Privacy Policy

Effective Date: 5/15/2025

North Summit Insurance (“North Summit Insurance,” “we,” “us,” or “our”) operates the website northsummitinsurance.com (the “Site”). We are an independent insurance agency and third-party marketing organization (TPMO) that helps consumers compare and enroll in health, Medicare, life, and related insurance products.

We take the privacy and security of your information seriously and seek to follow rules and guidance from the Centers for Medicare & Medicaid Services (CMS), as well as applicable federal and state privacy laws. This Privacy Policy explains what information we collect, how we use it, how we share it, and the choices you have.

By using this Site or providing information to us, you agree to the practices described in this Privacy Policy.

1. Who We Are and What We Do

North Summit Insurance is an independent insurance agency licensed in one or more states. We:

Provide education and guidance on Medicare, Affordable Care Act (ACA) Marketplace plans, individual and family health insurance, life insurance, and other related products.
Work with multiple insurance carriers and field marketing organizations (FMOs) to offer plan options.
Act as a TPMO when marketing or assisting with enrollment into Medicare Advantage (MA) plans and Part D (prescription drug) plans, and therefore follow CMS rules that govern how we collect, use, and share personal beneficiary data.

We are not part of, endorsed by, or acting on behalf of the U.S. government, CMS, or the federal Medicare program.

2. Information We Collect

The information we collect depends on how you interact with us.

2.1 Information You Provide Directly

When you fill out a form on the Site, request a quote, schedule an appointment, or communicate with us by phone, text, email, or in person, we may collect:

Contact Information: Name, mailing address, email address, phone number, and preferred contact method.
Demographic Information: Date of birth, age, household size, and similar information needed to determine eligibility and pricing.
Insurance Information: Current coverage, Medicare status, plan preferences, desired coverage type, and other information needed to compare plan options and provide recommendations.
Limited Health-Related Information for Life Insurance:
- Through this Site, we do not collect your full medical history or medical records.
- On certain life insurance forms, we may ask a small number of health-related questions (for example, whether you have high blood pressure, whether you use tobacco or nicotine, or whether you have diabetes) to determine basic eligibility and provide more accurate quotes. You may choose whether to answer these questions, but not answering may limit our ability to provide certain quotes.
Government and Identification Numbers: Medicare Beneficiary Identifier (MBI), Social Security number, or other identification numbers if required by a carrier, Marketplace, or for enrollment processing.
Financial Information: Limited payment or banking information if needed to assist you with premium payment setup and only as required by carriers or payment processors.
Communications and Call Recordings: Copies of emails, text messages, and, when required or permitted by CMS or other rules, recordings of telephone calls related to Medicare marketing, sales, or enrollment.

Online Forms (Forminator)

Our Site uses form tools, including the Forminator plugin, to collect information you submit (such as your name, contact information, and the limited health-related questions on life insurance forms). Form submissions may be stored in our website database and/or emailed to us so we can respond to your request. We use this information only to respond to your inquiries, provide quotes, and offer coverage options, in line with this Privacy Policy.

2.2 Information Collected Automatically

When you use the Site, we and our service providers may automatically collect:

Technical Data: IP address, browser type, operating system, device identifiers, and similar technical details.
Usage Data: Pages visited, links clicked, time spent on the Site, referring/exit pages, and general navigation patterns.
Cookies and Similar Technologies: Small data files placed on your device that help us remember your preferences and understand how visitors use the Site.

2.3 Information from Third Parties

We may receive information about you from:

Insurance carriers, FMOs, or plan administrators in connection with your applications or policies.
Government Marketplaces or CMS systems when permitted or required.
Lead vendors or other TPMOs, but only where appropriate consent has been obtained and in accordance with CMS rules and applicable law.

3. How We Use Your Information

We use your information to:

Provide Services and Insurance Guidance
- Respond to your inquiries and requests.
- Determine eligibility for coverage and provide quotes.
- Compare plan options and make recommendations.
- Assist with applications, enrollments, and policy servicing.
Comply with Legal, Regulatory, and CMS Requirements
- Satisfy documentation, disclosure, call-recording, and record-keeping obligations under CMS rules, carrier requirements, and other applicable laws.
- Help detect and prevent fraud, waste, and abuse.
Communicate with You
- Send confirmations, reminders, policy-related notices, and other transactional communications.
- Provide educational content about coverage, enrollment periods, and regulatory changes.
- Send marketing communications where permitted by law and your preferences.
Operate, Improve, and Secure the Site and Our Business
- Maintain and improve the Site and our services.
- Conduct analytics and reporting to understand how visitors use the Site.
- Protect our systems, data, and users from unauthorized access or misuse.

4. How We Share Your Information

We do not sell your personal information to data brokers. When we act as a TPMO, we do not share or sell Medicare personal beneficiary data to other TPMOs for their own marketing purposes without required consent under CMS rules.

We may share your information in the following situations:

Insurance Carriers, Marketplaces, and FMOs
- To obtain quotes, verify eligibility, complete applications, enroll you in coverage, or service your policies.
- To meet carrier, Marketplace, or CMS data and reporting requirements.
Service Providers and Contractors
- With third-party vendors who help us operate the Site, provide communications, host data, record calls, send emails or text messages, manage customer relationships, or perform analytics.
- These vendors are required by contract to use your information only to provide services to us and to protect it appropriately.
Other Marketing Partners or TPMOs (Medicare-Specific)
- In limited circumstances where you have provided appropriate consent and where sharing is consistent with CMS rules and other applicable laws.
Legal and Regulatory Requirements
- To comply with applicable laws, regulations, subpoenas, or court orders.
- To respond to lawful requests or inquiries from regulators or government authorities.
- To protect our rights, privacy, safety, or property, or that of you or others.
Business Transfers
- In connection with a merger, acquisition, reorganization, or sale of assets, subject to appropriate confidentiality protections and continued safeguards for your information.

