OUR PRIVACY PRINCIPLES
The terms of this Policy are based on the following ten interrelated privacy principles:
- Accountability: Wawanesa has designated its Chief Legal Officer (the “Designated Individual”) to be accountable for Wawanesa’s compliance with this Policy.
- Identifying Purposes: Personal information may be collected, used and disclosed by Wawanesa only for the purposes identified in this Policy.
- Consent: Wawanesa will only collect, use and disclose your personal information with your knowledge and consent, or as otherwise permitted by applicable law.
- Limiting Collection: Wawanesa will only collect, use or disclose personal information that is necessary for the purposes identified in this Policy. Wawanesa will collect your personal information only by lawful means.
- Limiting Use And Disclosure: Wawanesa will not use or disclose your personal information for purposes other than as identified in this Policy, except with your consent or as permitted by applicable law.
- Accuracy Of Information: Wawanesa will ensure that all personal information is as accurate, complete and as up-to-date as possible when used for the purposes identified in this Policy.
- Safeguards: Personal information will be protected by security safeguards appropriate to the sensitivity of the information.
- Openness: Wawanesa is open about its policies and practices relating to the management of personal information, and will make information about such policies and practices readily available.
- Access: Upon request, you will be informed of the existence, use and disclosure of your personal information and will be given access to such information.
- Compliance: You may challenge our compliance with this Policy, request access to your personal information, or request a correction, amendment or deletion of your personal information by sending a written request to the Designated Individual at:
Wawanesa General Insurance Company
Attention: Chief Legal Officer
9050 Friars Road
San Diego, CA 92108-5865
What We Collect
We may collect personal information about you, and other members of your household that you may provide regarding an insurance transaction, including, but not limited to your name, address, telephone number, email address, date of birth, social security number, claims history, motor vehicle records, and in some cases, your credit history. We collect such information from various sources, including:
- The application forms you submit for a rate quote, policy, or amendments to any policy;
- Other policy service documents or claim forms you submit;
- Your dealings with us in person, over the telephone, or through our website, mobile app, or the mail;
- From third parties who assist us in the investigation, processing or payment of claims;
- From credit reporting agencies and insurance support organizations; and
- Through our “Refer a Friend” program.
We will not use your credit history for underwriting or policy rating purposes where prohibited by law. The information obtained from a report prepared by an insurance support organization may be retained by such insurance support organization and disclosed to third parties.
What We Disclose
We may disclose the following personal information about you:
- Personal information that you provide;
- Personal information about you received from third parties in connection with the evaluation, investigation or processing of a claim;
- Personal information about your dealings with us, including, but not limited to, information on your policy coverage, premiums, and payment record; and
- Personal information received from consumer reporting agencies or insurance support organization.
We only disclose the personal information of former policyholders for the following purposes:
- Investigating or processing ongoing claims;
- Reporting, investigating or preventing actual or potential fraud or material misrepresentation;
- Compiling statistics and analyzing business results, and
- As permitted by applicable law.
To Whom We May Disclose
We may disclose your personal information to the following:
- To third parties who perform a business, professional or other insurance function for Wawanesa. Such third parties may include, but are not limited to, claims management companies, claims adjusters, repair shops, roadside assistance program providers, third parties who assist in determining an individual’s eligibility for an insurance 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;
- Other insurance companies involved in the claims or underwriting process;
- To medical care institutions or medical care professionals as necessary to verify coverage or benefits;
- To insurance regulatory authorities and insurance rate advisory organizations;
- To law enforcement or other governmental authority, pursuant to applicable law;
- To third parties for the purposes of conducting actuarial or research studies;
- To third parties for the purposes of assisting Wawanesa in the development or marketing of property and casualty insurance products and services to better meet our customers’ needs;
- To another insured or claimant when the information disclosed is from certain accident reports, supplemental reports and investigative reports;
- To consumer reporting agencies, in accordance with the Fair Credit Reporting Act; and
- To affiliates of Wawanesa as permitted by applicable law.
In these situations, we will provide only the information appropriate to the circumstances, and use contractual or other means to ensure your personal information is protected while it is being used by the other party.
Purposes For Which Personal Information May Be Collected, Used or Disclosed
We may collect, use or disclose your personal information for the following purposes:
- To establish and maintain communications with you about an insurance transaction;
- To offer or provide information on property and casualty insurance products and services;
- To investigate, evaluate and pay claims;
- To assist a third party in the performance of a business, professional or other insurance function for Wawanesa;
- To determine your eligibility for an insurance benefit or payment;
- To detect or prevent criminal activity, fraud, material misrepresentation or material nondisclosure in connection with an insurance transaction;
- To conduct actuarial studies or business analysis;
- To facilitate a proposed or consummated sale, transfer, merger or consolidation of all or part of Wawanesa;
- To perform marketing services by a third party on Wawanesa’s behalf, as permitted by applicable law;
- To report claims experience or conduct an audit of our operations;
- To review the conduct of a medical care institution or medical care professional
- To determine eligibility for health benefits for which a governmental authority may be liable;
- To provide information regarding the status of an insurance transaction to any lienholder, lessor or other person identified in our records as having a legal or beneficial interest in a policy; and
- As otherwise permitted by applicable law.
