Privacy PoLicy

At Marshall+Sterling, we believe in transparency and your right to understand how your personal information is handled when you visit our website. We are committed to maintaining the highest standards of data security and to protecting your personally identifiable information. This privacy policy outlines the practices regarding the collection, use and disclosure of information obtained through our website and reflects our dedication to compliance with applicable privacy laws and industry standards. (“Privacy Policy”).

Purpose of This Notice

Title V of the Gramm-Leach-Bliley Act (“GLBA”) generally prohibits any financial institution, directly or through its affiliates, from sharing nonpublic information about you with a non-affiliated third party unless the institution provides you with a notice of its privacy policy and practices, such as the type of information that it collects about you and the categories of personal information or entities to whom it may be disclosed. In compliance with the GLBA, Marshall+Sterling is providing you with this privacy policy, which notifies you of the policies and practices of our agency.  By continuing to engage with our website and/or our services, you acknowledge and accept these practices, including any updates we may make from time to time as described herein.

Our Privacy Policies and Practices

Information We Collect: To provide you with accurate insurance quotes, coverage options and financial services tailored to your needs, Marshall+Sterling may collect nonpublic personal information about you from the following sources, including but limited to:

• Information you voluntarily provide on applications, forms or through our website;
• Information about your transactions with us, our affiliates or others;
• Information and data we receive from consumer-reporting agencies including creditworthiness and credit history.

Cookies and Their Use on This Website: A cookie is a message given to a web browser by a web server. The message is then sent back to the server each time the browser requests a page from that server. Cookie files define you as a user, not as an identifiable person. Marshall+Sterling uses cookies and similar technologies to enhance your experience, improve website functionality and deliver content and services tailored to your preferences.  We do not use cookies to retrieve information from your computer that was not willingly provided by you. By continuing to use our website, you consent to our use of cookies as described.  You may adjust your browser settings to disable cookies, however doing so may limit your access to certain features or services.

Information We May Disclose to Third Parties: In the course of providing insurance and financial services, Marshall+Sterling may disclose nonpublic personal information as necessary to fulfill contractual obligations, comply with legal requirements and deliver products tailored to your needs. This may include:

• Information you provide on applications, forms or through digital channels, such as your name, address, Social Security number, assets, income and designated beneficiaries;
• Information about your transactions with us, our affiliates or service providers such as your policy coverage, premiums and payment history; and
• Information we receive from a consumer reporting agency, such as your creditworthiness, credit history and other relevant financial data.

Third Parties to Whom We May Disclose Information: In order to provide you with comprehensive insurance and financial services, Marshall+Sterling may disclose nonpublic personal information about you to the following types of third parties who assist in delivering, underwriting, servicing or marketing our products.  They may include:

• Financial service providers, such as life insurers, automobile and home insurers, commercial insurers, mortgage bankers, securities broker-dealers and insurance agencies;

• Technology vendors, data processors, and service providers who support our operations;
• Joint marketing partners and affiliated institutions with whom we have formal agreements.

All third parties are required by contract and/or applicable law to maintain the confidentiality and security of your information and to use it solely for the purposes for which it was disclosed. Such disclosures are made only as necessary to fulfill our obligations to you, comply with legal requirements, or improve the quality and efficiency of our services.

Service Providers and Joint Insurance Marketers: To support the delivery and promotion of our insurance and financial services, Marshall+Sterling may disclose nonpublic personal information we collect, as described above under the caption “Information We May Disclose,” to insurance companies, financial institutions and other organizations that perform marketing services on our behalf, or to other financial institutions with whom we have joint insurance marketing agreements. All third parties are contractually obligated to maintain the confidentiality and security of your information and to use it only for authorized purposes. By engaging with our services, you consent to these disclosures, which are conducted in accordance with applicable laws and industry standards.

