Privacy Policy
Last updated:
October 14, 2026
This Privacy Policy describes how Cushion Insurance Agency, LLC and Cushion Insurance Inc. (collectively, "Cushion," "we," "us," or "our") collect, use, store, disclose, and protect your personal information when you visit our website, use our web applications, apply for coverage, or interact with our services (collectively, the "Services").
1. Information We Collect
We collect information that identifies, relates to, describes, or is reasonably capable of being associated with you ("Personal Information") to evaluate eligibility, underwrite, and bind insurance policies.
A. Information You Provide Directly
• Identity & Contact Details: Legal name, email address, phone number, residential physical address, state of domicile, date of birth, and government-issued identification numbers.
• Employment & Financial Data: Employer name, job title, employment tenure, income/salary details, and banking information.
• Insurance Application & Eligibility Warranties: Responses to eligibility questions, employment status and prior claims history.
• Claims Data: State Unemployment Insurance (UI) Determination Letters, separation agreements, and claims documentation.
B. Consumer-Permissioned Payroll Data Ingestion
• Consumer-Permissioned Payroll API Providers: With your express authorization, we connect to your payroll system (e.g., via OAuth integrations) to extract employment data, verify income, employment tenure, job title, and active employment status.
C. Information Received from Third PartiesConsumer Reporting Agencies (CRAs):
• In specific underwriting scenarios, and with your express authorization, we may verify employment tenure and base compensation through authorized third-party CRAs (such as Truework) pursuant to the Fair Credit Reporting Act (FCRA).
D. Information Collected Automatically
• Device & Usage Data: IP address, browser type, operating system, device identifiers, pages viewed, links clicked, and interaction times.
• Location Data: Approximate location derived from your IP address.
• Cookies & Tracking Technologies: We use cookies, web beacons, and similar tracking tools to enhance site navigation, analyze usage, and assist in our marketing efforts.
A. Information You Provide Directly
• Identity & Contact Details: Legal name, email address, phone number, residential physical address, state of domicile, date of birth, and government-issued identification numbers.
• Employment & Financial Data: Employer name, job title, employment tenure, income/salary details, and banking information.
• Insurance Application & Eligibility Warranties: Responses to eligibility questions, employment status and prior claims history.
• Claims Data: State Unemployment Insurance (UI) Determination Letters, separation agreements, and claims documentation.
B. Consumer-Permissioned Payroll Data Ingestion
• Consumer-Permissioned Payroll API Providers: With your express authorization, we connect to your payroll system (e.g., via OAuth integrations) to extract employment data, verify income, employment tenure, job title, and active employment status.
C. Information Received from Third PartiesConsumer Reporting Agencies (CRAs):
• In specific underwriting scenarios, and with your express authorization, we may verify employment tenure and base compensation through authorized third-party CRAs (such as Truework) pursuant to the Fair Credit Reporting Act (FCRA).
D. Information Collected Automatically
• Device & Usage Data: IP address, browser type, operating system, device identifiers, pages viewed, links clicked, and interaction times.
• Location Data: Approximate location derived from your IP address.
• Cookies & Tracking Technologies: We use cookies, web beacons, and similar tracking tools to enhance site navigation, analyze usage, and assist in our marketing efforts.
2. How We Use Your Information
We process and use Personal Information for business and commercial purposes, including to:
• Provide & Administer Services: Process applications, execute underwriting, bind coverage, manage billing, and process claims through independent Third-Party Administrators (TPAs).
• Verify Eligibility: Authenticate identity, confirm employment, and verify statutory State UI status.
• Fraud Mitigation: Detecting, investigating, and preventing insurance fraud and digital forgery
• Communication: Send administrative notices, policy updates, claims status notifications, and customer support responses.
• Marketing & Personalization: Provide tailored content, market relevant services (subject to your opt-out rights), and evaluate campaign performance.
• Legal & Regulatory Compliance: Comply with surplus lines tax reporting, state Department of Insurance (DOI) mandates, audit requirements, anti-money laundering regulations, and statutory reporting.
• Re-Employment Assistance: With explicit consent during an active claim, routing displaced policyholders and claimants to authorized executive search and placement partners for active re-employment support.
