1. Introduction

This Privacy Policy (“Privacy Policy”) details how Mulberri, Inc., (“Mulberri”, “we”, “our” or “us”) collect, share, and otherwise process information relating to individuals using our website (mulberri.io), platform, mobile application, and modules (collectively “Website”) when we provide insurance related services and products (collectively “Services”), as well as when you call, email, or interact with us. Any reference to “you” means any person using our Services or submitting any data or information on our Website. If any of the terms or conditions in this Privacy Policy are unacceptable to you, please do not use the Website or provide us with any Personal Information.

2. Personal Information

“Personal Information” is subject to definition by applicable federal and state law, but in general is information that identifies, describes, is reasonably capable of being associated with, or could reasonably be linked with a particular person.

3. Collection of Your Information

(a) Information you provide to us.

We may collect information about you in order to provide our Services, including, but not limited to, providing you with the insurance products and services we offer. This may include the following information:

• Your name; telephone number; home address; employment address; email address (both work and personal); date of birth; gender; any online profile you may have, including your Facebook, LinkedIn, or Google+ accounts; your social security number, driver's license number, financial data, marital status, employment history, payroll information, and educational background.

• Insurance claims information.

• Information associated with your social media or other online account, such as your public profile and email address connected to those accounts, when you access our Website through such an account.

• Your activity on our Website, such as preferences, page views, order information, or information provided when requesting insurance quotes, submitting applications, customer services, claims, or surveys.

• Information collected using automated technologies, including web server logs that compile IP addresses, web beacons, and cookies.

• Background of business owners, including criminal history; bankruptcy, tax, or credit liens; loss reports, history of lawsuits; and information relating to prior and current insurance.

• Any other information you provide or submit to us.

You agree to only submit information and Personal Information, if applicable, which is current and accurate, and you agree to update the information and inform us of any relevant changes to our contact information below.

For any Personal Information you provide, we may collect or verify the same or similar information from our affiliates and other third parties, such as insurers, brokers or agents, credit agencies (where allowed), departments of motor vehicle and driver licensing, financial institutions, healthcare providers, and other sources.

(b) Personal Information we collect

We may collect certain information when you visit our Website or use our Services, which may also be categorized as Personal Information, such as your IP address, browser information, operating system information, mobile devise information, pages accessed, time and date of visits, and referring website, application, or service, including the relevant search queries that led you to our Website.

4. How We Use Your Personal Information

We collect information related to you, including Personal Information as described below, which may include:

• Enhance or improve the functionality of our Websites and Services, including, but not limited to underwriting, quoting, and transacting insurance services.

• Process transactions for the Services we offer.

• Communications with you.

• Send email messages and updates about our Website and Services.

• Contact you regarding our Services if you expressly provide us with your contact information in connection with our Services.

• Provide you with information and/or services you request.

• Determine eligibility for our Services and process applications for insurance products and services.

• Inform you regarding products and Services we may offer.

• Analyze claims data or other data.

• Obtain and update insurance or credit information, if applicable with appropriate third parties, such as credit reporting agencies.

• Conduct employee and other training.

• Perform market analysis, analytics, advertising and marketing of products and services to you, or to facilitate advertising and marketing.

• Fulfill contractual obligations.

• Comply with or satisfy a legal or regulatory requirement.

5. With Whom Do We Share Your Personal Information

We may disclose your information, including Personal Information, as follows:

• To process the Services we provide, including, but not limited to insurers, reinsurers, insurance intermediaries, brokers, underwriters, fraud detection agencies, our advisers, loss adjusters, lawyers, accountants, and others involved in the claims handling process.

• To enforce our Website policies; comply with the law or legal process; in connection with an investigation of suspected or actual illegal activity; or to investigate a complaint or security threat.

• To a third party in the event of any reorganization, merger, sale, joint venture, assignment, transfer, or other disposition of all or any portion of our business, assets, or stock.

• For any other purpose where you have provided your consent.

• To our service providers which are contractually restricted from using or disclosing your information except as necessary to perform services on our behalf or to comply with legal requirements.

6. Duration We Retain Your Personal Information

We retain Personal Information only for as long as reasonable, necessary or required by applicable law and regulatory requirements.

7. Data Protection and Security

We take commercially reasonable measures to protect the information you submit via our Website against loss, theft, and unauthorized use, disclosure, or modification. Examples of these security mechanisms include but are not limited to, where applicable, password-protected access, high security public/private keys, encryption on processed data, and TLS encryption to protect transmission of data. However, no security system is totally impenetrable, including ours. Despite our commercially reasonable efforts, it may be possible for system invaders, human or robotic, to intercept or access customer information. We cannot and do not guarantee the security of your information and you agree to not hold Mulberri responsible for unauthorized access or other breach of security.

