Privacy Policies

HTK and any third party that we hire for the purpose of administering, operating, hosting, configuring, designing, maintaining, and providing internal support for our Web Properties may collect the following categories of information (collectively, “Information”) when you visit or interact with the website:

• your Internet Protocol (or IP) address, protocol, and sequence information;
• your browser language and type;
• domain name system requests;
• your operating system and platform, device type, and device identifiers;
• your geographic location (including city and state);
• your age, gender or other demographic information about you (if this information is contained in your browser);
• information about yourself that you provide to us through the website or that we receive on your behalf (such as when you complete forms or applications, contact us, or sign up for a mailing list);
• information we may receive from our partners, affiliates or service providers;
• information about your transactions with us, as well as information that we receive as a result of your use of our services or purchases of our products (as applicable);
• your browsing history (including time spent at a domain, time and date of your visit) and number of clicks;
• any hypertext transfer protocol headers, application client and server banners, and operating system fingerprinting data;
• your MAC address, device ID/UDID, or similar device-specific code; and
• aggregated information.

We collect Information about you from your computer or mobile device, the following types of technologies:

Cookies: From time to time, we may use “cookies” to keep track of your visit and your use of the Web Properties. A cookie is a small piece of data that your browser stores on your computer’s or device’s hard drive and is used to collect information, such as identifying those areas of the Web Properties that you have visited in the past in order to enhance your next visit to the Web Properties. You can choose whether to accept cookies by changing the settings of your browser, but some functionality of the Web Properties may be impaired or not function as intended if you choose not to accept cookies. Each browser is a little different, so look at your Help menu to learn the correct way to modify your cookies.

We also use Google Analytics to help analyze how users use the Web Properties. These tools use cookies to collect standard Internet log information and visitor behavior information in an anonymous form. The information generated by the cookie about your use of the Web Properties (including IP address) is transmitted to our data collection tool service providers. This information is then used by us to evaluate visitors’ use of the Web Properties and to compile statistical reports on website activity for HTK. If you would like to opt-out from the use of your information by Google analytics, you may use Google’s analytics opt-out browser add-on designed for this purpose.

Statistics and Log Files: We collect aggregate information about our visitors, including the IP address, type of information used and browser software. In addition, we track what portion of our Web properties are visited, the number of visitors, and time spent on our Web Properties. We keep this information for our internal use for statistical purposes, to analyze trends, and to improve our Web Properties. None of the information is linked back to you as an individual user.

iBeacons and Geolocation: While using certain features of the Web Properties, we may track the physical location of your mobile device or web browser. WiFi and IP addresses received from your device or browser may be used to determine your approximate location. You will always have control over whether to transmit your physical location, and you can prevent such disclosure by disabling Bluetooth and Wi-Fi, declining the request to share your physical location, or adjusting your privacy settings.

Information collected by HTK may be used for the following primary purposes:

1. To improve the Web Properties by determining which of our features and services are most popular. We may analyze your information to enable us to provide effective services to you, for our internal business purposes, and to develop new features, functionality, and services.
2. To personalize your experience on the Web Properties.
3. To inform you about our products and services. We may send you and keep you updated with information about existing and new services, products, features, and special offers by email, telephone, mail, or by means of any other contact details that you provide to us or to our third party service providers.

We might disclose your Information: (1) in the good-faith belief that such disclosure is necessary to service or process an insurance product or service that you requested or authorized; (2) with your consent or at your direction; (3) to your legal representative; (4) in response to a subpoena; (5) to comply with federal, state or local laws; and (6) to protect against fraud. We are also permitted to disclose your Information to companies that perform services for us, such as Google Analytics (as described above)

With respect to the Web Properties themselves, we might disclose your Information: (1) to enforce this Privacy Policy; (2) to take precautions against liability and respond to any claim that any document, image, graphic, logo, design, audio, video, audio-visual material, photo, commentary, or any other information provided to, from, or on the Web Properties by you violates the rights of third parties; (3) to protect our rights, property, or the safety or the rights, property, or personal safety of our visitors and the public, which includes exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction, and, if required by law, disclosing information to U.S. federal and state governmental agencies; or (4) to investigate potential unauthorized access or misuse of the Web Properties or otherwise enforce or apply our Terms of Use and other agreements.