• Provide & Administer Services: Process applications, execute underwriting, bind coverage, manage billing, and process claims through independent Third-Party Administrators (TPAs).
• Verify Eligibility: Authenticate identity, confirm employment, and verify statutory State UI status.
• Fraud Mitigation: Detecting, investigating, and preventing insurance fraud and digital forgery
• Communication: Send administrative notices, policy updates, claims status notifications, and customer support responses.
• Marketing & Personalization: Provide tailored content, market relevant services (subject to your opt-out rights), and evaluate campaign performance.
• Legal & Regulatory Compliance: Comply with surplus lines tax reporting, state Department of Insurance (DOI) mandates, audit requirements, anti-money laundering regulations, and statutory reporting.
• Re-Employment Assistance: With explicit consent during an active claim, routing displaced policyholders and claimants to authorized executive search and placement partners for active re-employment support.
3. How We Share & Disclose Information
We do not sell your Personal Information to third parties for monetary payment or marketing purposes. We share Personal Information solely to the following entities:
• Insurance Carriers & Reinsurers: To underwrite, issue, and reinsure insurance policies under delegated authority agreements.
• Independent Third-Party Administrators (TPAs) & Claims Partners: To facilitate independent, fair and objective claims adjudication, loss verification and loss disbursements.
• Service Providers: Vetted vendors providing cloud hosting, payroll API connectivity, forensic OCR processing, database management, billing, and customer support under strict confidentiality agreements.
• Surplus Lines Stamping Offices & Regulatory Bodies: To comply with home-state tax filings, diligent search logging, and statutory audit requirements.
• Authorized Re-Employment Partners: Upon a covered claim, policyholder profiles are transmitted to vetted executive search and recruitment agencies to assist with career placement and provide active re-employment services.
• Legal Obligations: When required by law, subpoena, court order, or to protect the safety, rights, or property of Cushion, our users, or the public.
• Fraud Investigation Units: Disclosed to State Insurance Department Anti-Fraud Units or law enforcement bodies when mandated by state fraud reporting statutes.
• Insurance Carriers & Reinsurers: To underwrite, issue, and reinsure insurance policies under delegated authority agreements.
• Independent Third-Party Administrators (TPAs) & Claims Partners: To facilitate independent, fair and objective claims adjudication, loss verification and loss disbursements.
• Service Providers: Vetted vendors providing cloud hosting, payroll API connectivity, forensic OCR processing, database management, billing, and customer support under strict confidentiality agreements.
• Surplus Lines Stamping Offices & Regulatory Bodies: To comply with home-state tax filings, diligent search logging, and statutory audit requirements.
• Authorized Re-Employment Partners: Upon a covered claim, policyholder profiles are transmitted to vetted executive search and recruitment agencies to assist with career placement and provide active re-employment services.
• Legal Obligations: When required by law, subpoena, court order, or to protect the safety, rights, or property of Cushion, our users, or the public.
• Fraud Investigation Units: Disclosed to State Insurance Department Anti-Fraud Units or law enforcement bodies when mandated by state fraud reporting statutes.
4. Statutory Privacy Rights
Your privacy rights regarding personal data processing depend on your customer status and applicable statutory exemptions:
A. Bound Policyholders (The GLBA Insurance Track)
Pursuant to the Gramm-Leach-Bliley Act (GLBA) and state privacy regulations (e.g., California Consumer Privacy Act / CCPA, Cal. Civ. Code § 1798.145(e)), personal data collected or processed in connection with an issued insurance policy is governed by statutory GLBA framework rules. Cushion is legally mandated to maintain policyholder data, underwriting records, and claims ledgers for a minimum of seven (7) years to satisfy state Department of Insurance market conduct rules, financial reporting audits, and anti-fraud mandates. Consequently, statutory CCPA "Right to Delete" requests cannot be executed for active or historical policy records during this mandatory retention window.
B. Non-Bound Applicants & General Website Visitors (The Privacy Track)
For prospects who do not bind coverage, or those who submit information or request a quote but do not bind a policy, you retain statutory state privacy rights:
• Right to Know & Access: The right to request disclosures regarding the categories and specific pieces of personal data collected during your session.
