Privacy Policy

1. Who we are

Seven16 Activator is operated by Seven16 Group, LLC ([ENTITY], registered in [STATE]; the “Company,” “we,” “our,” or “us”) as part of the Seven16 Group family of commercial insurance distribution products. This Privacy Policy explains how we collect, use, share, and protect information when you visit seven16survey.com or use the Seven16 Activator platform (the “Service”).

Our role depends on how you interact with the Service:

• If you are a prospect completing a survey shared by a commercial insurance agent, we act as the data processor on behalf of the agent or agency that sent you the survey link (the data controller).
• If you are an agent, agency principal, wholesaler, or MGA using the Service to send surveys or review prospect responses, we are the data controller for your account information, and you are the data controller for prospect data routed through your attribution link.
• If you are a visitor reading marketing pages, we collect minimal analytics data.

2. Information we collect

2.1 Information you provide

• Contact and identity: first name, last name, email address, phone number (if you provide it), company name, company domain, job title, state.
• Survey responses: your answers to the questions in the vertical-specific survey you completed, including any free-text comments.
• Communication preferences and consent records: whether you have opted in to email, SMS, phone, or ringless-voicemail outreach, and when those consents were granted or revoked.

2.2 Information we collect automatically

• Technical metadata: IP address (stored in a hashed form for fraud detection and rate limiting), user agent string (hashed), referring URL, UTM parameters (utm_source, utm_medium, utm_campaign, utm_content, utm_term).
• Attribution: the agent slug embedded in the survey link you arrived from, used to route your response to the correct producer.
• Session lifecycle: timestamps for when you started and completed the survey (used for stuck-detection and fraud signals).
• Cookies: we use a small set of first-party cookies for session continuity and a third-party cookie set by LinkedIn Insight Tag (when configured) for conversion attribution. We do not use advertising cookies for retargeting outside the Seven16 Group family of products.

2.3 Information we do NOT collect

• Government identification numbers (SSN, EIN, passport).
• Driver license numbers or motor vehicle records.
• Bank account credentials, payment card numbers, or financial account access.
• Insurance policy numbers, claim numbers, or underwriting decisions.
• Health information.

3. How we use information

• Provide the Service: compute your assessment result, generate the agent follow-up brief, route your response to the attributed agent, and store your activation state.
• Communicate with you: send the result link, confirmation emails, and (only if you opt in) follow-up communications from the attributed agent.
• Improve the Service: analyze aggregated and anonymized usage patterns to refine survey questions, scoring formulas, and follow-up brief content.
• Fraud prevention and security:detect duplicate submissions, rate-limit abuse, identify bot traffic, and protect the Service from misuse.
• Comply with law: respond to lawful requests, enforce our Terms of Service, and meet regulatory obligations.

We do not sell your information to third parties. We do not use your information for advertising on platforms outside the Seven16 Group family.

4. How we share information

• With the attributed agent or agency:your survey responses and contact information are shared with the licensed commercial insurance agent or agency that sent you the survey link. This is the core purpose of completing the survey.
• With our service providers:Supabase (database hosting), Vercel (application hosting), Cloudflare (DNS and edge security), Seven16 Email API (email delivery), and any future providers explicitly named in this section. Each provider is bound by contractual confidentiality and security obligations.
• Within the Seven16 Group family:with sibling products (DotIntel, AgencySignal, Bind Lab, Seven16 Group Support, Seven16 Email, partners.seven16group.com) only as necessary to provide integrated functionality you have explicitly engaged with.
• For legal reasons: if required by subpoena, court order, regulatory request, or to protect rights, property, or safety.
• In a business transfer: if the Service is sold, merged, or reorganized, your information may be transferred as part of that transaction. We will notify you and honor the protections of this policy under any new owner.

5. Consent and communications

Email, SMS, phone, and ringless voicemail are each treated as separate consent channels. We never enable any channel without explicit, recorded opt-in. SMS communications, if any, require prior express written consent under the federal Telephone Consumer Protection Act (TCPA).

You can revoke consent for any channel at any time. Theunsubscribe endpoint(also accessible via the unsubscribe link in any email) immediately suppresses your email and phone number across all Seven16 Activator channels.

