Privacy Policy
1. Who we are
Kornugle Group LLC, together with its affiliates, subsidiaries, members of the corporate group, successors, and assigns (collectively, “Kornugle,” “we,” “our,” or “us”), operates the Services. The Kornugle Parties include, without limitation:
- Finazo LLC — Florida-domiciled consumer financial comparison and publication platform
- Cubierto Insurance LLC — Florida-domiciled licensed insurance broker
- Hogares Mortgage LLC — Florida-domiciled mortgage broker (NMLS issuance pending Q3 2026)
- Kornugle Group LLC — Florida-domiciled parent holding entity
- Cubierto Corredores de Seguros, S.A. de C.V. — Salvadoran insurance brokerage affiliate (named only in the Tier 2 cross-border opt-in)
Each Kornugle Party is a separately operating legal entity, but for purposes of this Privacy Policy each Kornugle Party participates in shared data collection, processing, sharing, marketing, training, and service-delivery infrastructure. The addition of any new affiliated entity not named above requires separate consent and re-papering of this Policy.
2. What this policy does
This Privacy Policy describes the categories of Personal Information we collect about you, how we use, share, retain, and disclose that information, your choices, and how to contact us. By visiting any Service, creating an account, providing your information through any form (including by WhatsApp message, voice note, or AI chat), or otherwise interacting with us, you acknowledge and agree to the terms of this Privacy Policy. If you do not agree, do not use the Services.
This Privacy Policy is incorporated by reference into our Terms of Service. To the extent of any conflict, the Terms of Service govern.
3. Information we collect
3.1 Information you provide directly
- Identifiers: name, email address, telephone number, WhatsApp number, mailing address, date of birth, Social Security number or ITIN (where required for credit or underwriting), driver's license number, government-issued ID
- Account credentials: username, password, security questions and answers
- Financial information: income, employment, assets, debts, credit history, bank account information, payment-card information (the latter handled by PCI-compliant third-party processors)
- Insurance-related: vehicles owned, properties owned, prior claims, prior coverage, medical history (only when expressly requested for the line of insurance), beneficiaries
- Mortgage-related: property address, purchase price, down payment, loan amount sought, credit score range, employment, household composition
- Preferences: product interests, communication frequency, language preference
- User-generated content: queries, profile data, photographs uploaded for inspection (e.g., vehicle photos, property photos), voice notes (including WhatsApp audio), chat messages with AI assistants and human agents, reviews, comments
- Co-applicants and dependents: information about other individuals you provide (e.g., spouse, household members, beneficiaries). You represent and warrant that you have authority to provide their information to us.
3.2 Information collected automatically
When you visit any Service, we and our service providers automatically collect:
- Device information: IP address, device type, operating system, browser, screen resolution, language
- Usage information: pages viewed, time on each page, clicks, form interactions (including keystrokes, mouse movements, and scroll depth), search queries, referring URL
- Cookies, pixels, web beacons, SDKs, and other tracking technologies
- Approximate location derived from IP address; precise GPS location only if you grant device permission
- Session recordings: we may record your interaction with the Services using site-visit recording technology, including mouse movements, clicks, the information you input into forms, page snapshots, and HTTP headers. By visiting our Services or using them, you acknowledge and consent to such recording.
- Conversations: chat transcripts, voice recordings, video recordings, transcripts of phone calls with our agents (we may record any inbound or outbound call for quality, training, fraud detection, and compliance purposes), and the contents of WhatsApp messages (including voice notes, images, videos, and AI-generated content)
3.3 Information from third parties
- Credit bureaus (Equifax, Experian, TransUnion) when you authorize a soft or hard credit pull
- Public records (court records, real estate records, lien records, business filings)
- Data brokers and lead aggregators when we acquire leads or supplement an existing record
- Insurance carriers, lenders, and other Kornugle Parties when sharing information for the products and services you have requested
- Social-media platforms when you interact with our pages, accept a single sign-on, or our advertising
- Affiliate partners and lead generators when they refer you to us with your consent (per the FCC one-to-one consent rule, the named seller you consented to be referred to must include at least one Kornugle Party)
- Government and identity-verification services to verify identity and prevent fraud
3.4 Combination of information
We may combine all of the above into a single record about you, and we may use, disclose, and protect that combined record for any purpose described in this Privacy Policy.
