Kensington Vanguard Statement of Online Privacy Practices

Updated May 2024

Kensington Vanguard is committed to protecting your privacy and developing technology that gives you the most powerful and safe online experience. This Statement of Online Privacy Practices applies to the Kensington Vanguard site and governs data collection and usage. By using the Kensington Vanguard site, you consent to the data practices described in this statement.

What does this Policy Cover?

This Kensington Vanguard Statement of Online Privacy Practices (“Privacy Policy”) describes how we collect information when you visit or use Kensington Vanguard’s websites, applications and other online services that link to this Privacy Policy. It also describes how we use and share such information and explains your privacy rights and choices.

Our Online Services are intended for a U.S. audience. The terms Kensington Vanguard, “we,” “us,” or “our” mean Kensington Vanguard and its subsidiaries and affiliates. “You” means an individual who visits our Online Services and does not refer to a business or other entity or to individuals outside the U.S.

Kensington Vanguard’s business address is Kensington Vanguard National Land Services, LLC, 41 Madison Avenue, 21fl, New York, NY, 10010, USA]. For Privacy related questions, please contact Privacy Compliance at 866-858-5158.

What isn’t covered by this policy?

This Privacy Policy does not apply to the websites or services of Kensington Vanguard’s businesses and affiliates that do not directly link to this policy. Some Kensington Vanguard businesses and affiliates have their own privacy policies, which can be found on their websites. It also does not apply to non-Kensington Vanguard companies, such as third-party websites to which we link online. Please review the privacy policies of other websites and services you visit to understand their privacy practices.

Other important notices

Our Consumer Privacy Notice applies to information that we collect about individuals who seek, apply for, or obtain our financial products and services for personal, family, or household purposes. In addition, our CCPA Notice At Collection related to the California Consumer Privacy Act applies to certain information we collect about California residents.

What information does Kensington Vanguard collect?

When you visit a Kensington Vanguard website, application, or otherwise interact with us online, we may collect the following information:

  • Your browser type (such as Google Chrome, Microsoft Edge and Apple Safari)
  • Your Internet Protocol or “IP” address (Your IP address is a number that is automatically assigned to your device by your Internet Service Provider. An IP address is identified and logged automatically whenever you visit a site, along with the time of the visit and the page(s) that were visited)
  • The presence of any software on your device that may be necessary to view our site
  • Configuration information about the device you are using, including, but not limited to your device type, web browser type and version, operating system type and version, display/screen settings, domain names, language preferences, access times and referring website addresses
  • Information from your mobile device, such as contacts, photos, mobile network information, and cross-device IDs
  • Location information from your device
  • Personal information submitted on applications and forms, . Types of personal information typically include:
    • Name
    • Social Security number
    • Driver’s license number or other government-issued ID
    • Date of Birth
    • Address(s)
    • Email
    • Telephone number(s)
    • Account numbers, account information and policy number
    • Usernames
    • Passwords and other authentication information
    • Other non-public information such as credit and income information
  • Website analytics information such as pages visited and average time spent on a particular page
  • Search engine traffic referral information
  • Data relating to activities on our websites
  • Responses to advertisements and promotions
  • Transactional information from behind the secure login about your relationship with us (such as types of accounts or policies

How does Kensington Vanguard use the information collected?

The information we collect online helps Kensington Vanguard to, by way of example:

  • Effectively manage your policies and accounts:
  • Protect your identity and the security of your personal and account information from unauthorized access
  • Process transactions on your account
  • Respond to product applications and questions
  • Fulfill regulatory requirements and respond to Carrier Audits/Reviews
  • Analyze our site usage and enhance the user's experience:
  • Diagnose server problems
  • Alert users of any possible software compatibility issues
  • Help us make decisions about how various technologies are used and identify usage trends
  • Send marketing communications:
  • Present personalized or targeted offers, ads, or content we believe may be of interest to you
  • Determine the effectiveness of promotional campaigns
  • Make business decisions:
  • Analyze data
  • Perform market research
  • Conduct audits
  • Develop and improve products and services
  • Carry out other day-to-day business operations, such as to comply with applicable laws; share with our affiliates and subsidiaries; disclose to contractors, business partners, and other third parties under specific contracts and agreements; perform compliance activities; conduct credit reporting activities; and engage in human resources activities
  • Prevent and detect fraud
  • For any other purposes outlined in our CCPA Notice at Collection
  • Protect against risks to security:
  • Monitor network activity logs
  • Detect security incidents and conduct data security investigations
  • Protect against malicious, deceptive, fraudulent, or illegal activity

We only use personal information that we have about you when we have a legal basis to use such personal information under applicable data protection laws.

Kensington Vanguard may, from time to time, contact you on behalf of external business partners about a particular offering that may be of interest to you. In those cases, your unique personally identifiable information (email, name, address, telephone number) is not transferred to the third party without your consent.

How does Kensington Vanguard share the information it collects?

