Privacy Policy

1. Introduction

Attune, Inc. ("the Company," "we," "us," or "our") operates the website inattune.com (the "Service"). Attune is an AI risk-scoring and underwriting-assistance platform designed for commercial insurance brokers. This Privacy Policy explains what information the Company collects through the Service, how we use it, and the choices available to you.

Attune is not a licensed insurance carrier or producer. All information processed through the Service is handled as described below in the context of providing broker-facing software tools.

The Company is based at 80 Pine Street, 24th Floor, New York, NY 10005, and can be reached at [email protected].

2. Information We Collect

2.1 Information You Provide

We collect information you submit directly, including:

• Contact details (name, email address, phone number) when you fill out a form, request access to the platform, or submit an inquiry;
• Professional information (agency name, role, lines of business, submission volume) that you choose to share when describing your brokerage;
• Commercial insurance application data that brokers submit through the platform for risk scoring purposes, including business type, gross revenue, years of operation, prior claims history, and location information;
• The content of any messages you send us.

Application data submitted by brokers relates to their small-business clients, not to personal consumer data. Attune processes this data solely to generate risk scores and underwriting-assistance outputs for the submitting broker.

2.2 Information Collected Automatically

When you visit inattune.com, we automatically collect limited technical information:

• IP address and approximate location (city and region level);
• Browser type, operating system, and device class;
• Pages visited, referring URLs, and time on page;
• Cookie and similar identifiers (see Section 5 and our Cookie Policy).

2.3 We Do Not Knowingly Collect Children's Data

inattune.com is directed to commercial insurance professionals, not to children under 13. We do not knowingly collect personal information from children. If you believe a child has provided us information, contact [email protected] and we will delete it.

3. How We Use Information

The Company uses the information we collect to:

• Respond to inquiries, process access requests, and deliver the risk-scoring and underwriting-assistance outputs that brokers submit commercial applications for;
• Operate, maintain, and improve the Service, including training and calibrating the risk-scoring model using submitted application data in aggregated and de-identified form;
• Send service updates and (with your consent where required) product-related communications;
• Detect, investigate, and prevent fraud or unauthorized access;
• Comply with applicable legal obligations, including financial services and data protection laws.

We do not use broker-submitted commercial application data to train models on an individually identified basis. Model improvement uses aggregated, de-identified signals. We do not sell personal information for monetary value. Where applicable state law treats certain advertising arrangements as a "sale" or "share," see your state's section below.

4. Sharing of Information

The Company shares personal information only with:

• Service providers acting on our behalf (for example, cloud hosting, email delivery, and usage analytics) under contractual confidentiality and data-processing terms;
• Regulatory authorities or law enforcement, when required by law or to protect rights, safety, or property;
• A successor entity in the event of a merger, acquisition, or asset sale, subject to this Policy.

We do not sell personal information to third parties. We do not share commercial application data submitted by brokers with any carrier, third-party insurer, or marketing platform.

5. Cookies and Tracking

The Company uses cookies and similar technologies to operate the site, remember preferences, and measure usage patterns. For details and choices, see our Cookie Policy.

6. Data Retention

We retain personal information only as long as needed for the purposes described in this Policy, to comply with legal or accounting obligations, and to resolve disputes. Inactive marketing-list contacts are purged after 24 months. Commercial application data submitted for risk scoring is retained for the period necessary to deliver the scored output and support any dispute resolution, then deleted or de-identified. Server access logs are retained for 90 days, then aggregated.

Brokers using the Attune platform remain responsible for their own recordkeeping obligations under applicable regulations, including financial services recordkeeping requirements that may apply to insurance placement records.

7. Security

The Company uses administrative, technical, and physical safeguards designed to protect personal information, including TLS encryption in transit, restricted-access databases, and least-privilege access controls. No system is perfectly secure; we cannot guarantee absolute security.

8. Your General Rights

Depending on your jurisdiction, you may have rights including access, correction, deletion, and the ability to limit certain processing. To make a request, email [email protected]. The Company will respond within the timeframe required by applicable law.

9. New York Residents

New York does not currently have a comprehensive consumer privacy statute. As a matter of policy, the Company extends the following baseline rights to all U.S. residents regardless of state of residence.

9.1 Baseline Rights

• Right to Know: request the categories of personal information we have collected about you.
• Right to Delete: request deletion of personal information you have provided.
• Right to Correct: request correction of inaccurate personal information.
• Right to Opt Out of Marketing: unsubscribe from marketing emails or opt out via the link in each marketing message.

9.2 How to Exercise

Email [email protected] with a description of your request and enough detail for us to verify your identity. The Company responds within 45 days.

9.3 Sector-Specific Rights

If you are protected by federal sector laws (for example, the Gramm-Leach-Bliley Act for financial services data), those laws may give you additional rights with respect to data covered by them. Attune processes commercial insurance application data in its capacity as a software tools provider to licensed brokers; broker clients remain responsible for their own GLBA compliance obligations regarding their customers' non-public personal information.

9.4 California Visitors

If you are a California resident visiting from another state, you may also exercise the rights granted under the California Consumer Privacy Act ("CCPA") and California Privacy Rights Act ("CPRA"), including the right to know, the right to delete, the right to correct, and the right to opt out of sale or sharing. The Company does not sell personal information and does not "share" personal information for cross-context behavioral advertising.

To submit a CCPA / CPRA request, email [email protected] with the subject line "California Privacy Request."

10. Changes to This Policy

The Company may update this Policy from time to time. Material changes will be reflected by a new "Last updated" date and, where appropriate, a notice on the Service.

11. Contact

Questions, requests, or complaints can be sent to:

Attune, Inc.
80 Pine Street, 24th Floor
New York, NY 10005
Email: [email protected]
Phone: +1 (212) 551-2400