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Privacy Policy

APPLICABLE TO CLAIMANTS AND WEBSITE VISITORS

Wawanesa General Insurance Company (“Wawanesa” or “us” or “our”) respects the privacy concerns of our customers, our claimants, and the visitors to our website. This privacy policy (“Privacy Policy”) describes our practices regarding any Claimant Information that we may receive in connection with our Claims Servicing and any Website Information that we may receive from our Website Visitors (all as defined below).

Wawanesa may collect or receive personal information from consumers in a variety of ways. First, Wawanesa collects personal information from individual customers and potential customers of our personal insurance products. Second, Wawanesa collects personal information from third party claimants in connection with administering the various insurance policies we have issued to our customers. Finally, Wawanesa may collect limited personal information from visitors to our website at www.wawanesa.com (such website visitors, the “Website Visitors” and such website, the “Wawanesa Website”) when they visit the Wawanesa Website. More information regarding the personal information collected from each of these methods is described below.

For purposes of this Privacy Policy, personal information does not include publicly available information from government records or de-identified or aggregated information.


I. PERSONAL INFORMATION COLLECTED FROM CUSTOMERS AND POTENTIAL CUSTOMERS

Wawanesa offers various personal insurance products and we collect personal information from customers, former customers and potential customers when they apply for and/or purchase insurance products from us, when we administer claims, and in connection with other insurance transactions (collectively, “Insurance Information”). We only collect and process Insurance Information in connection with our provision and administration of our personal insurance products. Because Insurance Information is subject to the Gramm-Leach-Bliley Act (“GLBA”), this Privacy Policy does not apply to any Insurance Information — rather, Insurance Information is subject to a separate Privacy Notice, available here. If you are a customer, former customer, potential customer of an insurance product we offer, please consult our Privacy Notice available here for more information regarding how we collect, use and share your Insurance Information.


II. PERSONAL INFORMATION COLLECTED FROM CLAIMANTS

Wawanesa services claims for our customers in connection with the various insurance policies that we offer (“Claims Servicing”). In connection with our provision of the Claims Servicing, we may collect, and may have collected in the twelve (12) months prior to the date of this Privacy Policy, certain personal information from claimants who are not our customers (such information, the “Claimant Information”, and such non-customer claimants, the “Claimants”), as described below. It is important to note that the types of personal information we may collect or may have collected will depend on each Claimant’s interaction with us.


Category of Personal Information Collected Examples Whether Category Has Been Disclosed or Shared for a Business Purpose
Identifiers 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 YES
Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)) 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 other financial information, medical information, or health insurance information YES
Protected classification characteristics under California or federal law Age, race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex YES
Commercial information Records of personal property YES
Geolocation Data Physical location or movements YES
Audio or visual data Audio recordings or visual images YES
Professional or employment-related information Current job or name of employer YES
Inferences drawn from other personal information Profile reflecting a person's preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes YES

III. PERSONAL INFORMATION COLLECTED FROM WAWANESA WEBSITE

In connection with our provision of the Wawanesa Website, we may collect, and we may have collected in the twelve (12) months prior to the date of this Privacy Policy, certain personal information from our Website Visitors when they visit or use the Wawanesa Website (such information, the “Website Information”), as described below. It is important to note that the types of personal information we collect will depend on each Website Visitor’s interaction with us.


Category of Personal Information Collected Examples Whether Category Has Been Disclosed or Shared for a Business Purpose
Internet or network activity Browsing history, search history, information on a consumer's interaction with a website, application, or advertisement YES
Commercial information Records of products or services obtained, or considered, or other purchasing or consuming histories or tendencies YES
Inferences drawn from other personal information Profile reflecting a person's preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes. YES

IV. THIRD PARTIES WE SHARE PERSONAL INFORMATION WITH

Wawanesa may share or disclose personal information to the following:

  • Third parties who perform a business, professional or other insurance function for Wawanesa;
  • Other insurance companies involved in the claims or underwriting process;
  • Medical care institutions or medical care professionals as necessary to verify coverage or benefits;
  • Insurance regulatory authorities and insurance rate advisory organizations;
  • Law enforcement or other governmental authority, pursuant to applicable law;
  • Third parties for the purpose of assisting Wawanesa in the development or marketing of products and services to better meet consumer needs;
  • Another insured or claimant when the information disclosed is from certain accident reports, supplemental reports and investigative reports;
  • Another insured, claimant or their legal representatives in connection with pending litigation; and
  • Consumer reporting agencies, in accordance with the Fair Credit Reporting Act.

V. WHERE WE GET PERSONAL INFORMATION

Wawanesa may collect personal information from the following sources:

  • From your dealings with us in person, over the telephone, or through our website, mobile app, or the mail:
  • From the forms, documents and written communications you or your representatives submit to us:
  • From third parties who assist us in the investigation, processing or payment of claims: and
  • From credit reporting agencies and insurance support organizations.

VI. PURPOSES FOR COLLECTION, USE OR SHARING PERSONAL INFORMATION

Wawanesa may collect, use or share personal information for the following 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, including to debug and to identify and repair errors that impair existing intended functionality on the Wawanesa Website;
  • 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 non-disclosure in connection with an insurance transaction;
  • To detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, and prosecute those responsible for that activity;
  • 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 merger, divestiture, acquisition, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by us is among the assets transferred;
  • To comply with applicable laws and regulatory requirements, or as requested by government or regulatory authorities or law enforcement;
  • To share with our attorneys, accountants and auditors; and
  • In connection with pending litigation.

VII. NO SALE OF PERSONAL INFORMATION

Wawanesa has not sold your personal information to third parties in the twelve (12) months prior to the date of this Privacy Policy. In addition, Wawanesa will not sell your personal information to third parties (including for their own direct marketing purposes). If you are entitled to any disclosure rights in your jurisdiction regarding our sale of your personal information to third parties or our disclosure of your personal information to third parties for their own direct marketing purposes, this disclosure satisfies those requirements. If we change our practices in the future for any new information that we collect from you, we will update this Privacy Policy accordingly.


VIII. CCPA RIGHTS FOR CALIFORNIA CONSUMERS

The California Consumer Privacy Act of 2018 (“CCPA”) provides California consumers with certain rights with regard to their personal information. This Section explains those rights. If you are a California consumer and would like to exercise any of those rights under the CCPA, please see Section VIII.E below for more information on how to submit a request.

For purposes of this Privacy Policy, a “California consumer” is a natural person who resides in California, and does not include persons to the extent they are (i) acting as an employee, owner, director, officer or contractor of a company, partnership, sole proprietorship, nonprofit or government agency that is doing business with Wawanesa (which includes any independent insurance agents that offer our insurance products) or (ii) acting as a job applicant to, an employee of, owner of, director of, officer of, medical staff member of, or contractor of Wawanesa.

The CCPA excludes from its scope any information that is subject to the GLBA. Accordingly, the rights described in this Section do not apply to any Insurance Information that we collect from our customers, former customers or potential customers. The rights described in this Section only apply to Claimant Information and Website Information that we receive from California consumers. If you are a customer, former customer or potential customer, please consult our GLBA Privacy Notice for more information regarding how we use your Insurance Information.


A. RIGHT TO KNOW ABOUT AND ACCESS YOUR PERSONAL INFORMATION

If you are a California consumer, you have the right to request that Wawanesa provide you with information regarding what personal information about you we have collected, used, disclosed, or sold in the preceding twelve (12) months. Once we receive your request and verify your identity, we will disclose to you one or more of the following as requested:

  • The categories of personal information we have collected about you in the preceding twelve (12) months;
  • The categories of sources from which we collected your personal information in the preceding twelve (12) months;
  • The business or commercial purposes for collecting your personal information in the preceding twelve (12) months;
  • The categories of third parties with whom we shared your personal information in the preceding twelve (12) months;
  • The categories of personal information we have disclosed for a business purpose; and
  • The specific pieces of personal information we collected about you in the preceding twelve (12) months.

B. RIGHT TO DELETE YOUR PERSONAL INFORMATION

If you are a California consumer, you have the right to request that Wawanesa delete your personal information that we have collected from you. However, this right to deletion does not apply to any of your personal information that is subject to an exception under the CCPA (as described below). Once we receive your request and verify your identity, we will delete (and direct our service providers to delete) your personal information in our records that is not subject to any of the CCPA exceptions.

CCPA Exceptions

We may deny your deletion request where your personal information is required for any of the following reasons, which we will identify in our response to you if we deny your request:

  • To complete the transaction for which we collected the personal information, provide a product or service that you requested (e.g., insurance product), take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you;
  • To detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities;
  • To debug products to identify and repair errors that impair existing intended functionality;
  • To exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law;
  • To comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et seq.);
  • To 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 information's deletion may likely render impossible or seriously impair the research's achievement, if you previously provided informed consent;
  • To enable solely internal uses that are reasonably aligned with your expectations based on your relationship with us;
  • To comply with a legal obligation; and
  • To make other internal and lawful uses of that information that are compatible with the context in which you provided it.


C. RIGHT TO OPT-OUT OF THE SALE OF YOUR PERSONAL INFORMATION

If you are a California consumer, you have the right to opt-out of the sale of your personal information. As indicated in Section VII above though, we have not sold personal information to third parties in the twelve (12) months prior to the date of this Privacy Policy and will not sell personal information without further notice. Therefore, this obligation does not apply to us because we do not sell your personal information. If we change our practices in the future for any new information that we collect from you, we will notify you by updating this Privacy Policy.


