Insurance Privacy Notice
Last updated:
Hogan3 LLC (“iContentsPro,” “we,” “us”) provides software for documenting and valuing personal property and contents in connection with insurance claims. This Insurance Privacy Notice supplements our Privacy Policy and applies when we process personal information on behalf of insurance carriers, adjusting firms, and their service partners (each a “Customer”).
1) Role & Scope
- For data that a Customer or its users (e.g., adjusters) and homeowners upload into the app (“Customer Data”), the Customer is the controller/business, and iContentsPro is the processor/service provider/contractor.
- For our own site, accounts, and marketing, iContentsPro acts as a controller; see the Privacy Policy.
2) Categories of Personal Information in Customer Data
- Identifiers: names, emails, claim/policy identifiers.
- Contents data: item descriptions, categories, quantities, condition, purchase year.
- Images/media: photos/videos of property; limited metadata (e.g., EXIF orientation).
- Valuation data: replacement sources and prices, depreciation results, confidence scores.
- Technical logs: event and access logs for security and auditing.
Customers should avoid uploading government IDs, precise geolocation, or sensitive biometric data unless necessary and lawful.
3) Purpose & Instructions
We process Customer Data solely to: (a) provide, maintain, and secure the app; (b) comply with law; and (c) generate aggregated/de-identified data that does not identify a person or Customer, to improve and develop the service. We act only on the Customer’s documented instructions (see DPA).
4) CCPA/CPRA Service Provider/Contractor Commitments
- We do not sell personal information and do not share it for cross-context behavioral advertising.
- We do not retain, use, or disclose personal information for any purpose other than the business purpose of providing the app or as permitted by law.
- We restrict use of Sensitive Personal Information to necessary service purposes and do not use it to infer characteristics.
- We support Global Privacy Control (GPC) signals where applicable via Customer configuration.
5) GLBA, NAIC, and State Insurance Privacy
We maintain a written information security program aligned with the GLBA Safeguards Rule, the NAIC Insurance Data Security Model Law, and relevant state rules (e.g., NY DFS 23 NYCRR 500) as applicable to service providers. Controls include encryption in transit/at rest, access control and least privilege, logging and monitoring, vulnerability management, backups, vendor management, and incident response.
6) Sub-processors & Disclosures
We use vetted sub-processors (e.g., hosting, storage, email) to deliver the service and remain responsible for their performance. Each sub-processor is bound by written terms no less protective than ours.
7) International Data Transfers
Where Customer Data is transferred internationally, we use appropriate safeguards (e.g., Standard Contractual Clauses) unless an adequacy decision applies.
8) Retention & Deletion
We retain Customer Data only for the subscription term and as instructed by the Customer, and then delete or return it within a reasonable period (typically within 90 days) unless law requires longer retention.
9) Security Incidents
We notify the Customer without undue delay after becoming aware of a personal data breach affecting Customer Data and provide information reasonably needed for the Customer’s obligations.
10) Data Subject / Consumer Requests
If you are a homeowner or individual and your information is in Customer Data, please contact your insurer/adjuster (the controller/business). We assist Customers in responding to requests (access, deletion, correction, restriction, portability, and applicable opt-outs).
11) Children’s Data
The app is not directed to children under 16. Customers should not knowingly submit children’s data without appropriate consent and lawful basis.
12) Contact
Email: privacy@icontentspro.com • support@icontentspro.com
Mailing: Hogan3 LLC, 1350 NASA Parkway, Suite 114, Houston, TX 77058