This Privacy Policy explains how Headwaters Final Expense, a division of North American Senior Benefits ("Headwaters," "we," "us," or "our") collects, uses, shares, and protects information through the Headwaters FEX mobile application (the "App").
The App is a private business tool. Only authorized Headwaters employees, contracted agents, and approved team members ("Users") can log in. It gives Users mobile access to our customer relationship management system (the "CRM"). The App is not available to the general public.
This policy covers two kinds of information:
User Information: information about Users themselves, collected when they log in to and use the App.
Client Data: information about our leads, clients, applicants, and policyholders that Users view or enter in the CRM through the App.
If you are a client or prospective client of Headwaters, we also handle your information under our consumer privacy notice and any privacy notices required by insurance law and the carriers we represent. Those notices are available on request from Headwaters.
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Information We Collect
From Users:
Account details: name, work email, phone number, role, license number and state, and login credentials.
Activity in the App and CRM: logins, records viewed or edited, notes, tasks, appointments, and calls, texts, and emails sent through the CRM. Call recordings may be included where recording is enabled and permitted by law.
Device and technical data: device type, operating system, app version, IP address, crash logs, and diagnostic data.
Permissions you allow: depending on features you use, the App may request access to notifications, microphone (for calls), camera or photos (for uploading documents), or contacts. You can turn these off in your device settings at any time.
Client Data (entered or viewed by Users):
Contact details: name, phone number, email, and mailing address.
Application details: date of birth, gender, beneficiary information, and coverage and policy details.
Health information disclosed during the insurance application process, such as medical conditions, medications, height, weight, and tobacco use.
Financial information needed to place a policy, such as premium payment method and bank account details for drafting premiums.
Communication history and records of consent or opt-out.
The App does not use third-party advertising trackers, and we do not track Users or clients across other companies' apps or websites.
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How We Use and Share Information
We use information to:
Give Users secure access to the CRM and keep the App working.
Contact leads and clients, submit insurance applications, and service policies.
Supervise, train, and support Users, and track performance and commissions.
Verify identity, prevent fraud, and protect the security of our systems and Client Data.
Meet our legal, regulatory, licensing, and carrier obligations, including telemarketing and consent rules.
Fix bugs and improve the App.
We do not sell personal information, and we do not share it for cross-context behavioral advertising.
We share information only as follows:
CRM and software providers: a third-party CRM provider and other vendors that host, operate, or support the App, CRM, phone, texting, and email systems for us. They may use the information only to provide services to us.
Insurance carriers: application and policy information goes to the carriers that underwrite and issue policies.
Professional advisors: attorneys, accountants, and auditors, under confidentiality obligations.
Legal and safety: regulators, law enforcement, or others when required by law, subpoena, or court order, or to protect the rights, safety, or property of Headwaters, our clients, or others.
Business transfers: a buyer or successor if Headwaters is involved in a merger, acquisition, or sale of assets, subject to this policy.
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Security, Retention, and Deletion
We protect information with encrypted connections, password-protected and role-based access, activity logging, and the security controls of our CRM provider. Users must lock their devices and keep credentials private. No system is completely secure, so we cannot guarantee that information will never be accessed without authorization. If a breach affects your information, we will notify you as required by law.
We keep User Information for as long as you have an active account, and afterward for as long as needed for payroll, commission, compliance, and legal purposes. We keep Client Data for as long as required by insurance regulations, carrier agreements, and other law, and then delete or de-identify it.
Account deletion:
User accounts are created and managed by Headwaters. Access is removed when your relationship with Headwaters ends. You can also request that your User account be deleted at any time by emailing support@nasb.headwatersfex.com. We will delete or de-identify your User Information except what we must keep for legal, tax, or regulatory reasons.
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Your Choices and Rights
Users can manage device permissions and notifications in their phone settings. You may ask to access, correct, or delete your User Information by emailing support@nasb.headwatersfex.com. Depending on the state where you live, you may have additional privacy rights; we will honor them as required by law.
Clients who want to access, correct, or ask questions about their information, or to opt out of calls or texts, can contact us at support@nasb.headwatersfex.com or 330-808-4455. We will respond within the time required by law.
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Children
The App is only for authorized adult Users. We do not knowingly collect information from children under 13 through the App.
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Changes to This Policy
We may update this policy from time to time. We will post the updated version on this page and in the App, and change the date at the top. Continued use of the App after an update means you accept the updated policy.
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Contact Us
Questions about this Privacy Policy or the App go to:
