Legal
Privacy Policy
RefinedCRM is operated by Refined Capital LLC (“RefinedCRM,” “we,” “us”). This policy explains what we collect, why, who we share it with, and what choices you have.
We handle personal information in two different roles, and this policy is organized around that split because your rights depend on which one applies:
- As a business — for people who visit our website, book a demo, or subscribe to RefinedCRM.
- As a service provider — for the client records our customers store inside their own RefinedCRM account. Our customers are licensed insurance and annuity producers. That data belongs to the producer. We process it on their instructions and we do not use it for our own purposes.
If you are a consumer who worked with an insurance producer and you want your information corrected or deleted, contact that producer directly. They control their records. We will support any request they pass to us.
1. Information we collect
When you use our website
When you visit our website, we and our analytics and advertising partners automatically collect information about your visit through cookies, pixels, tags and similar technologies. This includes your IP address and the approximate location derived from it, your browser and device type, the pages you view and the links and buttons you use, and how you arrived at our site. Section 3explains these technologies and your choices.
Some features on our pages, such as our scheduling tool, are provided by third parties and may use cookies or similar technologies.
When you book a demo
The booking form collects your name, email address, phone number, anything you write in the message field, and the meeting time you select, together with the campaign information described above. This goes to our CRM platform and to us, and we use it to contact you about the demo and about RefinedCRM, and to measure which of our advertising leads to bookings.
When you become a customer
To open and operate your account we collect your name, business name, email address, phone number, mailing address, and your insurance producer license details. For billing we collect what is needed to process your subscription; payment card details go directly to our payment processor and we never receive or store your full card number.
Because we register your messaging campaign with mobile carriers on your behalf (Section 6), we also collect your legal entity name, business registration or tax identification details, and supporting business information that registration requires.
When you use the service
We receive operational records generated by your use of RefinedCRM: sign-in records, activity and audit logs, support communications, and system events. Where our staff accesses your account to provide support, that access is logged.
Client records you store in RefinedCRM
You decide what you put into your account. This typically includes your clients’ contact details, communication history, appointments, opportunity and pipeline records, policy-related information, documents, and notes you write. We process this on your behalf and under your instructions. We do not sell it, mine it for our own purposes, or use it to market to your clients.
You are responsible for what you collect and for having the right to collect it. See our Terms of Service for categories of information the service is not built to hold.
2. Where lead information comes from
RefinedCRM operates digital advertising campaigns with media partners on behalf of customers who have signed an agency-of-record authorization appointing us to act for them in that capacity.
A consumer responding to one of those campaigns reaches a landing page and submits an inquiry form. That inquiry is delivered into the account of the producer it is intended for. We handle it as that producer’s authorized agent. Once delivered, it is the producer’s record.
Consent to be contacted is obtained where the consumer submits the form, and the consumer is contacted by the producer, using the producer’s own registered phone number and sending identity.
3. Cookies, analytics and advertising technology
We and our analytics and advertising partners use cookies, pixels and similar technologies to understand how our site is used, measure our advertising, and show our ads to people who may be interested in RefinedCRM. These partners may collect information about your activity on our site and on other sites over time. You can manage cookies through your browser and adjust ad preferences in the settings each advertising platform provides.
Client records our customers store in RefinedCRM are never used for our own marketing or advertising.
4. How we use information
- To provide, operate, maintain and support the service
- To create and administer your account, and to register your messaging campaign with carriers
- To bill you and manage your subscription
- To respond to enquiries, demo requests and support requests
- To deliver lead inquiries to the customer they are intended for
- To monitor for abuse, fraud, security incidents and violations of our Terms of Service
- To measure and improve the service, our website and our advertising
- To advertise RefinedCRM, including on other websites and apps
- To send you service and administrative messages, and marketing about RefinedCRM (you can opt out of marketing at any time)
- To comply with law and to establish, exercise or defend legal claims
We do not sell the client records our customers store in RefinedCRM, and we never will.
5. Artificial intelligence features
RefinedCRM includes, or will include, AI features that help producers work their pipeline — summarizing conversations, drafting replies, scoring and prioritizing records, and responding to inbound messages from a producer’s contacts.
An AI assistant only replies. It never starts a conversation. It responds to people who have already messaged the producer, and it is not used to send unsolicited or promotional messages to anyone who has not contacted them first. Outbound campaigns are written and sent by the producer.
How your information is involved. When these features are used, the relevant conversation content and related record details are sent to an AI provider so a response can be generated. That can include the substance of what a consumer has written and contextual details drawn from the producer’s own records, such as appointment history, pipeline stage, notes and amounts.
Which providers. We use third-party AI providers and may change them. We choose providers that offer business terms appropriate for this kind of data, and we require them by contract to process it only to deliver the feature.
What we do not do. We do not permit our AI providers to use customer or consumer information to train their general-purpose models where that use is within our control, and we do not sell or license this information to anyone.
Things worth being direct about:
- AI output can be wrong, incomplete or inappropriate. Producers are responsible for what goes out under their name.
- An AI assistant replies only to people who have messaged the producer first. It does not initiate contact, and it is not used for unsolicited or promotional outreach.
- Where an AI assistant communicates with a consumer, it identifies itself as an AI assistant when asked. It will not claim to be a human being.
- AI features do not provide insurance, financial, tax or legal advice, and nothing produced by them should be relied on as such. A licensed producer is responsible for advice and suitability.
- Automated messages sent through AI features are subject to the same consent and opt-out rules as any other message. Reply STOP to a text or use the unsubscribe link in an email.
- AI features may make suggestions or prioritize records, but they do not make decisions that produce legal or similarly significant effects about any consumer. Coverage, pricing, underwriting and suitability decisions are made by carriers and licensed producers, not by us.
6. Messaging and communications
Producers send messages from their own RefinedCRM account using their own phone numbers, under a carrier messaging registration held in their own name or legal entity. We submit that registration on the producer’s behalf, using information the producer provides. The producer is the sender of those messages and is responsible for having consent to send them.
Producers may also send email using an address on a domain we provide, and may connect their own mailbox and calendar to their account.
We do not sell, rent or share mobile phone numbers, text message opt-in data or consent with third parties or affiliates for their marketing or promotional purposes. Mobile information is shared only with the service providers that deliver messages, and only to deliver them.
If you receive a message from a producer using RefinedCRM and want it to stop, reply STOP to a text message or use the unsubscribe link in an email. That opt-out is recorded and honored. You can also contact the producer directly.
7. Producer profile pages
RefinedCRM provides each customer with a public profile page they can use to let prospects verify who they are dealing with.
That page belongs to the producer, not to us. The producer supplies and controls everything on it — their name, photo, biography, license and National Producer Number, contact details, calendar, and any claims made on the page. The producer is responsible for the accuracy of that content and for their own compliance with insurance advertising rules.
We provide the page and the technology behind it. We do not verify, endorse, vouch for, or recommend any producer, and a producer having a page does not mean we have checked them. Where a page links to a state Department of Insurance license lookup, verification happens at that state’s official source, not with us.
If you visited a producer’s page and want your information handled differently, contact that producer. Their contact details are on the page.
8. Who we share information with
We share information with the following categories of service providers and partners. Our service providers are bound by contract to handle it only for the purposes we specify.
| Category | What it does | What it receives |
|---|---|---|
| CRM and communications platform | The platform RefinedCRM is built on; delivers text messages and email and runs scheduling | Account data, client records, message content, booking details |
| AI providers | Power AI features (Section 5) | Conversation content and record context, when AI features are used |
| Cloud hosting, database and authentication providers | Host our website and application and store account data | Account data, operational records, website request data |
| Payment processors | Process subscription payments | Billing details; card data goes directly to the processor |
| Analytics providers | Help us understand how the website is used | Website usage and device information |
| Advertising partners | Measure and deliver our advertising (Section 3) | Website usage and device information |
We also share information:
- With the customer whose account it belongs to, which is how the service works
- When you tell us to, or when you use an integration you connect
- For legal reasons — to comply with law, respond to lawful requests, enforce our terms, or protect the rights and safety of any person
- In a business transfer — if RefinedCRM is involved in a merger, acquisition or sale of assets, information may transfer as part of that transaction
9. How long we keep information
We keep information for as long as we need it for the purpose we collected it, and then only as long as the law requires or as we need it to resolve a dispute or enforce our agreements.
One specific commitment, because customers ask and because it matters:
| What | How long we keep it |
|---|---|
| A customer’s account and the client records in it | 60 days after the subscription ends. During that window the customer can export their data. After it, we may delete the account and its contents. |
For everything else, the rule rather than a fixed date:
- Billing and tax records — kept as long as tax, accounting and audit rules require
- Demo requests and enquiries from people who did not become customers — kept while there is a realistic prospect of doing business, then deleted. Ask us and we will delete them sooner
- Operational and security logs — kept as long as needed to run the service securely and to investigate problems
- Website analytics data — kept for a limited period under our analytics and advertising providers’ retention settings
Opt-out and do-not-contact records are kept for as long as needed to keep honoring them.
10. Your privacy rights
Depending on where you live, you may have the right to:
- Know what personal information we hold about you and how we use it
- Get a copy of it
- Correct it if it is wrong
- Ask us to delete it
- Opt out of targeted advertising, the sale or sharing of personal information, or certain profiling
- Not be discriminated against for exercising these rights
To make a request, contact us at info@refined-crm.com. We will verify your identity before acting and respond within the time the law allows. You may use an authorized agent where the law permits.
If your information is in a producer’s RefinedCRM account or on a producer’s profile page, that producer controls it. Send your request to them. We will help them fulfil it.
Some information handled by insurance producers is governed by financial privacy and insurance laws rather than general state privacy laws, and rights may differ for that information.
You may appeal a decision we make about your request by replying to our response. If you remain unsatisfied, you may contact your state attorney general.
11. Children
RefinedCRM is a business tool and is not directed to children. We do not knowingly collect information directly from anyone under 18. Producers may hold records containing information about minors, such as a dependent or beneficiary named in a policy; that information is the producer’s record and is subject to their privacy practices.
12. Security
We use reasonable administrative, technical and physical safeguards to protect personal information.
No method of transmission or storage is completely secure, so we cannot guarantee the security of your information.
If a security incident affects your information, we will notify you as required by law and without undue delay.
13. Where your information is held
We and our service providers store and process information in the United States. RefinedCRM is offered to customers in the United States and is not directed to individuals outside it.
14. Changes to this policy
If we change this policy we will update the date at the top. For material changes we will notify customers by email or in the product before the change takes effect.