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Privacy Policy

This Privacy Policy (“Policy”) is adopted by Wawanesa General Insurance Company (“Wawanesa”, “we” or “us”) to comply with the California Consumer Privacy Act, as amended by the California Privacy Rights Act (“CCPA”). This Policy describes how we collect, use and disclose personal information, including sensitive personal information, as such terms are defined in the CCPA. This policy applies to residents of the State of California only and does not apply to information exempted from the scope of the CCPA, including information subject to the Gramm-Leach-Bliley Act (“GLBA”). For information concerning information subject to the GLBA, such as information we collect about those who apply for or obtain our financial products or services for personal, family or household purposes, see our separate Privacy Notice.

If you are a Wawanesa employee, job applicant or independent contractor, see our separate Employee Privacy Policy.

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

1. Categories of Personal Information We Collect

We have collected the following categories of personal information in the preceding 12 months:

Category of Personal Information Collected Examples Disclosed for a Business Purpose
Category of Personal Information Collected Identifiers Examples Name, postal address, email address, date of birth, telephone number, driver’s license number or state identification card number, credit or debit card number or other similar identifiers Disclosed for a Business Purpose YES
Category of Personal Information Collected 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, credit or debit card number, driver’s license number or state identification card number, education or employment history Disclosed for a Business Purpose YES
Category of Personal Information Collected 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 (including gender, gender identify, gender expression), same sex orientation for same sex benefits, veteran, military status or immigration status Disclosed for a Business Purpose YES
Category of Personal Information Collected Commercial Information Examples Records of personal property Disclosed for a Business Purpose YES
Category of Personal Information Collected Internet or Network Activity Examples Browser history, search history, IP address, mobile device or information regarding your interaction with our website Disclosed for a Business Purpose YES
Category of Personal Information Collected Geolocation data Examples Physical location or movements Disclosed for a Business Purpose YES
Category of Personal Information Collected Audio, electronic, or visual data Examples Audio recordings, pictures and videos Disclosed for a Business Purpose YES
Category of Personal Information Collected Professional or employment-related information Examples Current job or name of employer Disclosed for a Business Purpose YES
Category of Personal Information Collected Inferences drawn from other personal information Examples Profile reflecting a person's preferences, characteristics, behavior, attitudes, intelligence, abilities, and aptitudes Disclosed for a Business Purpose YES
Category of Personal Information Collected Sensitive Personal Information Examples Driver’s License, state identification card, racial or ethnic origin, health information or sexual orientation Disclosed for a Business Purpose YES

2. Sources of Personal Information

We collect personal information from the following sources:

  • Your dealings with us in person, over the telephone, through e-mail, mail or our website;
  • The forms, documents, and written communications you or your representatives submit to us;
  • Third parties who assist us in the underwriting and administration of insurance policies or in the investigation, processing, or payment of claims;
  • Government agencies, public records, insurance support organizations and credit reporting agencies; and
  • Any other lawful sources.

3. Purposes for Collecting or Disclosing Personal Information

We collect and disclose personal information for one or more of the following purposes:

  • To provide, operate and improve our services and our business, including to investigate, evaluate and pay claims and to otherwise facilitate an insurance transaction and to offer or provide products or services available to you;
  • To determine eligibility for an insurance benefit or payment;
  • To detect or prevent criminal activity, fraud, material misrepresentation or material non-disclosure in connection with an insurance transaction;
  • To communicate with you, including by sending notices, updates, and support and administrative messages and to notify you or any lienholder or other third party identified as having a legal or beneficial interest in a policy regarding the status of an insurance transaction;
  • To provide support and respond to your requests and questions;
  • To communicate with your representatives, such as lawyers or claims agents or other third parties designated by you or where you have instructed us or provided your consent to do so or where doing so is otherwise necessary to provide our services;
  • To facilitate or complete an actual or prospective business transaction, including, but not limited to, investments in Wawanesa, financing of Wawanesa, or the sale, transfer or merger of all or part of our business, assets, or shares;
  • For research and development purposes, including to analyze and improve our business, to develop new products and services and to help us understand user activity on our website and online services;
  • To comply with applicable laws, lawful requests, and legal process, such as to respond to subpoenas, investigations, or requests from government authorities;
  • To protect our, your or others’ rights, privacy, safety, or property (including by making and defending legal claims);
  • To audit or conduct analyses with respect to our internal processes for compliance with legal and contractual requirements or our internal policies;
  • To enforce the terms and conditions that govern our business; and
  • To prevent, identify, investigate, and deter fraudulent, harmful, unauthorized, unethical or illegal activity, including cyberattacks and identity theft.

4. Disclosure of Personal Information

We have disclosed personal information to the following categories of third parties in the preceding 12 months:

  • Our parent company;
  • Service providers who perform a business, professional or other insurance function for Wawanesa including, but not limited to, claims management companies, claims adjusters, repair shops, roadside assistance providers, third parties who assist in determining an individual’s eligibility for an insurance policy, policy benefit or payment or third parties who assist in detecting or preventing criminal activity, fraud, material misrepresentation or material nondisclosure in connection with an insurance transaction;
  • Your representatives and other third parties designated by you;
  • Other insurance companies involved in the claims or underwriting process;
  • Medical care institutions or professionals are necessary to verify coverage or benefits;
  • Government authorities, regulators, and law enforcement;
  • Another insured or claimant;
  • Accountants, auditors, lawyers, insurers, and other professional advisors; and
  • Other parties not listed above that are identified at or before the point at which we collect personal information along with the purposes for which the information will be shared.

