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Privacy Policy

This Privacy Notice applies to Wawanesa General Insurance Company (“Wawanesa” or “us” or “our”) and to all applicants, customers, policyholders, visitors or users of the Wawanesa website who reside in the State of California (“consumers” or “you”).

Information We Collect

We collect information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, to a particular consumer or household (“Personal Information”). We have collected the following categories of Personal Information from consumers within the last twelve (12) months:

Category
Examples
Collected
Category: A. Identifiers.
Examples: Name, mailing address, email address, date of birth, telephone number, Internet Protocol (IP) address, bank account, credit or debit card numbers, or other similar identifiers.
Collected: YES
Category: B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).
Examples: Name, signature, physical characteristics or description, address, telephone number, driver's license number, insurance policy number, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information.
Collected: YES
Category: C. Protected classification characteristics under California or federal law.
Examples: Age, race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex.
Collected: YES
Category: D. Commercial information.
Examples: Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.
Collected: YES
Category: E. Biometric information.
Examples: Genetic, physiological, behavioral, and biological characteristics, 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.
Collected: NO
Category: F. Internet or network activity.
Examples: Browsing history, search history, information on a consumer's interaction with a website, application, or advertisement.
Collected: YES
Category: G. Geolocation data.
Examples: Physical location or movements.
Collected: YES
Category: H. Audio or visual data.
Examples: Audio recordings or visual images.
Collected: YES
Category: I. Professional or employment-related information.
Examples: Current or past job history.
Collected: YES
Category: 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)).
Examples: 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.
Collected: NO
Category: K. Inferences drawn from other personal information.
Examples: Profile reflecting a person's preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.
Collected: YES

Personal information does not include:

  • Publicly available information from government records.
  • De-identified or aggregated consumer information.
  • Information specifically excluded under applicable privacy laws, including, but not limited to:
    • health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and the California Confidentiality of Medical Information Act (CMIA);
    • personal information covered by the Fair Credit Reporting Act (FRCA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver's Privacy Protection Act of 1994.

Disclosure Of Personal Information

Providers and those third parties to whom you or your agents authorize us to disclose your Personal Information, in connection with an insurance transaction or other business purpose. In the preceding 12 months, we have disclosed the following categories of Personal Information to third parties for a business purpose:

Categories A, B, C, D, F, G and H

In the preceding 12 months, we have not sold any Personal Information. If in the future, we anticipate selling your Personal Information to any third party, we will provide you with notice and an option to opt-out, as required by applicable law.

Use Of Personal Information

We may use the Personal Information we collect for one or more of the following business purposes:

  • To establish and maintain communication with you about an insurance transaction.
  • To offer or provide information and notices about products or services purchased by you, or available to you.
  • To improve our website and the content and features available to you.
  • To determine eligibility for an insurance benefit or payment.
  • To investigate, evaluate and pay claims.
  • To assist a third party in the performance of a business, professional or other insurance function on our behalf.
  • To provide information regarding the status of an insurance transaction to any lienholder, lessor or other third party identified as having a legal or beneficial interest in a policy.
  • To detect or prevent criminal activity, fraud, material misrepresentation or material nondisclosure in connection with an insurance transaction.
  • To conduct actuarial or business analysis, or to conduct an audit of our operations.
  • To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.
  • To carry out our obligations and enforce our rights arising from insurance policies issued by us.
  • To evaluate or conduct a sale, merger, reorganization or transfer of some or all of our assets.
  • As otherwise permitted by applicable law.

Your Rights With Regards To Your Personal Information

Consumers have the following rights regarding their Personal Information.

  • To Access Information. You have the right to request that we disclose the following information to you about our collection and use of your Personal Information over the past 12 months.
    • The categories of Personal Information we have collected about you
    • The specific pieces of Personal Information we have collected about you
    • The categories of sources from which the Personal Information has been collected
    • The business purpose for using your Personal Information
    • If Personal Information has been disclosed to third parties, then the categories of Personal Information disclosed to third parties for business purposes.
  • To Opt Out of Having Your Personal Information Sold. If in the future we anticipate selling your Personal Information to any third party, we will provide you with notice and an option to opt-out, as required by applicable law.
  • To Request Deletion. You have the right to request that we delete any of your Personal Information that we’ve collected from you, and that our Service Providers with who we have disclosed your Personal Information for a business purpose also delete your Personal Information. We may deny your request to delete your Personal Information if retaining it is necessary for us, or our Service Providers, to do any of the following:
    • Complete the transaction for which we collected the Personal Information, provide products or services that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our obligations under an insurance policy with you.
    • Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
    • Debug systems, or to identify and repair errors that impair existing intended functionality.
    • Exercise rights to free speech, ensure the right of others to exercise their free speech rights, or exercise another right provided for by law.
    • Comply with the California Electronic Communications Privacy Act.
    • Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the deletion of the Personal Information may likely render impossible or seriously impair the research's achievement.
    • Enable internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
    • Make other internal and lawful uses of that Personal Information that are compatible with the context in which you provided it.
    • Comply with a legal obligation.
  • To Non-Discrimination. We will not discriminate against you for exercising any of your rights with regards to your Personal Information.

Exercising Your Rights

To exercise your rights with regards to your Personal Information, you may submit a request by either:

You are not required to create an account with us in order to make a request.
You may submit up to 2 requests in any 12 month time period.

In order to respond to your request, you must provide sufficient information to allows us to verify you are the person about whom we collected Personal Information or an authorized representative and provide sufficient detail that allows us to properly understand, evaluate, and respond to your request.

Only you, another person acting on your behalf, or a business registered with the California Secretary of State that you authorize to act on your behalf, may make a request related to your Personal Information.

Changes To Our Privacy Notice

This Privacy Notice be reviewed and updated as necessary from time to time, at least on an annual basis.

Contact Information

If you have any questions or comments about this Privacy Notice you may contact us at:

Wawanesa General Insurance Company
Attention: Chief Privacy Officer
PO Box 85048
San Diego, CA 92186-5048

800-640-2920

This Privacy Notice was updated on: January 1, 2020

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