We may provide Information to our subsidiaries, affiliated companies, and other businesses or persons for the purposes of processing such information on our behalf and to allow them to provide you with information about products and services that may interest you, however, we do not share any information about you with third parties for those third parties’ marketing information. In addition to the other rights described herein, we have the right—unless you object—to exploit, share, and use, for any purpose, the collected Personal Information in an aggregated, anonymized form, such that you are not individually identified.

We reserve the right to transfer your Information, as well as any information about or obtained from you, in connection with the merger, sale, or other disposition of all or part of our business and/or assets. We cannot make any representations regarding the use or transfer of your Information or other information that we may have in the event of our bankruptcy, reorganization, insolvency, receivership, or an assignment for the benefit of our creditors. You expressly agree and consent to the use and/or transfer of your Information or other information in connection with a sale or transfer of some or all of our assets in any of the above described proceedings.

While we may provide certain encryption technologies and use other reasonable precautions to protect your confidential information and provide suitable security, we do not and cannot guarantee or warrant that any information transmitted through the Internet is secure, or that such transmissions are free from delay, interruption, interception, or error. You are ultimately responsible for protecting your username, and password (as applicable) from disclosure to third parties, and you are not permitted to circumvent the use of required encryption technologies.

We do not knowingly collect or maintain information about any person under the age of thirteen. No parts of our Site are directed to or designed to attract anyone under the age of thirteen.

The Web Properties may contain links to third party websites. Any access to and use of such third party websites is not governed by this Privacy Policy, but instead is governed by the privacy policies of those third party websites, and we are not responsible for the information practices of such third party websites.

We may use the services of third party service providers, for example to process payments and other transactions. By using our Web Properties, you grant us all necessary rights and consents under applicable laws to disclose to our third party service providers -- or allow those third party service providers to collect, use, retain, and disclose -- any Information for purposes of providing services to you, including data that we may collect directly from you using cookies or other similar means.

The Web Properties and our products and services are hosted in the United States and are governed by United States law. If you are using the Web Properties or our products or services from outside the United States, please be aware that your Information may be transferred to, stored, and processed in the United States where our servers are located and our central database is operated. The data protection and other laws of the United States and other countries might not be as comprehensive as those in your country. By using the Web Properties or our products and services, you consent to your Usage Information being transferred to our facilities and to the facilities of those third parties with whom we share it as described in this Privacy Policy.

Whether you submit any Personal Information to us is entirely up to you. You are under no obligation to provide any Personal Information to us. However, this information is essential for the provision and quality of some of the services that we offer to you, so we cannot provide you with certain services or provide you with access to certain features if you choose to withhold requested information.

You may choose to prevent us from disclosing or using Information we have received about you under certain circumstances (“opt out”). You may opt out of any disclosure or use of your Information for purposes that are incompatible with the purpose(s) for which it was originally collected or for which you subsequently gave authorization by notifying us by one of the methods at the end of this Privacy Policy, including by using our toll-free telephone number, 800-873-7637, or by following the procedures set forth in an electronic communication from us, if applicable. Furthermore, even where your Personal Information is to be disclosed and used in accordance with the stated purposes in this Privacy Policy, you may elect to opt out of such disclosure to and use by a third party that is not acting as our agent. There are some uses from which you cannot opt out, such as to provide products, features, or services that you have requested from us.

Note that your browser settings may allow you to automatically transmit a “Do Not Track” signal to websites and online services that you visit. Like many websites and online services, HTK currently does not alter its practices when it receives a “Do Not Track” signal from a visitor’s browser. To find out more about “Do Not Track,” you may wish to visit https://www.allaboutdnt.com.