Your Right to Opt-out of Third Party Disclosures: If you prefer that we not disclose nonpublic information about you to nonaffiliated third parties, you may opt out of those disclosures and direct us not to make those disclosures (other than disclosures permitted or required by law). If you wish to opt out of disclosures to nonaffiliated third parties, you may contact us during normal business hours. Our contact information is on our website in the Contact Us section. Your request must include sufficient identifying information to process the opt-out effectively.

Our Practices Regarding Information Confidentiality and Security: Marshall+Sterling is committed to safeguarding your nonpublic personal information.  Access to your personal information is strictly limited to employees, affiliates and authorized third parties who require that information in order to provide products or services, fulfill contractual obligations or comply with legal and regulatory requirements. We maintain physical, electronic and procedural safeguards that comply with applicable federal and state laws and regulations to guard your nonpublic personal information.  While we take reasonable and diligent steps to protect your data, no system can guarantee absolute security. Accordingly, we encourage you to take appropriate precautions when sharing personal information online and to notify us promptly of any suspected unauthorized activity. By using our services, you acknowledge and accept the inherent risks associated with digital communications and data storage.

Links and Co-Branded Sites: Our website may contain links to third-party or co-branded  websites for your convenience.  These external sites operate independently of Marshall+Sterling and may have privacy policies, security standards and data collection practices that differ from ours.  If you choose to use the services provided by those sites, you may be asked by those sites to provide certain personally identifiable information (some of which may, on an individual or aggregated basis, be shared with Marshall+Sterling). Marshall+Sterling is not responsible for the privacy practices of those sites, even though Marshall+Sterling’s name or logo may appear on those sites. We strongly encourage you to read the Privacy Statements of each and every external website that you visit before providing personal information or engaging with their services.  Your use of linked sites is at your own discretion and risk and Marshall+Sterling expressly disclaims any liability arising therefrom.

Our Policy Regarding Dispute Resolution: Any dispute, controversy or claim arising out of or relating to this Privacy Policy or a breach thereof or your use of our website shall be settled by arbitration in accordance with the rules of the American Arbitration Association, and judgment upon the award rendered by the arbitrator(s) may be entered in any court having jurisdiction thereof.  The arbitration shall take place in the state in which Marshall+Sterling maintains its principal office.  This agreement to arbitrate is intended to be interpreted broadly and shall survive any termination of your relationship with Marshall & Sterling.

Reservation of the Right to Change Our Privacy Policy: Marshall+Sterling reserves the right to modify, amend or replace this Privacy Policy without notice, at any time. We encourage you to review our Privacy Policy periodically to stay informed of how your information is used and protected.  Your continued use of our website or services following any changes constitutes your acceptance of the revised Privacy Policy regardless of whether you have reviewed the updated terms.

Marshall+Sterling
110 Main Street
Poughkeepsie, NY 12601
Tel: 845-454-0800
Fax: 845-454-0880

California Consumer Privacy Act Disclosures

Last Updated: January 1, 2025

This California Privacy Rights Disclosure supplements the Marshall + Sterling Privacy Statement and applies to California residents (“consumers”) whose personal information we collect, use, disclose, or otherwise process in the course of providing insurance products and services. This notice is provided pursuant to the California Consumer Privacy Act of 2018 (CCPA), as amended by the California Privacy Rights Act of 2020 (CPRA).

Marshall+Sterling is committed to maintaining the privacy and security of your personal information. The information below describes the categories of personal information we collect, the purposes for which we use it, the categories of third parties to whom we disclose it, and the rights available to California residents under state law.

1. Categories of Personal Information We Collect

In the past 12 months, we have collected the following categories of personal information, as defined by the CCPA/CPRA:

A. Identifiers

Such as name, aliases, postal address, email address, telephone number, account identifiers, policy numbers, IP address, and device identifiers.

B. Personal Information Under the California Customer Records Statute

Such as signature, Social Security number, driver’s license number, passport number, financial information (including partial credit card or bank account information used for billing), and medical or health-related information as necessary for underwriting.

C. Protected Classification Characteristics

Such as age, gender, marital status, veteran status, or other legally protected characteristics as required for underwriting.