5. Retention

We retain personal information for as long as necessary to fulfil the purposes for which we collected it, including for the purposes of satisfying any legal, accounting, or reporting requirements, to establish or defend legal claims, or for the compliance and protection purposes identified above.

6. Categories of Personal Information Sold or Shared

Wawanesa has not sold or shared personal information with any third parties in the preceding 12 months. Please see section 7(E) below for more information.

7. Your California Privacy Rights

The CCPA provides California residents with certain rights regarding their personal information. However, these rights are not absolute and are subject to certain exceptions. This section explains those rights.

A. Right to Know About Your Personal Information

You have the right to request that Wawanesa provide you with information regarding the personal information Wawanesa has collected about you in the preceding (12) months. Once we receive your request and verify your identify, we will disclose to you, subject to any exemptions under the CCPA, the following:

  • Categories of personal information collected;
  • Categories of sources from which the personal information is collected;
  • Business or commercial purpose for collecting, selling, or sharing the personal information;
  • Categories of third parties to whom Wawanesa disclosed the personal information; and
  • Specific pieces of personal information Wawanesa has collected about the consumer.

B. Right to Delete Your Personal Information

You have the right to request that Wawanesa delete your personal information that we have collected from you. However, this right does not apply to any personal information exempt under the CCPA. Once we receive your request and verify your identity, we will delete any personal information in our records that is not subject to any of the CCPA exemptions.

C. Right to Correct

You have the right to request that Wawanesa correct any inaccurate personal information that Wawanesa has about you. Once we receive your request and verify your identify, we will correct any inaccurate personal information that we have collected about you.

D. Right to Limit the Use and Disclosure of Sensitive Personal Information

You have the right to limit the use and disclosure of your sensitive personal information. However, we do not use or disclose sensitive personal information in ways subject to the right of California residents to limit use or disclosure of sensitive personal information under the CCPA. If we change our practices in the future, we will notify you by updating this Policy.

E. Right to Opt-Out of the Selling or Sharing of Personal Information

You have the right to opt out of the sale or sharing of your personal information. We do not sell any personal information. We do not believe that we share personal information as defined by the CCPA. However, we offer you the ability to opt-out of the collection of personal information by third parties on our website used by Wawanesa to learn about the type of users visiting our website, how they use our website, and to help us improve our website. If you would like to opt-out, you may do so here. If you visit our website using another browser or device, you will need to opt out again using that browser or device as well. Wawanesa also uses Google Analytics, which may collect personal information about you such as your IP address or the pages you visit on the Wawanesa website, which are used by Wawanesa to help us improve our website. You can learn more about Google Analytics (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 tools.google.com/dlpage/gaoptout/.

F. Right to Non-Discrimination

You have the right to not receive discriminatory treatment by Wawanesa for exercising your CCPA rights.

8. How To Submit a Request

If you would like to exercise your CCPA rights identified above, you may submit a request here or by calling us at 800-640-2920 and selecting Option 7.

A. How We Verify Your Identity and Requests

To process your request, we must be able to verify your identify or authority to make the request and confirm the personal information relates to you. This requires that you submit all requests here or by calling us at 800-640-2920 and selecting Option 7. When submitting your request, you must provide your full name, your relationship to Wawanesa, if any, your policy or account number if you are a current Wawanesa policyholder, your address, your email address, phone number, and any other information pertaining to your request. Submitting your request through one of these channels allows us to verify your identity as required by the CCPA. As such, we cannot accept requests through other channels. We cannot process your request if you do not provide us with sufficient detail to allow us to understand and respond to it. We reserve the right to confirm your current California residency. If we cannot successfully verify your identity, we will inform you of that fact.

B. Responding To Your Requests

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. We will advise you within forty-five (45) days after receiving your request if an extension is necessary and why it is needed. If we cannot fulfill your request, our response to you will explain the reason why we cannot fulfill your request.

C. Submitting A Request Through Your Authorized Agent

You have the option to designate an authorized agent to submit a request on your behalf. We may require you and your authorized agent to verify your identify or confirm that the agent has permission to submit a request on your behalf.

9. Personal Information of Children Under the Age of 16

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

10. Changes To This Policy

We reserve the right to change this Policy at any time. The “Effective Date” listed at the bottom of this Policy indicates when it was last revised. All updated policies will be posted on our website.

11. Questions

If you have any questions about this Policy, you may contact us at:

By Mail:
Wawanesa General Insurance Company
Attention: Chief Privacy Officer
7650 Mission Valley Road
San Diego, CA 92108

By E-mail:
privacy@wawanesa.com

The Effective Date of this Policy is January 1, 2023.


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