California Privacy Notice

 

 

CALIFORNIA RESIDENTS: YOUR CALIFORNIA PRIVACY RIGHTS (EFFECTIVE 1/1/2020)

This section of our privacy policy supplements the information contained in our general privacy policy.  At its current state, this applies only to those who reside in the State of California (“consumers” or “you”). We adopt this notice to comply with the California Consumer Privacy Act of 2018 and other laws that provide rights to specific California residents.

For more information, please go to: https://oag.ca.gov/privacy/ccpa

WHAT PERSONAL INFORMATION WE COLLECT

In compliance with the California Consumer Privacy Act (CCPA) and other California privacy laws, we collect information that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household (“personal information”). We have collected categories of personal information from consumers within the last twelve (12) months. This does not mean that all examples of that category of personal information were in fact collected; we may collect all or just a few of these categories with regard to a particular consumer.

 

Category Examples Collected
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. NO
G. Geolocation data. Physical location or movements. NO
H. Sensory data. Audio, electronic, visual, thermal, olfactory, or similar information. NO
I. Professional or employment-related information. Current or past job history or performance evaluations. YES
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. NO

 

USE OF PERSONAL INFORMATION

WHERE WE MIGHT COLLECT YOUR PERSONAL INFORMATION FROM

We might collect your personal information from various sources, depending on your circumstances, including:

  • You.
  • Your family members.
  • Other insurance market participants.
  • Credit reference agencies.
  • Anti-fraud databases, sanctions lists, court judgments and other databases.
  • Government agencies.
  • Open electoral register.
  • In the event of a claim, third parties including the other party to the claim (claimant/defendant) witnesses, experts (including medical experts), loss adjustors, solicitors and claims handlers.

HOW WE USE YOUR PERSONAL INFORMATION

In the course of providing our services, we may use your personal information for the following purposes:

  • Setting you up as a client, including possible fraud, sanctions, credit and anti-money laundering checks, evaluating the risks to be covered and matching to appropriate policy/ premium and payment of premium where the insured/policyholder is an individual.
  • Client care, including communicating with you and sending you updates and processing payments to and from individuals.
  • Managing insurance and reinsurance claims, defending or prosecuting legal claims and investigation or prosecuting fraud.
  • Contacting the insured/policyholder to renew the insurance policy, evaluating the risks to be covered and matching to appropriate policy/ premium and payment of premium where the insured/policyholder is an individual.

Other purposes outside of the insurance lifecycle but necessary for the provision of insurance throughout the insurance lifecycle period:

  • Complying with our legal or regulatory obligations.
  • General risk modelling.
  • Transferring books of business, company sales & reorganizations.

If we are involved in any merger, acquisition, sale of company assets, transition of service to another provider, or insolvency, bankruptcy or receivership, we also reserve the right to transfer your personal information in connection with such transaction.

SHARING PERSONAL INFORMATION

 Further to the purposes set out above, we may disclose personal information to our service providers, contractors, agents and to other companies within the Group that perform activities on our behalf.  We will only disclose your personal information for business purposes if reasonably necessary and proportionate to achieve the operational purpose for which the personal information was collected – such as, in connection with the insurance cover that we provide and to the extent required or permitted by law. Additionally, when we disclose personal information for a business purpose, we enter a contract that describes the purpose and requires both parties to keep that personal information confidential and not use it for any purpose except in the performance of the contract.

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.

SALES OF PERSONAL INFORMATION

In the preceding twelve (12) months, Ascot has not and will not sell any personal information.

YOUR RIGHTS AND CHOICES

If you have any questions in relation to our use of your personal information, you should contact our Data Protection Officer. Under certain conditions, you may have the right to request that we disclose certain information to you about our collection and use of personal information over the past 12 months.  Subject to certain exceptions, California consumers may have the right to require us to:

  • Provide you with a copy of the personal information that you have provided to us, including but not limited to the categories of personal information collected about you, the categories of sources for the personal information collected about you, and specific pieces of personal information we collected from you.
  • Provide you with further details of the use we make, including but not limited to our business or commercial purpose for collecting or selling that personal information.
  • Provide the categories of third parties with whom we share that personal information.
  • Update any inaccuracies in the personal information that we hold.
  • Delete any personal information, or special categories of personal information, that we have collected and retained (unless an exemption listed below applies).

If we sold or disclosed your personal information for a business purpose, two separate lists disclosing:

  • Sales (if any) along with the personal information categories that each category of recipient purchased; and
  • Disclosures for a business purpose along with the personal information categories that each category of recipient obtained.

In certain circumstances, we may need to restrict the above rights in order to safeguard the public interest (e.g. the prevention or detection of crime) and our interests (e.g. the maintenance of legal privilege). The response we provide will also explain the reasons we cannot comply with a request, if applicable. Otherwise, we endeavor to deal with your request free of charge. However, where a request is manifestly unfounded or excessive (or repetitive), we may either refuse to respond or charge a reasonable fee, taking into account the administrative costs of providing the information.  Please see the Contact Us section below for information about how to exercise these rights.

DELETION REQUEST RIGHTS

You have the right to request that we delete any of your personal information that we collected from you and retained, subject to certain exceptions.  Once we receive and confirm your verifiable consumer request to delete your personal information, 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 providers as permitted by law.

EXERCISING YOUR RIGHTS

To exercise any of the rights stated above, please submit a verifiable consumer request to us through either of the following methods:

You may make a verifiable consumer request for access or data portability twice within a 12-month period. The 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. Making a verifiable consumer request does not require you to create an account with us.  We will only use personal information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request, and cannot use for any other purposes.

Only you or a person registered with the California Secretary of State that you authorize 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.

RESPONSE TIMING AND FORMAT

We endeavor to acknowledge a verifiable consumer request within 10 days and respond within 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. Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request’s receipt.

NON-DISCRIMINATION

We will not discriminate against you for exercising any of your CCPA rights, including by: (A) denying goods or services to the consumer; (B) charging different prices or rates for goods or services, including the use of discounts or other benefits or imposing penalties; (C) providing a different level or quality of goods or services to the consumer; or (D) suggesting that the consumer will receive a different price or rate for goods or services or a different level or quality of goods or services.

CHANGES TO OUR PRIVACY NOTICE

We reserve the right to amend this privacy notice at our discretion and at any time. Any amendments or modifications to this Privacy Policy will become effective immediately upon posting. Your continued use of our Website following the posting of changes constitutes your acceptance of such changes.

CONTACT INFORMATION

If you have any questions or concerns about this Privacy Policy, or if you would like to access, correct or delete any of your personal information, or make a complaint, please contact CCPA Inquiries at
55 West 46th Street, 26th Floor, New York, NY 10036

Email: USComplaints@ascotgroup.com
Toll Free Phone: +1(844)-589-1559

 

 

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California Privacy Notice

 

 

CALIFORNIA RESIDENTS: YOUR CALIFORNIA PRIVACY RIGHTS (EFFECTIVE 1/1/2020)

This section of our privacy policy supplements the information contained in our general privacy policy.  At its current state, this applies only to those who reside in the State of California (“consumers” or “you”). We adopt this notice to comply with the California Consumer Privacy Act of 2018 and other laws that provide rights to specific California residents.

For more information, please go to: https://oag.ca.gov/privacy/ccpa

WHAT PERSONAL INFORMATION WE COLLECT

In compliance with the California Consumer Privacy Act (CCPA) and other California privacy laws, we collect information that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household (“personal information”). We have collected categories of personal information from consumers within the last twelve (12) months. This does not mean that all examples of that category of personal information were in fact collected; we may collect all or just a few of these categories with regard to a particular consumer.

USE OF PERSONAL INFORMATION

WHERE WE MIGHT COLLECT YOUR PERSONAL INFORMATION FROM

We might collect your personal information from various sources, depending on your circumstances, including:

  • You.
  • Your family members.
  • Other insurance market participants.
  • Credit reference agencies.
  • Anti-fraud databases, sanctions lists, court judgments and other databases.
  • Government agencies.
  • Open electoral register.
  • In the event of a claim, third parties including the other party to the claim (claimant/defendant) witnesses, experts (including medical experts), loss adjustors, solicitors and claims handlers.

HOW WE USE YOUR PERSONAL INFORMATION

In the course of providing our services, we may use your personal information for the following purposes:

  • Setting you up as a client, including possible fraud, sanctions, credit and anti-money laundering checks, evaluating the risks to be covered and matching to appropriate policy/ premium and payment of premium where the insured/policyholder is an individual.
  • Client care, including communicating with you and sending you updates and processing payments to and from individuals.
  • Managing insurance and reinsurance claims, defending or prosecuting legal claims and investigation or prosecuting fraud.
  • Contacting the insured/policyholder to renew the insurance policy, evaluating the risks to be covered and matching to appropriate policy/ premium and payment of premium where the insured/policyholder is an individual.

Other purposes outside of the insurance lifecycle but necessary for the provision of insurance throughout the insurance lifecycle period:

  • Complying with our legal or regulatory obligations.
  • General risk modelling.
  • Transferring books of business, company sales & reorganizations.

If we are involved in any merger, acquisition, sale of company assets, transition of service to another provider, or insolvency, bankruptcy or receivership, we also reserve the right to transfer your personal information in connection with such transaction.

SHARING PERSONAL INFORMATION

 Further to the purposes set out above, we may disclose personal information to our service providers, contractors, agents and to other companies within the Group that perform activities on our behalf.  We will only disclose your personal information for business purposes if reasonably necessary and proportionate to achieve the operational purpose for which the personal information was collected – such as, in connection with the insurance cover that we provide and to the extent required or permitted by law. Additionally, when we disclose personal information for a business purpose, we enter a contract that describes the purpose and requires both parties to keep that personal information confidential and not use it for any purpose except in the performance of the contract.

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.

SALES OF PERSONAL INFORMATION

In the preceding twelve (12) months, Ascot has not and will not sell any personal information.

YOUR RIGHTS AND CHOICES

If you have any questions in relation to our use of your personal information, you should contact our Data Protection Officer. Under certain conditions, you may have the right to request that we disclose certain information to you about our collection and use of personal information over the past 12 months.  Subject to certain exceptions, California consumers may have the right to require us to:

  • Provide you with a copy of the personal information that you have provided to us, including but not limited to the categories of personal information collected about you, the categories of sources for the personal information collected about you, and specific pieces of personal information we collected from you.
  • Provide you with further details of the use we make, including but not limited to our business or commercial purpose for collecting or selling that personal information.
  • Provide the categories of third parties with whom we share that personal information.
  • Update any inaccuracies in the personal information that we hold.
  • Delete any personal information, or special categories of personal information, that we have collected and retained (unless an exemption listed below applies).

If we sold or disclosed your personal information for a business purpose, two separate lists disclosing:

  • Sales (if any) along with the personal information categories that each category of recipient purchased; and
  • Disclosures for a business purpose along with the personal information categories that each category of recipient obtained.

In certain circumstances, we may need to restrict the above rights in order to safeguard the public interest (e.g. the prevention or detection of crime) and our interests (e.g. the maintenance of legal privilege). The response we provide will also explain the reasons we cannot comply with a request, if applicable. Otherwise, we endeavor to deal with your request free of charge. However, where a request is manifestly unfounded or excessive (or repetitive), we may either refuse to respond or charge a reasonable fee, taking into account the administrative costs of providing the information.  Please see the Contact Us section below for information about how to exercise these rights.

DELETION REQUEST RIGHTS

You have the right to request that we delete any of your personal information that we collected from you and retained, subject to certain exceptions.  Once we receive and confirm your verifiable consumer request to delete your personal information, 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 providers as permitted by law.

EXERCISING YOUR RIGHTS

To exercise any of the rights stated above, please submit a verifiable consumer request to us through either of the following methods:

You may make a verifiable consumer request for access or data portability twice within a 12-month period. The 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. Making a verifiable consumer request does not require you to create an account with us.  We will only use personal information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request, and cannot use for any other purposes.

Only you or a person registered with the California Secretary of State that you authorize 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.

RESPONSE TIMING AND FORMAT

We endeavor to acknowledge a verifiable consumer request within 10 days and respond within 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. Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request’s receipt.

NON-DISCRIMINATION

We will not discriminate against you for exercising any of your CCPA rights, including by: (A) denying goods or services to the consumer; (B) charging different prices or rates for goods or services, including the use of discounts or other benefits or imposing penalties; (C) providing a different level or quality of goods or services to the consumer; or (D) suggesting that the consumer will receive a different price or rate for goods or services or a different level or quality of goods or services.

CHANGES TO OUR PRIVACY NOTICE

We reserve the right to amend this privacy notice at our discretion and at any time. Any amendments or modifications to this Privacy Policy will become effective immediately upon posting. Your continued use of our Website following the posting of changes constitutes your acceptance of such changes.

CONTACT INFORMATION

If you have any questions or concerns about this Privacy Policy, or if you would like to access, correct or delete any of your personal information, or make a complaint, please contact CCPA Inquiries at
55 West 46th Street, 26th Floor, New York, NY 10036

Email: USComplaints@ascotgroup.com
Toll Free Phone: +1(844)-589-1559

 

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