Access To Your Personal Information
You may request to have access to your personal information by sending a written request to the Designated Individual. Within thirty (30) business days Wawanesa shall inform you of the nature and substance of the personal information maintained by Wawanesa, permit you to see and copy such personal information or to obtain a copy of the personal information at a reasonable fee to cover the cost of providing such information. You may also request to have your personal information in Wawanesa’s possession corrected, amended or deleted by sending a written request to the Designated Individual. Within thirty (30) business days Wawanesa shall notify you of the corrections, amendment or deletion, or will provide you with a written notice of refusal and advise you of your rights to appeal such determination, in accordance with applicable law.
Information For Visitors To Our Website Or Mobile Application
Wawanesa does not collect your personal information when you visit wawanesa.com unless you affirmatively provide such information, nor do we permit other parties to do so. Examples of ways in which you may affirmatively provide us with your personal information include, but are not limited to, the following:
- Submitting online requests for insurance quotes or applications;
- Making online billing inquiries;
- Requesting online policy changes;
- Providing us with online feedback; and
- Submitting online insurance claims.
In these situations, we will collect, use and disclose your personal information in accordance with the terms of this Policy.
Wawanesa may also collect other types of information when you visit wawanesa.com, such as
- Your Internet protocol address (“IP address”);i and
- Details concerning the route you took to the website, the type of device you used, and how you interacted with the site.
Wawanesa places cookies (files which store details concerning your interaction with our website) on your computer or mobile device to tailor wawanesa.com to suit your interests.ii This information also helps you to navigate the site more efficiently. We do not store your personal information in cookies.
When you install our app on your mobile device, you can choose to allow it to access the location information detected by your mobile device.iii If you allow the app to access this information, it will be used only to provide you with content specific to your location and not to identify you personally. You may withdraw your consent to the collection of your location information at any time by adjusting the location services setting on your mobile device. We do not automatically track your location information when you use our app, and do not store it unless you affirmatively provide it (for instance, if you use the app to submit the location of an accident).
Wawanesa uses Google Analytics to produce anonymous statistics to help us improve wawanesa.com. Google Analytics generates these statistics in the following ways:
- IP address. By using our visitors’ IP addresses, Google Analytics is able to provide us with a general sense of where they are located, without specifically identifying the location of any particular visitor.
- Cookies. By tracking cookies, Google Analytics is able to provide us with general information about how our visitors interact with our website, such as the times of their visits, whether they accessed the site before, and which sites referred them to wawanesa.com.
Google Analytics does not collect your personal information.
Wawanesa’s webpages contain objects (known as “web beacons”) which are provided by our advertising partners.v These objects help us monitor the effectiveness of our marketing campaigns by allowing us to keep track of the number of visitors who have responded to our online advertisements. They do not collect your personal information.
Wawanesa does not use the information collected at wawanesa.com for online behavioral advertising purposes, nor do we permit third parties to do so.vi
Wawanesa may modify this Policy from time to time. In the event that we do, the current version will be posted at wawanesa.com.
Confidentiality and Security
- We do not share your personal information with other companies for their own marketing purposes;
- We require companies performing services on our behalf to protect your personal information in a manner appropriate to the type and sensitivity of the information, and to use it only in connection with those services;
- We allow only those employees and agents who need your personal information to access, use it or disclose it for the purposes identified herein;
- We restrict access to it through physical, electronic and procedural safeguards;
- We monitor our safeguards regularly; and
- We revise our procedures when needed to meet new concerns.
Effective February 1, 2016.
iYour IP address is a unique number which identifies your computer or mobile device when you access the Internet. Collecting your IP address allows us to provide you with web content tailored to your region.
iiCookies are small files that a website places on your computer or mobile device (assuming your web browser settings allow them) which contain information about the pages that you visit on the website. When you return to the website, it recognizes the cookies that it previously placed on your computer or mobile device.
iiiAn app (also known as a mobile application) is a type of web-based software designed to be operated on mobile devices such as smartphones and tablets.
vA web beacon (also known as a pixel tag or clear GIF) is a small piece of computer code which may be included in a web page for analytical purposes. Web beacons allow third parties to collect certain information about your online activity, such as the address of the page you are visiting, the address of the page you previously visited, the time you viewed the page and the type of browser you used.
viOnline behavioral advertising (also known as interest-based advertising) involves tracking your online activity (such as the websites that you visit) in order to predict your interests and to present you with advertisements relevant to those interests.