Privacy Policy

1. Scope and who we are

NetEnroll is operated by PVN LLC (“PVN,” “we,” “us”), a Florida limited liability company. This policy applies to personal information we collect through netenroll.com, messaging.netenroll.com, the agent and administrative portals, our call routing and messaging systems, and our own marketing communications (together, the “Services”).

This policy covers two distinct groups of people:

• Agents — licensed insurance producers and agencies who register for and use the Services.
• Consumers — individuals who contact us or are connected to an Agent through the Services in connection with an insurance inquiry.

Where we determine the purposes and means of processing, we act as a controller. Where we process information on behalf of an Agent or a carrier under their instructions, we act as a service provider or processor, and that party's own privacy notice governs their use of the information. Once information is transferred to an Agent or a carrier, their handling of it is governed by their policies and is outside our control.

2. Information we collect

2.1 Information you give us

• Agent registration data: whether you register as a company or an individual; for a company, its name, entity type, and state of formation; first and last name; business email address; telephone number for call forwarding; the states you select for call routing; and the Programs you select.
• Payment data: payments are processed by Stripe, Inc. Card numbers and security codes are entered on Stripe's systems and are not collected or stored by PVN. We receive limited transaction records such as a payment identifier, amount, date, status, and the last four digits and brand of the card.
• Consumer inquiry data: name, telephone number, mailing address or ZIP code, state, email address, date of birth or age range, and information about the coverage being sought.
• Application data: carrier, policy or submission number, applicant name, applicant state, and submission status, recorded for billing and reporting.
• Correspondence: the content of messages, support requests, complaints, and opt-out or rights requests you send us.

2.2 Communication metadata and content

Because the Services route calls and send messages, we necessarily collect information about those communications:

• Call records: calling and called telephone numbers, the routing number (DID) used, date, time, duration, disposition, the Agent to whom the call was routed, and the Program.
• Call recordings: where calls are recorded or monitored, the audio recording and any transcript or notes derived from it. Recording practices, and the notice and consent required, are described in our TCPA & Compliance Policy.
• SMS and MMS: message content, sending and receiving numbers, timestamps, delivery receipts and error codes, carrier responses, opt-in and opt-out keywords, and message status.
• Consent records: the consent language displayed, the web page or form on which consent was given, date and time, IP address, browser user agent, and the values submitted. These records are retained to evidence prior express written consent.

2.3 Information collected automatically

• IP address and approximate location derived from it, device and browser type, operating system, screen size, and language.
• Pages viewed, referring URL, links clicked, time on page, and dates and times of access.
• Server and application logs, error reports, and security event records.

2.4 Information from third parties

• Lead sources and marketing partners: consumer inquiry data and the associated consent record, where a Consumer submitted a request through a partner's property.
• Service providers: telephony and messaging carriers, our payment processor, and fraud or deliverability tools.

3. Cookies and tracking technologies

We and our providers use cookies, local storage, pixels, and similar technologies. We use them to keep you signed in and maintain session state, remember preferences, measure traffic and page performance, secure the Services and detect abuse, and attribute inquiries to the source that generated them.

Most browsers let you refuse or delete cookies through their settings. Blocking cookies that are strictly necessary will prevent parts of the agent portal from working. Where required by law, we present a consent mechanism for non-essential technologies, and you may change your choice at any time.

4. How we use information

We use personal information to:

• Create and administer accounts.
• Route inbound calls to an Agent licensed in the Consumer's state, and connect the parties.
• Send and receive SMS and MMS messages relating to an inquiry or an account.
• Record calls and applications against an account, calculate fees, process payments, and issue receipts.
• Provide reporting, analytics, and support to Agents about their own activity.
• Maintain and evidence consent, honor do-not-call and opt-out requests, and meet our recordkeeping and regulatory obligations.
• Monitor for fraud, duplicate or falsified applications, abuse, and security incidents.
• Operate, debug, secure, and improve the Services.
• Communicate with you about the Services, including service and transactional messages, and, where permitted, marketing about our own offerings.
• Comply with law, respond to lawful requests, and establish, exercise, or defend legal claims.

We do not use call recordings, message content, or Consumer inquiry data to train third-party generative artificial intelligence models for purposes unrelated to providing the Services.

5. How we share information

We disclose personal information in the following circumstances:

• With licensed Agents. Consumer inquiry data is disclosed to the Agent to whom a call or inquiry is routed, so that the Agent can respond and, if the Consumer chooses, complete an application. Agents are contractually required to use it only for that purpose.
• With insurance carriers. Application information may be transmitted to or recorded with the carrier through which an application is submitted.
• With service providers. Payment processing (Stripe, Inc.), telephony and SMS carriers, cloud hosting and infrastructure, email delivery, analytics, and security vendors, each engaged to process information on our behalf under contractual restrictions.
• For legal reasons. Where we believe disclosure is required by law, subpoena, regulator request, or court order, or is necessary to investigate suspected fraud or to protect the rights, property, or safety of any person.
• In a business transfer. In connection with a merger, acquisition, financing, reorganization, or sale of assets, subject to this policy or a successor notice.
• With your direction or consent. Where you ask us to share information with someone else.