D. Commercial Information

Such as insurance products purchased, policy numbers, transaction history, claim information, premiums, and customer account records.

E. Internet or Other Electronic Network Activity

Such as interactions with our website, browser type, device information, and log data.

F. Geolocation Data

Approximate location based on IP address or information provided for policy-related services.

G. Professional or Employment-Related Information

Such as occupation, employer information, business contact information, and loss-control data relevant to commercial lines.

H. Sensitive Personal Information (SPI)

Only collected as necessary to provide insurance services, including:

• Social Security numbers
• Driver’s license and state ID numbers
• Financial account numbers (non-tokenized)
• Health or medical information required for underwriting
• Precise identifiers needed for fraud prevention or regulatory compliance

We do not use or disclose Sensitive Personal Information for purposes other than those permitted by CPRA §1798.121.

I. Inferences

Such as risk profiles or insurance-related assessments developed from the information above.

2. Purposes for Collecting Personal Information

We collect and use personal information solely for legitimate business purposes related to providing insurance products and services, including:

• Underwriting, quoting, and placing insurance policies
• Managing customer accounts
• Processing claims
• Servicing policies and communicating with you
• Premium billing and accounting
• Fraud detection and prevention
• Regulatory reporting and compliance
• Website operation, security, and analytics
• Internal business operations and quality assurance

We do not collect or use personal information for purposes unrelated to our insurance business without providing additional notice.

3. Categories of Third Parties to Whom We Disclose Personal Information

We disclose personal information to the following categories of third parties solely for business purposes, including:

• Insurance carriers, wholesalers, MGAs, and program administrators
• Claims administrators, adjusters, and investigators
• Regulatory agencies, as required by law
• Service providers supporting IT, cybersecurity, analytics, document management, or communications
• Professional advisors (legal, financial, compliance)
• Third-party consumer reporting agencies used for underwriting or claims handling

We do not permit these third parties to use personal information for their own marketing or independent purposes.

4. Retention of Personal Information

We retain personal information for as long as necessary to:

• Provide insurance products and services
• Fulfill legal, regulatory, and contractual obligations
• Maintain business records in accordance with statutory retention schedules
• Support audit, compliance, and fraud-prevention activities

Retention periods vary by category of data and type of insurance product but are generally aligned with statutory insurance record-keeping requirements.

5. Sale or Sharing of Personal Information

Marshall + Sterling does not sell personal information and does not share personal information for cross-context behavioral advertising as defined by the CPRA.

We also do not use Sensitive Personal Information for any purpose requiring a “Limit the Use of My Sensitive Personal Information” link.

6. Your Rights Under the CCPA/CPRA

California residents have the following rights:

A. Right to Know / Access

To request the categories or specific pieces of personal information we have collected about you.

B. Right to Delete

To request deletion of personal information, subject to statutory exceptions (e.g., legal or regulatory retention requirements).

C. Right to Correct

To request correction of inaccurate personal information.

D. Right to Opt-Out of Sale or Sharing

Not applicable because we do not sell or share personal information.

E. Right to Limit Use of Sensitive Personal Information

Not applicable because we only use Sensitive Personal Information for exempt insurance-related purposes.

F. Right to Non-Discrimination

We will not discriminate against you for exercising any CCPA/CPRA rights.

7. Submitting a Privacy Request

To exercise your privacy rights, you may contact us through any of the following methods:

• Web Form: Contact Us
• Email: privacy@marshallsterling.com
• Toll-Free Number: 800-333-3766

We will verify your identity before processing your request and may request additional information solely for verification purposes.

Authorized agents may submit requests on your behalf with appropriate documentation.

8. Children’s Data

We do not knowingly collect or sell personal information of minors under 16 years of age. Any collection of information related to children occurs strictly in connection with insurance products where required by law or contract.

9. Updates to This Disclosure

We may update this disclosure from time to time to reflect changes in our practices or applicable law. The “Last Updated” date above indicates when this notice was most recently revised.