Kensington Vanguard  shares your information in different ways as permitted and required by law. For example, we may share your information with:

  • Affiliates and other entities of Kensington Vanguard
  • Businesses with which we partner to offer products and services for our clients or prospective customers, such as: joint marketing partners or bill pay partners
  • Service providers that provide various services to us, such as administering, operating, configuring site design, maintaining and providing internal support for our Websites and Content on our Websites such as:  those we use to help detect and prevent fraud, improve our online services, and to better market and advertise our services to you]
  • Other parties when you authorize or direct us to share your information, ME]
  • Credit or consumer reporting agencies to report on or learn about your financial circumstances as permitted by law
  • Government entities and other third parties as needed for legal or similar purposes, such as:
  • To respond to requests from our regulators
  • To respond to a warrant, subpoena, governmental audit or investigation, law enforcement request, legal order, or other legal process
  • If we believe you are, have or may violate any law, regulation or our Terms of Use
  • If we believe you are or may be a threat to safety, property, interests or rights of us or others;
  • To facilitate a merger, acquisition, sale, bankruptcy, or other disposition of some or all of our assets

In order to investigate, respond to or resolve problems or inquiries or to exercise or defend our interests and/or legal claims

We do not sell, rent, lease, provide or otherwise disclose your Personal Information to unaffiliated entities without your consent.

Please see Kensington Vanguard’s Consumer Privacy Notice and CCPA Notice at Collection that are linked at the bottom of this website for more information on how your personal information may be shared and how you may be able to limit certain types of sharing.

Please note, we may also share aggregated and de-identified data, such as aggregated statistics regarding product usage, with third parties.

We reserve the right to transfer personal information we have about you in the event we sell or transfer all or a portion of our business or assets (including, without limitation, in the event of a reorganization, dissolution, or liquidation).

What if I am visiting the Kensington Vanguard website from outside the United States?
Our sites are intended only for U.S. residents and we do not knowingly collect personal data or information via our websites of residents of other jurisdictions.

How long does Kensington Vanguard retain records?

We store your personal information as long as it is required to meet our contractual and legal obligations, or if we have a legitimate business need to do so.

What technologies does Kensington Vanguard use?

Kensington Vanguard and its online advertising and marketing partners may employ various technologies to collect information, including:

  • Cookies -Cookies are pieces of information stored directly on your device. Cookies provide information that is used for security purposes, to facilitate navigation, to display information more effectively, and to personalize/customize your online experience. The cookies Kensington Vanguard uses do not collect or store any personally identifiable information about you. Kensington Vanguard uses cookies to learn how visitors use our site, such as which pages are viewed the most, to identify the most common navigation paths, or to customize the presentation of information on the site]. Kensington Vanguard also uses cookies to assist in delivering some online transactions. Session cookies are no longer active after you log off the service that initiated them, and all session cookies are automatically deleted when you close all browser windows. Kensington Vanguard may also contract with third parties, including, but not limited to Adobe see Cross-Device Tracking, below, to track user activity on our website. You can choose to block or disable these cookies as most devices and browsers offer their own privacy settings. Doing so, however, may result in diminished performance on our site.
  • Marketing pixels, web beacons, clear GIFs, or other technologies - This technology may be placed on certain pages of our website, applications, emails, and other marketing initiatives. These tags usually work in conjunction with cookies and allow us to measure the effectiveness of our site and compile statistics about usage and response rates.
  • Advertising and Cross-Device Tracking: Kensington Vanguard uses certain Adobe Analytics services and products, which help companies build websites, applications, and advertisements that seamlessly flow between all your devices (such as a desktop, laptop, tablet, phone or smart watch). The services recognize which of your devices are linked through use of technology that includes cookies and your IP address (without collecting your personal information). Visit the service’s website] for more information on opting-out of certain services, cross-device tracking, and/or to unlink your devices. NOTE: Adobe needs to install a cookie on your browser to identify that you have opted out. If you delete the opt-out cookie, or change devices or web browsers, you will need to opt out again.
  • Firewalls, passcodes, data encryption, and other safety features – Kensington Vanguard  uses these technologies to ensure that the information you provide us remains secure.
  • Third-party plugins - Other companies may have plugins that appear on certain pages of our website or applications. Some of these, for example, may be from social media companies (for example, the Facebook “Like” button). These plugins may collect information, such as information about the pages you visit, and share it with the company that created the plugin even if you do not click on the plugin. These third-party plugins and the way they operate are governed by the privacy policies and terms of the companies that created them.

How does Kensington Vanguard interact with me online?

Online advertising on Kensington Vanguard  websites and applications

Kensington Vanguard advertises its products and services on pages within our sites To make the content and advertising as informative and useful as possible, Kensington Vanguard  may target and personalize content and advertisements for products and services on our site.

