Last updated: January 2023
California Consumer Privacy Act (“CCPA’”)
This CCPA Section describes our policies and practices regarding the collection, use, and disclosure of PI we collect about you, including PI we obtain when you access or use our website, https://www.cfins.com and affiliated websites or mobile applications that link to this Policy or through other channels including but not limited to visits to our offices, phone and email conversations, interactions on third party websites such as social media sites, viewing our emails, or through our authorized services providers.
This CCPA Section supplements and amends the information contained in the Site Policy with respect to California residents. Any terms defined within the CCPA have the same meaning when utilized within this CCPA Section. The other provisions of the Site Policy continue to apply except as modified in this CCPA Section.
This CCPA Section does not apply to PI we collect about you as a job applicant to, an employee of, director of, officer of, or contractor of the Company. If you are an employee, contractor, or job applicant, please contact us at [email protected] for information on our privacy practices under the CCPA.
IF YOU DO NOT CONSENT TO THE COLLECTION, USE, AND SHARING OF YOUR INFORMATION AS DESCRIBED IN THIS CCPA SECTION, PLEASE DO NOT PROVIDE US WITH SUCH INFORMATION.
A. Personal Information We Collect.
As described below, we may collect or have collected in the preceding 12 months the following categories of PI. We may add to the categories of PI we collect and the purpose we use PI. In that case, we will inform you by posting an updated version of this CCPA Section on the Site. Please note that we do not disclose your personal information to third parties for their direct marketing purposes.
PI does not include:
B. Purposes for Which We Collect Your Personal Information
C. Sources of Personal Information
You. We may collect PI from you, your agent, broker or other representative when you contact us, visit our offices, submit forms, or through website technologies such as browser cookies set when you visit the Site.
Social media and related services.
Third Parties. We may collect information about you from third parties such as from your employer, through your social media services consistent with your settings on such services, or from other third-party sources that are lawfully entitled to share your data with us.
D. Sharing or Disclosing Personal Information
During the past 12 months, we may have shared the categories of PI noted above with third parties, including those listed below, in connection with providing, producing and servicing commercial and personal lines insurance products:
We retain your PI for as long as necessary to provide you products and services, while you have an open account/claim with us and/or in accordance with the Company’s data retention schedule. We may retain your PI for longer if it is necessary to comply with our legal obligations or reporting obligations, resolve disputes, collect fees or as permitted or required by applicable law. We may also retain your PI in a deidentified or aggregated form so that it can no longer be associated with you. To determine the appropriate retention period for your PI, we consider various factors such as the amount, nature, and sensitivity of your information; the potential risk of unauthorized access, use or disclosure; the purposes for which we process your PI; applicable legal requirements.
The California Consumer Privacy Act (CCPA) provides California residents with the following rights, subject to certain exceptions, upon receipt of a verifiable consumer request:
1. Right to Request Deletion
You have the right to request that we delete PI we collected or maintained about you, subject to certain exceptions. Upon receipt of a verifiable consumer request (see below), and as required by the CCPA. Once we receive your request, we will let you know what, if any, PI we can delete from our records. As applicable, we will also direct any service providers, contractors and third parties to whom we disclosed your PI to also delete your PI from their records.. The Company is not required to comply with your request to delete your PI if it is necessary for the Company (or its service provider) to maintain your PI in order to:
2. Right to Know
You have the right to request that we disclose the following to you as it relates to the 12-month period preceding the Company’s receipt of your verifiable consumer request (see below):
3. Right to Request Correction
You have the right to request that the Company correct any inaccurate PI we maintain about you, taking into account the nature of that information and purpose for processing it. Upon receipt of a verifiable consumer request (see below), and as required by the CCPA, we will provide a response to such requests.
We will not discriminate against you for exercising any of your CCPA rights. For example, we generally will not provide you a different level or quality of goods or services if you exercise your rights under the CCPA. It also includes an employee’s, applicant’s, or independent contractor’s right not to be retaliated against for the exercise of their CCPA rights.
5. Right to Opt-Out of Selling or Sharing of Your PI; Limiting the Use of Your Sensitive PI
You have the right to opt-out of having your PI sold or shared; however, we do not sell or share your PI as those terms are defined in the CCPA and we do not have actual knowledge that we have sold or shared the PI of minors under age 16.
You have the right to limit the use of your sensitive PI; however, we do not use or disclose your sensitive PI for purposes other than those specified in Cal. Code Regs., tit. 11 sec. 7027, subsection (l). We do not process your PI for targeted advertising.
F. Verifiable Requests
We reserve the right to only respond to verifiable consumer requests. A verifiable consumer request is one made by any individual who is:
a. the consumer who is the subject of the request,
b. a consumer on behalf of the consumer’s minor child, or
c. by a natural person or person registered with the Secretary of State authorized to act on behalf of a consumer.
If we request, you must provide us with sufficient information to verify your identity and/or authority to act on behalf of a Consumer. In general, we may ask you to provide identifying information that we already maintain about you or we may use a third-party verification service. In either event, we will try to avoid asking you for sensitive PI to verify your identity. We may not be able to respond to your request or provide you with PI if we cannot verify your identity or authority to make the request and confirm the PI relates to you. However, making a verifiable consumer request does not require you to create an account with us.
Additionally, you will need to describe your request with sufficient detail to allow us to review, understand, assess, and respond. We will not use the PI we collect from an individual to determine a verifiable request for any other purpose, except as required by law.
G. Authorized Agents
You may authorize a natural person, or a business registered with the California Secretary of State to act on your behalf with respect to the right under this CA Addendum. When you submit a Request to Know, Request to Correct or a Request to Delete, the Agent must provide proof that you gave the Agent signed permission to submit the request, and you either must (i) verify you own identity with the business or (ii) directly confirm with us that you provide permission to the Agent. However, these steps are not required when you have provided the authorized agent with power of attorney pursuant to Probate Code sections 4000 to 4465. We reserve the right to deny requests from persons or businesses claiming to be authorized agents that do not submit sufficient proof of their authorization.
H. To Exercise Your Rights Under the CCPA or to Seek Assistance, Please Do One of the Following:
Fill out and send back to C&F the Request to Know / Request to Delete forms to:
Crum & Forster Legal Department
P.O. Box 1973
305 Madison Avenue
Morristown, NJ 07962
We will attempt, where practical, to respond to your requests and to provide you with additional privacy-related information. C&F will confirm receipt of verifiable consumer requests within ten (10) days of receipt. You may only make a verifiable consumer request for personal information twice within a twelve (12) month period. C&F cannot respond to your request if it cannot verify your identity or authority to make the request and confirm the personal information relates to you. Any consumer with a disability may access this notice by contacting us at the address, email or toll-free number listed above. 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.
I. Changes to this CA Privacy Notice.