6. Data retention

We retain survey responses, agent attribution, and consent records for as long as needed to provide the Service and comply with legal obligations:

• Active prospect records:retained while the activation pipeline is in progress (typically up to 90 days after survey completion).
• Bound or testimonial-candidate records:retained for the duration of the underlying business relationship plus up to 7 years for record-keeping.
• Suppression list entries:retained indefinitely to honor unsubscribe requests across all future campaigns.
• Audit events: retained for 7 years for compliance and dispute resolution.

You can request deletion of your personal information at any time via theDelete My Datapage or by contacting us directly. When you delete your data, we anonymize the PII fields (name, email, phone, company, free-text answers) and preserve only the anonymized score and stage history for aggregate reporting.

7. Your rights

7.1 All users

• Request a copy of the personal information we hold about you.
• Request correction of inaccurate information.
• Request deletion of your personal information.
• Opt out of marketing communications at any time.

7.2 California residents (CCPA / CPRA)

California residents have additional rights under the California Consumer Privacy Act (as amended by the California Privacy Rights Act):

• Right to know what categories of personal information we collect, the sources, the purpose, and the categories of third parties with whom we share it.
• Right to delete personal information we hold about you.
• Right to correct inaccurate personal information.
• Right to opt out of the “sale” or “sharing” of personal information. We do not sell or share personal information for cross-context behavioral advertising.
• Right to limit the use and disclosure of sensitive personal information.
• Right to non-discrimination for exercising any of the above rights.

To exercise California rights, use theDelete My Datapage or contact privacy@seven16group.com. We will verify your identity before processing a request.

7.3 European Economic Area, UK, Switzerland (GDPR / UK-GDPR)

If you are located in the EEA, UK, or Switzerland, the General Data Protection Regulation (and equivalent local laws) provides additional rights:

• Lawful basis for our processing: legitimate interest in providing the Service and consent for marketing communications.
• Right of access (Article 15).
• Right to rectification (Article 16).
• Right to erasure (Article 17) — exercise via Delete My Data.
• Right to restriction of processing (Article 18).
• Right to data portability (Article 20).
• Right to object to processing (Article 21).
• Right to lodge a complaint with your local data protection authority.

International data transfers: data may be processed in the United States. When transferring personal information from the EEA, UK, or Switzerland to the US, we rely on Standard Contractual Clauses (SCCs) and supplementary technical measures (encryption in transit, RLS, hashed identifiers).

8. Cookies and tracking

We use a small set of cookies:

• Session cookies (first-party): maintain your survey session and consent state. Strictly necessary; cannot be disabled without breaking the survey.
• Partner attribution cookie(first-party, seven16_partner_ref): tracks referral attribution for the Seven16 Group Partner Program. Lifespan up to 90 days.
• LinkedIn Insight Tag(third-party, set by snap.licdn.com when configured): conversion attribution for LinkedIn campaigns. Currently dormant; will be active only when explicitly enabled.

You can disable cookies in your browser. Disabling session cookies will prevent survey completion.

9. Security

We use industry-standard practices to protect your information:

• Encrypted transport (TLS 1.2+) for all connections.
• Row-Level Security (RLS) on every database table; cross-tenant access is technically blocked.
• Hashed storage of IP addresses and user agents to prevent re-identification.
• Least-privilege access controls for administrative roles.
• Audit logging of all administrative actions.
• Regular security advisories from our infrastructure providers (Supabase, Vercel, Cloudflare).

No system is perfectly secure. If we become aware of a security incident affecting your personal information, we will notify you and applicable authorities as required by law.

10. Children's privacy

The Service is intended for business users — commercial insurance agents, agency principals, wholesalers, MGAs, and the owners or operators of small and mid-sized businesses. We do not knowingly collect personal information from children under 16. If you believe a child has provided information to us, contact privacy@seven16group.com and we will delete it promptly.

11. Changes to this policy

We may update this policy from time to time. When we make material changes, we will update the effective date at the top of this page and, where required by law, notify affected users by email. Continued use of the Service after a material change constitutes acceptance of the updated policy.

12. Contact

For privacy questions, data access requests, deletion requests, or other concerns:

• Email: privacy@seven16group.com
• Postal: Seven16 Group, LLC, [REGISTERED_ADDRESS]
• Self-service deletion: /privacy/delete-my-data