California Consumer Privacy Statement
Last Updated: 1 November 2021
This California Consumer Privacy Statement (“Statement”) supplements the Everlake® Online Privacy Notice. It applies solely to California consumers and addresses personal information we collect online and offline. This Statement does not apply to Everlake® personnel, B2B personnel, or to information collected, processed, sold, or disclosed pursuant to the federal Gramm-Leach-Bliley Act and its implementing regulations or the California Financial Information Privacy Act. Sections 2-5 of this Statement do not apply to job applicants.
This Statement uses certain terms that have the meaning given to them in the California Consumer Privacy Act of 2018 and its implementing regulations (the “CCPA”).
Notice of Collection and Use of Personal Information
We may collect (and may have collected during the 12-month period prior to the effective date of this Statement) the following categories of personal information about you:
- Identifiers: identifiers such as a real name, alias, postal address, unique personal identifier (such as a device identifier; cookies, beacons, pixel tags, mobile ad identifiers and similar technology; customer number, unique pseudonym, or user alias; telephone number and other forms of persistent or probabilistic identifiers), online identifier, internet protocol address, email address, Social Security number, driver’s license number, passport number, and other similar identifiers.
- Additional Data Subject to Cal. Civ. Code § 1798.80: signature, physical characteristics or description, state identification card number, insurance policy number, education, bank account number, credit card number, debit card number, and other financial information, medical information, and health insurance information.
- Protected Classifications: characteristics of protected classifications under California or federal law, such as race, color, national origin, religion, age, sex, gender, gender identity, gender expression, sexual orientation, marital status, medical condition, disability, citizenship status, and military and veteran status.
- Commercial Information: commercial information, including records of personal property, products or services purchased, obtained, or considered, and other purchasing or consuming histories or tendencies.
- Online Activity: Internet and other electronic network activity information, including, but not limited to, browsing history, search history, and information regarding your interaction with websites, applications, or advertisements.
- Sensory Information: audio, electronic, visual, and similar information.
- Employment Information: professional or employment-related information.
- Education Information: education information that is not publicly available personally identifiable information as defined in the Family Educational Rights and Privacy Act (20 U.S.C. Sec. 1232g; 34 C.F.R. Part 99).
- Inferences: inferences drawn from any of the information identified above to create a profile about you reflecting your preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.
We may use (and may have used during the 12-month period prior to the effective date of this Statement) your personal information for the purposes described in our Everlake® Online Privacy Notice and for the following business purposes specified in the CCPA:
- Performing Services: Performing services, including maintaining or servicing accounts, providing customer service, processing or fulfilling orders and transactions, verifying customer information, processing payments, providing advertising or marketing services, providing analytics services, or providing similar services.
- Auditing: Auditing related to a current interaction with you and concurrent transactions, including, but not limited to, counting ad impressions to unique visitors, verifying positioning and quality of ad impressions, and auditing compliance.
- Short Term Use: Short-term, transient use, including, but not limited to, the contextual customization of ads shown as part of the same interaction.
- Security Purposes: Detecting security incidents, protecting against malicious, deceptive, fraudulent, or illegal activity, and prosecuting those responsible for that activity.
- Debugging: Debugging to identify and repair errors that impair existing intended functionality.
- Undertaking Internal Research: Undertaking internal research for technological development and demonstration.
- Undertaking Other Activities: Undertaking activities to verify or maintain the quality or safety of a service or device that is owned, manufactured, manufactured for, or controlled by us, and to improve, upgrade, or enhance the service or device that is owned, manufactured, manufactured for, or controlled by us.
Sources of Personal Information
During the 12-month period prior to the effective date of this Statement, we may have obtained personal information about you from the following categories of sources:
- Directly from you (such as when you contact us, inquire about a policy, or file a claim)
- From other individuals with whom you have a relationship (such as family members)
- Your devices (such as when you visit our Site)
- Our affiliates
- Vendors who provide services on our behalf
- Social media companies
- Consumer reporting agencies
- Data analytics providers
- Government entities
Sale of Personal Information
We do not sell your personal information.
We do not have actual knowledge that we sell personal information of minors under 16 years of age.
Sharing of Personal Information
During the 12-month period prior to the effective date of this Statement, we may have shared your personal information with certain categories of third parties, as described in our Everlake® Online Privacy Notice and below.
We may have disclosed the following categories of personal information about you for a business purpose to the following categories of third parties:
Identifiers: Companies involved in insurance and other business transactions; authorized agents or brokers; service providers; and third parties involved in a business transaction.
Additional Data Subject to Cal. Civ. Code § 1798.80 Law: Companies involved in insurance and other business transactions; authorized agents or brokers; service providers; and third parties involved in a business transaction.
Protected Classifications: Companies involved in insurance and other business transactions; authorized agents or brokers; service providers; and third parties involved in a business transaction.
Commercial Information: Third parties involved in a business transaction.
Online Activity: Service providers and data analytics providers.
Sensory Information: Government entities.
Employment Information: Companies involved in insurance and other business transactions; authorized agents or brokers; service providers; and third parties involved in a business transaction.
Education Information: Service providers.
Inferences: Service providers and data analytics providers.
In addition to the categories of third parties identified above, during the 12-month period prior to the effective date of this Statement, we may have shared personal information about you with government entities such as law enforcement authorities and regulators.
California Consumer Privacy Rights
You have certain choices regarding your personal information, as described below.
Access: You have the right to request, twice in a 12-month period, that we disclose to you the personal information we have collected, used, disclosed, and sold about you during the past 12 months.
Deletion: You have the right to request that we delete certain personal information we have collected from you.
How to Submit a Request
To submit an access or deletion request, please email us at firstname.lastname@example.org or call us at (888) 885-8912. To submit a request as an authorized agent on behalf of a consumer, please email us at email@example.com. For questions or concerns about our privacy policies and practices, please contact us as described in the How to Contact Us section of our Everlake® Online Privacy Notice.
To help protect your privacy and maintain security, we will take steps to verify your identity before granting you access to your personal information or complying with your request. If you request access to or deletion of your personal information, we may require you to provide any of the following information: your name, postal address, email address, and telephone number. In addition, if you ask us to provide you with specific pieces of personal information, we will require you to sign a declaration under penalty of perjury that you are the consumer whose personal information is the subject of the request.
If you choose to exercise any of your rights under the CCPA, you have the right to not receive discriminatory treatment by us. To the extent permitted by applicable law, we may charge a reasonable fee to comply with your request.