Independent Contractor Privacy Notice

This notice is a working draft and should be reviewed by counsel before publication. It supplements our general Privacy Policy and applies specifically to agents. Where the two documents differ, this one controls for information related to the contractor relationship.

1. Who this notice applies to

You, if you’re an independent contractor producer working under a PlondoLife affiliation — including sponsored agents, downline producers, and applicants who are in the background-check or licensing-onboarding stage. PlondoLife agents are independent contractors, not employees, but the privacy framework that applies to your information is largely the same. We treat agent information with the same care we’d expect for our own.

2. Categories of personal information we collect

Using the labels California’s privacy law (CCPA/CPRA) recognizes:

• Identifiers — legal name, preferred name, agent ID, mailing address, email, phone, date of birth, and Social Security number or ITIN where required for tax reporting and licensing verification.
• Customer records (Cal. Civ. Code §1798.80) — driver’s license number, state insurance producer license number(s), professional history.
• Protected classifications — collected only where required by anti-discrimination law or carrier appointment.
• Commercial information — production history, applications submitted, policies placed, commissions earned, downline structure, sponsor relationships.
• Internet or network activity — CRM logins, IP address, device and browser information, page-level activity in the agent platform.
• Geolocation — coarse location derived from IP address; no precise GPS.
• Sensory information — recordings of inbound or outbound calls when permitted by state law and disclosed at the start of the call.
• Professional or employment information — résumé / CV, prior insurance experience, references, training and certification records.
• Financial information — bank account for commission disbursement, tax forms (W-9 / 1099), and the financial information needed to issue you a producer ID.
• Inferences — performance metrics, training needs, and aggregate scoring used to plan support.
• Sensitive personal information — Social Security or ITIN, driver’s license, financial-account credentials, and content of communications you mark confidential.

3. Where this information comes from

• Directly from you during onboarding, contracting, and ongoing operations.
• From insurance carriers we’re appointed with.
• From state insurance departments, the National Insurance Producer Registry (NIPR), and licensing services.
• From your sponsor agent or upline.
• From third-party background-check, license-verification, and producer-data services.
• From banks and payment partners that process commission payments.

4. Background reports and the FCRA

Some carriers and our own onboarding process require a background investigation — typically a producer-suitability check that pulls your criminal history, credit history, license history, and any sanctions or regulatory actions on file. These reports are governed by the federal Fair Credit Reporting Act (FCRA), and they’re ordered only after you’ve given us your written authorization.

You have the right to:

• A clear and conspicuous written disclosure that a consumer report may be obtained for these purposes.
• A copy of the report directly from the agency that produced it.
• Dispute information you believe is inaccurate or incomplete with the agency that produced the report.
• A “pre-adverse action” notice if a report would lead us to deny, withdraw, or terminate your contractor relationship — with at least five business days to respond before the decision is finalized.
• An “adverse action” notice if such a decision is ultimately made, with the agency’s name, address, and a summary of your FCRA rights.

5. How we use this information

• To establish, manage, and end your independent-contractor relationship with PlondoLife.
• To verify your eligibility, licensure, and appointments with carriers, and to maintain producer records the carriers and state DOIs require.
• To process commission payments, prepare 1099s, and meet tax obligations.
• To provide access to the agent platform, training, lead distribution, and back-office tools.
• To detect, prevent, and investigate fraud, market-conduct issues, or unauthorized account access.
• To comply with insurance, tax, anti-money-laundering, anti-fraud, and regulatory requirements.
• To improve plondolife.com and the agent platform, and to support a sale or financing of the business (subject to confidentiality protections at least as strong as these).

We use a small amount of artificial intelligence inside the agent platform — see our AI Systems Notice for the full picture of where, why, and what AI does not do.

6. Disclosure to third parties (GLBA framework)

To insurance carrierswe’re appointed with — for appointment, contracting, and the carriers’ own producer-record requirements.

To state insurance departments and the NIPR — for license verification and continuing-education tracking.

To the IRS and other tax authorities — for 1099 reporting and other required filings.

To banking and payment partners — for commission disbursement.

To background-check, license-verification, and producer-data vendors — under written contracts that limit their use of your information to performing the service.

To service providers (CRM, hosting, email delivery, SMS delivery, customer support, analytics, AI providers) — under written contracts as above.

To our affiliates — companies under common ownership with PlondoLife — for the same purposes described here.

To our auditors, attorneys, and other professional advisors — under confidentiality.

To law enforcement, regulators, courts, or government authorities — when legally compelled or when we believe in good faith that disclosure is required.

We do not sell your personal information. We do not share contractor information for cross-context behavioral advertising. Most of the disclosures above are covered by GLBA exceptions to the “sale” definition (carrier appointment, regulatory compliance, servicing).

7. Retention

We retain agent information for as long as the contractor relationship is active, and afterwards as required by:

• Carrier contracts (typically the longer of the carrier’s requirement or 7 years after the last transaction).
• State insurance regulations (typically 5–7 years).
• Federal tax rules (typically 7 years).
• Anti-fraud and anti-money-laundering rules.
• Litigation hold, when applicable.

When retention requirements expire, we delete or de-identify the information.

8. Security

We use administrative, technical, and physical safeguards designed to protect agent information from unauthorized access, use, or disclosure. These include encryption in transit (TLS) and at rest where appropriate, role-based access controls, multi-factor authentication for all staff and producer accounts, logging and monitoring, and vendor security reviews. We align our program with widely adopted frameworks (such as NIST 800-53 controls and the NAIC Insurance Data Security Model Law where applicable).

No system is perfectly secure.Email is not a secure channel — please don’t send Social Security numbers, account numbers, login credentials, or health information by email. Use the secure forms in the agent platform instead. Tell us immediately at support@plondo.com if you suspect unauthorized access to your producer account.

9. Fraud awareness — what we’ll never ask you

Real PlondoLife employees and licensed agents will never:

• Ask you to send your full Social Security number, full bank account number, or password by email or text.
• Ask you to wire money or send gift cards to a personal account.
• Ask you to install screen-sharing or remote-access software so we can “help” with your account.
• Threaten to immediately revoke your producer access unless you make a same-day payment.

If something feels off, stop and verify by emailing support@plondo.com directly.

10. Your rights

Depending on where you live, you have one or more of the following rights with respect to personal information we hold about you in connection with your contractor relationship:

• Right to know — what categories we’ve collected, the sources, the purposes, and the categories of recipients we’ve shared with.
• Right to access a copy of your information in a portable format.
• Right to correct inaccurate information.
• Right to delete, subject to legal, fraud-prevention, regulatory, and tax-retention exceptions.
• Right to limit use of sensitive personal information (CPRA).
• Right to non-discrimination and non-retaliation for exercising these rights — your contractor relationship is not affected by exercising any privacy right.
• Right to designate an authorized agent to make a request on your behalf.

California, Colorado, Connecticut, Delaware, Florida, Indiana, Iowa, Kentucky, Maryland, Minnesota, Montana, Nebraska, New Hampshire, New Jersey, Oregon, Tennessee, Texas, Utah, and Virginia residents (and residents of any state with a similar law adopted after this notice’s effective date) have specific rights under their state’s privacy law. To exercise any right, email support@plondo.com with your name, agent ID, the right you’re asking us to honor, and the state you live in. We’ll verify your identity before responding and aim to reply within 45 days. If we need more time, we’ll tell you why.

11. Updates

We may update this notice from time to time. The “Effective” date above will reflect the most recent revision, and material changes will be highlighted inside the agent platform for at least 30 days.

12. Contact