Effective Date: July 1, 2020
PURPOSE OF THIS NOTICE
- The types of information we collect through our Sites and Services
- How we use and protect that information
- The types of information we may share with others and under what circumstances
- The choices you have regarding our collection, use, and sharing practices
We also include specific disclosures for residents of California and Nevada.
OUR PRIVACY POLICIES AND PRACTICES
- Information we collect:
Categories of Information and Sources from Which it is Collected
We collect, use, and retain personal information that you provide when using our Sites and Services. We collect the following information from you:
- Information, such as your name, contact information, social security number, and driver’s license number, that you provide on applications, registration forms, and other forms;
- Your commercial information, including records of personal property, and products or services purchased, obtained, or considered, when you make purchases or we provide services to you;
- Your contact information and a record of any correspondence when you contact us;
- Your professional or employment-related information and education information;
- Health information when relevant to processing your insurance claims;
- Payment information and associated contact information when engaging in transactions; and
- Information you provide when you complete a survey administered by us or a vendor acting on our behalf.
- Information that you provide us on applications and other forms
- Information about your transactions with us from the insurance companies we contact to underwrite your insurance
- Information we receive from the Department of Motor Vehicles or other consumer reporting agencies
- Information contained in medical records or from medical professionals that is related to insurance claims.
Persons From Whom Information is Collected
We may collect personal information from individuals other than those proposed for coverage. Some of this information may be collected by external parties on our behalf. For example, we use payment processors when you engage in transactions related to our Sites and Services. We also collect the following information about you from other sources:
- Information about your transactions with us from the insurance companies we contact to underwrite your insurance;
- Contact information we receive from our marketing partners;
- Information we receive from the Department of Motor Vehicles;
- Information we receive from consumer reporting agencies; and
- Information contained in medical records or from medical professionals that is related to your insurance claims.
- Information we collect automatically:
When you interact with our Sites and Services, certain information about your use of the Sites and Services is collected automatically. This includes:
- Details of your visits to our Sites and information generated in the course of the use of our Sites (including the timing, frequency, and pattern of service use) including, but not limited to, traffic data, location data, weblogs and other communication data, the resources that you access, and how you reached our Sites.
- Details regarding the device you use to access our Sites and Services, including, but not limited to, your IP address, operating system, and browser type.
- Information about how you interact with our ads and newsletters, including whether you open or click links in any correspondence.
- Information that you make available to us on a social media platform (such as by clicking on a social media icon linked from our Services), including your account ID or username and other information included in your posts.
- Analytics: Allowing us to understand how our services are being used, track site performance and make improvements.
- Site Operations: Enabling features that are necessary for providing you the services on our Sites, such as identifying you as being signed in, tracking content views, and remembering your preferences.
Your browser or device may include “Do Not Track” functionality. At this time, we do not alter our Sites’ data collection and use practices in response to Do Not Track signals.
Most web browsers automatically accept cookies but, if you prefer, you can usually modify your browser setting to disable or reject cookies. If you delete your cookies or if you set your browser to decline cookies, some features of the Services may not be available, work, or work as designed. You may also be able to opt out of or block tracking by interacting directly with the other companies who conduct tracking through our Services.
- How we use your information:
We use the personal information we collect for one or more of the following purposes:
- To provide you with our products and services, including to provide you with quotations for insurance or other insurance or financial industry services (including those procured proactively and/or in connection with the movement of a book of business from one provider to another) on your behalf; to provide you with insurance or to facilitate the performance of related services; to maintain or service your account or insurance, including by reporting claims of loss to other entities such as insurance carriers and adjusters; to evaluate our performance or offerings; and, with your permission, to facilitate new quotations or placements.
- To make reports to credit bureaus;
- To process your requests, transactions, and payments and prevent transactional fraud.
- To distribute newsletters and promotional material, invite you to events, and market products and services to you.
- To assess, improve and develop our business, products and services, prepare benchmarking reports and for other research and analytics purposes.
- To comply with, or exercise rights under, applicable law – for example to make required or advisable reports to insurance regulatory, law enforcement or other similarly situated authorities; to respond to and comply with court orders, applicable law and other legal requirements; and to defend ourselves against claims and to enforce our rights or protect our employees or property.
- To market products and services to you.
- To provide or receive shared organizational services, such as claim and risk management services.
- To evaluate or effect a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, in which personal information held by us about our consumers is among the assets evaluated or transferred.
We use the information we collect from you for the following purposes:
- To provide you with our products and Services, including to underwrite your insurance, process payments, and send communications to you regarding our products and Services.
- To provide you with the best service and grow our business, including by understanding our customer base and understanding the effectiveness of our marketing;
- To understand how our Services are being used, track site performance, and make improvements;
- To detect, investigate, and prevent activities that may violate our policies or be fraudulent or illegal, and to comply with legal requirements regarding the provision of products and Services.
- How we share your information:
We disclose the information that we collect about you or others to the following types of institutions for the reasons described below:
To a vendor if the disclosure will enable that party to perform a business, professional or insurance function for us such as billing and collection providers, auditing and accounting firms, professional services and consultants, security vendors, and IT vendors
- To an insurance institution, agent or credit reporting agency in order to detect or prevent criminal activity, fraud or misrepresentation in connection with an insurance transaction.
- To an insurance institution, agent, or credit reporting agency for either this agency or the entity to whom we disclose the information to perform a function in connection with an insurance transaction involving you.
- To a medical care institution or medical professional in order to verify coverage or benefits, inform you of a medical problem of which you may not be aware, or conduct an audit that would enable us to verify treatment.
- To the California Department of Insurance or other insurance regulatory authority, law enforcement, or other governmental authority in order to protect our interests in preventing or prosecuting fraud, or if we believe that you have conducted illegal activities.
- To a group policyholder for the purpose of reporting claims experience or conducting an audit of our operations or
We also use or disclose your personal information if required to do so by law or on the good-faith belief that such action is necessary to conform to applicable law or comply with legal process served on us or our sites; protect and defend our rights or property, the websites or our users; or act to protect the personal safety of us, users of our websites, or the public.
We may transfer to another entity or its affiliates or service providers some or all information about you in connection with, or during negotiations of, any merger, acquisition, sale of assets or any line of business, change in ownership control, or financing transaction. We cannot promise that an acquiring party or the merged entity will have the same privacy practices or treat your information the same as described in this Policy.
- Our practices regarding information confidentiality and security:
We restrict access to personal information about you to those employees who need to know that information in order to provide products or services to you. We maintain physical, electronic, and procedural safeguards to guard your personal information. While we use these precautions to safeguard your information, we cannot guarantee the security of the networks, systems, servers, devices, and databases we operate or that are operated on our behalf.
- Our practices regarding children’s information:
Our Sites and Services are intended for users age sixteen and older. InterWest does not knowingly collect information from children. If we discover that we have inadvertently collected information from anyone younger than the age of 16, we will delete that information.
- Your California Privacy Rights
Residents of the State of California have the right to request information regarding third parties to whom companies have disclosed certain categories of personal information during the preceding year for the third parties’ direct marketing purposes. We do not disclose your information to third parties for direct marketing purposes.
The California Consumer Privacy Act (“CCPA”) provides California residents with rights to receive certain disclosures regarding the collection, use, and sharing of “personal information,” as well as rights to know or access, request deletion, and limit sharing of personal information. 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 consumer or household.” Certain information we collect may be exempt from the CCPA because it is considered public information (i.e., it is made available by a government entity) or covered by a specific federal privacy law, such as the Gramm–Leach–Bliley Act, the Health Insurance Portability and Accountability Act, or the Fair Credit Reporting Act. To the extent that we collect Personal Information that is subject to the CCPA, that information, our practices, and your rights are described below.
If you have a disability and require this Notice in an alternative format, please email us at email@example.com or contact us at 800-444-4134.
Right to Information Regarding Categories of Personal Information Collected, Sold, and Disclosed
The following is a description of our data collection practices, including the personal information we collect, the sources of that information, the purposes for which we collect information, and whether we disclose that information to external parties. We may use any and all of the information for any of the purposes described in this Policy, unless limitations are listed. The categories we use to describe the information are those enumerated in the CCPA.
- We collect your payment information when you complete a transaction.
- We do not collect your Social Security number, Driver’s License number, or Passport number.
- We collect your IP address automatically when you use our Services. We use this information to identify you, gauge online activity on our website, and measure the effectiveness of online services, applications, and tools.
- We collect your Device ID automatically when you use our Services. We use this information to monitor your use and the effectiveness of our Services, to identify you, and to provide you with targeted information and offers.
Protected Classifications. Age and Gender
Commercial Information. When you engage in transactions with us, we create records of goods or services purchased or considered, as well as your purchasing or consuming histories or tendencies.
Biometric Information: We collect health information when necessary to provide insurance to you. We do not otherwise collect information about your physiological, biological, and behavioral characteristics.
Internet or Other Electronic Network Activity Information: We collect information about your browsing history, search history, information regarding your interaction with websites, and applications or advertisements automatically when you use our Sites or Services.
Geolocation Data: As described above, we collect your IP address automatically when you use our Services. We may be able to determine your general location based on your IP address. If you allow your device to provide us with this information, we use it to make improvements to our products and services, and to provide recommendations and deliver relevant advertising.
Audio, electronic, visual, thermal, olfactory, or similar information: If you contact us via phone, we may record the call. We will notify you if a call is being recorded at the beginning of the call.
Professional or employment-related information: We do not collect your professional or employment-related information.
Education information: We do not collect any information about the institutions you have attended or the level of education you have attained.
Inferences drawn to create a profile about a consumer reflecting the consumer’s preferences or characteristics: We do not draw inferences in order to create a profile about you.
We may share any of the above-listed information with service providers, which are companies that we engage for business purposes to conduct activities on our behalf. Service providers are restricted from using personal information for any purpose that is not related to our engagement. The categories of service providers with whom we share information and the services they provide are described in this Notice.
We may also disclose information to other external parties who are not listed here when required by law or to protect our company or other persons, as described in this policy.
Right to Access
You have the right to request access to personal information collected about you and information regarding the source of that information, the purposes for which we collect it, and the categories of third parties and service providers with whom we share it. To protect our customers’ personal information, we will verify your identity before we act on your request.
Right to Request Deletion of Information
You have the right to request that we delete in certain circumstances any personal information that we have collected directly from you. To protect our customers’ personal information, we will verify your identity before we act on your request. We may have a reason under the law why we do not have to comply with your request, or why we may comply with it in a more limited way than you anticipated. If we do, we will explain that to you in our response.
Right to Opt Out of Sale of Personal Information to Third Parties
You have the right to opt out of any sale of your personal information at any time. The CCPA defines a “sale” as disclosing or making available to a third party personal information in exchange for monetary or other valuable consideration. To exercise this right, please visit our “Do Not Sell My Personal Information” webpage, www.iwins.com/privacy-policy/. . Please note that your right to opt out does not apply to our sharing of personal information with service providers, who are parties we engage to perform a function on our behalf and are contractually obligated to use the personal information only for that function.
How to Submit a Request
You may submit a request to exercise your rights to access or delete your information through one of two means:
(1) By filling out a consumer data request form available here https://www.iwins.com/california-consumer-privacy-act-request/.
(2) By calling us at 800-444-4134.
Only you, or someone legally authorized to act on your behalf, may make a request related to your personal information. You may also make a request on behalf of your minor child. We are not required to provide personal information to you more than twice within a 12-month period. 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 that the personal information relates to you. We will only use personal information provided in a request to verify your identity or authority to make the request.
In order to process your request to access or delete information we collect, disclose, or sell, we will verify your request. We do this by [asking you to provide personal identifiers we can match against information we may have collected from you previously; and confirm your request using the email or telephone account stated in the request]. We will not require you to create an account with us in order to make a request. However, we do consider requests made through your password protected account sufficiently verified when the request relates to personal information associated with that specific account.
- Special Information for Nevada Residents
Residents of Nevada have the right to opt out of the sale of certain pieces of their information to other companies who will sell or license their information to others. At this time, we do not sell your information.
- Contact Us
If you have any questions or comments about this Notice, the ways in which we collect and use your personal information described herein, your choices and rights regarding such use, or wish to exercise your rights under California law, please contact us at firstname.lastname@example.org or at:
P.O. Box 255188
Sacramento, CA 95865
- Your right to access and amend your personal information:
You have the right to request access to the personal information that we record about you. Your right includes the right to know the source of the information and the identity of the persons, institutions or types of institutions to whom we have disclosed such information within 2 years prior to your request. Your right includes the right to view such information and copy it in person, or request that a copy of it be sent to you by mail (for which we may charge you a reasonable fee to cover our costs). Your right also includes the right to request corrections, amendments or deletions of any information in our possession. Please be aware that we do not control the personal information about you obtained from other third parties such as, consumer reporting agencies or Department of Motor Vehicles. You will need to contact these third parties directly to correct your personal information. We will provide you with the name and address of these third parties. The procedures that you must follow to request access to or an amendment of your information are as follows:
- To obtain access to your information: You should submit a request in writing to Manager of Information Systems, InterWest Insurance Services, LLC., PO Box 255188, Sacramento, CA 95865. The request should include your name, address, social security number, telephone number, and the recorded information to which you would like access. The request should state whether you would like access in person or a copy of the information sent to you by mail. Upon receipt of your request, we will contact you within 30 business days to arrange providing you with access in person or the copies that you have requested.
- To correct, amend, or delete any of your information: You should submit a request in writing to Manager of Information Systems, InterWest Insurance Services, LLC., PO Box 255188, Sacramento, CA 95865. The request should include your name, address, social security number, telephone number, the specific information in dispute, and the identity of document or record that contains the disputed information. Upon receipt of your request, we will contact you within 30 business days to notify you either that we have made the correction, amended or deleted, or that we refuse to do so and the reasons for the refusal, which you will have any opportunity to challenge.
- .Our practices regarding information confidentiality and security:
We restrict access to nonpublic personal information about you to those employees who need to know that information in order to provide products or services to you. We maintain physical, electronic, and procedural safeguards that comply with federal regulations to guard your nonpublic personal information.
- Our policy regarding dispute resolution:
- Reservation of the right to disclose information in unforeseen circumstances:
In connection with the potential sale or transfer of its interests, InterWest Insurance Services, LLC., and its affiliates (if any), reserve the right to sell or transfer your information (including but not limited to your name, address, age, sex, zip code, state and country of residency, and other information that you provide through other communications) to a third party entity that (1) concentrates its business in a similar practice, product or service: (2) agrees to be InterWest Insurance Services, LLC’s successor in interest with regard to the maintenance and protection of the information collected: and (3) agrees to the obligations of this privacy statement.
- Opt-Out form available upon request
After reading this Notice, we are certain that you will now understand our agency respects your privacy and takes its responsibility to protect the information about you seriously. One of the purposes of this Notice is to inform you that you have the right to prohibit the sharing of your “non-public” personal information with any third parties. If you choose to exercise this right, you may communicate with our agency by any one of the following convenient methods:
a. Regular USPS Mail:
P.O. Box 255188
Sacramento, CA 95865
b. Fax: 916-979-7992