicable law or to comply with a lawful government request. 

Our Sharing of Personal Information

We may share Personal Information with service providers who act on our behalf, our carrier partners, or others operating at your direction or where legally necessary or appropriate. We do not share Personal Information with third parties for their own marketing purposes. 

  • Subsidiaries and Legal Affiliates: We share information with our subsidiaries and legal affiliates. 
  • Service Providers: We engage third parties to act as our service providers and perform certain tasks on our behalf in connection with delivering you our products and services. The tasks performed by service providers include: (1) processing and storing Personal Information, (2) assisting with marketing communications and advertising, (3) processing credit card or other financial charges, and (4) providing technology services. We may provide service providers with all types of Personal Information described above. We take reasonable steps to ensure that our service providers are contractually obligated to keep Personal Information confidential and only utilize the Personal Information as permitted. 
  • Partners: We may partner with third parties to provide services and other offerings. For example, we may share the types of Personal Information described above with our insurance carrier partners and other insurance providers for the provision of Services. Upon your request, we may also share your information with our other partners to provide products or services of interest to you. This excludes your opt-in consent to receive text messages from DIS, LLC – we will not share or transfer this consent to third parties for text communications.
  • Other Legal Purposes: We also may share Personal Information: (1) with your consent, (2) to respond to subpoenas, court orders, or other legal process or otherwise as required or allowed by law or the competent governmental or judicial authorities; (3) to cooperate with law enforcement, government or regulatory entities, and safety or investigation authorities; (4) to establish or preserve a legal claim or defense; (5) if we believe disclosure is necessary or appropriate to protect the rights, property, or safety of DIS,LLC, our clients, our employees, our franchise partners, or others; or (6) as part of a corporate restructuring, sale of assets, merger or divestiture. 

We have no actual knowledge of selling or sharing Personal Information of minors under 16 years of age to non-affiliated third parties without affirmative consent.   

Collection and Use of Employment and Franchise Partner Information

This Policy also applies to current and prospective DIS, LLC employees and franchise partners, including in respect of any Personal Information shared to apply for a career at DIS, LLC or to purchase a DIS, LLC franchise. We may use the Personal Information that we collect about you or that you provide to us to process applications for employment or to own a franchise and may also collect commercial and professional or employment related information, including education information, for employment and franchising purposes and to support the insurance licensing process for our franchise partners. We may also disclose your information for a business purpose if we believe disclosure is necessary or appropriate to protect the rights, property, or safety of DIS, LLC, our clients, our employees, our franchise partners, or others. For example, we may exchange such information with other companies and organizations for the business purposes of fraud protection and credit risk reduction.

Use of Cookies and Targeted Advertising

As you navigate through and interact with our Website, we collect information through the use of “cookies” and data analytics tools and third-party technologies to understand how you navigate through the Website so that we may continue to improve the DIS, LLC client experience. A cookie is a small file placed on the hard drive of your computer designed to store basic information and to help websites and apps recognize your browser. You may refuse to accept browser cookies by activating the appropriate setting on your browser. However, if you select this setting, you may be unable to access certain parts of our Website. Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies when you direct your browser to our Website.

We or our marketing and advertising service providers may use information about your activities on our Website or other websites to help tailor our advertisements or offers to what may interest you. The information is collected using cookies and web beacons (also called pixel tags) and similar technology (collectively, “tracking technologies”). Information we collect automatically about you may be combined with other personal information we collect directly. The information collected in this manner includes:  

  • The website from where you accessed our Website, where you went to when you left our Website, how frequently you visit our Website, when and whether you click the links contained in pages you visit on our Websites, the links you click and ads you view, or your location when you access our Website, 
  • Information about the device you use, such as your IP address, browser type, Internet service provider, platform type, device type/model/manufacturer, operating system, date and time stamp, a unique ID that allows us to uniquely identify your browser, mobile device or your account (including, e.g., a persistent device identifier or an Ad ID), and other similar information, and 
  • Analytics information collected by us or via approved third party analytics tools such as search engines, providers of measurement and analytics services, social media networks, and advertising companies, help us measure traffic and usage trends for our Website and to understand more about the demographics and behaviors of our users. Third parties use cookies in the process of delivering content, including ads relevant to your interests, to measure the effectiveness of their ads, and to perform services on behalf of DIS, LLC.

Security of Your Personal Information

We have implemented reasonable and appropriate measures designed to secure your personal information from accidental loss and from unauthorized access, use, alteration and disclosure.  

The safety and security of your information also depends on you. Where we have given you (or where you have chosen) a password for access to certain parts of our Website, you are responsible for keeping this password confidential. We ask that you not share your password with anyone. 

Unfortunately, the transmission of information via the internet is never completely secure. Although we take reasonable precautions to protect your Personal Information, we cannot guarantee the security of your information, including against unauthorized intrusions or acts by third parties. Any transmission of personal information by you over the internet is at your own risk. 

Your Rights and Choices Regarding Your Data

All Users 

  • Email Subscriptions: You can always unsubscribe from our commercial or promotional email campaigns by clicking unsubscribe in those messages. We will still send you messages about your insurance and business transactions with DIS, LLC.
  • Text Messages: You can opt out of receiving text message campaigns by following the opt-out instructions sent to the mobile device receiving the text messages or by emailing an opt-out request to this email. Please note that opting out of receiving text messages may negatively impact your use of DIS LLC services.