4. How we use your information
- Service delivery: to provide quotes, recommendations, applications, underwriting, policy or loan issuance, claims handling, payments, customer service, and all related activities
- Marketing and promotional communications: including by email, SMS, WhatsApp, automated telephone dialing systems (ATDS), prerecorded voice, live agent, and direct mail, for the Kornugle Parties and our Carrier Network / Lender Network
- Personalization: tailoring content, recommendations, and offers
- Interest-based advertising: including across third-party platforms (Google, Meta, TikTok, X, and others)
- Research, analytics, and business intelligence
- Development, training, refinement, and improvement of AI models, machine learning algorithms, automated decision systems, recommendation engines, fraud-detection systems, voice-recognition systems, computer-vision systems, and other predictive technologies operated by or for the Kornugle Parties — see Section 7
- Fraud prevention, identity verification, and security
- Compliance with law, court orders, subpoenas, and government requests
- Internal business operations, audit, and corporate transactions (including mergers, acquisitions, dispositions, bankruptcies, and corporate restructurings)
5. How we share your information
5.1 Kornugle Parties
We share your Personal Information freely among all Kornugle Parties for any purpose described in this Privacy Policy, including routing your lead to the correct Kornugle Party broker for the product you requested, cross-marketing other Kornugle Party products to you, AI training, fraud prevention, internal analytics, and corporate operations. By using the Services, you authorize this intra-group sharing.
5.2 Carrier Network (insurance) and Lender Network (mortgage)
When you request a quote, application, or recommendation for a product, we share your information with the licensed insurance carriers, underwriters, mortgage lenders, loan officers, and product partners (collectively, the “Carrier Network” and “Lender Network”) whom we determine match your request. The current Carrier Network is maintained at the entity-specific URL referenced in the Sign-Up Consent (e.g., cubierto.ai/carriers, hogares.us/lenders, finazo.us/partners). The Network is updated from time to time without re-papering this Privacy Policy.
5.3 Service providers
We share Personal Information with service providers performing services on our behalf, including hosting, analytics, marketing, fraud detection, payment processing, identity verification, communications (SMS / WhatsApp / email gateways), customer service, AI model providers, cloud computing, and document storage.
5.4 Marketing and advertising partners
We share Personal Information (or hashed identifiers, depending on the platform) with advertising platforms (Google, Meta, TikTok, X, advertising networks, and other publishers) for purposes of measurement, audience matching, retargeting, and interest-based advertising.
5.5 Lead-sale and data-monetization partners
We may sell, share, license, or otherwise transfer Personal Information to third-party marketing partners, data brokers, and lead-purchase counterparties for their own marketing, modeling, scoring, and analytics purposes. California residents have the right to opt out of “sale” and “sharing” as defined under the CCPA / CPRA via the “Do Not Sell or Share My Personal Information” link.
5.6 Corporate transactions
We may transfer Personal Information to an acquirer, successor, or assignee in any merger, acquisition, sale of assets, financing, reorganization, bankruptcy, receivership, or similar corporate transaction.
5.7 Legal, safety, and compliance
We may disclose Personal Information to law enforcement, regulators, courts, or other government authorities in response to subpoena, court order, government investigation, or lawful request; to enforce our rights and the Terms of Service; to detect, prevent, or investigate fraud, unauthorized access, or unlawful activity; or to protect the safety of any person.
5.8 De-identified and aggregated information
We may de-identify, anonymize, or aggregate Personal Information and disclose such information to any third party for any purpose without restriction.
6. GLBA Privacy Notice
This section is provided pursuant to the Gramm-Leach-Bliley Act (“GLBA”) for Kornugle Parties that are “financial institutions” within the meaning of GLBA, including Cubierto Insurance LLC and Hogares Mortgage LLC.
Why we collect nonpublic personal financial information: To provide you with insurance, mortgage, and related financial products and services.
What information we collect: As described in Section 3 above, including identifying information, application information, transaction information, and consumer-report information.
| Reasons we share | Do we share? | Can you limit? |
|---|---|---|
| For our everyday business purposes (servicing your account, processing transactions, court orders, reporting to credit bureaus) | Yes | No |
| For our marketing purposes (offering products and services to you) | Yes | No |
| For joint marketing with other financial companies | Yes | No |
| For our affiliates' everyday business purposes (transactions and experiences) | Yes | No |
| For our affiliates' everyday business purposes (creditworthiness) | Yes | Yes — see §11.4 |
| For our affiliates to market to you | Yes | Yes — see §11.4 |
| For non-affiliates to market to you | Yes | Yes — see §11.4 |
7. AI use — disclosure and training data
This section is incorporated into and forms part of this Privacy Policy. A standalone version of the full AI Use Disclosure is available at /legal/ai-disclosure.
7.1 We use AI
We use artificial intelligence (“AI”), machine learning, large language models, generative AI, automated decision systems, computer vision, voice recognition, and similar technologies throughout the Services. This includes AI chatbots and virtual assistants on our websites, in WhatsApp, and via voice; AI-supported product recommendation engines; AI-supported underwriting, credit-decision support, and fraud detection; AI-generated content shown to you (including messages, summaries, comparisons, and translations); and AI processing of voice notes, photos (e.g., vehicle and property inspection photos), and uploaded documents.
7.2 AI is informational; you must verify before acting
AI-generated outputs are informational only and may contain errors, omissions, hallucinations, or inaccuracies. You are responsible for evaluating and verifying any AI output before relying on it. You acknowledge and agree that you should consult a qualified, licensed professional (insurance agent, mortgage broker, accountant, attorney, financial advisor) for any recommendations related to your individual situation. We do not warrant the accuracy, completeness, or fitness for any particular purpose of any AI-generated content.
7.3 Training data — your authorization
By using the Services, you authorize the Kornugle Parties to use the Personal Information described in Section 3 — including queries, conversation transcripts, voice recordings, uploaded photos and documents, profile data, behavior data, and any other input you provide — to train, fine-tune, refine, develop, and improve AI models, machine learning algorithms, automated decision systems, and other predictive technologies operated by or for the Kornugle Parties. Training-data use survives termination of any specific service relationship.
Opt-out: You may opt out of prospective training-data use at any time by contacting privacy@kornugle.ai. Opt-out is prospective only — once your data has been incorporated into a trained model, opt-out cannot remove it from that model. Opt-out does NOT apply to data used for fraud detection, security monitoring, or compliance.
7.4 No automated decisions without human review for legally significant outcomes
For decisions about you that produce legal or similarly significant effects (e.g., denying an insurance application, denying a mortgage application, declining credit, terminating an account for fraud), we do not rely solely on AI output. A qualified human reviewer is involved in the final decision. AI is used as a decision-support tool, not as the sole decision-maker. This commitment satisfies CPRA, CO-CPA, and GDPR (where applicable) limits on automated decision-making.
7.5 What we will NOT use for AI training
- Payment-card numbers, full bank account numbers, full Social Security numbers (we will use hashes or tokenized versions only)
- Communications protected by legal privilege (when identified)
- Any information designated under applicable law as not permitted for training
8. Retention
We retain Personal Information for at least seven (7) years from the date of collection or last interaction, whichever is later, to fulfill the purposes described in this Privacy Policy and to satisfy our legal and regulatory obligations (which may extend for many years after the end of any service relationship). For specific record types: consent records (7 years), WhatsApp conversation history (7 years from last interaction), insurance policy files (7 years post-policy-expiration), mortgage applications (longest of 25 months post-action-taken per Reg B, 3 years post-closed-loan per RESPA, or 5 years for fair-lending audit), and adverse action notices (25 months from notice per Reg B). De-identified data may be retained indefinitely.
9. Security
We maintain physical, technical, and administrative safeguards designed to protect Personal Information from unauthorized access, disclosure, alteration, and destruction. No security measure is perfect. You acknowledge that data transmission over the Internet is inherently insecure, and we do not guarantee the security of any information you transmit to us. You are responsible for safeguarding any account credentials you have with us.
10. Children
The Services are intended only for individuals who are at least eighteen (18) years old and U.S. residents. We do not knowingly collect, sell, or share Personal Information from individuals under 18. If you believe we have collected information from a person under 18, contact us at privacy@kornugle.ai and we will delete it.
11. Your choices and rights
11.1 Marketing opt-out
You may opt out of receiving marketing communications by replying STOP, BAJA, UNSUBSCRIBE, or similar to any SMS or WhatsApp message; clicking the “Unsubscribe” link in any commercial email; or contacting privacy@kornugle.ai.
Opt-out is independent per Kornugle Party: opting out of one entity does not opt you out of the others, and you may need to opt out separately from each. If you re-engage with the Services after opting out, your renewed use will constitute renewed consent to receive marketing communications, in addition to any other consents required by applicable law.
Even after opt-out, you may continue to receive non-marketing transactional communications (e.g., billing notices, claims status, fraud alerts).
11.2 AI training opt-out
By contacting privacy@kornugle.ai. Prospective only.
11.3 Cookies and trackers
Click the cookie banner on any first visit to manage tracking preferences. You may also adjust browser/device settings, including enabling Global Privacy Control (GPC), which we honor as an opt-out signal for sale and sharing under CCPA / CPRA.
11.4 GLBA opt-outs
To limit sharing of nonpublic personal financial information for affiliate marketing, non-affiliate marketing, or affiliate creditworthiness sharing (per the table in Section 6), contact privacy@kornugle.ai. Your opt-out will apply across all Kornugle Parties to the extent permitted by the GLBA framework.
11.5 State-specific rights
Residents of the following states have additional rights under applicable state privacy laws:
- California (CCPA / CPRA): right to know, delete, correct, opt out of sale and sharing, limit use of sensitive personal information, no discrimination for exercising rights
- Virginia, Colorado, Connecticut, Utah, Texas, Oregon, Montana, Iowa, Tennessee, Indiana, New Hampshire, Delaware, New Jersey — substantially similar consumer privacy rights
To submit a state privacy request, contact privacy@kornugle.ai.
11.6 Right to revoke TCPA consent
You may revoke express written consent to receive marketing SMS, WhatsApp, or autodialed calls at any time, by any reasonable method. Revocation will be processed within a commercially reasonable time and in any event within the period required by applicable law. Revocation of TCPA consent does not delete data already collected and does not affect your obligations under any active service relationship (e.g., a policy or loan).
12. International users — services limited to the United States
Our Services are designed for and directed to residents of the United States. We make no representation that our Services are available, appropriate, or governed by or operated in accordance with the laws of any other country. Residents of the European Union, the United Kingdom, Switzerland, and other non-U.S. jurisdictions are not permitted to use the Services and should not provide Personal Information through the Services. We may geo-block access from non-U.S. IP addresses.
Cross-border services involving our Salvadoran affiliate, Cubierto Corredores de Seguros, S.A. de C.V., are subject to a separate Tier 2 opt-in administered via WhatsApp and are not invoked by use of this site.
13. Changes to this Privacy Policy
We may update this Privacy Policy from time to time. The “Last Updated” date at the top reflects the most recent revision. Unless otherwise stated, the current version of this Privacy Policy applies to all Personal Information under our control, whether collected before or after a change. By visiting or using the Services after a change, you agree the updated Privacy Policy shall apply. We will provide additional notice for material changes if required by applicable law.
14. Contact us
| Privacy email | privacy@kornugle.ai |
|---|---|
| Mailing address | Kornugle Group LLC 700 S Rosemary Ave, Suite 204 West Palm Beach, FL 33401 |
| Compliance email | compliance@kornugle.ai |
This Privacy Policy is governed by the laws of the State of Florida. See the Terms of Service for governing-law and arbitration provisions.