8. Third-Party Links

We may include on our Website links to other websites containing third party products or services. Our Privacy Policy does not apply to those websites or services. We recommend you read the privacy statements and terms and conditions of any linked or referenced third-party websites you enter. These third-party websites may use their own cookies and tracking devices, log your IP address, and otherwise collect data or solicit your Personal Information.

9. Use of Cookies

We collect information about how you use our Website by using cookies. Cookies allow a website to identify a user’s device whenever that user returns to the website. This provides the user with a more stable and enriching experience and allows a website owner to gather usage information.

You can configure your internet browser preferences to limit the acceptance and storage of cookies, but blocking all cookies may limit your browsing experience on our and other websites. We may also utilize web beacons and similar tracking technologies to gather information about your interactions with our Website. You can remove and block the cookies on which web beacons rely to gather information about your user activity.

10. State-Specific Rights

The Personal Information about you that we collect includes information within the below categories of data. These categories also represent the categories of Personal Information that we have collected over the past 12 months. The categories listed below refers to the category of Personal Information as defined under the California Privacy Rights Act (“CPRA”). Inclusion of a category in the list below indicates only that, depending on the Services and products we provide you with, we may collect some information within that category. It does not mean that we collect all information listed in a particular category for all of our customers. In addition, Personal Information which is governed by the federal Gramm- Leach-Bliley Act (GLBA) or Fair Credit Reporting Act (FCRA) is exempted from the CCPA.

We have disclosed Personal Information in each of the below categories with our subsidiaries and affiliates, business partners, and service providers, as well as with government entities as necessary, within the past 12 months.

Category	Sources	Purpose of Processing
Identifiers such as 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.	Website and Platform modules and forms; and other communications with you.	Performance of our agreements to provide you Services and products; offer you products or services that may be of interest to you; comply with legal or regulatory obligations; and prevent fraud and enhance security.
Information that identifies, relates to, describes, or is capable of being associated with, a particular individual, including, but not limited to, your name, signature, social security number, physical characteristics or description, address, telephone 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.	Website and Platform modules and forms; and other communications with you.	Performance of our agreements to provide you Services and products; offer you products or services that may be of interest to you; comply with legal or regulatory obligations; and prevent fraud and enhance security.
Characteristics of protected classifications under California or federal law, including: familial status, disability, sex, national origin, religion, color, race, sexual orientation, gender identity and gender expression, marital status, veteran status, medical condition, ancestry, source of income, age, or genetic information.	Website and Platform modules and forms; and other communications with you.	Performance of our agreements to provide you Services and products; offer you products or services that may be of interest to you; comply with legal or regulatory obligations; prevent fraud and enhance security; and for accessibility purposes.
Commercial information, including records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.	Website and Platform modules and forms; and other communications with you.	Performance of our agreements to provide you Services and products; offer you products or services that may be of interest to you; comply with legal or regulatory obligations; and prevent fraud and enhance security.
Internet or other electronic network activity information, including, but not limited to, browsing history, search history, and information regarding the consumer’s interaction with an Internet Web site, application, or advertisement.	Web server logs that compile IP addresses, web beacons, and cookies.	Providing Services to you; and maintaining the security and integrity of our electronic systems.
Geolocation data.	Web server logs that compile IP addresses, web beacons, and cookies.	Providing Services to you; and maintaining the security and integrity of our electronic systems.
Audio, electronic, visual, or similar information.	N/A	N/A
Professional or employment-related information.	Website and Platform modules and forms; and other communications with you.	Performance of our agreements to provide you Services and products; offer you products or services that may be of interest to you; and comply with legal or regulatory obligations.
Inferences (defined as “the derivation of information, data, assumptions, or conclusions from facts, evidence, or another source of information or data”) drawn from any of the information identified in this subdivision to create a profile about a consumer reflecting the consumer’s preferences, characteristics, psychological trends, preferences, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.	Data analytics partners.	Performance of our agreements to provide you Services and products; offer you products or services that may be of interest to you.

In addition to the categories of information above, we also collect the following categories of sensitive personal information:

Category	Sources	Purpose of Processing
Social security, driver's license, state Identification card, or passport number.	Website and Platform modules and forms; and other communications with you.	Performance of our agreements to provide you Services and products; offer you products or services that may be of interest to you; and comply with legal or regulatory obligations.
Account log-In, financial account, debit card, or credit card number in combination with any required security or access code, password, or credentials allowing access to an account.	Website and Platform modules and forms; and other communications with you.	Performance of our agreements to provide you Services and products; offer you products or services that may be of interest to you; and comply with legal or regulatory obligations.
Precise geolocation information.	N/A	N/A
Racial or ethnic origin, religious or philosophical beliefs, or union membership.	Website and Platform modules and forms; and other communications with you.	Performance of our agreements to provide you Services and products.

