Diligence International Group LLC is strongly committed to maintaining the privacy of your Personal Information

Diligence International Group LLC, its affiliates and related entities (hereinafter known as “Diligence”, “we”, “our”, or “us”) are committed to protecting the privacy of your personal information and providing you with a secure experience as practically possible in the use of our website, mobile apps, and the provision of our diverse business services that we offer which can be found in more detail at: https://digroup-us.com/about.

This Online Privacy Policy (“Privacy Policy”) explains what information we collect and how we use it. We collect and use “nonpublic personal information” in order to provide our customers with a broad range of financial products and services as effectively and conveniently as possible. We treat nonpublic personal information in accordance with our Privacy Policy.

Definitions

Most capitalized terms are defined within this Privacy Policy. However, other important terms are also included here.

  1. “Communications”: Any mode of interacting with you relating to our communications, such as email, online or offline newsletters and related materials, that reference this Privacy Policy.
  2. “Personal Information”: Recognizing that the definition of personal information varies significantly based on applicable law or standard, for purposes of this Privacy Policy, we define personal information as any information that identifies, relates to, describes, or is capable of being associated with, a particular individual. This may include information such as a unique personal identifier, name, alias, social security number, date of birth, physical description, address, telephone number, e-mail address, passport number, driver’s license or state identification data, account information, insurance policy data, education, employment-related information, financial information, medical information, health insurance information, commercial information or other purchase or consumption data, biometric information, Internet Protocol address, online identifiers or other electronic network information activity, geolocation data, audio, electronic, visual, and inferences drawn from any of the information identified to create a profile about a consumer reflecting the consumer’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, and aptitudes.
  3. “Website” or “Websites” mean web pages of the https://digroup-us.com/ website, that is designated as a United States website or web pages, or any other website with respect to which this Privacy Policy is posted or linked.

Legal Requirements pertaining to Personal Information

  1. Collection and purpose limitation: Diligence collects Personal Information only when necessary and uses it in line with its purpose for collection.
  2. Data quality: To the best of our ability, Diligence strives to ensure that the Personal Information it processes is accurate, complete, timely and relevant to the purpose for which it is collected.
  3. Data retention and destruction: Diligence maintains its records as required by applicable laws and regulations. Any, and all Personal Information shall be retained to fulfill the purposes outlined in this Privacy Policy and destroyed in accordance with our policies governing data retention and in compliance with applicable laws and regulations.
  4. Legal basis for processing personal information: Diligence shall establish a legitimate legal basis for the processing (collecting, using, sharing, etc.) of Personal Information. Where there are specific requirements for that legal basis, such as consent, we shall abide by those requirements where it is in our control.
  5. Record of data processing: Diligence maintains its records as required by applicable laws and regulations, and where required, retains records of data processing activities.
  6. Data transfers: Diligence is a United States limited liability company and may transfer certain Personal Information across geographical borders to other Diligence affiliates and related entities or to outside companies working with us or on our behalf. We may also store Personal Information in a jurisdiction other than where you are based, and such jurisdiction may not provide the same level of protection for your Personal Information as your home country. By providing your Personal Information to Diligence, you are consenting to this transfer and/or storage of your Personal Information across geographical borders. Each Diligence affiliate and related entity is required to safeguard Personal Information in accordance with its contractual obligations and data protection legislation applicable to its provision of services. Your Personal Information will only be transferred if appropriate or suitable safeguards are in place.
  7. Transparency and notice: Where required and where Diligence obtains the Personal Information for its own purposes and not through a contractual agreement, Diligence shall communicate transparently with individuals regarding Diligence’s privacy practices by providing them with this Privacy Policy which is posted on the https://digroup-us.com/ website. Notice shall be provided at or before (or as soon as practical thereafter) the time Personal Information is collected, and when Diligence changes its privacy practices and procedures that impact what notice shall be provided. Where applicable, this Privacy Policy shall be mobile-optimized for readability on mobile devices.

Protecting Information

We maintain security policies and practices in our facilities and systems to protect appropriate information from unauthorized access and inappropriate disclosure, alteration or destruction. Security may include, but is not limited to, encryption, physical access security and other appropriate technologies. Our team continually reviews and enhances security systems as necessary. Personnel failure to hold in confidence private information is subject to our disciplinary process. Personnel are required to execute an acknowledgement of their receipt and understanding of our policies and procedures containing confidentiality obligations, to which they are subject.

