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Policies & Agreements

Privacy Policy

I. Your Privacy

Privilege Underwriters Inc., and its subsidiaries and affiliates, including Privilege Underwriters Reciprocal Exchange and PURE Specialty Exchange (collectively "PURE", “we” or “us”) are committed to protecting your privacy. This Privacy Policy discloses how we collect, protect, use and share information gathered about you (a) on our website, (b) offline or when you contact us via email or through our service and claims centers, (c) from third parties, including publicly-available information, (d) or any related online or offline services we provide. Note that customers of any PURE insurance products or services will receive a Customer Privacy Notice, which will supersede this policy to the extent there is any conflict. This policy also describes your choices about the collection and use of your information.

Please read this Privacy Policy carefully before you use our services. By using the services, you agree to be bound and abide by this Privacy Policy and our posted Legal Notices, as applicable. 

II. Collection, Use, and Sharing of Personal Information

A. Collection of Personal Information

We often collect information that can be used to identify or contact a particular person (we refer to this type of data as "personal information"). The types of personal information we collect and process depends on which of our products or services you may use. In addition to the personal information you provide us, PURE may collect personal information through use of our website or other services, from online sources (e.g., social media platforms), and from various reporting or databases and agencies or bureaus. The personal information we collect about you can include:

  • Identifiers: Full name; work or home postal address; work, mobile or home telephone number; work or personal email address; any other personal information you may provide when contacting us or submitting an inquiry, username, Social Security Number, date of birth, and driver’s license number.
  • Other Personal Information such as profile preferences, responses to any surveys we send you, communications (such as via email, mail, phone, or other channels).
  • Financial Information: Credit card information and credit reporting information such as credit scores.
  • Employment Information: Occupation and Employer.
  • Commercial Information: Whether your own or rent your residence; information about your property; and products or services purchased, obtained, or considered.
  • Internet or other electronic network activity information: Internet Protocol (IP) address, device identifier and cookie data (including third-party cookies and related data).
  • Vehicle information: motor vehicle and claims histories, vehicle operator information, mortgages, lien or lease holder information.

We collect your personal information, for example, when you:

  • Apply for insurance, file a claim, contact us for information or with questions.
  • Send us emails or other correspondence.
  • Communicate with us by telephone (please note that we may record or monitor the call).
  • Visit or interact with our website and online services (such as our member portal).

If you provide us with information regarding another individual (e.g., a family member), you represent that you have any necessary consent(s) to give us their information for use in accordance with this Policy

B. Use of Personal Information

PURE collects and uses personal information to: underwrite insurance policies; adjust claims; operate the other functions necessary to provide you with the products and services we offer; monitor and improve our products and services; improve our websites and services; review or enhance our marketing, promotional activities and communications; and comply with and enforce as needed legal requirements, industry standards, our policies, and our contractual rights.

Most importantly, we use your personal information for the following purposes:

  • If you apply for insurance or file a claim with us: we use your personal information to determine coverage, issue and administer your policy, process payment, adjudicate claims, and contact you regarding your policy and claims. In these situations, we may need to process your personal information to comply with relevant laws or fulfill our obligations under an insurance contract to which you are subject.
  • If you use our member portal or are a broker logging on to PURE Online: we use your personal information (including username and password) as necessary to register, maintain and secure your account (e.g., to identify you at sign-in and prohibit others from accessing your account) and communicate with you. These processing activities are based on your consent or our legitimate interest in securing our services and improving your experience while using our website.
  • If you email us or otherwise submit an inquiry or request: we use your personal information as necessary to respond to you and provide you with the information requested. These processing activities are either based on your consent or our legitimate interest in communicating with you about our products and services, or are necessary to provide you with the products or services requested.
  • A credit report or other consumer report about you may be used to develop an insurance score. Your insurance score may be used to review your application for insurance and subsequent amendments and renewals. An insurance score uses information from your credit and/or consumer report to help predict how often you are likely to file claims and how expensive those claims will be. Insurance score information may then be used to determine how much we will charge for insurance. Items from a credit report that could affect an insurance score include payment history, number of revolving accounts, number of new accounts, and the presence of collection accounts, bankruptcies and foreclosures. We will use information provided by LexisNexis (formerly ChoicePoint) or an equivalent third-party vendor in connection with the development of your insurance score. We engage in these processing activities based on our legitimate interest in properly assessing insurance eligibility, rates, and coverage.
  • For any other purpose for which you provide affirmative consent or specific instructions.

