Privacy Policy, Makoto Insurance Services, LLC
Makoto Insurance Services, LLC is a licensed California insurance agency dedicated to protecting the privacy, confidentiality, and security of our clients’ personal and financial information. In the course of providing insurance and financial products — including term life insurance, whole life insurance, indexed universal life insurance (IUL), fixed annuities, and long-term care insurance — we collect, use, and maintain nonpublic personal information (“NPI”) about our clients and prospective clients.
This Privacy Policy is provided in compliance with the California Insurance Information and Privacy Protection Act (IIPPA), the Gramm-Leach-Bliley Act (GLBA) and its implementing regulations, the California Consumer Privacy Act (CCPA) as amended by the California Privacy Rights Act (CPRA), and all applicable regulations and guidance issued by the California Department of Insurance. We encourage you to read this policy carefully. If you have questions at any time, please contact us using the information provided at the end of this document.
Information We Collect
We collect nonpublic personal information about you from a variety of sources in connection with the sale, underwriting, issuance, and ongoing servicing of insurance and annuity products. The categories of information we may collect include:
Information You Provide Directly
- Full legal name, current and prior addresses, date of birth, and Social Security number
- Government-issued identification such as a driver’s license or passport number
- Financial information including income, assets, net worth, existing insurance and annuity holdings, and bank or payment account information
- Health and medical history, including physician information, prescription history, diagnoses, and related health data collected in connection with life insurance, indexed universal life, and long-term care insurance applications
- Beneficiary designations and related personal information about third parties you identify
- Responses to application and suitability questionnaires
Information We Receive From Third Parties
- Consumer reporting agencies and credit information providers
- The Medical Information Bureau (MIB) in connection with life and health insurance underwriting
- Insurance carriers, reinsurers, and third-party administrators with whom we place business
- Other insurance companies, as permitted by law, in connection with fraud prevention and underwriting
- Publicly available sources, where applicable
Information Generated Through Our Business Relationship
- Policy numbers, coverage amounts, and premium payment history
- Claims history and correspondence related to policy servicing
- Records of communications between you and our agency
How We Use Your Information
We use the nonpublic personal information we collect for legitimate business purposes directly related to the products and services we provide. Specifically, we use your information to:
- Evaluate your insurance and annuity needs and make product recommendations appropriate to your financial situation and objectives
- Process, underwrite, and facilitate the issuance of insurance and annuity applications submitted on your behalf
- Service your existing policies, including processing premium payments, policy changes, reinstatements, loans, surrenders, and beneficiary updates
- Communicate with insurance carriers, reinsurers, third-party administrators, and other service providers as necessary to place and administer your coverage
- Comply with California insurance suitability requirements applicable to the sale of annuities and life insurance products
- Detect, investigate, and prevent fraud, misrepresentation, and other unlawful activity
- Respond to your inquiries and resolve complaints or disputes
- Maintain accurate business records and satisfy legal and regulatory recordkeeping obligations
- Comply with applicable federal and California law, including responding to lawful subpoenas, court orders, and regulatory examinations
We do not use your personal information for purposes unrelated to the products and services described in this policy, and we do not sell your personal information to unaffiliated third parties for their own marketing or commercial purposes.
Information We May Share
We do not share your nonpublic personal information except in the limited circumstances described below. In all cases, we share only the minimum information necessary for the stated purpose.
With Your Authorization — We will share your information with any individual or entity you have authorized in writing, including other advisors, attorneys, or family members you designate.
With Insurance Carriers and Service Providers — We share information necessary to underwrite, issue, and administer your insurance and annuity policies with the carriers, reinsurers, third-party administrators, and other service providers involved in your coverage. These parties are contractually required to maintain the confidentiality of your information and are prohibited from using it for purposes other than those for which it was shared.
With the Medical Information Bureau (MIB) — In connection with life insurance and long-term care insurance applications, information may be reported to and received from the MIB as part of the underwriting process. You have the right to request disclosure of any information the MIB holds about you by contacting MIB directly at www.mib.com.
With Affiliated Companies — If we share information with affiliated companies, we will do so only as permitted under applicable federal and California law and consistent with the terms of this policy.
As Required or Permitted by Law — We may disclose your information to regulators, law enforcement agencies, courts, or other governmental authorities when required to do so by applicable law, regulation, subpoena, court order, or in connection with a regulatory examination or investigation. We may also disclose information as permitted by law to prevent fraud or in connection with the sale or transfer of our business.
Opt-Out Right for Certain Sharing — To the extent we share your NPI with nonaffiliated third parties in circumstances not described above and not required by law, you have the right to opt out of such sharing. To exercise this right, please contact us using the information at the end of this policy. We will honor all opt-out requests within a reasonable time as required by applicable law. Please note that opting out of certain sharing may affect our ability to service your policies in some circumstances, and we will advise you accordingly if that is the case.