We do not provide private information to the general public. We do not compile or distribute mailing lists or consumer marketing data from information received from clients. We do not modify or correct information obtained from other persons or organizations, since such information is not prepared by us.

What Information we collect and from whom we collect it

  1. Information we receive from you on applications or other forms
  2. Information about your transactions with us, our affiliates, or others
  3. Information we receive from non-affiliated third parties, including consumer reporting agencies
  4. Information we receive from you voluntarily, such as your e-mail address and any information contained in your e-mail messages

“Nonpublic personal information” is nonpublic information about you that we obtain in connection with providing a financial product or service to you.

What Information we disclose and to whom we disclose it

We do not disclose any nonpublic personal information about you to either our “affiliates” or non-affiliates, except as permitted or required by law. We may disclose the nonpublic personal information we collect, as described above, to persons or companies that perform services on our behalf and to other financial institutions with which we have joint marketing agreements.

“Our affiliates” are companies with which we share common ownership and which offer products or services. Other reasons we may disclose what we know about you include:

  1. Doing what a court or government agency requires us to do; for example, complying with a search warrant or subpoena.
  2. Telling another company what we know about you if we are or may be selling all or any part of our business or merging with another company.

Our Security Procedures

We restrict access to your nonpublic personal information and only allow disclosures to persons and companies as permitted by law to assist in providing products or services to you. We maintain physical, electronic, and procedural safeguards to protect your nonpublic personal information.

You may obtain a more detailed description of the information practices prescribed by law by contacting us directly at [email protected].

Sharing Personal Information

We do not share Personal Information with unaffiliated third-parties, except as stated in this Privacy Policy, including as necessary for our legitimate professional and business needs, to carry out your requests, to market our services, as required or permitted by law, or otherwise with your consent.

In some instances, we may share Personal Information about you with various third-party service providers and vendors working on our behalf. These third-parties include providers of website hosting, infrastructure provisioning, IT services, customer service, e-mail delivery services, marketing and advertising services, and other similar service providers. We may share your usage and Personal Information with mobile carriers, platform providers and other similar entities in connection with the operation of the website or communications.

Each third-party is required to safeguard Personal Information in accordance with its contractual obligations and data protection legislation applicable to its provision of services.

We may share your Personal Information with subsidiaries or affiliates of Diligence, so that they may send you information about special interests or services that may be of interest to you based on your purchase history, activity on our website, communications and other information that you have given us.

We may share your Personal Information with law enforcement and regulatory authorities or other third-parties as required or permitted by law, including for the purpose of: 1) responding to a subpoena, court order or other legal processes; 2) defending, protecting or enforcing our rights; 3) assisting in the event of an emergency; and 4) complying with applicable law or regulation.

If we sell, transfer, or otherwise share some or all our assets in connection with a merger, reorganization, liquidation, dissolution, or sale of assets, we may transfer your Personal Information without your consent.

We may share some aggregated, anonymized, and statistical non-Personal Information with third-parties to better understand how our website or other apps are used and to improve user experience.

Cookies

We make use of both session and persistent cookies on websites we own and operate directly or operate indirectly through a third-party partner. Cookies are small pieces of data that are stored by the user’s web browser on the user’s hard drive. Cookies are utilized by websites to enhance a user’s experience and remember information such as username, language, viewing preferences, shortcut navigation and other user preferences. On some websites under our direct or indirect control, user’s browsing and/or buying habits are also tracked and stored in a cookie. However, at no point in time will any user’s medical or health information be stored in cookie data.

Server and Application Logging

Our servers automatically collect Internet Protocol (IP) addresses which are used solely for reporting demographic information, number of visits, and in communications troubleshooting. Authentication credentials are also recorded to comply with auditing requirements and assist in the investigation of customer-initiated service requests. As we upgrade, enhance, modify or maintain our systems, services and procedures, modifications may be made to this policy.

Obtaining and Sharing Information

We respect the privacy of individuals while obtaining information for legitimate businesses that can demonstrate an appropriate need for the information. We obtain information ordered by our clients using sources identified by clients – either the subject individual or a reputable source. We obtain and disclose such information pursuant to appropriate written authorizations to gather information for our clients for the purposes of their underwriting and servicing of insurance policies, and for their other legitimate purposes authorized by law. We handle such information in accordance with our clients’ directions, the written authorizations, our contracts with clients, and applicable law. We do not share information we obtained for a client with our other clients, unless the subject’s authorization permits such.