D. RIGHT TO NON-DISCRIMINATION

Wawanesa will not discriminate against any California consumer who exercises any of the rights described above. Specifically, except as permitted by the CCPA, we will not deny you goods or services; charge you different prices or rates, including through granting discounts or other benefits, or imposing penalties; provide you with a different level of service or quality of goods or services; or suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.


E. HOW TO SUBMIT A REQUEST

If you are a California consumer and would like to exercise any of the CCPA rights identified above, you may submit a request by either submitting a request online here or by calling us at 1-800-640-2920.


F. SUBMITTING A REQUEST THROUGH YOUR AUTHORIZED AGENT

If you are a California consumer, you may have the option to designate an authorized agent to submit a request on your behalf, so long the authorized agent has your written permission to do so and you have taken steps to verify your identity directly with us. We may deny a request from an agent who does not submit proof that they have been authorized to submit a request of your behalf, or if you do not verify your identity directly with us.


G. HOW WE VERIFY YOUR REQUEST

To process your request for access or deletion, we must be able to verify your identity or authority to make the request and confirm the personal information relates to you. This requires that you provide the information requested here or if you submit a request by calling us at 1-800-640-2920, you must provide your full name, your account number or policy number if you are a current Wawanesa customer, your address, your email address if you prefer to receive a response via email, and your phone number. This information will be used to verify and respond to your request. Making a verifiable consumer request does not require you to create an account with us.

Depending on your type of request or the information requested by you, we may require additional information in order to verify your identity and fulfill your request. If we cannot successfully verify your identity, we will inform you of that fact.

We will respond to your request within forty-five (45) days. However, in certain circumstances, we may require additional time to process your request, as permitted by the CCPA or other applicable law. We will advise you within forty-five (45) days after receiving your request if such an extension is necessary and why it is needed. Any disclosures we provide will only cover the twelve (12)-month period preceding our receipt of your request. If we cannot fulfill your request, our response to you will also explain the reason why we cannot fulfill your request.


IX. TRACKING

Certain web browsers may provide a do-not-track (“DNT”) option. You may be able to ask your browser to inform websites that you do not wish your activities to be tracked, either with cookies or other persistent identifiers, commonly called “DNT signals.” The Wawanesa Website currently does not respond to DNT signals.

The Wawanesa Website may engage third parties that collect personal information about an individual consumer’s online activities over time and across different websites, including for retargeting purposes. If you wish to exercise your opt-out options, please visit here.


X. ANALYTICS PROVIDER

Wawanesa works with third party analytics service providers, including but not limited to Google Analytics, to help us better understand how you use the Wawanesa Website. For example, we use Google Analytics to learn more about the types of users that visit the Wawanesa Website, how they use the Wawanesa Website, and to help us improve the Wawanesa Website. Google Analytics provides us with certain data regarding the demographics of the users that visit the Wawanesa Website. To provide this service, Google Analytics may collect certain information about you from your computer, including through the use of cookies. Such information may include information regarding your visit (such as the pages you visit and the length of your visit), information about your device (such as your IP address), how you got to the Wawanesa Website, and other information about you. You can learn more about Google Analytics and how it collects and processes data (including how to control the information sent to Google) by visiting: www.google.com/policies/privacy/partners/. You can opt-out of Google Analytics by using the Google Analytics opt-out browser add-on, available at https://tools.google.com/dlpage/gaoptout/.


XI. EXCLUSIONS

As a provider of insurance products, Wawanesa does not seek to, nor do we knowingly collect, information directly from children under the age of 16. As we do not sell any personal information, we also have not sold the personal information of children under the age of 16.


XII. INTERNATIONAL TRANSFER

To facilitate Wawanesa’s operations, Wawanesa may store, transfer or provide access to the personal information that you provide to Wawanesa with or to our third party service providers around the world, including the United States. This Privacy Policy shall apply even if Wawanesa transfers such information to other countries. By providing us with any Claimant Information or by providing any information through the Wawanesa Website, you consent to the transfer of your personal information among the facilities in these countries. Do not provide us with Claimant Information or provide us with personal information through the Wawanesa Website if you do not want your personal information to be transferred to other countries, or if the laws in your country restrict these types of transfers.


XIII. CONTACT US

For questions, comments or concerns regarding this Privacy Policy or our privacy practices, or to request a copy of this Privacy Policy in another format, please contact us at:

By Phone:

1-800-640-2920

By Mail:

Wawanesa General Insurance Company
Attention: Chief Privacy Officer
9050 Friars Road
San Diego, CA 92108

By E-Mail:

privacy@wawanesa.com


XIX. UPDATES TO PRIVACY POLICY

We will review and update this Privacy Policy as necessary from time to time, at least on an annual basis. When we do, we will note at the bottom of the Privacy Policy the date that any changes are made and/or when they become effective. If the changes being made are material, we may alert you to the changes in a more prominent way. By using the Wawanesa Website after these changes are made, you agree to the revised version of the Privacy Policy.


This Privacy Policy was updated on: June 26, 2020

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