• Right to Deletion: The right to request the permanent deletion of your non-bound personal information from our active databases.
• Right to Correct: The right to request the correction of inaccurate personal data recorded in our staging systems.
• Opt-Out of Marketing: Unsubscribe from promotional communications at any time via the "Unsubscribe" link in our emails.
• Non-Discrimination: Cushion will never discriminate against, alter pricing for, or deny service to any user exercising their statutory privacy rights.
C. Fair Credit Reporting Act (FCRA) & Adverse Action NoticesIn the event that an underwriting decision or eligibility denial is based in whole or in part on data obtained from a Consumer Reporting Agency (CRA), Cushion will issue an FCRA-compliant Adverse Action Notice detailing your rights to dispute information and request a free report from the CRA.
D. Employer Anonymity
Cushion will never contact your employer. Underwriting and verification processes rely on direct, consumer permissioned connections. We do not send verification requests, notifications, or communications regarding your application or policy to your employer's human resources or management teams.
A. Bound Policyholders (The GLBA Insurance Track)
Pursuant to the Gramm-Leach-Bliley Act (GLBA) and state privacy regulations (e.g., California Consumer Privacy Act / CCPA, Cal. Civ. Code § 1798.145(e)), personal data collected or processed in connection with an issued insurance policy is governed by statutory GLBA framework rules. Cushion is legally mandated to maintain policyholder data, underwriting records, and claims ledgers for a minimum of seven (7) years to satisfy state Department of Insurance market conduct rules, financial reporting audits, and anti-fraud mandates. Consequently, statutory CCPA "Right to Delete" requests cannot be executed for active or historical policy records during this mandatory retention window.
B. Non-Bound Applicants & General Website Visitors (The Privacy Track)
For prospects who do not bind coverage, or those who submit information or request a quote but do not bind a policy, you retain statutory state privacy rights:
• Right to Know & Access: The right to request disclosures regarding the categories and specific pieces of personal data collected during your session.
• Right to Deletion: The right to request the permanent deletion of your non-bound personal information from our active databases.
• Right to Correct: The right to request the correction of inaccurate personal data recorded in our staging systems.
• Opt-Out of Marketing: Unsubscribe from promotional communications at any time via the "Unsubscribe" link in our emails.
• Non-Discrimination: Cushion will never discriminate against, alter pricing for, or deny service to any user exercising their statutory privacy rights.
C. Fair Credit Reporting Act (FCRA) & Adverse Action NoticesIn the event that an underwriting decision or eligibility denial is based in whole or in part on data obtained from a Consumer Reporting Agency (CRA), Cushion will issue an FCRA-compliant Adverse Action Notice detailing your rights to dispute information and request a free report from the CRA.
D. Employer Anonymity
Cushion will never contact your employer. Underwriting and verification processes rely on direct, consumer permissioned connections. We do not send verification requests, notifications, or communications regarding your application or policy to your employer's human resources or management teams.
5. Children’s Online Privacy Protection
Our website, digital portals, and insurance products are strictly intended for working professionals aged 18 and over. We do not knowingly collect, market to, or solicit personal information from individuals under sixteen (16) years of age.
6. Updates To This Policy
We reserve the right to amend this Privacy Policy periodically to reflect changing regulatory requirements, statutory state insurance code updates, or operational enhancements. Material changes will be posted on this page with an updated "Effective Date." Bound policyholders will receive annual GLBA privacy updates.
7. Contact Us & Privacy Inquiries
For questions, concerns, or requests regarding this Privacy Policy, please contact us:
Email: privacy@needcushion.com
Mailing Address: Cushion Insurance Agency, LLC,
Attn: Privacy & Compliance Officer,
390 NE 191st St, Suite 93139
Miami, FL, 33179
Phone (Toll-Free): 1-844-564-CSHN (2746)
Email: privacy@needcushion.com
Mailing Address: Cushion Insurance Agency, LLC,
Attn: Privacy & Compliance Officer,
390 NE 191st St, Suite 93139
Miami, FL, 33179
Phone (Toll-Free): 1-844-564-CSHN (2746)