Kinds of Information

We are authorized by our clients to act as their representatives in obtaining information on individuals regarding the following:

  • Health history
  • Medical information
  • Family history
  • Lifestyle character
  • General reputation
  • Habits, use of alcohol and other drugs
  • Driving records
  • Marital status
  • Death records
  • Civil and criminal court records
  • Past and present employment and job duties
  • Finances
  • Other insurance coverage
  • Participation in hazardous hobbies or activities

Sources of such information may include various governmental agencies, medical facilities, independent consumer reporting agencies or other information exchange organizations or individuals provided for personal and business references.

Opting Out

Diligence does not use the information it obtains on behalf of its clients. Therefore, if a subject of information desires to opt out of having the information used for any purpose, the subject should address this option with Diligence’s client when the subject provides the authorization to release information to Diligence’s client. However, when Diligence makes a direct inquiry of the subject of the information, there is an opportunity presented for the subject to opt out of providing the information. In these instances, the subject need only decline to provide the requested material. In all other instances, Diligence only gathers and discloses the information pursuant to the subject’s written authorization obtained by Diligence’s clients.

Notice to all Users

The systems are restricted solely to authorized Diligence users and may be monitored for administrative and security reasons. All users expressly consent to such monitoring. Any use of the system must be in compliance with all our policies and applicable laws. Unauthorized users or any unauthorized use will subject the user to criminal and civil penalties under applicable law.

EUROPEAN UNION BASED INDIVIDUALS ONLY – Your Rights and Choices

This European Union Privacy Notice (the “EU Disclosures”) supplements the information contained in the Privacy Policy and applies solely to individual residents of the European Union ("you"). These EU Disclosures describe how individuals in the European Union can exercise their Data Subject Rights Request pursuant to the General Data Protection Regulation (GDPR). Unless otherwise expressly stated, all terms in these EU Disclosures have the same meaning as defined in the privacy Notice or as otherwise defined in the GDPR.

1. Access to Specific Information and Data Portability Rights: You have the right to obtain confirmation as to how Personal Information concerning you is processed, and where that is the case, you have the right to request and get access to that Personal Information from us. We shall provide you with access to the Personal Information we hold in a commonly accepted format that is reasonably acceptable to you in a timely manner.

2. Rights to Correction, Amendment, and Deletion: You have the right to have your Personal Information corrected, amended, and/or deleted by us, recognizing that there may be legal or technical reasons that prohibits or restricts honoring such request. You also have the right to provide us with additional Personal Information to complete any incomplete Personal Information. We shall provide you with confirmation of the completion of such request where granted. Where there is a legitimate reason not to do so, we shall explain the reason for denial to you.

3. Rights for Choice, Consent and Right to Object: We shall provide you with a choice about the processing of your Personal Information and seek consent. In certain cases, you have the right to object to the processing of your Personal Information, including profiling and automated processing. You also have the right to object to further processing of your Personal Information in so far as such data has been collected for direct marketing purposes.

4. Other Rights: We intend to honor the rights granted to individuals under applicable law or other binding requirements. Any rights not otherwise listed above shall be granted where required. When considering such requests, we shall consider legal, contractual, and technical limitations.

5. Communications to/from Third-Parties: Where we have shared Personal Information to third-parties and where the Personal Information is reasonably feasible, we shall notify applicable third-parties of your request. We shall also require third-parties to notify us of your request to exercise your rights and the intent to abide by any requests.

6. Exercising Your GDPR Rights: To exercise any of your rights as described above, please submit a Data Subject Rights Request, which includes which right you would like to exercise by contacting us at [email protected]. Only you or a person you authorize to act on your behalf, may make a Data Subject Rights Request related to your Personal Information. You may also make a Data Subject Rights Request on behalf of your minor child. The Data Subject Rights Request must provide enough information that allows us to reasonably verify your identity and describe your request with enough detail that allows us to properly understand, evaluate, and respond to it. We cannot respond to your request or provide you with Personal Information if we cannot verify your identity or authority to make the request and confirm the Personal Information relates to you.

7. Response Timing: We strive to respond to a Data Subject Rights Request within 30 days of its receipt. If we require additional time, we will inform you of the reason and extension period in writing. Written responses will be provided based on the information you provide to us. We use any information you give us in your request only to fulfill the request and delete it within 12 months.

    Contact Us

    If you have any questions regarding our Privacy Policy, the ways in which we may collect and use your Personal Information, how to update or correct any outdated or inaccurate information, or your choices and rights regarding such use, please contact us at [email protected] or call 1-800-660-4202.