Privacy Policy

1. Scope and Our Role as an Insurance Intermediary

In Short: Harmonic acts as an insurance broker, program manager, and technology provider for institutional clients — not as a direct-to-consumer insurer or lender.

Harmonic Insurance Services is a licensed insurance producer in all states. Harmonic Financial Technology, Inc. provides program management and technology infrastructure that supports the placement and administration of insurance and risk-transfer programs — including, for example, layoff/income-protection insurance, home warranty, and related consumer-protection benefit programs offered through bank and lender partners, and private mortgage insurance-linked programs offered through institutional investors and originators.

In each case, Harmonic typically acts on behalf of, or under contract with, a carrier, reinsurer, or program sponsor — not as the party contracting directly with an individual consumer. Where we process personal information about an individual insured, applicant, or beneficiary, we generally do so as a service provider or business associate carrying out the instructions of, and under confidentiality obligations to, the carrier or program sponsor responsible for that individual's coverage.

2. What Information Do We Collect?

Business Contacts

In Short: We collect professional contact information about individuals who represent our institutional clients and partners.

When we work with a bank, carrier, MGA, reinsurer, or other institutional partner, we collect information about the individuals who represent that organization in the relationship, which may include:

• names, job titles, and business affiliation;
• business email addresses, phone numbers, and mailing addresses;
• professional licensing information (e.g., insurance producer license numbers, NPN), where relevant to the engagement; and
• communications and meeting records related to the business relationship.

Nonpublic Personal Information (NPI) Connected to Insurance Programs

In Short: In our capacity as a broker and program manager, we and our service providers process information about individual applicants, insureds, and beneficiaries as necessary to place and administer coverage.

Depending on the specific program, this may include:

• identifying information (name, date of birth, address, Social Security number or other government identifier);
• financial information (income, employment status, bank account or payment information, mortgage or loan account details relevant to a program);
• insurance application, underwriting, and policy information (coverage elected, premium, effective dates, beneficiary designations);
• claims information (nature of claim, supporting documentation, claim status and payment history); and
• for certain lines of coverage, health or disability-related information, collected and processed subject to additional confidentiality protections.

We generally receive this information from the carrier, program sponsor, or institutional client on whose behalf we are acting, from the individual directly during enrollment or claims processes administered on a partner's behalf, or from service providers engaged to support underwriting or claims (e.g., verification, fraud-prevention, or eligibility services).

Information Automatically Collected From Our Website

In Short: We automatically collect standard technical information when you visit harmonicft.com.

This includes IP address, browser and device characteristics, operating system, referring URLs, and information about how you interact with our site (e.g., pages viewed, time on page). This information is used to operate and secure our website and for internal analytics; it is not used to make decisions about insurance eligibility, pricing, or claims.

Job Applicants

If you apply for a position with Harmonic, we collect the information you provide in connection with that application (resume, contact information, work history), used solely for recruiting and hiring purposes.

3. How Do We Process (Use) Information?

In Short: We process information to broker, place, and administer insurance programs; to support our clients' underwriting and compliance needs; and to meet our own regulatory obligations.

• To place and administer insurance and risk-transfer programs. Including quoting, binding, endorsements, renewals, and claims coordination on behalf of carriers and program sponsors.
• To support underwriting and program design. We may process aggregated or individual-level data to help carrier and program-sponsor clients evaluate risk, price coverage, and structure programs — acting under their instruction and confidentiality requirements, not as an independent underwriter of consumer risk.
• To satisfy regulatory and licensing obligations. As a licensed insurance producer, we maintain records and process information as required by state insurance departments and applicable insurance producer licensing laws.
• For compliance, fraud prevention, and AML/KYC purposes. Including verifying the identity of counterparties and, where applicable, screening against sanctions and watch lists.
• To manage our business relationships. Including contracting, invoicing, and communicating with client and partner representatives.
• To operate and secure our website and systems.
• To comply with law and to establish, exercise, or defend legal claims.

4. When and With Whom Do We Share Information?

In Short: We share information with the carriers, program sponsors, and service providers necessary to place and administer coverage, under contractual confidentiality obligations.

We may share personal information with:

• Insurance carriers and reinsurers for whom we place or administer coverage;
• Managing general agents, program administrators, and third-party administrators (TPAs) involved in underwriting, servicing, or claims handling for a given program;
• Institutional clients and program sponsors (e.g., banks and lenders) in connection with programs offered through them;
• Service providers who perform functions on our behalf under written contracts limiting their use of the information to the services requested, including:
  • Cloud computing and data hosting services
  • Data analytics services
  • Compliance, licensing, and recordkeeping platforms
  • Payment processors
  • Communication and collaboration tools
• Regulators and government authorities, including state departments of insurance, where required by law or in connection with an examination or inquiry;
• Affiliates, including Harmonic Financial Technology, Inc., Harmonic Insurance Services, and any parent, subsidiary, or commonly controlled entity, each bound by this notice or an equivalent standard; and
• Successors in connection with a merger, financing, acquisition, or sale of business assets.

We do not sell personal information to third parties for their own independent marketing purposes, and we do not use NPI collected in our insurance-producer capacity for unrelated targeted advertising.

5. Nonpublic Personal Information (GLBA) Notice

In Short: As a licensed insurance producer, Harmonic Insurance Services is subject to the Gramm-Leach-Bliley Act privacy and safeguarding requirements and applicable state insurance information privacy laws.

The Gramm-Leach-Bliley Act and its implementing regulations, together with state insurance information and privacy protection laws (many modeled on the NAIC Insurance Information and Privacy Protection Model Act), govern how we collect, use, and disclose nonpublic personal information (“NPI”) about individual consumers in connection with insurance products. Consistent with those requirements:

• We collect NPI from applications, transactions with us or our affiliates, and from consumer reporting agencies or other third parties, as necessary to provide insurance-related services.
• We disclose NPI to affiliates and nonaffiliated third parties (such as carriers, reinsurers, TPAs, and service providers) as necessary to effect, administer, or enforce a transaction that an individual requests or authorizes, or as otherwise permitted by law — for example, to carriers for underwriting or claims, to service providers performing functions on our behalf, and to regulators.
• We maintain physical, administrative, and technical safeguards designed to protect NPI, consistent with the GLBA Safeguards Rule (16 C.F.R. Part 314) and applicable state insurance data security laws (many modeled on the NAIC Insurance Data Security Model Law).

6. Do We Use Cookies and Other Tracking Technologies?

In Short: We use cookies to operate our website, understand site usage, and support business-development marketing to institutional prospects — not to target individual insurance consumers with advertising.

We use cookies and similar technologies for site functionality, security, and basic analytics. We may also use marketing technologies (such as LinkedIn or website-analytics pixels) to support business development with prospective institutional clients and partners. We do not use cookies to build advertising profiles of individual insurance applicants, insureds, or claimants, and NPI is not used for targeted advertising.

You can manage cookie preferences through your browser settings. Disabling certain cookies may affect site functionality.

7. How Long Do We Keep Information?

In Short: We retain information for as long as needed to service a program and to satisfy insurance recordkeeping, licensing, and errors-and-omissions requirements.

Retention periods for NPI and program-related records are generally governed by applicable state insurance law.

Business-contact and website information is retained only as long as reasonably necessary for the purposes described in this notice, after which it is deleted or anonymized.

8. How Do We Keep Information Safe?

In Short: We maintain administrative, technical, and physical safeguards designed to protect personal information, consistent with the GLBA Safeguards Rule and applicable state insurance data security laws.

These safeguards include access controls, encryption of sensitive data in transit and at rest, vendor due diligence and contractual security requirements, and an incident response process. No system can be guaranteed 100% secure, and we cannot promise that unauthorized third parties will never defeat these safeguards.

9. Do We Collect Information From Minors?

Harmonic's services are directed to institutional clients and licensed insurance professionals, not to individual consumers, and are not directed to or marketed toward children. We do not knowingly collect personal information from individuals under 18. If we learn we have inadvertently done so, we will take reasonable steps to delete it.

10. State Insurance Privacy Rights

In Short: Individuals covered under insurance programs we help administer may have specific rights under state insurance privacy laws.

Depending on the state and line of business, individuals may have rights to access certain information we hold about them in connection with an insurance transaction, to request correction of inaccurate information, and to receive notice of certain disclosures, consistent with applicable state insurance information privacy statutes. Because Harmonic typically acts on behalf of a carrier or program sponsor, requests of this nature are often more efficiently directed to that carrier or program sponsor in the first instance; we will coordinate with them as needed to respond to a valid request directed to us.

11. Do United States Residents Have Other State Privacy Rights?

In Short: Comprehensive state privacy laws such as the CCPA generally exempt information covered by GLBA; separate, narrower rights may still apply to our general business website.

Most comprehensive state consumer privacy laws currently in effect (including California's CCPA/CPRA) include an exemption for personal information collected, processed, sold, or disclosed in accordance with the Gramm-Leach-Bliley Act, or for entities subject to it. Because much of the individual-level information Harmonic processes is NPI handled in our capacity as a licensed insurance producer, that information is likely exempt from those statutes' general consumer rights framework, which is addressed separately in Section 10 above.

For personal information that is not subject to that exemption — for example, general business contact information collected through our website from prospective institutional clients — California and certain other state residents may have rights to know, access, correct, or delete that information, and to opt out of its sale or use for targeted advertising (Harmonic does not sell personal information or use it for targeted advertising). To exercise these rights, contact us using the information in Section 13.

12. Do We Make Updates to This Notice?

We may update this notice from time to time to reflect changes in our practices or applicable law. The “Last Updated” date at the top reflects the most recent revision. Material changes will be communicated through the methods we determine are appropriate under the circumstances, which may include posting a notice on our website or, for carrier/program-sponsor relationships governed by GLBA annual notice obligations, through the applicable notice channel.

13. How Can You Contact Us?

If you have questions or comments about this notice, or wish to exercise a right described above, contact our Data Protection Officer:

Harmonic Financial Technology, Inc.

Attn: Data Protection Officer

677 King Street, 3rd Floor

Charleston, SC 29403

Email: info@harmonicft.com