California, Virginia, Colorado, and Connecticut also grant residents specific rights regarding the collection and use of their Personal Information. Subject to certain limitations, and based on your residency, you may be entitled to the following rights:

• Right to access/know. You have the right to know and request information about the categories and specific pieces of Personal Information we have collected about you within the last 12 months, as well as the categories of sources from which such information is collected, the purpose for collecting such information, and the categories of third parties with whom we share such information. You also have the right to know if we have sold or disclosed your personal information.

• Right to correct. You have the right to request we correct any mistakes in your Personal Information or update your preferences; we may also not be able to accommodate your request if we believe it would violate any law or legal requirement or cause the information to be incorrect. Data retained for data backup purposes is excluded.

• Right to delete. You have the right to request the deletion of your Personal Information, subject to certain exceptions.

• Right to non-discrimination. You have the right to not be discriminated against for exercising any of the above-listed rights. We may, however, provide a different level of service.

• Right to limit use and disclosure of Sensitive Personal Information. You have the right limit the use of and disclosure of your Sensitive Personal Information we collect or maintain, to only those purposes necessary to provide our Services.

• Opt-out of the sale or sharing of personal information. We do not sell your Personal Information to or share your Personal Information with third parties for cross contextual advertising, nor do we intend to, as those terms are defined by applicable state privacy law, including in California. We also have not done so for the last 12 months.

• Response Timing and Format. Our goal is to respond to a verifiable consumer request within 45 days of its receipt. If we require more time (up to 90 days), we will inform you of the reason and extension period in writing.  We will deliver our written response by mail or electronically, at your option, provided we have valid deliverable addresses for either method.  Any disclosures we provide will only address the 12-month period preceding the verifiable consumer request's receipt.  In our response, we may also explain the reasons why a request cannot be executed, if applicable.  We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or entirely unfounded.  If we determine that the request warrants a fee, we will tell you why and provide you with the costs before the request is executed.

If you would like to exercise any of the above rights, please submit your request by email to mulberricares@mulberri.io or contact us via the methods indicated in the “Contact Information” section at the bottom of this Privacy Policy.

We may require additional information from you in order to honor your request, and there may be circumstances where we will not be able to honor your request. For example, if you request deletion, we may need to retain certain personal information to comply with our legal obligations or other permitted purposes. We will only use Personal Information provided in a verifiable consumer request to verify your identity or authority to make the request. If you are submitting a request through an authorized agent, the authorized agent must provide us with your signed written permission stating that the agent is authorized to make the request on your behalf. We may also request that any authorized agents verify their identity and may reach out to you directly to confirm that you have provided the agent with your permission to submit the request on your behalf.

Further, if you are a California resident, California Civil Code Section 1798.83 permits you to request in writing a list of the categories of Personal Information relating to third parties to which we have disclosed Personal Information during the preceding year, for the third parties’ direct marketing purposes. To make such a request, please contact us at mulberricares@mulberri.io

11. Do Not Track Signals

Some browsers have incorporated “Do Not Track” (DNT) features that can send a signal to the websites you visit indicating you do not wish to be tracked. Because there is not yet a common understanding of how to interpret the DNT signal, our services do not currently respond to browser DNT signals.

12. We do Not Intend to Collect Information of Children

Our Services are not directed towards individuals under the age of thirteen (13), and we do not knowingly collect or solicit Personal Information from children or anyone under the age of 13. We do not knowingly allow such persons to utilize our Services. In the event that we learn that we have inadvertently collected Personal Information from a child or someone under the age of 13, we will delete that information as quickly as possible. If you believe that we might have any information from or about a child, please contact us via the methods listed below in the “Contact Information” section at the bottom of this Privacy Policy.

13. Changes To Our Privacy Policy

We reserve the right to change this Privacy Policy at any time by posting the changes/amended Privacy Policy on this Website. The date of this Privacy Policy was last revised is identified at the bottom of this page. All amended terms automatically take effect after they are initially posted on our website, unless a change in any applicable law requires immediate amendment. You are responsible for periodically monitoring and reviewing any updates to this Privacy Policy.

14. Contact Information

If you have any questions relating to this Privacy Policy or your Personal Information that we maintain, or wish to change the specific Personal Information you have provided, please use the contract information below:

Email: mulberricares@mulberri.io

U.S. Mail:
Mulberri, Inc.
440 N. Wolfe Road, Sunnyvale, CA 94085

Privacy Policy Revised: October 11, 2024