Willoughby Privacy Policy

Willoughby#willoughby

Notice of Insurance Information Practices#notice-of-insurance-information-practices

Last updated: 10/10/25#last-updated-10-10-25

Willoughby, Inc. (“Willoughby,” “we,” or “us”) is a wholly-owned subsidiary of Propel and a licensed Medicare broker that helps qualifying applicants apply for Medicare insurance plans (the “Medicare Brokerage Services”) using our website and mobile applications (collectively, the “App”). As a licensed Medicare broker, we are authorized under state insurance laws to collect your personal information to help you obtain Medicare insurance plans. This Notice of Insurance Information Practices supplements the Propel Privacy Policy to explain how we use and share the personal information you provide to us when you use the Medicare Brokerage Services. This Notice also explains your rights and choices for such personal information.

Information we collect#information-we-collect

We need information about you to help you apply for and enroll in Medicare insurance plans. The information we collect for these purposes may include your zip code, Social Security Number, age, medical history, drugs you use, doctors you see, insurance history, and other personal characteristics. Most of this information will come directly from you. We may also obtain some information from other parties. For example, we receive your name and contact information from your Propel account. We may also receive information from third-party partners, including field marketing organizations (“FMOs”) and others, to confirm your Medicare or Medicaid and otherwise assist us in providing the Medicare Brokerage Services to you. Where required, we will only obtain such information with your explicit acknowledgement.

Providing the requested information is voluntary. However, failing to provide it may delay or prevent your ability to use our Medicare Brokerage Services. If you don’t provide correct information on this form or knowingly and willfully provide false or fraudulent information, you may be subject to a penalty and other law enforcement action.

In addition to the information you provide to obtain the Medicare Brokerage Services, we may automatically collect information about your interactions with our App, such as the times you access the App, the pages you view, the type of device you use to access the App, your IP address, and other information. To learn more about how we collect information automatically through the App, please visit the Propel Privacy Policy.

How we use your information#how-we-use-your-information

We use your information to provide you the Medicare Brokerage Services, including to help you navigate Medicare insurance plans, select your preferred plan, and enroll. We may also use your information for customer support purposes and to analyze and improve the performance of the App and our Medicare Brokerage Services.

We also use your information as required by law or as we believe is necessary and appropriate to protect our business and legal rights. For more information on how we use your information, please visit the Propel Privacy Policy.

We do not disclose your information unless permitted by you or by law. We may, as allowed by law, disclose information to:

Insurance carriers that offer Medicare plans, including to help you select and enroll in plans offered by such carriers. In addition, we may offer you opportunities to connect with another brokerage service that can better serve your needs, and, if you accept, we will share your information with the brokerage service.
Service providers that provide services on our behalf or help us operate our Medicare Brokerage Services or the App, such as hosting services, communications, data and cyber security services, billing and payment processing services, identity verification, fraud detection, investigation and prevention services, web and mobile analytics, and email and communication distribution and monitoring services.
Professional advisors, such as service providers, professional agencies, and vendors where necessary in the course of the services that they render to us.
Authorities and others, law enforcement, government authorities, and private parties, as we believe in good faith to be necessary or appropriate.

We may also share your information with affiliates, including Propel, and with acquirers and other relevant participants in the sale of a part or all of our business, as described in the Propel Privacy Policy.

How we protect your information#how-we-protect-your-information

We maintain physical, electronic and procedural safeguards to protect information which we collect from you. We permit access to your information to authorized persons who are trained in the proper handling of this information.

Your rights and choices#your-rights-and-choices

You have the right to request a copy of the personal information that we have about you. If we receive such a request, we will provide you a copy of your requested personal information within 30 days, as long as the information is reasonably locatable and retrievable. We may charge a reasonable fee to cover the costs incurred to provide you with copies of requested personal information.

You have the right to correct, amend or delete personal information we may have recorded about you. We will respond to your written request to correct, amend or delete personal information about you, within our possession, within 30 business days from the date your request is received.

Your access to Medicare insurance plans is contingent upon your eligibility for such plans pursuant to applicable laws. We do not make such eligibility determinations. If you disagree with an eligibility determination, please contact the carrier responsible for the determination.

If you wish to exercise your rights as provided in this notice, please contact us at brokerageops@propel.app or write to us at:

Willoughby Insurance Services, LLC,
235 Duffield Street
Suite 1700
Brooklyn, New York 11201