We do not disclose personal information to third parties for their own independent marketing purposes without a lawful basis and, where required, your consent.

6. Sale, sharing and targeted advertising

We do not currently use personal information for cross-context behavioral advertising or profiling that produces legal or similarly significant effects. If that changes, we will update this policy and provide any opt-out required by law before the change takes effect.

7. How long we keep information

We keep personal information only as long as necessary for the purposes described here, and then delete it or de-identify it. Retention is driven by the following:

Where we are required to keep information to demonstrate compliance, such as consent and opt-out records, we retain it even after a deletion request and limit its use to that purpose.

8. Security safeguards

We maintain administrative, technical, and physical safeguards designed to protect personal information against unauthorized access, disclosure, alteration, and destruction. These include encryption of traffic in transit using TLS, access controls and authentication for the agent and administrative portals, segregation of each Agent's data so that one Agent cannot access another's, least-privilege access for personnel, logging and monitoring of administrative actions, and vendor diligence with contractual confidentiality and security terms.

No method of transmission or storage is completely secure, and we cannot guarantee absolute security. You are responsible for keeping your credentials confidential and for notifying us promptly of any suspected unauthorized use. If a breach affecting your personal information occurs, we will notify you and any regulator as required by applicable law.

9. Your rights and choices

9.1 Rights that may be available to you

• Access — confirm whether we process your personal information and obtain a copy, including the categories collected, the sources, the purposes, and the categories of recipients.
• Correction — have inaccurate personal information corrected.
• Deletion — request deletion, subject to exceptions where we must retain information by law or to evidence consent and opt-out status.
• Portability — receive a copy in a portable, readily usable format where technically feasible.
• Opt out of sale or sharing — direct us not to sell or share your personal information as those terms are defined in Section 6.
• Limit use of sensitive information — where we process sensitive personal information beyond what is necessary to provide the Services.
• Non-discrimination — we will not deny service, charge a different price, or provide a lesser quality of service because you exercised a privacy right.
• Appeal — if we decline a request, you may appeal by contacting us again and referencing the original request.

9.2 How to exercise a right

Contact us using the details in Section 14. Tell us which right you are exercising and give us enough information to locate your records, such as the telephone number or email address you used. We will verify your identity before acting, typically by confirming information already in our records, and we do not use verification information for any other purpose.

We respond within the period required by applicable law, generally 45 days, and may extend once where reasonably necessary with notice to you. An authorized agent may submit a request on your behalf with proof of authorization. There is no charge for a reasonable number of requests.

9.3 Communication opt-outs

10. State privacy disclosures

10.1 California

California residents have the rights described in Section 9 under the California Consumer Privacy Act as amended. The categories of personal information we collect, as those categories are defined in Cal. Civ. Code § 1798.140, are: identifiers; customer records information; commercial information; internet or other electronic network activity information; geolocation data derived from IP address; audio and electronic information, including call recordings and message content; professional or employment-related information, in the case of Agents; and inferences drawn from the foregoing. Sources, purposes, and recipients are described in Sections 2, 4, and 5. We retain each category as described in Section 7.

Where the information you provide relates to insurance eligibility, it may include elements treated as sensitive personal information. We use it only to provide the Services and for the purposes permitted without a right to limit under § 1798.121.

California's “Shine the Light” law permits residents to request information about disclosures to third parties for their direct marketing purposes. You may make that request using the details in Section 14.

10.2 Other states

Residents of states including Virginia, Colorado, Connecticut, Utah, Texas, Oregon, and Montana have comparable rights of access, correction, deletion, portability, and opt-out of targeted advertising, sale, and certain profiling, together with a right to appeal a refused request. We extend the rights in Section 9 to residents of every state.

10.3 Insurance-specific privacy law

Personal information collected in connection with an insurance transaction may also be subject to state insurance privacy statutes and to the Gramm-Leach-Bliley Act. Where those laws apply, we handle the information in accordance with them, and certain exemptions to general state privacy laws may apply.

11. Children's privacy

The Services are intended for adults. We do not knowingly collect personal information from anyone under 18, and the products offered are not directed to children. If we learn that we have collected information from a child under 13, or have sold or shared the information of anyone under 16 without required consent, we will delete it or cease the activity. Contact us if you believe a child has provided information.

12. Other disclosures

12.1 Do Not Track

Browsers may transmit a “Do Not Track” signal. There is no common industry standard for responding to it, and we do not currently respond. Where required, we honor recognized opt-out preference signals such as Global Privacy Control for the opt-out described in Section 6.

12.2 Third-party links

The Services link to sites we do not operate, including our payment processor. We are not responsible for their privacy practices, and we encourage you to read their notices.

12.3 Location of processing

The Services are intended for use in the United States, and information is processed and stored in the United States. If you access the Services from elsewhere, you do so on your own initiative and are responsible for compliance with local law.

13. Changes to this policy

We may update this policy. The “Last updated” date above reflects the most recent revision. If we make material changes, we will provide notice through the Services or by contacting you before the change takes effect. Continued use after the effective date constitutes acceptance.

14. Contact us

To ask a question about this policy, exercise a privacy right, or submit a complaint, contact us by telephone or by mail: