Last updated: November 2021
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 personal information 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. This CCPA Section also does not apply to personal information we collect about you as an employee, director, officer, or contractor of a company, partnership, sole proprietorship, non-profit, or government agency when your communications or transactions with the Company occur solely within the context of the Company conducting due diligence regarding, or providing or receiving a product or service to or from, such company, partnership, sole proprietorship, non-profit, or government agency.
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.
- Identifiers. Examples include real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, social security number, driver’s license number, or other similar identifiers.
- Other elements. Examples include name, signature, characteristics or description, address, telephone number, education, employment, employment history, bank account number, credit card number, driver’s license number, passport number, insurance policy number, payment card number, medical information and other information obtained in connection with underwriting products and adjusting claims.
- Characteristics of protected classifications under California or federal law. Examples include race, religion, and age.
- Commercial information. This includes services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.
- Education information. This includes information that is not publicly available personally identifiable information as defined in the Family Educational Rights and Privacy Act (20 U.S.C. section 1232g, Sec. 1232g; 34 C.F.R. Part 99).
- Internet or other electronic network activity. Examples include browsing history, search history, a consumer’s interaction with an internet website, application, or advertisement.
- Geolocation data. This might include location information while using one of our apps.
- Audio, electronic, visual, thermal, olfactory, or similar information. Examples of this category including identifiable information obtained about you while speaking with our customer service representatives on the telephone, call recordings, videos and photographs.
- Professional or employment-related information.
PI does not include:
- Publicly available information from government records.
- Deidentified or aggregated consumer information.
- Information excluded from the CCPA’s scope, such as certain health or medical information and other categories of information protected by different laws.
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:
- Third parties as directed by you, your agent, broker or other representative. Our business partners. For example, we might share your PI with one of our business partners for purposes of collaborating on providing services to you, or to invite you to an event we are organizing. These business partners should also have their own privacy statements that set out the manner in which they will collect, use, and disclose PI. Where applicable, we encourage you to review each such business partner’s privacy statement before signing on with them.
- Third parties that perform services on our behalf. For example, we share information with certain service providers, including marketing and promotional service providers, professional service providers, debt collectors, information technology providers and consultants, data storage companies, administrative service providers. We might also authorize our service providers to collect PI on our behalf.
- Governmental entities, legal service providers. We may share your PI in order to comply with the law and in the course of providing our products and services. We may also disclose information to respond to governmental inquiries or requests.
- Business Purposes. If there is a change or contemplated change in our corporate structure, we may disclose PI in preparation for or as part of that transaction. We may also disclose PI while engaging in commercial transactions including due diligence.
- Affiliates and subsidiaries.
E. Consumer Rights
The California Consumer Privacy Act (CCPA) provides California residents with the following rights upon receipt of a verifiable consumer request:
1. Right to Request Deletion
You have the right to request that we delete your PI from our records, subject to certain exceptions. Upon receipt of a verifiable consumer request (see below), and as required by the CCPA, we will delete and direct any service providers to delete your PI from its 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:
- Complete the transaction for which the PI was collected, provide a good or service requested by you, or reasonably anticipated within the context of the Company’s ongoing business relationship with you, or otherwise perform a contract between the Company and you.
- Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity; or prosecute those responsible for that activity.
- Debug to identify and repair errors that impair existing intended functionality.
- Exercise free speech ensure the right of another consumer to exercise his or her right of free speech, or exercise another right provided for by law.
- Comply with the California Electronic Communications Privacy Act pursuant to Chapter 3.6 (commencing with Section 1546) of Title 12 of Part 2 of the Penal Code.
- To enable solely internal uses that are reasonably aligned with your expectations based on your relationship with the Company.
- Comply with a legal obligation.
- Otherwise use your PI, internally, in a lawful manner that is compatible with the context in which you provided the information.
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):
- The categories of PI we have collected about you.
- The categories of sources from which the PI was collected.
- The business or commercial purpose for collecting or selling PI.
- The categories of PI we disclosed for a business purpose.
- The categories of third parties we disclosed PI to, by the category of PI.
- The specific pieces of PI we collected about you.
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.
4. Right to Opt-Out of Selling
You have the right to opt-out of having your PI sold; however, we do not sell your PI as that term is defined in the CCPA and we do not have actual knowledge that we have sold the PI of minors under age 16.
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 or a Request to Delete, unless you have provided the authorized agent with a qualifying power of attorney, you must provide your authorized agent written permission (signed by you) to act on your behalf and verify the authorized agent’s identity with us. 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:
- If you would like to make a Request to Know, click here or call 1.844.254.5754
- If you would like to make a Request to Delete, click here or call 1.844.254.5754
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.
I. Changes to this CA Privacy Notice.