Privacy Policy

Effective Date: September 30, 2026

1. Introduction and Scope

This Privacy Policy ("Policy") describes how Neil Jesani Risk Management ("NJRM," "we," "us," or "our"), a subsidiary of Neil Jesani Advisors, Inc., collects, uses, discloses, stores, and protects the personal information of visitors to our website (neiljesanirisk.com) (the "Site"), prospective clients, current clients, and former clients (collectively, "you" or "your"). This Policy applies to information collected through our website, email communications, electronic forms, social media interactions, telephone communications, in-person meetings, and any other means through which you provide information to us or we collect information about you in connection with insurance brokerage and risk advisory services.

By accessing or using our website, submitting information through any of our forms, engaging our services, or otherwise interacting with us, you acknowledge that you have read, understood, and agree to be bound by this Privacy Policy. If you do not agree with any provision of this Policy, you must discontinue use of our website and services.

NJRM is an affiliate of Neil Jesani Advisors, Inc. ("NJA").

2. Information We Collect

2.1 Personal and Nonpublic Personal Information

We may collect the following categories of personal information, including nonpublic personal information ("NPI") as defined under the Gramm-Leach-Bliley Act and applicable state insurance privacy laws:

• Identifiers — full legal name, email address, telephone number(s), physical mailing address, date of birth, and other identifiers.
• Financial and eligibility information — income, net worth, and insurable asset information relevant to Private Client Group eligibility; banking or payment information used to pay premiums.
• Insurance application and underwriting information — information about your home, vehicles, vessels, collections, valuables, and other property; prior claims and loss history; driving record; occupation and employer; and other information relevant to obtaining a quote, binding coverage, or servicing a policy.
• Policy and account information — policy numbers, coverage selections, carrier placements, premiums, renewal dates, and transaction history with us.
• Beneficiary and family information — where relevant to life insurance or estate-coordinated coverage.
• Sensitive underwriting information — health information collected only where necessary to obtain a quote or bind a life, disability, or similar product, and only for that limited purpose.
• Government-issued identification, where required by a carrier for underwriting or by law for identity verification.
• Any other information you voluntarily provide to us.

2.2 Information Collected Automatically

When you visit the Site, we may automatically collect: IP address; browser type and version; operating system and device type; referring and exit pages; pages viewed and navigation paths; date, time, and duration of visits; approximate geographic location (city/region level); and information collected via cookies, pixel tags, web beacons, and similar technologies (see Section 4).

2.3 Information from Third Parties

We may receive information about you from: insurance carriers and their affiliates; consumer reporting and insurance support organizations (for example, claims history and motor vehicle record databases); identity verification services; public records; referral sources, including the tax, wealth, and estate planning professionals within the NJA family of companies; appraisers and other valuation professionals for scheduled property; and other service providers with whom we maintain business relationships.

3. How We Use Your Information

We use the information we collect to: provide insurance brokerage, placement, and risk advisory services; process and respond to your inquiries and form submissions; obtain quotes, underwrite, bind, and service insurance coverage on your behalf; verify your identity and prevent fraud; perform account administration and internal recordkeeping; communicate with you about your coverage, renewals, claims, and our services; coordinate with your other professional advisors at your direction (attorneys, CPAs, wealth or tax advisors, including those within the NJA family of companies); analyze and improve our website and services; send marketing communications, subject to your opt-out preferences; comply with applicable insurance laws, regulations, and carrier requirements; enforce our agreements and this Policy; and protect our rights, property, and safety and those of our clients and the public.

4. Cookies and Tracking Technologies

Our website uses cookies, pixel tags, web beacons, and similar technologies to collect information about how visitors interact with the Site. We use the following categories:

• Essential cookies — necessary for the Site to function and cannot be disabled.
• Analytics cookies — help us understand how visitors use the Site (for example, Google Analytics).
• Functional cookies — remember your preferences.
• Advertising/targeting cookies — used only if the Site runs ad pixels (for example, Meta or Google Ads); see the note below.

You may control or disable cookies through your browser settings; disabling certain cookies may limit some Site functionality. Where required by law, the Site will display a cookie consent banner allowing you to accept or reject non-essential cookies before they are set.

5. Disclosure of Information

We do not sell, rent, lease, or trade your personal information to third parties for their own marketing purposes. We may disclose your information in the following circumstances:

• Insurance carriers — to obtain quotes, bind coverage, and service your policy.
• Service providers — technology and hosting providers, email service providers, compliance vendors, accounting and legal counsel, and cybersecurity consultants, each contractually obligated to protect your information and use it only to provide services to us.
• Legal and regulatory — as required by applicable law, regulation, legal process, or governmental request, including state insurance department examinations and inquiries, court orders, subpoenas, and tax reporting requirements.
• Business transfers — in the event of a merger, acquisition, reorganization, or sale of assets, your information may be transferred as part of that transaction; we will notify you of any such change.
• With your consent — including when you direct us to coordinate with your other professional advisors.
• Affiliates — information may be shared with Neil Jesani Advisors, Inc. and its affiliates.

