California Consumer Privacy Policy

Last Updated: [04/29/2021]

This California Consumer Privacy Policy (as updated from time-to-time, this “CA Privacy Policy”) is to explain our data collection and privacy practices regarding the personal information of California residents. This CA Privacy Policy supplements our general privacy statement and applies only to California residents.

The California Consumer Privacy Act (CCPA) provides you with certain privacy rights related to the personal information we collect about you. Please see below to learn more about your rights under the CCPA and to learn more about your rights and our practices.

1. What Information Does This Privacy Statement Apply To?.

   The CCPA is a state law that protects the personal information of California residents. It is not the only law that regulates how we collect and use personal information. In fact, various federal laws preempt the CCPA with respect to the information we collect and process. For example, the CCPA does not apply to personal information collected, processed, sold, or disclosed pursuant to the federal Gramm-Leach-Bliley Act (Public Law 106-102) or the Driver’s Privacy Protection Act of 1994 (18 U.S.C. § 2721 et seq.) As a result, not all of the personal information we collect and process will be discussed in this CA Privacy Policy. To learn about the information and collection practices generally, please review our general privacy statement.

2. Summary of CCPA Privacy Policy.

   Please read this entire Policy carefully to understand our practices regarding your personal information. The following points summarize some of the important details about the CCPA discussed below:

   • a California consumer has the right to request that we disclose what personal information we collect, use, disclose, and sell.
   • a California consumer also has the right to request that we delete the personal information we have collected from the consumer.
   • a California consumer has the right to opt-out of the sale of their personal information.
   • a California consumer has the right to not receive discriminatory treatment by us for the exercise of their privacy rights under the CCPA.

3. What Is Personal Information?

   The CCPA provides personal information rights to California residents. The CCPA defines personal information as information that “identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular” California consumer or household. Personal information does not include publicly available information or consumer information that is deidentified or aggregate consumer information.

4. What Personal Information Do We Collect About You?

   The following chart sets out the CCPA categories of personal information we have collected from California consumers in the last twelve (12) months.

   Categories of Personal Information We Collect	Categories of Third Parties With Which We May Share that Information
   Identifiers (such as name, address, email address)	Our Internet Service Providers (ISPs); data analytics providers; advertising service providers; operating systems and platforms; social networks; and business service providers.
   Personal Characteristics (Any categories of personal information described in subdivision (e) of Section 1798.80 of the California Civil Code)	Business service providers, advertising service providers.
   Commercial Information (such as transaction data)	ISPs; data analytics providers; advertising service providers; operating systems and platforms; social networks; and business service providers.
   Internet or Other Network or Device Activity (such as browsing history or app usage)	Our ISPs; data analytics providers; advertising service providers; operating systems and platforms; and business service providers.
   Geolocation Information We do not collect geolocation information but may infer a general or precise location from your IP address or your physical address, respectively.	ISPs; data analytics providers; operating systems and platforms; and business service providers.
   Inferences drawn from other personal information.	Our data analytics providers; advertising service providers; operating systems and platforms; and business service providers.

5. How Do We Use Your Personal Information?

   We use your personal information for the following business purposes:

   • To offer you products and services, determine your eligibility for insurance, service your policy, administer policy benefits, to process, service and enforce transactions (including credit or debit card transactions) and to provide users with product, service, or company updates.
   • To respond to your inquiries or comments, or to contact you about your policy.
   • To establish and verify the identity and eligibility of users.
   • To open, maintain, administer, manage, and service users’ profiles or accounts.
   • To analyze and improve our products, services, or Systems, improve safety; manage our communications; perform market research; perform data analytics; and perform accounting, auditing and other internal functions.
   • To communicate with you about or through external social networking platforms.
   • To conduct special events, sweepstakes, surveys, programs, contests, and other offers (and communicate with you about such events).
   • To market and advertise our products and services or those of third-parties.
   • To maintain the security and integrity of our Systems and internal records.
   • To conform to legal requirements or industry standards, respond to regulators, comply with subpoenas or legal process, detect and prevent fraud or criminal activity, defend our legal rights, or protect others.
   • To create anonymized or aggregated data sets.
   • In connection with a merger, acquisition, bankruptcy, transfer, sale, corporate change, or any other transaction involving all or a portion of our business.

   We may also use your personal information for any other purpose that we disclose at the time you provide, or when we collect, your information and other purposes permitted by applicable law. We may also use data that we collect on an aggregate or anonymous basis for various business purposes, where permissible under applicable laws and regulations.

6. What Are the Sources Of The Personal Information We Collect About You?

   • You, the consumer (including the device you use to access our website);
   • ISPs;
   • Data Analytics Providers;
   • Web browsers;
   • Advertising networks;
   • Operating systems and platforms;
   • Social networks;
   • Data brokers

7. With Whom Do We Share Your Personal Information?

   We share personal information as set forth above. You should also be aware of the following:

   • Our third-party service providers including advertisers and remarketers to show our ads on sites across the internet.
   • Our affiliates so that they may market their products and services to you.
   • Other financial institutions with which we may have joint-marketing agreements.
   • Non-affiliated companies, insurance agencies, mortgage brokers, bankers, securities broker-dealers, retailers, airlines, and others.
   • We may also allow third parties to place cookies, web beacons, and similar technologies to collect or receive information from our website and use that information to provide measurement services and target ads.

8. Do We Sell Personal Information?

   California law requires that we describe certain disclosures of personal information where we receive valuable consideration. We do not sell personal information to third parties. However, we do allow California residents to exercise their opt-in and opt-out rights regarding the sharing of personal information under California law. To exercise your California opt-in and opt-out rights, please click here https://privacychoices.confie.com/.

9. What Are My CCPA Rights to Know About My Personal Information?

   You have the right to know certain information about our collection, use, and disclosure of your personal information for the 12 months preceding the date of your request. You also have the right to request that we provide you with specific pieces of your personal information. These rights are subject to certain exceptions.

   Upon receipt of your request, and after we verify your identity, we may provide you with information about the following:

   • The categories of personal information we collected about you.
   • The categories of sources of the personal information we collected about you.
   • Our business or commercial purpose for collecting the personal information.
   • The categories of personal information we disclosed about you to a service provider.
   • The specific pieces of personal information we collected about you (data portability).

   If responding to all or part of your request would conflict with federal or state law, or your personal information is subject to an exemption under the CCPA, we will inform you of that fact. We will respond to the portion of your request that is not in conflict with applicable laws or exempt under the CCPA.

10. What are My CCPA Rights to Have my Personal Information Deleted?

    You have the right to request that we delete personal information we have collected from you, subject to certain exceptions and exemptions. Absent an exception or exemption, upon receipt of your request, and after we verify your identity, we will delete and will request that our service providers delete your personal information.

11. How Do I Exercise My CCPA Rights?

    CLICK HERE TO SUBMIT YOUR CCPA RIGHTS REQUESTS

    Only you, or someone legally authorized to act on your behalf, may make a verifiable consumer request related to your personal information. Agents must submit proof that they have been authorized by the consumer to act on their behalf. Making a verifiable consumer request does not require you to create an account with us. We will only use personal information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.

    We verify requests by sending a confirmation email to the requestor and by matching the identifying information provided by the consumer to the personal information already maintained by us. We cannot respond to your request or provide you with personal information if we cannot: (i) verify your identity or authority to make the request; and (ii) confirm the personal information relates to you. If we are unable to verify the identity of a requestor we will not provide any information.

    To exercise your California privacy rights, please click here https://privacychoices.confie.com/. You may also call us at 877-214-0149 toll free for more information.

12. What Are My CCPA Non-Discrimination Rights?

    We will not discriminate against you for exercising any of your CCPA rights, which means we will not:

    • Deny you goods or services.
    • Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.
    • Provide you a different level or quality of goods or services.
    • Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.

13. How Do I Contact You with Questions About the CCPA Privacy Policy?

    We are committed to working with you to obtain a fair and rapid resolution of any queries, complaints, or disputes about privacy. If you have any other questions or comments regarding our privacy practices, please call us at 877-214-0149 toll free for more information.