PURE or PURE’s authorized service providers may use artificial intelligence (AI) to provide products or services to you, which may involve the use of your Personal Information.  PURE may use AI in connection with PURE’s products or services to aid, assist, and facilitate PURE’s business, including but not limited to underwriting, pricing, claims handling, or other business-related activities, at all times in compliance with applicable laws and regulations.  In addition, PURE may use AI to enhance user experience on PURE’s websites and other applications. The type of AI used may vary based on your engagement with PURE, or vary based on the product or service provided by PURE.

C. Sharing of Personal Information

We disclose the following personal information about consumers for business purposes:

  • All Personal Information.  We may share personal information with service providers who need the information to perform a technology, business, or other professional function for us (examples include IT services, hosting our website, payment processors, marketing partners, and other service providers). We only provide such vendors with information so they can perform their required functions on our behalf.
  • Internet or other electronic network activity information. We may allow third parties to utilize cookies and similar tools on our websites to receive limited information (e.g., IP address, pageview, etc.) to measure site performance, and for marketing or advertising purposes customized to your apparent interests or needs (more information located in the Cookies section below)

We may also potentially disclose personal information for the following reasons:

  • We may disclose personal information (i) if required to do so by law or legal process, (ii) when we believe disclosure is necessary to prevent harm or financial loss, (iii) in connection with an investigation or suspected or actual fraudulent, or illegal activity, or (iv) under exigent circumstances to protect the personal safety of our staff, users, or the public.
  • If we reorganize or transfer all or a relevant portion of our business or assets, we may transfer personal information to the reorganized or new business as needed, provided that we will make reasonable efforts to direct the recipient to use personal information in a manner that is consistent with this Policy.
  • We also share personal information (such as transactions and experiences with PURE) among our affiliates, including Privilege Underwriters, Inc. (PUI), PURE Insurance Company (PIC), PURE Risk Management, LLC (PRM), PURE Specialty Risk Management (PSRM), PURE Art Services (PAS), and PURE Programs LLC, for our legitimate interest in performing group administrative purposes.

We do not sell personal information for monetary compensation, but as described above, certain limited information may be shared through cookies and other techniques in connection with marketing partners. 

Note that we do not share your text message program enrollment or consent with third parties for their own purposes. Where appropriate, we will limit the sharing of your information in accordance with the choices you have provided to us and consistent with applicable law.

D. Your Privacy Choices

We offer you certain choices about what information we collect from you, how we use and disclose the information, and how we communicate with you.

  • Marketing Emails: From time to time, we may contact you via email for the purpose of providing announcements, promotional offers, alerts, confirmations, surveys, and/or other general communications. You may choose not to receive marketing emails from us by clicking on the unsubscribe link in the marketing emails you receive from us. Even if you opt out of receiving such communications, we will continue sending you non-marketing email communications, such as administrative or transaction alerts, or information about changes to our Legal Notices or this Policy, when necessary.
  • Text messages: If you affirmatively consent to receive text messages from us and enroll in such a program, you will receive updates via text unless you opt-out of the text message program. These messages may be unencrypted. Message frequency may vary based on the Services. If at any time you would like to stop receiving text message notifications, please text “STOP” in reply to our message, we will send you a reply message to confirm that you have been unsubscribed and you will no longer receive messages from us. If you want to join again, just sign up as you did the first time and we will start sending messages to you again. If at any time you forget what keywords are supported, just text “HELP” back to us and we will respond with instructions on how to use our service as well as how to unsubscribe.
  • Cookies: Web browsers may offer users the ability to disable certain types of cookies; however, if cookies are disabled, some features or functionality of our Services may not function correctly. We may also implement a cookie banner or similar opt-out tool on our website through which you can disable third party performance and targeting cookies. Cookies are addressed in greater detail below.
  • Jurisdiction-specific rights: See the relevant sections below for certain privacy rights that you may be able to exercise based on the jurisdiction where you reside.

III. Cookies

Cookies are a commonly-used web technology that allow websites to store and retrieve certain information on a user’s system, and track users’ online activities. We, together with vendors we use, may collect information about your use of our services by such automated means, including but not limited to cookies, pixels and other similar technologies. 

Cookies and similar technologies can help us automatically identify you when you return to our services. Cookies help us review website traffic patterns, improve the services, and determine which services are popular. We can also use such information to deliver customized content and advertising to users of the services whose behavior indicates that they are interested in a particular subject area. We may also share with or allow third parties to utilize cookies for marketing or advertising customized to your apparent interests or needs. 

