Privacy Policy

Your privacy is important to us. This privacy policy (the “Privacy Policy”) describes how the HCG Brokerage, LLC (“HCG Brokerage”, “we,” “our,” or “us”) collects, uses and shares personal information and other information (collectively, the “Information”) obtained through our website (the “Site”) or that we otherwise collect in providing services to you. HCG Brokerage helps facilitate membership in the Aging at Home Association, where members may choose to acquire an insurance benefit (Home Care Secure) underwritten by Guaranteed Trust Life for home care services with a lifetime maximum coverage, access to the services of partner Wellthy, a technology-enabled platform offering services and care through vetted care coordinators as well as personalized care plans to help aging at home, and availability of a health and well-being assessment jointly developed with Fidelity Investments®.

Information we collect and how we use it

When you use the Site, including when you sign up to create an account, or when you otherwise interact with us, we collect different types of Information from you. We also may collect information from and about you in processing your transactions, and from other parties, including our affiliates.

The table below lists the different types of Information that the HCG Brokerage may obtain about you and the purposes for which we may use such Information. When you are no longer our customer, we will continue to use and disclose your information as described in this notice.

Member Information


Contact and identification information, including:

  • First and last name
  • Email address
  • Cell/other phone number
  • Home address
  • Payment information
  • To verify your identity in connection with the creation of your online account and use of the Site and when we otherwise provide services to you
  • To provide you with the Site and requested services (whether those services are requested through the Site or another channel)
  • To communicate with you and respond to your questions or requests
  • To send you marketing communications or contact you about special events, programs, surveys, contests, sweepstakes, and other offers or promotions
  • To generate and analyze usage statistics and improve and customize your experience with the Site
  • To address and respond to your questions and inquiries
  • To administer surveys and questionnaires, such as for market research or customer satisfaction purposes

Other Information


Online transaction information, including:

To ensure the proper functioning and availability of the Site

  • IP address
  • Device type, model and operating system
  • Information about how and when you interact with our Site
  • To generate and analyze Site usage statistics and improve and customize your experience with the Site
  • To assist us with our online advertising efforts

Information about age and other insurance coverage

  • To help screen for potential eligibility in Home Care Secure and guide you to appropriate insurance products and benefit offerings
  • To offer you products and services you may be interested in

Enrollment, renewal, and disenrollment information related to Aging at Home Association and Home Care Secure

  • To ensure we can help guide you to the appropriate insurance products and benefit offerings
  • To offer you products and services you may be interested in

In addition, we may use the Information obtained to:

  • Improve our products and services, and to develop new products and services
  • Detect, prevent and respond to fraud or theft, violations of law, our Privacy Policy or Terms of Service and other policies, or other misuse of the Site or our services
  • Comply with and enforce applicable legal requirements, contractual obligations and our policies
  • Support our business operations and perform accounting, auditing and other internal functions
  • To create aggregate and de-identified data

Information automatically collected about your visit to our Site

We may automatically collect certain information when you visit our Site, including through cookies, web beacons and other technologies. We may use cookies to generate and analyze statistics about your use of the Site, improve and customize your experience with the Site, and for online advertising purposes. We may also use cookies to collect aggregate information about Site users. The information collected for these purposes (including your IP address and other information collected by automated means) may be disclosed to or collected directly by our web analytics service providers, such as Google Analytics. To learn more about Google’s privacy practices, please review the Google Privacy Policy at You can also download the Google Analytics Opt-out Browser Add-on to prevent your data from being used by Google Analytics at

If you do not want cookies, most web browsers include an option that allows you to not accept them. However, if you set your browser to refuse cookies, you may not be able to log in successfully and/or some features of the Site may not function properly. We do not currently respond to web browser “do not track” signals on the Site.

Site visitors may opt out of many advertising networks. For example, you may go to the Digital Advertising Alliance (“DAA”) Consumer Choice Page for information about opting out of interest-based advertising and their choices regarding having information used by DAA companies. You may also go to the Network Advertising Initiative (“NAI”) Consumer Opt-Out Page for information about opting out of interest-based advertising and their choices regarding having information used by NAI members. Opting out from one or more companies listed on the DAA Consumer Choice Page or the NAI Consumer Opt-Out Page opts you out from those companies’ delivery of interest-based content or ads to you, but it does not mean you will no longer receive any advertising through our Site or on other websites. You may continue to receive advertisements, for example, based on the particular website that you are viewing (i.e., contextually based ads). Also, if your browsers are configured to reject cookies when you opt out on a consumer choice website, your opt out may not be effective.

With whom we may share your information

We may share your Information:

  • With our team members working on your requests as appropriate.
  • With service providers who work on our behalf, such as cloud storage providers, and companies that provide services or functionalities on the Site, such as payment processors, email/SMS communication or marketing service companies.
  • With our affiliated entities, including information about your transactions and experiences with us. Our affiliates include entities that are related by common ownership or control,and can include financial and non-financial companies, including the Aging at Home Association.
  • With insurance producers, agents, and brokers we work with to help provide you with insurance products and services you request.
  • With companies who provide benefits to Home Care Secure policyholders. To facilitate Home Care Secure policyholders’ use of the benefits available to them, we share information, including names and policy numbers, with these benefit providers.
  • As necessary or appropriate for our everyday business purposes. All financial companies, including insurance brokers like us, need to share customers’ personal information to run their everyday business. We may share personal information with affiliated and non-affiliated parties for our everyday business purposes and as permitted by law, including processing transactions, maintaining accounts, and reporting to consumer reporting agencies.
  • As necessary or appropriate, with our attorneys, accountants, auditors or other advisors.
  • To comply with applicable law or legal process, including government reporting obligations or in response to a law enforcement request.
  • As we believe it is necessary or appropriate to protect, enforce, or defend our legal rights, to prevent suspected fraud or illegal activities, to comply with and enforce applicable legal requirements, contractual obligations and our policies.
  • To the extent reasonably necessary to proceed with the negotiation or completion of a merger, acquisition, or sale of all or a portion of our assets (including in the event of a reorganization, dissolution or liquidation).
  • With your consent in circumstances other than those described above.

In addition, we may share aggregated or de-identified data with third parties for reporting, research, and advertising/marketing purposes. This generally includes aggregated level information such as how many people have signed up to the services, and not individual-level information.


The HCG Brokerage may post customer testimonials on the Site, which may include personal information. We obtain consent from users of the Site before posting these testimonials. If you would like to request that your testimonial be edited or removed from the Site, please contact us at [email protected].

Links to other websites, apps, or services

Our Site may contain links to other websites, apps or other online services for your convenience or information. These websites, apps and services are operated by companies not affiliated with the HCG Brokerage. Linked websites, apps or services may have their own privacy policies or notices, which we strongly encourage you to review. We are not responsible for the content and privacy practices of any third-party websites, apps or services.


The HCG Brokerage is not intended for and may not be used by children under the age of 13. We do not knowingly collect information from children under the age of 13 and we do not target our Site to children under the age of 13. You cannot sign up for a user account if you are under 13. If you learn that a child under the age of 13 has created a user account with us, please contact us at [email protected]. However, in connection with the services we offer through the Site, we may obtain Information about children under the age of 13 if a parent or legal guardian submits or shares such Information with us. We ask that users of the Site do not provide Information about children under the age of 13 without first getting the consent of the parent or legal guardian. By providing Information regarding a child under the age of 13, you are affirming that you are legally authorized to do so.

Protection of Personal Information

We maintain administrative, technical, and physical safeguards designed to protect the personal information the HCG Brokerage obtains about you and stores on its systems. However, no information system can be 100% secure, so we cannot guarantee the absolute security of your information. Moreover, we are not responsible for the security of information you transmit to the Site over networks that we do not control, including the Internet and wireless networks. In connection with your account, you should use passwords that are sufficiently complex and not share your passwords with others.

Changes to this Privacy Policy

We may modify this Privacy Policy at any time and without prior notice to you. Any changes to the Privacy Policy will be reflected on this page and will become effective immediately upon posting. If we make significant changes to this Privacy Policy, we will notify you by posting a prominent notice on this Site. We also may, at our discretion or when required by applicable law, notify you by email of such significant changes. Please check the effective date below to determine if there have been any changes since you have last reviewed the Privacy Policy.

Contact Us

If you have any questions about this Privacy Policy, please contact us at [email protected]

Date: 10/08/2020