Our privacy policy,
in plain English first.

3.1

Definitions.

For purposes of this Policy:

• "mnw," "we," "us," "our" means Meanwhile Agency LLC, a Delaware limited liability company, including (where the context requires) its subsidiaries and operating affiliates. In the State of California, Meanwhile Agency LLC solicits insurance under the approved fictitious name Meanwhile Insurance Agency LLC; the fictitious name does not create a separate entity for privacy-law purposes.
• "You," "your" means the natural person about whom mnw collects, uses, or discloses Personal Information.
• "Personal Information" means information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household, as defined by applicable law.
• "Sensitive Personal Information" means the subset of Personal Information defined as such under California Civil Code §1798.140(ae) and analogous state statutes.
• "Voice Recording" means an audio recording of a conversation between you and an mnw AI voice advisor or an mnw human producer.
• "Transcript" means a written or computer-generated representation of a Voice Recording.
• "Inference" means an inference drawn by mnw's systems from Personal Information about you for the purpose of providing or improving the Service.
• "Service" means the mnw life-insurance brokerage service and any related software, websites, communications, or features.

3.2

Information we collect.

We collect Personal Information from three sources.

From you directly.

When you create an account, complete an insurance application, or interact with our AI advisor:

• Identity information: legal name, residential address, mailing address, date of birth, gender, marital status.
• Contact information: email address, telephone number.
• Government identifiers: Social Security Number (for identity verification and carrier underwriting), driver's license number (where required).
• Financial information: household income range, net worth range, source of premium funds.
• Insurance information: existing insurance policies, beneficiary designations, replacement information for any policy being replaced.
• Health and lifestyle information: answers to medical questions necessary for life-insurance underwriting, including medical conditions, medications, tobacco use, family medical history, and hazardous activity history.
• Voice Recordings and Transcripts.
• Other information you provide voluntarily in the course of using the Service.

From third parties on your behalf.

With your authorization and for the purpose of completing your insurance application:

• Identity verification information from our identity-verification provider, AiPrise, and from other identity-verification or fraud-prevention services.
• Pharmacy benefit information from Milliman IntelliScript or equivalent prescription-history services.
• Medical Information Bureau (MIB) information.
• Motor Vehicle Report information from state motor-vehicle agencies through our authorized vendor.
• Public-record information from LexisNexis Risk Solutions or equivalent providers.
• Electronic Health Record information from Human API or equivalent providers, where you have specifically authorized retrieval.

Automatically when you use our website or Service.

Cookies, IP address, browser type and version, operating system, device identifiers, pages visited, referring URL, the time and duration of your visit. We use a limited set of first-party cookies and a small number of third-party cookies for analytics and security. See Section 3.10 for cookie details.

3.3

How we use your information.

We use the Personal Information described above for the following purposes:

• To provide the Service: to complete your conversation with the AI advisor, generate carrier illustrations, prepare and submit your insurance application, process your application through carrier underwriting, and service any policy you eventually purchase through us.
• For compliance review: a licensed human compliance officer reviews every submitted application for suitability and regulatory compliance before submission to the carrier.
• For quality assurance: to monitor and improve the AI advisor and our internal processes. This may include review of Voice Recordings and Transcripts by mnw personnel.
• For identity verification and fraud prevention: to verify your identity and prevent insurance fraud, money laundering, and other illegal activity, including via AiPrise and other third-party verification services.
• For legal and regulatory compliance: to comply with applicable state insurance laws, federal anti-money-laundering laws, court orders, lawful regulator inquiries, and other legal obligations.
• To communicate with you: to send you transactional and service-related communications, including illustration delivery, application status, underwriting requirements, policy delivery, and post-issue policy management.
• For marketing (limited): to send you communications about products and services that may be of interest. You may opt out of marketing communications at any time without affecting service-related communications.

We do not use Voice Recordings, Transcripts, or Personal Information collected through the Service to train artificial-intelligence or machine-learning models, except for limited internal evaluation of the AI advisor's performance and quality, with personally identifying elements removed.

3.4

Voice recordings and AI processing.

Because voice interaction is a core part of our service, this section provides additional detail.

Recording disclosure.

mnw's AI advisor records all telephone and voice-over-IP conversations with prospective and existing customers. The advisor announces this fact at the start of each conversation. Continuing the conversation after the recording disclosure constitutes consent to be recorded in all jurisdictions where mnw operates, including in states requiring all-party consent to call recording.

Use of recordings.

Voice Recordings and Transcripts are used:

• To provide the Service (to allow the AI advisor to reference prior turns in the conversation and to allow you to review what was said).
• For compliance review (a licensed human reviewer may listen to or read the recording when reviewing your case).
• For quality assurance and limited internal evaluation of the AI advisor's performance.
• To produce records required by state insurance regulations.

AI processing of voice content.

Your voice is processed by our AI advisor during the conversation. The AI may also generate Inferences from the conversation (such as the type of product you are likely to be interested in, your apparent financial sophistication level, or your understanding of specific product features). These Inferences are used to deliver a more relevant conversation and to flag cases for compliance review. They are treated as Personal Information for the purposes of this Policy.

Storage and security.

Voice Recordings and Transcripts are stored encrypted at rest and in transit. Access is restricted to mnw personnel with a service or compliance need to access them, our identity-verification and recording infrastructure providers, and authorized regulators.

Non-voice alternatives.

Every telephone and voice-over-IP call with mnw is recorded. Form, upload, and chat paths are planned non-voice continuations where available. Until those routes are live, ask for a licensed human follow-up or email privacy@mnw.agency before starting the call.

Voice biometrics.

Depending on your state of residence (including Illinois, Texas, Washington, and others with specific biometric-information statutes), the audio characteristics of your voice may constitute a "biometric identifier" subject to additional disclosure and consent requirements.

3.5

Identity verification.

When you submit an insurance application, mnw verifies your identity using AiPrise (operated by AiPrise, Inc.) and may use additional identity-verification and anti-fraud services. The verification process involves transmitting your name, address, date of birth, government-issued identifier, and, in some cases, an image of a government-issued identification document and a real-time photograph or video of you, to the verification provider. The provider returns a verification decision, a risk score, and (where applicable) the specific data points that did or did not match available records.

mnw retains the verification decision and audit trail. The verification provider's own retention and use of your information is governed by its agreement with mnw and the provider's own privacy policy. We require contractually that the provider use the information only for the purpose of completing the verification on our behalf.

3.6

Sharing and disclosure.

We share Personal Information with the following categories of recipients and only for the purposes stated below.

Insurance carriers.

When you submit an insurance application through mnw, we transmit your application information to the relevant carrier so the carrier can complete underwriting, issue the policy, and service the policy after issue. The carrier's use of your information is governed by the carrier's own privacy notice, which the carrier provides to you at application or issue.

Service providers and processors.

We share Personal Information with third parties that perform services on our behalf, including hosting providers, recording and transcription providers, identity-verification providers, communication providers (email, SMS), document-storage providers, and compliance-tooling providers. Each is bound by a written agreement requiring the provider to use the information only for the purpose for which we engaged it.

Legal compliance, law enforcement, and protection of rights.

We may disclose Personal Information when we believe in good faith that disclosure is required by law; in response to a valid subpoena, court order, or regulatory request; or to protect the rights, property, or safety of mnw, our customers, or others.

Business transfers.

In the event of a merger, acquisition, financing, reorganization, bankruptcy, or sale of all or part of our assets, Personal Information may be transferred to the successor or acquiring party, subject to the protections of this Policy.

We do not sell Personal Information.

We do not "sell" Personal Information for the purposes of CCPA / CPRA or analogous state statutes. We do not share Personal Information for cross-context behavioral advertising.

3.7

Your rights under California law (CCPA / CPRA).

If you are a California resident, you have the following rights:

• Right to know. You have the right to request that we disclose the categories and specific pieces of Personal Information we have collected about you in the preceding 12 months (or longer, if you so request and we maintain such records).
• Right to delete. You have the right to request that we delete Personal Information we collected from you, subject to the exceptions set out under California law and additional retention requirements imposed by state insurance regulations (see Section 3.13).
• Right to correct. You have the right to request that we correct inaccurate Personal Information we maintain about you.
• Right to limit use of Sensitive Personal Information. You have the right to limit our use of Sensitive Personal Information to those uses necessary to perform the Service.
• Right to opt out of sale or sharing. You have the right to opt out of the "sale" or "sharing" of Personal Information. As stated in Section 3.6, mnw does not sell Personal Information and does not share for cross-context behavioral advertising. This right is therefore not actionable against mnw's current practices; we describe it here for completeness.
• Right to non-discrimination. We will not discriminate against you for exercising any of these rights.

