California Consumer Privacy Act (“CCPA”)
DEFINITION OF PERSONAL INFORMATION
Personal Information does not include publicly available information and other information specifically excluded by the CCPA.
PERSONAL INFORMATION WE COLLECT
We may collect the following categories of Personal Information:
- Identifiers, including but not limited to, a real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, or other similar identifiers;
- Personal Information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)), including but not limited to a name, address, date of birth, telephone number, fax number, text message number, medical information or certain other similar information. Some Personal Information included in this category may overlap with other categories;
- Protected classification characteristics under California or federal law, including but not limited to, age (over 40 years), gender or other similar characteristics;
- Commercial information, including but not limited to purchasing or consuming tendencies;
- Internet or other similar network activity, including but not limited to, browsing history and search history within our Site or other websites owned by us; information on a consumer’s interaction with a website and advertisement.
- Inferences drawn from other personal information, including but not limited to, preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.
SOURCES OF COLLECTION OF PERSONAL INFORMATION
We obtain the categories of Personal Information from the following sources:
- Directly from you, from information you provide on this Site or other websites owned by us or our affiliates.
- Indirectly from our customers and clients, or their agents, in the course of providing services.
- Directly or indirectly from activity on this Site or other websites owned by us or our affiliates.
- From third parties that interact with us in connection with the services we perform.
USE OF PERSONAL INFORMATION
We may use or disclose the Personal Information we collect for one or more of the following business or commercial purposes:
- To fulfill or meet the reason for which the information was provided;
- To monitor traffic to this Site;
- To monitor the safety, security and integrity of this Site and our business and meeting requirements of applicable law or regulations;.
- For marketing services;
- To match Personal Information collected from you through different means or at different times and use such Personal Information, along with information obtained from other sources, including third parties;
DISCLOSURE OF PERSONAL INFORMATION TO OTHER PARTIES
We may disclose your Personal Information to the following categories of other parties for a business purpose or for a commercial purpose:
- Our affiliates;
- Service providers;
- Advertisers, analytics companies and other third partiers with whom we have business relationships;
- Our network of insurance companies, agents, brokers, discount program representatives, lead aggregators and other third party companies (“Third Party Companies”) who may contact you by telephone, including automatic telephone dialing system, by artificial pre-recorded message, by text message, by mail or by email or other form of communication;
- Government regulators;
- Our legal advisors and other parties involved in the legal process.
PERSONAL INFORMATION DISCLOSED AND SOLD
Within the last twelve months, we have disclosed and sold Personal Information to third parties for a business or commercial purpose. We do not sell the Personal Information of minors under 16 years of age.
YOUR CCPA PRIVACY RIGHTS AND CHOICES
The CCPA provides California residents with specific rights regarding their Personal Information as described below.
Right to know about personal information collected or sold.
You have the right to request that we disclose certain information to you about our collection, use, disclosure and sale of your Personal Information. After we receive and confirm your verifiable consumer request, we will disclose to you within the time required by the CCPA, the relevant information, which may include:
- The categories of Personal Information we collected about you in the past twelve months.
- The categories of sources for the personal information we collected about you.
- Our business or commercial purpose for collecting or selling that Personal Information.
- The categories of third parties with whom we share your personal information.
- The specific pieces of Personal Information we collected about you.
- If we sold your Personal Information, or disclosed your Personal Information for a business purpose, two separate lists disclosing:
- Sales, identifying the Personal Information categories that each category of recipient purchased; and
- Disclosures for a business purpose, identifying the Personal Information categories that each category of recipient obtained.
Right to Request Deletion of Personal Information
You have the right to request that we delete any of your Personal Information that we collected from you or is maintained by us, subject to certain exceptions, including if we need the Personal Information for a reason related to our business, such as:
- providing services to you;
- detecting and resolving issues related to security or functionality;
- complying with legal obligations;
- exercising free speech or ensuring another’s exercise of free speech; or
- using the information for internal purposes that a consumer might reasonably expect;
- fulfilling an enforceable governmental request or otherwise conform with the requirements of law or legal process;
- protecting or defending our legal rights or property, the Site, our employees or others;
- responding to an investigation of fraud or illegal activity regarding a specific user of the Site, even without a subpoena, warrant or court order;
After we receive and confirm your verifiable consumer request, we will delete your Personal Information from our records within the time period required by the CCPA, unless an exception applies.
Exercising your rights
To exercise the rights described above, you or a person we can validate as being authorized by you must submit a verifiable consumer request to us through one of the methods provided below in Contact Us.
The verifiable consumer request must provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative, which may include: providing your email and phone verification, known customer information, and/or account sign-up authentication or other information needed to verify your identity depending on the sensitivity of the personal information in question.
We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you.
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.
Response, Timing and Format
We will use good faith efforts to respond to a verifiable consumer request within forty-five (45) days after its receipt. If we need more time (up to 90 days), we will inform you of the reason and the needed extension period in writing.
We will deliver our written response by email.
Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request’s receipt. If we cannot comply with any portion of a request, the response we provide will also explain why, if applicable. We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.
Non-Discrimination for the exercise of CCPA Privacy Rights
We will not discriminate against you for exercising any of your CCPA rights.
Do Not Sell My Personal Information
The CCPA requires businesses to provide a web page where consumers can opt out of the “sale” of their Personal Information. The link to our Do Not Sell web form is located here.
California Civil Code Section 1798.83
California Civil Code Section 1798.83 permits California residents who have provided personal information to us to request certain information regarding our disclosure of such personal information to Third Party Companies for their marketing purposes. Within thirty days of receiving such a request, which should be made to us at firstname.lastname@example.org, we will provide a list of the categories of personally information disclosed to Third Party Companies for their respective marketing purposes during the immediately preceding calendar year, along with the names and addresses of those third parties and such other information required by law. This request may be made no more than once per calendar year. We reserve our right not to respond to requests submitted other than to email@example.com.
We place the highest value on the privacy of children. This Site is not developed for or directed at children. Persons under the age of 18 years (or the applicable age of majority in your jurisdiction if greater than age 18) and/or unable to enter into a legally binding contract are not eligible to do business with us.
By submitting any Personal Information to this Site, you fully understand and unconditionally consent to the transfer of such Personal Information to, and the collection and processing of such Information in the United States by Third Party Companies and are authorizing Third Party Companies to contact you directly by telephone, including automatic telephone dialing system, by artificial pre-recorded message, by text message, by mail or by email or other form of communication, regardless of the presence of your phone number(s) on any local or national do not call list.
If you are a California resident and would like to opt-out, please submit your information using our CCPA Opt-Out Request form.