Health and Medical Information
Because we offer life insurance, indexed universal life insurance, and long-term care insurance, we collect sensitive health and medical information as part of the application and underwriting process. We treat this information with the highest level of confidentiality. Health and medical information is shared only as strictly necessary to underwrite and administer your policy, as expressly authorized by you in writing, or as required by law. We do not use health or medical information for marketing purposes under any circumstances, and we do not share it with any party who is not directly involved in the underwriting or administration of your coverage.
Clients applying for long-term care insurance should be aware that California law provides specific protections regarding the use and disclosure of medical information in connection with LTC underwriting. If you have questions about how your health information is used in connection with a specific product application, please contact us directly.
Fixed Annuity and Suitability Information
In connection with the sale of fixed annuities, California law requires us to collect financial suitability information including your income, liquid assets, financial objectives, existing assets and liabilities, and risk tolerance. This information is used solely to evaluate the suitability of annuity products for your specific situation and to satisfy our regulatory obligations under California’s annuity suitability regulations. It is shared with the issuing insurance carrier as required for product issuance and compliance purposes and is not used for any other purpose without your consent.
Your California Privacy Rights
As a California resident, you have the following rights with respect to your personal information under the CCPA/CPRA and the California IIPPA:
Right to Know — You have the right to request disclosure of the categories and specific pieces of personal information we have collected about you, the sources from which it was collected, the business or commercial purposes for which it is used, and the categories of third parties with whom it is shared.
Right to Access — You have the right to obtain a copy of the specific personal information we have collected about you in a portable and, to the extent technically feasible, readily usable format.
Right to Delete — You have the right to request deletion of personal information we have collected from you, subject to exceptions required by law or necessary to complete insurance transactions, maintain required records, detect fraud, comply with legal obligations, or fulfill other permitted purposes under applicable law.
Right to Correct — You have the right to request correction of inaccurate personal information we maintain about you. Under the California IIPPA, you also have the right to request that we review and correct personal information collected in connection with an insurance transaction.
Right to Opt Out of Sale or Sharing — We do not sell your personal information or share it for cross-context behavioral advertising. Should this practice change, we will provide advance notice and a clear mechanism to opt out before any such activity occurs.
Right to Limit Use of Sensitive Personal Information — We collect sensitive personal information, including health data and Social Security numbers, only as necessary to provide the insurance and annuity products and services you have requested. We do not use sensitive personal information for purposes beyond those described in this policy.
Right to Non-Discrimination — We will not discriminate against you in any way for exercising your privacy rights. You will not be denied products or services, charged different rates, or provided a lesser level of service as a result of submitting a privacy rights request.
To exercise any of the rights described above, please submit a verifiable request to us using the contact information at the end of this policy. We will respond within the timeframes required by applicable law — generally 45 days, with the possibility of a single 45-day extension when reasonably necessary. We may need to verify your identity before processing certain requests to protect the security of your information.
Protection of Your Information
We maintain reasonable and appropriate physical, electronic, and administrative safeguards designed to protect your nonpublic personal information from unauthorized access, use, alteration, or disclosure. Our safeguards include:
- Restricting access to personal information to employees, agents, and service providers who have a legitimate need to know such information in connection with their duties
- Maintaining secure physical storage of paper records and applying access controls to electronic systems containing personal information
- Using encrypted transmission protocols for the electronic transfer of sensitive personal information where technically feasible
- Regularly reviewing and updating our information security practices in response to changes in technology, regulation, and risk
- Requiring third-party service providers and carriers to maintain appropriate data security standards through contractual agreements
While we take our data security obligations seriously and implement reasonable precautions, no security system can be guaranteed to be completely secure. In the event of a data breach affecting your personal information, we will notify you as required by applicable California law.
Retention of Your Information
We retain your personal information for as long as necessary to fulfill the purposes described in this policy, to service your insurance and annuity policies, and to comply with applicable federal and California legal and regulatory retention requirements. California Department of Insurance regulations and the terms of our carrier appointments impose specific minimum retention periods for certain records. When personal information is no longer required to be retained, we dispose of it in a secure manner designed to prevent unauthorized access or reconstruction.
Changes to This Policy
We reserve the right to amend this Privacy Policy at any time in response to changes in law, regulation, or our business practices. If we make material changes to this policy, we will provide notice to clients of record as required by applicable law, which may include mailing an updated policy notice or posting a revised version with an updated effective date. Your continued engagement with our agency following delivery of notice of a material change constitutes your acknowledgment of the revised policy. We encourage you to review this policy periodically.
Contact Us
If you have questions about this Privacy Policy, wish to exercise your California privacy rights, would like to opt out of certain information sharing, or want to request access to or correction of your personal information, please contact us at: info@makotoinsurance.com, 949-207-6100
This Privacy Policy is intended to satisfy the notice and disclosure requirements of the California Insurance Information and Privacy Protection Act, the Gramm-Leach-Bliley Act and its implementing regulations, and the California Consumer Privacy Act as amended by the California Privacy Rights Act. This document does not constitute legal advice and is not a substitute for review by a licensed California attorney or qualified insurance compliance professional. Makoto Insurance Services, LLC recommends that this policy be reviewed by qualified legal counsel prior to distribution to clients or posting on any public-facing platform.