Privacy Policy

Last updated: May 30, 2026 · Version 1.0

Short version: We collect the contact and demographic information you submit on our site so a licensed agent can help you find health coverage. We use an automated verification call (AI assistant) to confirm your interest before an agent contacts you. We do not sell your personal information. We share limited, hashed information with advertising platforms (like Meta) to measure ad performance. You can opt out, request your data, or delete your data at any time by emailing [email protected].

1. Who We Are

The Independents Club ("we," "us," "our") is an independent insurance agency owned and operated by Kyle DeGennaro, a licensed insurance agent. Our website is theindependentsclub.com. We are not affiliated with the U.S. Government, the Centers for Medicare & Medicaid Services, the Affordable Care Act Health Insurance Marketplace, Medicare, Medicaid, or any government program.

This Privacy Policy describes what information we collect about you, how we use and share it, and your rights with respect to that information. It applies to information collected through our website, our intake form, our automated verification calls, and any phone or email communications with our licensed agents.

2. Information We Collect

2a. Information you give us directly

When you submit our quote-request form, you give us:

First and last name
Email address
Mobile phone number
Date of birth and ZIP code
State of residence
Employment status (e.g., self-employed, between jobs)
Estimated household income range
Current coverage situation (e.g., uninsured, on COBRA, on ACA plan)
Household size
Your TCPA consent (timestamp, IP address, browser information, and the exact consent language you agreed to)

2b. Information we collect automatically

IP address, browser type and version, device type, operating system
Pages you visit on our site and time spent on each
Referring website (e.g., which ad platform brought you to us)
Cookies and similar technologies used for advertising measurement (see Section 5)

2c. Information we collect during the verification call

After you submit the form, an automated AI verification assistant (named "Avery") will call you to confirm your information and interest. During that call we collect:

An audio recording of the entire call
An automated transcript of the call
Your verbal confirmation (or correction) of the information you submitted
Your stated intent — whether you want to be connected to a licensed agent now, later, or not at all
Your preferred callback window, if applicable

The call is recorded for quality, training, and compliance purposes. You are notified that the call is recorded at the beginning of the call. If you do not consent to recording, you may end the call at any time.

3. How We Use Your Information

We use your information to:

Connect you with a licensed independent insurance agent for a quote and consultation
Verify the information you submitted (via the automated verification call)
Confirm your eligibility for various private health coverage products available in your state
Comply with our legal and regulatory obligations under the Telephone Consumer Protection Act (TCPA), state insurance laws, and other applicable law
Measure the performance of our advertising campaigns and improve our website and services
Respond to your questions, requests, and complaints
Defend ourselves in the event of a regulatory inquiry, audit, or legal claim

4. Information We Do Not Use or Sell

We do not sell your personal information to third parties for their independent marketing use. We do not share or use your information to make automated decisions that have legal or similarly significant effects on you. We do not collect protected health information (PHI) as defined under HIPAA.

5. Sharing Your Information

5a. With licensed insurance carriers and partner producers

With your consent, we share the information needed to provide a quote with one or more insurance carriers and/or partner-licensed agents who may write coverage that fits your situation. These parties receive information necessary to underwrite or quote a plan, including name, contact details, date of birth, ZIP code, household information, and (during the application process, if you choose to proceed) additional details required by the carrier.

5b. With service providers who help us operate

We share information with vendors who provide services to us, including:

Bland.ai — operates our automated verification calling system and stores call recordings and transcripts
Render — hosts our backend application and stores lead intake records
Cloudflare — hosts and serves our website
Google (Workspace) — provides our business email and document storage
Customer relationship management (CRM) and dialer software used by our licensed agents to manage follow-up

These providers are contractually limited to using your information only for the purposes of providing services to us, and may not use it for their own marketing.

5c. With advertising and measurement platforms

We use the Meta (Facebook) Pixel and Meta Conversions API to measure the performance of our advertising on Meta-owned platforms (Facebook, Instagram). When you visit our site or submit a form, we share certain information with Meta, including: page-view events, form-submission ("Lead") events, and a hashed version of identifying information such as your email address and phone number. Hashing is a one-way cryptographic transformation that allows Meta to match you to your account on their platforms (if you have one) for the purpose of attributing the conversion to our ad. We do not share your raw email address or phone number with Meta.

We may add additional advertising platforms (such as Google Ads, TikTok, or others) in the future. Any new platform we use will be added to this section of our policy.

You can opt out of Meta's use of your information for advertising in your Meta Ad Preferences.

5d. When required by law

We may disclose your information to comply with a subpoena, court order, regulatory request, audit, or other legal process; to enforce our terms; or to protect the rights, property, or safety of The Independents Club, our agents, our partners, or others.

6. TCPA Consent, Calls, and Texts

By submitting our form, you provide express written consent to receive (1) an immediate automated verification call, text message, or pre-recorded message from The Independents Club at the mobile number you provided, using an AI voice assistant, and (2) follow-up contact from one licensed independent agent regarding private health insurance options. The automated technologies we use include AI-generated voice, automatic dialing systems, and pre-recorded messages.

Consent is not a condition of purchase. Standard message and data rates may apply. We may contact you by phone, text, and email regarding your request and your coverage options.

You may revoke consent at any time by replying STOP to any text message we send, or by calling or emailing the contacts in Section 11. We will honor opt-out requests within ten (10) business days.

7. Your Privacy Rights

7a. Rights for residents of California, Colorado, Virginia, Connecticut, Utah, and other states with comprehensive privacy laws

Depending on your state of residence, you may have the right to:

Know what personal information we have collected about you and how we use it
Access a copy of the personal information we have about you
Correct inaccurate personal information
Delete personal information we have about you, subject to legal exceptions (e.g., we may retain records needed for TCPA defense or state insurance recordkeeping)
Opt out of "sales" or "sharing" of your personal information (we do not sell, and we limit our sharing as described in Section 5)
Restrict or object to certain uses of your information
Appeal a denial of your request
Be free from discrimination for exercising any of these rights

To exercise any of these rights, email [email protected] with the subject line "Privacy Request." We will verify your identity (by asking you to confirm information we already have, such as the email address or phone number you submitted) and respond within the time required by your state's law (typically 45 days, extendable once).

7b. Authorized agents

You may use an authorized agent to submit a privacy request on your behalf. We will require proof of the agent's authorization and may require you to verify your identity directly.

7c. Do Not Sell or Share — Global Privacy Control

We honor the Global Privacy Control (GPC) signal where required by law. We do not sell personal information for monetary consideration. The "sharing" of information for cross-context behavioral advertising is limited to the advertising-measurement use described in Section 5c. If you send us a GPC signal, we will treat it as an opt-out request for that advertising sharing for your browser/device.

8. Data Retention

We retain different categories of information for different periods of time:

Form submissions and TCPA consent records: ten (10) years, to defend against potential TCPA claims (which have a 4-year statute of limitations, plus a buffer)
Verification call recordings and transcripts: five (5) years
Agent call recordings (after transfer): minimum five (5) years, longer where state insurance law requires
Email and CRM records: typically retained for the duration of our relationship plus five (5) years
Advertising measurement data: typically anonymized or deleted within thirteen (13) months

If you submit a deletion request under Section 7, we will delete or de-identify your information except where we are legally required to retain it (for example, TCPA defense or state insurance recordkeeping).

9. Security

We use reasonable administrative, technical, and physical safeguards to protect your information from unauthorized access, disclosure, alteration, or destruction. This includes encrypted transmission (HTTPS), encrypted storage, access controls limiting who at our agency can view your information, and vendor agreements requiring our service providers to maintain similar safeguards. However, no system is 100% secure, and we cannot guarantee the security of information transmitted to or from us.

10. Children's Privacy

Our services are not directed to children under the age of 18, and our intake form is restricted to users ages 18 to 63. We do not knowingly collect personal information from children under 13. If we learn that we have inadvertently collected information from a child under 13, we will delete it.

11. Contact Us

The Independents Club
50 Island Park Drive
Charleston, SC 29492

Email: [email protected]
Phone: (843) 642-9090
To opt out of calls and texts: reply STOP to any text, or email/call the contacts above

12. Changes to this Policy

We may update this Privacy Policy from time to time. When we do, we will post the updated version at this URL and revise the "Last updated" date at the top. For material changes, we will provide additional notice (for example, by email or a prominent notice on our homepage). Your continued use of our site after the effective date of an updated policy constitutes your acceptance of the changes.

13. State-Specific Disclosures

California (CCPA / CPRA)

In the preceding twelve (12) months, we have collected the categories of personal information listed in Section 2 (identifiers, commercial information, internet/electronic activity, geolocation by ZIP, professional/employment information, inferences). We have disclosed these categories for the business purposes listed in Section 3 to the categories of recipients listed in Section 5. We have not sold personal information. We have shared information for cross-context behavioral advertising as described in Section 5c. California residents have the rights described in Section 7.

Florida, Texas, and other state TCPA / mini-TCPA laws

The TCPA consent you provided when you submitted the form complies with the federal TCPA as well as the state-level "mini-TCPA" laws of Florida, Oklahoma, Texas, Washington, and other states with comparable statutes. You may revoke that consent at any time as described in Section 6.