To exercise these rights, see Section 3.12 (Rights-request mechanics) below.

3.8

Your rights under other state privacy laws.

If you reside in Virginia, Colorado, Connecticut, Utah, Texas, Oregon, Montana, Delaware, Iowa, Nebraska, New Hampshire, New Jersey, Maryland, Minnesota, Tennessee, or any other state with a comprehensive consumer privacy law in effect at the time of your request, you may have rights substantially similar to those described in Section 3.7. The mechanisms to exercise these rights are described in Section 3.12 below.

3.9

Children's information.

The Service is not directed to children under 18 and we do not knowingly collect Personal Information from children under 18 except where a child is identified as a covered dependent on a policy purchased by an adult. If we learn that we have collected Personal Information from a child under 18 in any other context, we will delete the information.

3.10

Cookies and similar technologies.

mnw uses a limited set of first-party cookies and a small number of third-party cookies. Cookies fall into the following categories:

• Strictly necessary cookies: required for the Service to function, including session cookies, authentication cookies, and security cookies. These cannot be turned off.
• Performance and analytics cookies: measure how visitors interact with the Service so we can improve it. We use Google Analytics, operated by Google LLC. Google Analytics sets cookies under the _ga* namespace and processes information about your visit (including your IP address, in truncated form, and pages viewed) on Google's infrastructure. Google's use of your information is governed by Google's own privacy policy in addition to this Policy.
• Functional cookies: remember your preferences and choices.

We do not use cookies for cross-context behavioral advertising.

3.11

Security.

We maintain reasonable administrative, technical, and physical safeguards designed to protect Personal Information against unauthorized access, alteration, disclosure, or destruction. Specific measures include encryption of Personal Information in transit and at rest, access controls limiting access to personnel and processors with a need to know, regular security reviews, and an incident-response process. No security measure is perfect; in the event of a security incident affecting your Personal Information, we will notify you and applicable regulators as required by law.

3.12

Rights-request mechanics.

You may exercise any of the rights described in Sections 3.7 and 3.8 by:

• Submitting a request through the form linked at the bottom of this page.
• Emailing us at privacy@mnw.agency.
• Writing to the mailing address in Section 3.15.

We may need to verify your identity before processing your request. Verification typically requires you to confirm information we already maintain about you (such as the email address associated with your account, your date of birth, and other identifiers).

Timing.

We acknowledge each request within 10 days and resolve within 45 days, except where an extension is permitted by law and we provide notice of the extension.

Authorized agents.

You may designate an authorized agent to make a request on your behalf. The agent must submit proof of authorization in a form satisfactory to us, and we may require you to verify your own identity directly.

Appeals.

If we deny a request in whole or in part, you may appeal by following the procedure described in our response. State insurance departments and state attorneys general also have authority to investigate denied requests.

3.13

Retention.

We retain Personal Information for as long as necessary to provide the Service and to comply with our legal and regulatory obligations. Specifically:

• Insurance application records, including Voice Recordings and Transcripts: retained for seven years after the application is closed or the policy is terminated, whichever is later.
• Identity-verification records: retained for the period required by applicable anti-money-laundering and identity-verification regulations.
• Account information for customers who never purchased a policy: retained for 7 years after the last interaction.
• Marketing-list information: retained until you opt out, then retained as necessary to honor the opt-out.

Retention may override deletion rights.

Where state insurance regulations require us to retain records, we may not be able to honor a deletion request as to those records. We will tell you when this applies, what records we are required to retain, and for how long.

3.14

International users.

The Service is offered in the United States and is not directed to users outside the United States. If you access the Service from outside the United States, you do so at your own risk and you understand that your information will be transferred to and processed in the United States.

3.15

Contact.

Questions, concerns, or requests regarding this Policy may be directed to:

• Email: privacy@mnw.agency
• Mail: Meanwhile Agency LLC, 1209 Orange Street, Wilmington, DE 19801, Attn: Privacy

You may also contact your state's attorney general or insurance department with concerns about how we have handled your information.