You have the ability to accept or decline cookies using your web browser settings. If you choose to not accept cookies from our website, you may not be able to take full advantage of its features or to receive some of the services that it provides. To learn more about cookies and your ability to opt-out of certain advertising cookies, please visit the following websites: http://www.aboutads.info/choices or http://www.networkadvertising.org/choices.

For example, the website uses Google Analytics, a web analytics service provided by Google, Inc. (“Google”). Google Analytics may set cookies on your browser or mobile device or read cookies that are already there to collect information. Google Analytics may also receive information about you from apps you have downloaded that partner with Google. Google Analytics collects information such as how often you use the website and how you use the website. We use the information provided by Google Analytics to improve the website and our services. For more information regarding how Google collects, uses and shares your information and how to opt out of certain uses please visit http://www.google.com/policies.

IV. Non-Personal and Aggregated Information

We may use or share information in an anonymized or aggregate manner for many purposes such as research, analysis, modeling, marketing, and improvement of our services. Once de-identified, such information is not subject to this Policy.

V. International Transfers of Information

 Our services are primarily intended for use in the United States, although our affiliates may operate similar services in other jurisdictions around the world and they may support these services from such jurisdictions. If you use our services from outside the United States, you acknowledge and agree that we may transfer your information to and from the United States, including countries which may not guarantee the same level of protection of personal information as the one in which you reside. However, we will handle your personal information in accordance with this policy regardless of where your personal information is stored or accessed. Notwithstanding the foregoing, we will endeavor to accommodate requests with respect to your information to the extent required by law and otherwise in our reasonable discretion.

VI. Security 

We endeavor to maintain reasonable administrative, technical and physical safeguards (encryption, passwords, physical security, etc.) designed to protect your personal information against unauthorized access and disclosure. However, we cannot ensure the security of any information you transmit to us, or guarantee that this information will not be accessed, disclosed, altered, or destroyed. Therefore, we do not promise, and you should not expect, that your personal information provided through our website will always remain private. We will make any legally required disclosures in the event of any compromise of personal information. To the extent the law allows us to provide such notification via e-mail or conspicuous posting on the Services, you agree to accept notice in that form. 

VII. Links to Other Websites and Third Party Content

Our services may contain links to other websites or online services, including social media. Please be aware that we are not responsible for the content or privacy practices of such other websites or online services, and we encourage you to be aware when you leave our services and to read the privacy statements of any other website or online service that collects personal information.

You may see us promoted by other businesses on various websites, web pages, social media or other platforms. Please note that we do not always have complete information about where our brand may be displayed or promoted, and if you believe that we are featured in venues that are inappropriate or offensive, please contact us.

VIII. State-Specific Notices

Note: A number of state privacy laws grant individuals a right to access, correct or delete personal information maintained about them by a business, as well as the ability to opt-out of certain data activities. However, PURE is an insurance business primarily subject to federal privacy laws including the Gramm-Leach-Bliley Act (GLBA) and Fair Credit Reporting Act (FCRA) and is therefore subject to exceptions provided by such state laws. Likewise, the specific insurance-related information we maintain about customers is subject to such exceptions. 

This Section is provided specifically for residents of California, Oregon and Minnesota. In addition to the disclosures and rights provided above in this policy, you may have certain rights with respect to the collection, use, transfer and processing of your personal information, as described below, subject to the exceptions that apply to us or your data as described above. To exercise any of the rights below, please contact us using the applicable contact information below. Only you, or a person duly authorized to serve as your agent, may make a request related to your personal information.

A. Collection and Use of Personal Information

This Section elaborates on the disclosures at the top of this policy in regard to the categories of personal information we may about you: 

  • Internet or other electronic network activity information: Browsing history; Search history; Information regarding a consumer’s interaction with an Internet Web site, application, or advertisement; Internet Protocol address; Device ID; Cookies; Beacons; Pixel Tags; Mobile Ad Identifiers
  • Identifiers: Personal Identifiers; Name; Address; Email address; Telephone number; Date of Birth; Social Security number; Signature

The foregoing types of personal information have been collected about consumers in the past 12 months. All other personal information collected about consumers is in connection with the furnishing of insurance or in response to a request for insurance. Such personal information is collected and handled pursuant to applicable federal and/or state insurance laws and therefore exempt from general state privacy laws.

  • We collect identifiers, through third-party lead generators and credit services.
  • We collect internet or other electronic network activity information from interactions with our website.

Such personal information is used for the following purposes: (i) Authenticate identity; (ii) marketing purposes; (iii) Respond to court orders and legal investigations; (iv) Provide customer service and support; (v) Safeguard against potential fraud; (vi) Protect data from unauthorized parties and comply with legal requirements; (vii) Enforce this Policy, our Legal Notice, and any other agreements entered into with us; (viii) Send offers and promotions for our products and services; (ix) Operate, understand, optimize, develop, or improve our sites, applications, products, services and operations; (x) Detecting security incidents, protecting against malicious, deceptive, fraudulent, or illegal activity, and prosecuting those responsible for that activity; (xi) Debugging to identify and repair errors that impair existing intended functionality; and (xii) Investigate and prevent activities that may violate our policies.

PURE shares such information with affiliates, analytics providers, service providers, IT vendors, and law enforcement (if necessary), as further described above.

In the preceding 12 months, we have disclosed personal information to third parties for business or commercial purposes as described below:

1. Auditing related to a current interaction with the consumer and concurrent transactions, including, but not limited to, counting ad impressions to unique visitors, verifying positioning and quality of ad impressions, and auditing compliance with this specification and other standards.

  • Internet or other electronic network activity information

2. Detecting security incidents, protecting against malicious, deceptive, fraudulent, or illegal activity, and prosecuting those responsible for that activity.

  • Identifiers

3. Debugging to identify and repair errors that impair existing intended functionality.

  • Identifiers
  • Internet or other electronic network activity information

4. Performing services on behalf of the business including maintaining or servicing accounts, providing customer service, processing or fulfilling orders and transactions, verifying customer information, processing payments, providing financing, providing advertising or marketing services, providing analytic services, or providing similar services on behalf of the business or service provider.

  • Identifiers
  • Internet or other electronic network activity information

5. Undertaking internal research for technological development and demonstration.

  • Internet or other electronic network activity information

B. Individual Rights

If you reside in one of the states specifically referenced above, you may request:

  • To know if we have their information, or alternatively, a copy of the following: (1) the categories of personal information we collected about you; (2) the categories of sources from which the personal information is collected; (3) the business or commercial purpose for collecting or selling (if applicable) the personal information; (4) the categories (or in some states, the identity) of third-parties with whom we shared personal information, and the categories of personal information shared; and (5) the specific pieces of your personal information that we have collected, used, disclosed, or sold.
  • That we (and our service providers) correct your personal information if it is inaccurate or delete your personal information. Note that deletion requests are subject to certain limitations, for example, we may retain personal information as permitted by law, such as insurance-related information as explained above, and for tax or other record keeping purposes, to maintain an active account, to process transactions and facilitate customer requests, and for certain other internal business purposes described in this Policy.
  • To opt out of (i) any selling or sharing of your personal information to a third-party (excluding service providers or other exceptions permitted by law); (ii) any third-party targeted advertising (i.e., cross-context behavioral advertising); (iii) any use of sensitive personal information (such as precise geo-location or financial information) except for the purposes it was collected and as otherwise permitted by law; (iv) impactful profiling activities or automated decision making activities with respect to your personal information. As described above, certain identifying information with cookies may be shared with brands/services we partner with, advertising businesses and other third-parties through, and anyone can opt-out of such cookies through our website cookie banner or other opt-out mechanism.

You can submit your request by calling us at 914.992.0012. You may also submit a request via email at [email protected]. We will process your request in a manner and timeframe proscribed by any applicable privacy law, subject to the applicable exceptions including in our capacity as an insurance business.

Note that before completing any privacy request, we will take steps to verify you as the person (or authorized agent) to whom the information relates, and you may be required to promptly respond as necessary to any verification requests we communicate to you. 

If we deny a privacy request, you may appeal the decision to us at the contact information provided below or in our denial notice. To the extent possible, please describe the basis for your appeal and if there is any specific personal information that concerns you. We will endeavor to provide a prompt response and within the timeframe provided by any applicable law.

If you are unsatisfied with our response to an appeal, you can raise your concerns with your state’s Office of the Attorney General.

C. No Discrimination

We may not, and will not, discriminate against any customer for exercising their privacy rights, including those provided by the applicable privacy laws. Please note that we may otherwise continue to share your personal information with our affiliates and service providers, and as otherwise directed by you, for the purposes described in our Policy.

D. Additional Disclosures for California Residents

PURE does not generally assign monetary value to consumers’ personal information or offer financial incentives in return for personal information. 

Privacy rights in California apply to all individuals (not just retail customers), including job applicants, current and former employees, contractors and business partners. Due to the nature of these relationships, the collection and use of personal information can vary, but all such individuals can request additional information about our privacy practices with respect to their information, as well as make the access, deletion, correction and opt-out requests, by contacting us as described above.

Please note that we currently do not have technology that would respond to web browser “Do Not Track” signals and handle all information subject to this policy and our cookie opt-out tool. We do endeavor to respond to Global Privacy Control (GPC) signals.

X. Retention and Deletion of Personal Data

PURE implements and maintains reasonable restrictions on the retention of personal information and generally endeavors to dispose of such personal information once it is no longer necessary for the purposes for which it was collected or further processed, including for any business, legal, accounting or reporting requirements. To determine the appropriate retention period for such personal information, we consider the amount, nature, and sensitivity of the information, the potential risk of harm from unauthorized use or disclosure of the information, the purposes for which we process the information and whether we can achieve those purposes through other means, as well as all applicable legal requirements. We may continue to store archived copies of your personal information for legitimate business purposes and as necessary to comply with applicable law. In addition, we may continue to store anonymous, aggregated or anonymized information for any legitimate business use described in this policy.

XI. Children’s Information

Our services are not intended for use by children. We do not knowingly collect personal information from children under legal age. Please contact us if you believe we may have unknowingly collected information about a child under legal age, and we will take immediate steps to delete any such personal information.

XII. Updates to this Policy

The effective date of our most recent privacy policy is indicated at the top of this page. We may change this privacy policy from time to time by updating this page. By using our website or sending us any personal information after the indicated effective date, you signify your agreement with this policy and you will be deemed to be bound to the policy in effect as of the date of such use.

XIII. Contact Us

If you would like to review or ask us to correct information you have submitted to us through our website, you may do so by contacting us as follows:

Kirk Raslowsky, General Counsel
1 North Lexington Avenue, Suite 1900, White Plains, NY 10601
t: 914.992.0012 | e: [email protected]

Effective Date: September 23, 2025

NY State Insurance Law §2612, Confidentiality Notice
Click here to access a printable version of the NY State Insurance Law §2612, Confidentiality Notice.

DO NOT SELL OR SHARE MY PERSONAL INFORMATION

As a California resident, you have the right to tell us not to 'sell' or 'share' your personal information under California Consumer Privacy Act ("CCPA"), as modified by the California Privacy Rights Act ("CPRA"). We do not sell your Personal Information to third parties for money. However, we use certain third party analytical cookies or other technologies that may be considered 'sales' or 'sharing' under the CCPA.

We are in the process of implementing a third-party tool that will allow you to opt-out of our use of cookies directly through this page. At this time, you may exercise your right to opt-out of our use of cookies and tracking technologies through the controls available to you in your browser (described below). Additionally, you can opt-out of tracking by Google Analytics by clicking this link and learn more about how to manage your cookies by visiting www.aboutcookies.org.

To access your browser controls, enter the settings section of your browser. From the settings section, search the privacy settings for controls regarding cookies, site data, and site permissions. In these settings, you may control what cookies you permit to be placed on your device, including by prohibiting the placement of any cookies and deleting existing cookies.

Please note that some portions of our Site may not run properly if cookies are disabled.

More Information

Please review our Privacy Policy for a complete description of our data management practices and your rights under California law.

Accessibility

Accessibility Assistance.

If you have difficulty using or accessing any element of this website, the Member Portal, or on any PURE Insurance mobile app or tool, please feel free to call us at 888.813.7873 or email us at [email protected] and we will work with you to provide the information, item, or transaction you seek through a communication method that is accessible for you consistent with applicable law (for example, through telephone support).

Goal of being better for All.

PURE Insurance desires to provide a positive customer experience to all our customers, and we aim to promote accessibility and inclusion. Our goal is to permit our customers to successfully gather information and transact business through our websites.

Whether you are using assistive technologies like a screen reader, a magnifier, voice recognition software, or captions for videos, our goal is to make your use of PURE Insurance’s websites a successful and enjoyable experience.

Actions.

We are taking a variety of steps and devoting resources to further enhance the accessibility of our websites.

Ongoing Effort.

Although we are proud of the efforts that we have completed and that are in-progress, we at PURE Insurance view accessibility as an ongoing effort.

Feedback.

Please contact us if you have any feedback or suggestions as to how we could improve the accessibility of our websites.