Residents of Certain States

Residents of the following states have comprehensive privacy laws enacted with the additional rights below: California, Colorado, Connecticut, Utah and Virginia. To exercise your privacy rights via our Website, please fill in the appropriate webform here: https://www.independentwholesaleadvocates.com/consumer-privacy-requests/

  • Right to Know:You have the right to know and see what data we have collected about you over the past 12 months, including:
    • The categories of Personal Information we have collected about you.
    • The categories of sources from which the Personal Information is collected.
    • The business or commercial purpose for collecting your Personal Information.
    • The categories of third parties with whom we have shared your Personal Information.
    • The specific pieces of Personal Information we have collected about you.
  • Right to Delete:You have the right to request that we delete the Personal Information we have collected from you (and direct our service providers to do the same). There are several exceptions, however, that include, but are not limited to, when the information is necessary for us or a third party to do any of the following:
    • Complete your transaction. 
    • Provide you with a good or service.
    • Perform a contract between us and you.
    • Protect your security and prosecute those responsible for breaching it.
    • Fix or debug our system.
    • Comply with state and federal laws including, but not limited to, the California Insurance Code.
    • Comply with a legal obligation.
    • Make other internal or lawful uses of the information that are compatible with the context in which you provided it.
  • Right to Correct: If you are California, Colorado, Connecticut, or Virginia resident, you have the right to correct inaccurate Personal Information. 
  • Right to Opt Out: Of the sale or sharing of your personal information for targeted advertising.
  • Right to Appeal: If you are a Colorado, Connecticut or Virginia, resident, you also have the right to appeal our decision to process the foregoing data requests. For Virginia and Connecticut residents, DIS, LLC will have 60 days to respond in writing to your appeal, and if denied, will provide you with a method to contact the Attorney General to submit a complaint. For Colorado residents, DIS, LLC will have 45 days to respond in writing to your appeal. 
  • No Discrimination: DIS, LLC will not discriminate against you for exercising any of the above rights.
  • Retention Periods: We retain your information for as long as necessary for the business or commercial purpose(s) for which we collected it, such as to provide you with our Services or to comply with contractual obligations to our carrier partners and applicable state and federal laws. We will delete your data once we are no longer legally or contractually obligated to retain.   

 Exercising your State Specific Comprehensive Privacy Rights 

 To submit a data privacy request and request access to or deletion of your personal information, or to exercise any other data rights under California, Colorado, Connecticut, Utah or Virginia law, please contact us using one of the following methods:

  • Email: you may contact us at here to exercise your privacy rights. Please include your full name, email address, and the phone number associated with your insurance policy, along with why you are writing.
  • Phone: you may leave a voicemail by calling 1-888-928-0031 to exercise your privacy rights. Please include your full name and the phone number associated with your insurance policy, along with why you are calling.
  • Mail: you may mail a letter to exercise your privacy rights (see Contact Us below). Please include your full name, phone number, and the details of your request
  • Methods to Opt-Out of Sharing of Personal Information for Targeted Advertising: To opt out of the sale or sharing of your personal information for targeted advertising go to the “Do Not Sell or Share My Personal Information” link on our Website footer. To limit interest-based advertising generally click here to visit the Digital Advertising Alliance and/or select the “limit ad tracking” or equivalent setting in your mobile device settings.  
  • Verification: We must verify the identity of any consumer that exercises his or her right to know or right to delete (described above). To verify the identity of a consumer, we must have enough information internally about that consumer. If you submit a data privacy request using one of the methods described above, then we will call you to verify your identity by confirming certain personal information that we have in our database about you. If we are unable to verify your identity, then your data privacy request will be denied.
  • Agent:   You may designate an authorized agent to submit a request on your behalf by providing said agent with the contact information listed above and responding to an e-mail asking you to send a verification response.   Your authorized agent may need to provide documentation supporting the agent’s authority to make the request on your behalf.  We may also require you to verify your identity directly with us and confirm the request before we process it.
  • Response of Timing and Format: We strive to respond to all verifiable consumer requests within the earlier of 45 days of receipt or as otherwise required by law. If we require more time, then we will inform you of the reason and extended response time in writing. We will deliver our written response by e-mail. If you do not have an e-mail address on file with us, then we will deliver our written response to you by mail.
  • Cost: We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded or the request is the consumer’s second request during the same 12-month period, as permitted by law. If we determine that your request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.

Children 

Our website is not intended for children under 13 years of age. We understand the importance of taking extra precautions to protect the privacy and safety of children. Accordingly, we do not knowingly collect, use or disclose personal information from children under 13. If you are under 13, do not use or provide any information on our Website or provide any information about yourself to us, including your name, address, telephone number, e-mail address, or interests. If we learn we have collected or received personal information from a child under 13 without verification of parental consent, we will delete that information as soon as possible. If you believe we might have any information from or about a child under 13, please contact us here.

Changes to this Policy

We will post any material changes we make to our Policy on this page. The date the Policy was last revised is identified at the top of the page. If we make material changes to how we treat our users’ personal information, we will notify you through a notice on the Website home page or by some other method of communication like email. You are responsible for periodically visiting our Website and this Policy to check for any changes. Your continued use of our Website following the posting of changes constitutes your acceptance of such changes. 

Changes were made to incorporate Utah’s Consumer Privacy Act.

Contacting Us

We’ve done our best to describe our Policy in plain English. However, if you have any questions or comments, please let us know: 

USPS or Overnight MailDIS, LLC
4848 Lemmon Avenue 100-126 Dallas,
TX 75219
Toll Free Phone Number(470) 705-4535
Email[email protected]
Onlinehttps://www.independentwholesaleadvocates.com/consumer-privacy-request/