If you would prefer to not receive a specific advertisement, content or offers on Kensington Vanguard  authenticated (after signing-in) pages, you can click “No Thanks” to the specific pop-up ad you are being presented. Note that this will not prevent you from potentially receiving other ads, content, or offers for a different product or service. Also note that simply closing the pop-up message by clicking on the “X” will not register that you do not wish to receive this specific message again.

Online advertising on third-party websites and applications

Kensington Vanguard  advertises its products and services on websites and via email marketing such as Constant Contact and other applications not affiliated with Kensington Vanguard . The third-party companies we hire to display these ads use their own tracking technologies to measure the effectiveness of these ads and to understand your interests. Many of our third-party partners have their own privacy policies. We encourage you to review these policies carefully.

Some of our third-party advertising is interest-based and may use information about your online interests to customize the online ads you see. Kensington Vanguard  has adopted the use of the AdChoices Icon for our interest-based advertising (excluding ads appearing on platforms that do not accept the icon). Anyone receiving an interest-based ad can click on the displayed icon to receive more information. The AdChoices Icon does not prevent you from receiving advertisements; instead, it allows you to control whether you receive interest-based advertisements and from which companies.

Visit the Digital Advertising Alliance website for more information about the AdChoices Icon and interest-based advertising]. If you would like to know more about how to opt out with your specific browser and device, go to you may visit the DAA Webchoices Browser C Check and NAI Opt Out of Interest-Based Advertising tools for additional options. You can also download the AppChoices app to opt out in mobile apps.

Social media

Kensington Vanguard  provides experiences on social media platforms such as Facebook, Instagram, LinkedIn, or Twitter (now “X”) that enable online sharing and collaboration. We use social media to facilitate social engagement and sharing, when such sharing is appropriate and safe Please note, any content you post, such as pictures, information, opinions, or any personal information that you make available to other participants on these social platforms, is subject to the terms of use and privacy policies of those platforms. Please refer to them to better understand your rights and obligations with regard to such content.

Given the very public nature of social media, it is critical that we all safeguard confidential financial information. If you post information on a Kensington Vanguard  site that we feel should be shielded from public view, we will remove it. This includes not only specific details about your Kensington Vanguard  accounts, policies and other private, confidential information (such as your Social Security number), and  details of information relayed in private conversations between you and Kensington Vanguard representatives. Please know that in taking down or editing your posts, we are focusing our experience and best judgment to keep your personal information safe.

Email

Email transmitted across the internet is normally not protected and may be intercepted and viewed by others. Therefore, you should refrain from sending any confidential or private information via unsecured email to Kensington Vanguard . We will never ask you to send confidential information to us via email, such as your logon ID, password, full policy or account numbers, or Social Security number.

Occasionally, we will retain the content of your email—and our replies—to confirm proper responses to your questions and requests, to comply with legal and regulatory requirements, and to ensure that we consistently deliver an enjoyable client experience to you.

Linking to other sites

Kensington Vanguard  may provide links to non-Kensington Vanguard  companies. If you choose to link to websites not controlled by Kensington Vanguard , we are not responsible for the privacy or security of these sites, including the accuracy, completeness, reliability or suitability of their information. If you are asked to provide information on one of these sites, we urge you to carefully study their privacy policies before sharing.

Control your online and other privacy preferences

How does Kensington Vanguard protect my children?

Kensington Vanguard strictly follows the federal guidelines of the Children’s Online Privacy Protection Act (COPPA), which gives parents control over what type of information is collected online about their children. We do not knowingly collect, maintain, or use personally identifiable information from children under age 13 on our websites. We are not responsible for the data collection and use practices of nonaffiliated third parties that are linked from our websites. Visit the Federal Trade Commission’s COPPA Website for more information.

How does Kensington Vanguard protect me from fraud and secure information?

To protect personal information from unauthorized access and use, we use security measures that comply with applicable federal and state laws. These measures may include device safeguards, secured files and buildings, as well as oversight of our third- party service providers to ensure information remains confidential and secure.

How can I make sure my information is accurate, and use my individual rights?

Keeping your account information accurate and up to date is very important. If your information is incomplete, inaccurate or not current, please contact us at or by calling 866-858-5158.

We respond to all requests we receive from individuals wishing to exercise their data protection rights in accordance with applicable data protection laws. Please see additional information regarding what may be available under the California Consumer Privacy Act  (https://www.kvnational.com/CAprivacy.php)  We will ask you to verify your identity to help us respond efficiently to your request.

How will Kensington Vanguard notify me about online privacy practices updates?

Kensington Vanguard’s Online Privacy Practices may be revised from time to time, so please review them periodically. Any changes will become effective when we post the revised Practices on the site (Please note the effective date listed at the top of this page). If we revise our Online Privacy Practices in a material way, we will provide a conspicuous notice on our website when any changes take effect.

How can I contact Kensington Vanguard?

If you have any questions or comments on our Online Privacy Practices, please contact Privacy Compliance at: 866-858-5158.