6. Data Security

We implement administrative, technical, and physical safeguards designed to protect your personal information, including encryption of data in transit and, where applicable, at rest; access controls limiting information access to authorized personnel on a need-to-know basis; employee security training; vendor due diligence; and secure document destruction procedures. No method of transmission over the internet or electronic storage is completely secure, and we cannot guarantee absolute security. If you prefer not to submit sensitive information online, you may contact us to provide that information by another method.

7. Data Retention

We retain personal information for as long as necessary to service your policy, fulfill the purposes for which it was collected, and comply with our legal and regulatory obligations. Insurance producer recordkeeping requirements vary by state; we generally retain policy and transaction records for a minimum of seven (7) years. Non-client inquiry data submitted through website forms is retained for a minimum of three (3) years. Website analytics data is retained in aggregate form.

8. Your Rights and Choices

Subject to applicable law, you may have the right to: access a copy of the personal information we hold about you; correct inaccurate or incomplete information; request deletion of your information, subject to our legal and regulatory retention obligations; request that we restrict certain processing; request your information in a portable format; object to processing for direct marketing purposes; and opt out of marketing communications at any time by using the "unsubscribe" link in our emails or by contacting us directly.

To exercise any of these rights, contact us using the information in Section 19. We will respond within thirty (30) days, or such other timeframe as required by applicable law, and may require you to verify your identity before processing your request.

9. California Privacy Rights (CCPA/CPRA)

If you are a California resident, the California Consumer Privacy Act, as amended by the California Privacy Rights Act (CCPA/CPRA), gives you the right to know what personal information we collect, use, and disclose; the right to delete personal information, subject to exceptions such as information we must retain for insurance recordkeeping or legal compliance; the right to correct inaccurate information; the right to opt out of the sale or sharing of personal information; the right to limit use of sensitive personal information; and the right to non-discrimination for exercising these rights. We do not sell personal information as defined under the CCPA/CPRA. To exercise these rights, contact us using the information in Section 19; you may also designate an authorized agent to submit a request on your behalf.

10. Other State Privacy Rights

Residents of certain other states with comprehensive privacy laws may have similar rights to know, access, correct, delete, and opt out of certain processing of their personal information. To exercise these rights, contact us using the information in Section 19.

11. Gramm-Leach-Bliley Act and State Insurance Privacy Compliance

As a licensed insurance producer, NJRM is subject to the Gramm-Leach-Bliley Act's Privacy Rule and Safeguards Rule, and to state insurance privacy and data security laws (many states have adopted versions of the NAIC Insurance Information and Privacy Protection Model Act and the NAIC Insurance Data Security Model Law). Where applicable, we provide clients with an initial and annual privacy notice describing the categories of nonpublic personal financial information we collect and disclose and the categories of third parties with whom we share it. We do not disclose NPI to nonaffiliated third parties for their own marketing purposes except as permitted by law. You may have the right to opt out of certain disclosures of NPI to nonaffiliated third parties; instructions for doing so, if applicable, are provided in our annual privacy notice. Insurance services are provided by an independent insurance agency. NJRM is licensed in the states where services are offered. License numbers are available upon request.

12. Children's Privacy

Our website and services are not directed to individuals under the age of eighteen (18), and we do not knowingly collect personal information from children under 18 (or under 13 for purposes of the Children's Online Privacy Protection Act). If we become aware that we have inadvertently collected personal information from a child, we will take steps to delete it. If you believe we have collected information from a child, please contact us using the information in Section 19.

13. Third-Party Links and Services

Our website may contain links to third-party websites and services that we do not own or control, including carrier portals, payment processors, and scheduling tools. This Policy applies only to our website and services. We are not responsible for the privacy practices of any third-party site, and we encourage you to review their privacy policies before providing information to them.

14. Mobile and Text Message Privacy

If you opt in to receive text messages or SMS communications from us, we will use your mobile phone number solely to send the communications you requested. No mobile opt-in information will be shared with third parties or affiliates for marketing or promotional purposes. Message and data rates may apply, and message frequency may vary. You may opt out at any time by replying STOP to any message, and reply HELP for support.

15. Do Not Track Signals

Some browsers offer a "Do Not Track" (DNT) feature. There is no universally accepted standard for responding to DNT signals, and at this time our website does not respond to them. You can manage your tracking preferences through your browser's cookie settings as described in Section 4.

16. International Users

Our website and services are operated in and directed to users in the United States. If you access our website from outside the United States, you understand and consent to the collection, transfer, storage, and processing of your information in the United States. We do not target or market our services to individuals located outside the United States.

17. Data Breach Notification

In the event of a data breach involving your personal information, we will comply with applicable federal and state breach notification laws, including applicable state insurance data security laws. We maintain an incident response plan covering detection, investigation, containment, and remediation of security incidents.

18. Changes to This Privacy Policy

We may modify this Policy at any time. Changes are effective upon posting the revised Policy on our website with an updated "Last Updated" date. Your continued use of our website after changes are posted constitutes acceptance of the revised Policy. For material changes affecting how we use or share your information, we will make reasonable efforts to provide additional notice.

19. Contact Information

If you have questions, concerns, or requests regarding this Privacy Policy or our privacy practices, please contact us at: