We adopt this Privacy Notice to comply with the California Consumer Privacy Act, as amended by the California Privacy Rights Act (collectively “CCPA”). The notice applies only to California residents to the extent personal information is subject to the CCPA. The notice does not apply to information exempt from the requirements of the CCPA, including information subject to the Gramm-Leach-Bliley Act (GLBA), California Financial Information Privacy Act (FIPA), and the Fair Credit Reporting Act (FCRA).
Information We Collect
We collect information that identifies, relates to, describes, references, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer, household, or device ("personal information").
We have collected the following categories of personal information from consumers within the last twelve (12) months:
|A. Identifiers.||A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, Social Security number, driver's license number, passport number, or other similar identifiers.||YES|
|B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).||A name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver's license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information. Some personal information included in this category may overlap with other categories.||YES|
|C. Protected classification characteristics under California or federal law.||Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information).||YES|
|D. Commercial information.||Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.||YES|
|E. Biometric information.||Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as, fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data.||NO|
|F. Internet or other similar network activity.||Browsing history, search history, information on a consumer's interaction with a website, application, or advertisement.||YES|
|G. Geolocation data.||Physical location or movements.||NO|
|H. Sensory data.||Audio, electronic, visual, thermal, olfactory, or similar information.||YES|
|I. Professional or employment-related information.||Current or past job history or performance evaluations.||NO|
|J. Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)).||Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records.||NO|
|K. Inferences drawn from other personal information.||Profile reflecting a person's preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.||YES|
|L. Sensitive Personal Information||Account log-in, financial account, debit card, or credit card in combination with any required security or access code, password, or credentials allowing access to an account.||YES|
We obtain the categories of personal information listed above from the following categories of sources:
- Directly from you. For example, from quote requests and applications submitted to us.
- From your transactions with us. For example, from payment and claim activity.
- From government agencies and aggregators of public records. For example, information about your home.
- From consumer reporting agencies. For example, information regarding you, your property, your prior claims history or your credit history.
- From third parties as permitted by law, such as agents, brokers, and service providers.
- From your online interactions with us, we and analytics companies may automatically collect information about your use and access to our website.
- From publicly available sources.
We make no active effort to collect personal information from children and do not wish to receive any such information. If we learn that we have collected the personal information of a child under 16, we will take steps to delete the information as soon as possible.
Use of Personal Information
We may use or disclose the personal information we collect for one or more of the following business purposes:
- To facilitate, fulfill or meet the reason you provided the information, provide you services and products, take actions within the context of our ongoing business relationship with you, and perform our contract with you. For example, if you share your name and contact information to request a quote or ask a question about our products or services, we will use that personal information to respond to your inquiry. If you provide your personal information to purchase insurance, we will use that information to issue your policy, to adjust your claim when you report a loss and to process your payment. We may use that personal information to obtain an inspection of your property. We may also save your information to facilitate future transactions.
- To communicate with you.
- To update or correct our records.
- To determine eligibility for an insurance benefit or payment.
- To obtain consumer reports.
- To provide information to insurance support organizations to detect or prevent fraud.
- To create, maintain, customize, and secure your account with us.
- To process your requests, payments, and claims transactions, and prevent transactional fraud.
- To provide you with support and to respond to your inquiries, including to investigate and address your concerns and monitor and improve our responses.
- To present offers of earthquake insurance as required by California law.
- To respond to law enforcement requests, to comply with laws, regulations or other legal obligations, to assist in an investigation, to defend our rights and property or the rights of third parties or enforce terms and conditions. We may also use your personal information to prevent suspected fraud, threats to our network or other illegal activities, prevent misuse or for any other reason permitted by law.
- To perform analytics and research to improve, develop, and protect our websites, services and products.
- To provide marketing and advertising that may be of interest to you.
- As described to you when collecting your personal information or as otherwise allowed under the CCPA.
Sharing of Personal Information
We may disclose your personal information to a third party for a business purpose. When we disclose personal information for a business purpose, we enter into a contract that describes the purpose and requires the recipient to both keep that personal information confidential and not use it for any purpose except performing the contract.
We may share your personal information with the following categories of third parties:
- Service providers, such as financial institutions to process your payments, agents, brokers, and companies involved in insurance and other business transactions, inspection companies to perform inspections of your property, independent adjusters, contractors, and vendors to assist in evaluating, processing, and managing your claims, and third parties who assist in determining an individual’s eligibility for an insurance policy.
- Legal, tax, and accounting service providers.
- Data analysis and application service providers.
- Administrative service providers.
- Security service providers.
- Data aggregators.
- Consumer reporting agencies.
- Law enforcement, regulators, and other parties for legal reasons, as required by law or subpoenas, or if we believe such actions are necessary to comply with the law and the requests of regulators, law enforcement or other public authorities, or to protect our or others safety, rights or property, or to investigate fraud or protect the security or integrity of our products and services.
In the preceding twelve (12) months, we have disclosed the following categories of personal information for a business purpose:
- Category A: Identifiers.
- Category B: California Customer Records personal information categories.
- Category C: Protected classification characteristics under California or federal law.
- Category D: Commercial information.
- Category F: Internet or other similar network activity.
- Category H: Sensory data.
- Category K: Inferences drawn from other personal information.
We do not sell your personal information for monetary compensation. We also do not share your personal information for cross-context behavioral advertising as defined by the CCPA.
Retention of Personal Information
We retain personal information for as long as necessary or permitted for the purposes described in this notice or otherwise authorized by law, including satisfying any legal, accounting, regulatory, reporting or business requirements, establishing or defending legal claims, and satisfying record retention requirements.
Your Rights and Choices
The CCPA provides consumers (California residents) with specific rights regarding their personal information. This section describes your CCPA rights and explains how to exercise those rights.
Right to Know
You have the right to request that we disclose certain information to you about our collection and use of your personal information over the past 12 months. Once we receive and confirm your verifiable consumer request, we will disclose to you:
- The categories of personal information we collected about you.
- The categories of sources for the personal information we collected about you.
- Our business or commercial purpose for collecting that personal information.
- The categories of third parties with whom we share that personal information.
- The specific pieces of personal information we collected about you.
- If we disclosed your personal information for a business purpose, a list of disclosures for a business purpose, identifying the personal information categories that each category of recipient obtained.
Right to Delete
You have the right, subject to certain exceptions, to request that we delete your personal information that we collected from you and are maintaining. Once we receive and confirm your verifiable consumer request, we will delete (and direct our service providers to delete) your personal information from our records, unless an exception applies. We may deny your deletion request if retaining the information is necessary for us or our service provider(s) to:
- Complete the transaction(s) for which we collected the personal information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you.
- Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
- Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
- Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et. seq.).
- Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
- Comply with a legal obligation.
- Make other internal and lawful uses of that information that are compatible with the context in which you provided it.
Right to Correct
If you believe that personal information we maintain about you is inaccurate, you have the right, subject to certain restrictions, to request that we correct that information. We may request that you provide documentation to support your request to correct.
Right to Opt Out
You have the right to opt out of the sale of your personal information or the sharing of your personal information for cross-context behavioral advertising. However, we do not sell your personal information or share your personal information for cross-context behavioral advertising.
Right to Limit
You have the right to limit sensitive personal information use and disclosure to specifically permitted purposes. However, we do not use or disclose sensitive personal information for purposes other than the specifically permitted purposes.
Right to Non-Discriminate
You have the right not to receive discriminatory treatment by us for the exercise of your CCPA rights.
Exercising Your CCPA Rights
To exercise the rights described above, please submit a verifiable consumer request to us by either:
- Calling us at 800-234-2103
- Emailing us at [email protected]
- For current policyholders, by logging in to our Customer Service Center and completing the CCPA Request Form
Only you, or someone legally authorized to act on your behalf, may make a verifiable consumer request related to your personal information. You may also make a verifiable consumer request on behalf of your minor child.
You may only make a verifiable consumer request for access or data portability twice within a 12-month period. 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.
- Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.
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. 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.
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 endeavor to respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time (up to 90 days), we will inform you of the reason and extension period in writing.
If you have an account with us, we will deliver our written response to that account. If you do not have an account with us, we will deliver our written response by mail or electronically, at your option.
Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request's receipt. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your personal information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance.
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.
Changes to Our Privacy Notice
We reserve the right to amend this privacy notice at our discretion and at any time. When we make changes to this privacy notice, we will post the updated notice on the Website and update the notice’s effective date. Your continued use of our website following the posting of changes constitutes your acceptance of such changes.
If you have any questions or comments about this notice, the ways in which we collect and use your information described here, your choices and rights regarding such use, or wish to exercise your rights under California law, please do not hesitate to contact us at:
Email: [email protected]
Western Mutual Insurance Group
Attn: Privacy Officer
PO Box 19626
Irvine, CA 92623-9626
Download our CCPA Consumer Request form here.
Last Updated June 30, 2023Related Links