5. Medicare Beneficiaries and Personal Beneficiary Data

When we work with Medicare beneficiaries or prospects, we may collect “personal beneficiary data,” which can include contact information, demographic details, health status relevant to coverage, prescription drugs, and other information needed to help find and enroll you in Medicare Advantage and Part D plans.

CMS rules require TPMOs to:

Protect personal beneficiary data.
Use such data only for permitted marketing, sales, enrollment, and servicing activities.
Obtain proper consent before sharing personal beneficiary data with another TPMO, where required.

We follow these requirements and limit the use and sharing of personal beneficiary data to what is necessary to discuss coverage options, complete or service enrollment you request, and comply with CMS, carrier, and legal obligations.

6. HIPAA and Health Information

The Health Insurance Portability and Accountability Act (HIPAA) applies to certain entities and their business associates. North Summit Insurance may sometimes act in coordination with HIPAA-covered entities, such as health plans, and may be subject to business associate agreements and related obligations.

Regardless of our specific role under HIPAA, we:

Treat health-related information and personal beneficiary data as sensitive.
Use reasonable administrative, technical, and physical safeguards to protect it.
Limit health information collected through this Site to a small number of life-insurance-related questions (for example, high blood pressure, tobacco use, and diabetes status) and do not collect full medical histories or medical records through the Site.
Follow applicable CMS and carrier requirements for data security and privacy.

If you have questions about how HIPAA applies to your situation, you may also contact the U.S. Department of Health and Human Services Office for Civil Rights.

7. Cookies, Google reCAPTCHA, and Online Tracking

We and our service providers may use cookies and similar technologies to:

Remember your preferences and settings.
Help the Site function properly.
Understand how visitors use the Site.
Support security and fraud prevention.

Most web browsers allow you to refuse or delete cookies. If you choose to block cookies, some features of the Site may not work correctly.

Google reCAPTCHA

We use Google reCAPTCHA on certain forms to help protect the Site from spam and abuse. reCAPTCHA analyzes information such as device and browser information, IP address, and user behavior (for example, mouse movements and clicks) to determine whether a visitor is a human or an automated program.

Use of reCAPTCHA is subject to the Google Privacy Policy and Google Terms of Service. Where reCAPTCHA is used, you may see or should assume the following notice applies:

This site is protected by reCAPTCHA and the Google Privacy Policy and Terms of Service apply.

Third-party analytics or advertising tools (such as Google Analytics or similar tools) may also collect or receive information from your browser and use it according to their own privacy policies.

8. Text Messaging (SMS/MMS)

If you choose to receive text messages (SMS/MMS) from us:

We use your mobile number to send information related to quotes, appointments, reminders, coverage information, and, where permitted, limited marketing messages.
Your opt-in to text messages applies only to North Summit Insurance; we do not share your text message opt-in or consent with third parties for their own marketing.
You may opt out of text messages at any time by replying STOP or following instructions provided in the message. Message and data rates may apply, depending on your mobile plan.

9. Data Security

We use reasonable physical, technical, and administrative safeguards designed to protect your information from unauthorized access, use, or disclosure. These safeguards may include:

Encrypted connections (HTTPS) on the Site where supported.
Access controls and authentication on internal systems.
Vendor due-diligence and contractual security requirements for service providers.
Data retention and call-recording practices aligned with CMS, carrier, and legal obligations.

No system can be guaranteed completely secure. You are responsible for protecting passwords and for using secure networks when transmitting information to us.

10. Your Choices and Rights

Depending on your state of residence and applicable law, you may have certain rights with respect to your personal information, which can include:

Access: You may request a copy of the personal information we hold about you.
Correction: You may request that we correct inaccurate or incomplete information.
Deletion: You may request that we delete certain information, subject to our need to retain records for legal, regulatory, or contractual reasons (for example, CMS or carrier retention requirements).
Marketing Preferences: You may ask us to stop sending marketing emails or text messages. We may still send transactional or service-related messages.

To exercise these rights or update your preferences, contact us using the information in the Contact Us section below. We may need to verify your identity before responding to certain requests.

11. Data Retention

We retain your information only as long as reasonably necessary to:

Provide services and support your coverage.
Maintain records required by CMS, carriers, and applicable laws and regulations.
Resolve disputes and enforce our agreements.

When information is no longer needed, we will delete, de-identify, or otherwise dispose of it in a secure manner consistent with our data-retention policies and legal obligations.

12. Children’s Privacy

The Site and our services are intended for adults. We do not knowingly collect personal information online from children under 13 years of age. If we learn that we have inadvertently collected information from a child under 13, we will take reasonable steps to delete it as required by law.

13. Third-Party Websites

The Site may contain links to third-party websites, including carrier sites, Medicare.gov, HealthCare.gov, or other resources. We are not responsible for the privacy or security practices of those third parties. We encourage you to review the privacy policies of any third-party websites you visit.

14. Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our practices, technologies, or legal requirements. When we update the policy, we will revise the “Effective Date” at the top. In some cases, we may provide additional notice (for example, by posting a notice on the Site).

Your continued use of the Site after any changes are posted means you accept the updated Privacy Policy.

15. Contact Us

If you have any questions about this Privacy Policy, how we handle your information, or your privacy choices, please contact us:

North Summit Insurance
Website: northsummitinsurance.com
Email: support@northsummitinsurance.com
Phone: 954-211-1512
Mailing Address: 2436 N Federal Highway, unit 332