By using the Web Properties, you consent to the collection and use of your information by us as specified above or as we otherwise see fit, in compliance with this Privacy Policy, unless you inform us otherwise by means of the procedure identified below. If we decide to change this Privacy Policy or some part of it, we will make an effort to post those changes on this web page so that you will always be able to understand what information we collect, how we use that information and under what circumstances we may disclose that information to others. Your use of the Web Properties following our publication of any amendment of this Privacy Policy will signify your assent to and acceptance of its revised terms for all previously collected information and information collected from you in the future. We may use comments, information or feedback that you may submit in any manner that we may choose without notice or compensation to you.

If you have additional questions or comments, please let us know by sending your comments or questions to:

Hornor, Townsend & Kent, LLC
600 Dresher Rd,
Horsham, PA 19044
Phone: 800-873-7637
Email: privacy@pennmutual.com

The HTK California Privacy Policy describes how and for what purposes HTK collects, processes and uses the Personal Information of HTK California clients.

This California Privacy Policy describes Hornor, Townsend & Kent, LLC (“HTK,” “we,” “us,” or “our”) practices regarding the collection, use, and disclosure of the personal information of California residents (“Consumers”), describes the rights of Consumers under the California Consumer Privacy Act of 2018 (“CCPA”), and explains how Consumers may contact HTK to exercise those rights. This policy only applies to the personal information of Consumers (i.e., California residents).

This section describes certain rights of Consumers under the CCPA. For information on how Consumers may contact HTK to exercise these rights, please see the section below entitled, “How to Submit a Request.”

A Consumer has the right to request that a business disclose what personal information it collects, uses, discloses or sells. Specifically, a Consumer may request that a business that collects personal information about the Consumer disclose to the Consumer the following:

1. The categories of personal information it has collected about that Consumer.
2. The categories of sources from which the personal information is collected.
3. The business or commercial purpose for collecting or selling personal information.
4. The categories of third parties with whom the business shares personal information.
5. The specific pieces of personal information it has collected about that Consumer.

A Consumer may request that a business that sells the Consumer’s personal information, or that discloses it for a business purpose, disclose to that Consumer:

1. The categories of personal information that the business sold about the Consumer and the categories of third parties to whom the personal information was sold, by category or categories of personal information for each third party to whom the personal information was sold.
2. The categories of personal information that the business disclosed about the Consumer for a business purpose.

A Consumer has the right to request that a business delete any personal information about the Consumer which the business has collected from the Consumer. If it is necessary for HTK to maintain the personal information for certain purposes, HTK is not required to comply with your deletion request. If we determine that we will not delete your personal information when you request us to do so, we will inform you and tell you why we are not deleting it.

A Consumer has the right not to be discriminated against because the Consumer exercised any of the Consumer’s rights under the CCPA. HTK may charge a Consumer a different price or rate, or provide a different level or quality of goods or services to the Consumer, if that difference is reasonably related to the value provided to the Consumer by the Consumer’s data.

How to Submit a Request

To exercise the rights described above, you must submit a verifiable Consumer request to us by contacting HTK through one of the following methods:

• Calling 1-800-873-7637 (Option 2) or
• Filling out the following online form: www.htk.com/ccpa-request-form

You may submit a request as frequently as you would like, but we are not required to respond to requests to provide personal information to you more than twice in any 12-month period. To submit a verifiable Consumer request, you will be asked to provide certain information to help us verify your identity. The information we ask you to provide to initiate a request may differ depending upon the type of request, the type, sensitivity and value of the personal information that is the subject of the request, and the risk of harm to you that may occur as a result of unauthorized access or deletion, among other factors. In certain circumstances, we may also require you to provide a written declaration that you are who you say you are.

You may make a verifiable Consumer request on behalf of your minor child. You may also designate an authorized agent to make a request on your behalf. Upon request, your authorized agent must provide proof of identity and authority to speak on your behalf. If we cannot verify your identity or authority to make the request, we will not be able to comply with your request. We will inform you if we cannot verify your identity or authority. We will only use personal information provided in a verifiable Consumer request to verify the requestor’s identity or authority to make the request.

HTK has collected the following categories of Personal Information about Consumers in the twelve (12) months prior to the Effective Date of this Policy:

• 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.
• 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.
• Characteristics of protected classifications under California or federal law (Race, color, national origin, religion, gender (including pregnancy), disability, age (at least 40 years old), citizenship status, sexual orientation, gender identity and gender expression).
• Commercial information, including records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.
• Audio, electronic, visual, thermal, olfactory, or similar information.
• Professional or employment-related information.
• Education information.
• Inferences drawn from any personal information to create a profile about a Consumer reflecting the Consumer’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.

HTK collects the personal information described above from the following categories of sources:

• From you directly, when you provide us with information over our websites or in person, in applications or questionnaire responses you submit in connection with one of our products or services, when you provide information about yourself to one of our Financial Professionals.
• From others on your behalf, such as when you are named as a beneficiary or emergency contact of one of our employees or associated with a policy held by one of our clients.
• From financial services organizations who provide us with information about purchase and sale transactions made by you or on your behalf.
• From public records or published databases.

HTK collects the personal information described above for a variety of business purposes. HTK uses the personal information to:

• Provide our products and services to you and activities related to our provision of such products and services, including maintaining or servicing accounts, providing customer service, processing or fulfilling orders and transactions, verifying customer information, processing payments, providing advertising or marketing services, or providing analytics services;
• Improve, upgrade, or enhance our products and services;
• Provide you with information about products and services that we and other businesses may provide that we think may be of interest to you;
• Detect security incidents, protecting against malicious, deceptive, fraudulent, or illegal activity, and prosecuting those responsible for that activity;
• Debug to identify and repair errors that impair existing functionality;
• For research and analysis purposes.

HTK may share the personal information described above with the following categories of third parties:

• We share your personal information with our service providers to assist us in providing our products and services to you, including service providers that:
• host our databases, infrastructure and websites;
• provide analytics services to help us understand the activity on our website;
• assist us with marketing and communications with our clients or potential clients;
• assist us to analyze and understand the financial status and needs of our client base;
• assist us with the financial, regulatory and legal aspects of our business,
• assist us with quote and estimates specific to particular individuals interested in our products or services;
• assist us with event planning; and
• host our databases, infrastructure and websites;
• assist us with data security and privacy;
• With courts or governmental entities as we deem necessary to respond to a subpoena, regulation, binding order of a data protection agency, legal process, governmental request or other legal or regulatory process.

HTK has not sold Personal Information about Consumers in the twelve (12) months prior to the Effective Date of this Policy.

HTK has disclosed Personal Information about Consumers for a business purpose in the twelve (12) months prior to the Effective Date of this Policy.

HTK has disclosed the following categories of Personal Information about Consumers for a business purpose in the twelve (12) months prior to the Effective Date of this Policy:

• 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.
• 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.
• Characteristics of protected classifications under California or federal law (Race, color, national origin, religion, gender (including pregnancy), disability, age (at least 40 years old), citizenship status, sexual orientation, gender identity and gender expression).
• Commercial information, including records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.
• Audio, electronic, visual, thermal, olfactory, or similar information.
• Professional or employment-related information.
• Education information.
• Inferences drawn from any personal information to create a profile about a Consumer reflecting the Consumer’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.

If you have any questions or concerns about HTK’s privacy policy and practices, please contact:

Hornor, Townsend & Kent, LLC
600 Dresher Road
Horsham, PA 19044
Phone: 800-873-7637 (Option 2)
Email: privacy@pennmutual.com

Effective Date: January 1, 2020