California Consumer Privacy Act Notice
This California Consumer Privacy Act (“CCPA”) Privacy Policy and Notice at the time of Collection (“CCPA Notice”) is provided on behalf of Private Client Select Insurance Services (“Private Client Group”) and its subsidiaries and affiliates (each a “Private Client Group Company,” “Private Client Group Companies,” “we,” or “us”). We are providing this CCPA Notice in accordance with our obligations under applicable law and as part of our commitment to handling your personal information responsibly and transparently. Please review this CCPA Notice to understand our privacy practices, including what personal information we collect, why we collect it, how we collect it, and how you can exercise your rights with respect to your personal information.
This CCPA Notice applies to individuals associated with corporations, partnerships, other non-individual clients, and other non-client individuals who are California residents and whose personal information we collect. This CCPA Notice should be read in conjunction with any other privacy notices you receive from other Private Client Group Companies. We refer to any company that is not a Private Client Group Company as a non-affiliated third party.
This CCPA Notice is not applicable to employees or current and former individual clients of the Private Client Group Companies who purchased or are seeking to purchase products primarily for personal, family or household use such as life insurance, retirement products, homeowner’s insurance, travel insurance, etc. If you are an individual client who has obtained or is covered by such a product or service from us, federal law requires that we provide you with a separate notice at the establishment of the customer relationship and annually thereafter, which explains what personal information we collect and what rights you may exercise with respect to your personal information.
If you are not a California resident or this CCPA Notice does not otherwise apply to you, please refer to our Privacy Notice for more information about how we handle personal information.
1. What Personal Information Do We Collect and How Do We Share or Disclose This Information?
Depending on your relationship with us, we may disclose your personal information for the purposes described in Section 3 with the following categories of recipients: entities within the Private Client Group Companies’ family, including subsidiaries and affiliates; insurance and distribution parties; service providers; providers of Internet-connected devices and associated software; governmental authorities and third parties involved in court action; parties to a merger or acquisition; and our business partners or other third parties as may be required and where we have obtained the appropriate authorization.
The following chart details which categories of personal information we collect and the third parties to whom we disclose such personal information for our operational business purposes, including within the 12 months preceding the date this notice was last updated. We use or disclose your sensitive personal information for the limited purposes permitted under the CCPA, such as to perform or provide services as requested by you.
Category |
Third Parties to Whom We Disclose Personal Information for Business Purposes |
Identifiers, such as name, contact information, online identifiers, Social Security numbers and other government-issued ID numbers |
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Personal information, as defined in the California customer records law, such as insurance policy number, education, employment, employment history, financial information and medical information. Some personal information included in this category may overlap with other categories. |
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Characteristics of protected classifications under California or federal law, such as sex, age (40 years or older), race, religion, national origin, disability, medical conditions and information, citizenship, immigration status and marital status |
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Commercial information, such as transaction information and history |
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Internet or network activity information, such as browsing history and interactions with our and other websites and systems |
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Geolocation data, such as when you use our mobile applications and choose to share your device geolocation data |
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Audio, electronic, visual, or similar information, such as photographs or video recordings created in connection with our business activities, and recordings of calls to our representatives and call centers |
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Professional or employment-related information, such as work history, prior employer, information relating to references, details of qualifications, skills and experience, human resources data, and data necessary for benefits and related administration services |
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Inferences drawn from any of the personal information listed above to create a profile or summary about, for example, an individual’s preferences and characteristics |
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Sensitive personal information, such as Social Security number, driver’s license information, state identification information, or passport number, ethnic or racial origin, citizenship |
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We may also disclose your personal information to third parties in connection with any reorganization, financing transaction, merger, sale, joint venture, partnership, assignment, transfer, or other disposition of all or any portion of our business, assets, or stock (including in connection with any bankruptcy or similar proceeding).
We do not “sell” or “share” personal information, as the terms are defined under the CCPA, as amended by the California Privacy Rights Act. We have not sold or shared personal information in the 12 months preceding the date that this CCPA Notice was last updated. Without limiting the foregoing, we do not “sell” or “share” personal information of minors under 16 years of age.
We retain each category of personal information that we collect for as long as needed or permitted in light of the purpose(s) for which it was collected. The criteria used to determine our retention periods include:
- The length of time we have an ongoing relationship with you (for example, for as long as you have an account with us) and the length of time thereafter during which we may have a legitimate need to reference your personal information to address issues that may arise;
- Whether there is a legal obligation to which we are subject (for example, certain laws require us to keep records of your transactions for a certain period of time before we can delete them); or
- Whether retention is advisable in light of our legal position (such as in regard to applicable statutes of limitations, litigation or regulatory investigations).
2. What Are Our Sources of Personal Information?
We collect the personal information described above directly from you such as through your transactions with us and our business partners, and your interactions with us on our websites and social media pages. We also collect this personal information from other categories of sources such as publicly available databases, consumer reporting agencies, commercially available sources, third parties authorized by you such as doctors, financial advisors, and prior and current employers, when they share the information with us.
3. For What Purposes Do We Use or Disclose Personal Information?
Depending on your relationship with us, we may use the personal information described above for the following purposes:
- to operate, manage, and maintain our business, such as to make insurance decisions, communicate with you and others as part of our business, provide our products and services, and maintain records;
- to develop and improve our products and services, such as to undertake quality and safety assurance measures, audit customer interactions, facilitate social sharing functionality, resolve complaints, and evaluate customer service;
- for our vendor management purposes;
- for security purposes, such as to maintain our facilities and infrastructure, protect against malicious, deceptive, or fraudulent activity, and conduct internal investigations;
- for monitoring purposes, such as to establish the existence of facts, maintain compliance with regulatory or self-regulatory practices, or for other purposes permissible under applicable law;
- to operate, maintain and improve our websites and other online services or applications;
- to perform other necessary and appropriate internal functions, such as accounting and auditing;
- to report to credit bureaus;
- to conduct research, analytics, and data analysis, and for marketing purposes, such as to personalize, advertise, and market our products and services and administer contests and promotions, in accordance with applicable law;
- to comply with legal and regulatory requirements, defend legal claims, and assist with legal processes such as investigations, and regulatory requests, litigation, and arbitration; and
- to facilitate and implement any reorganization, financing transaction, merger, sale, joint venture, partnership, assignment, transfer, or other disposition of all or any portion of our business, assets or stock (including in connection with any bankruptcy or similar proceedings).
4. What Rights Are Available?
If you are a California resident and this CCPA Notice applies to you, subject to applicable law, you may request that we:
1. Disclose to you the following information :
- The categories of personal information we collected about you and the categories of sources from which we collected such personal information;
- The specific pieces of personal information we collected about you;
- The business or commercial purpose for collecting or sharing personal information about you; and
- The categories of personal information about you that we shared or disclosed, and the categories of third parties with whom we shared or to whom we disclosed such personal information (if applicable).
2. Delete certain personal information we collected from you. In the event that you choose to exercise this right, please note that we may nevertheless retain your personal information as permitted under applicable law, including, but not limited to, for the following purposes:
- To provide goods or services within the context of our relationship with you;
- To detect security incidents or other fraudulent or illegal activity;
- To comply with our legal and regulatory obligations; and
- To enable other uses that are compatible with your expectations or appropriate given the context in which the personal information was collected.
3. Correct inaccuracies in the personal information we collected from you. We may request documentation from you in connection with your request where we have reliable documentation showing the accuracy of the information. To protect you, we will require you (or your agent) to be verified before honoring your correction requests. Upon receipt of a verifiable request to correct inaccurate personal information, we will use commercially reasonable efforts to correct the information as you direct.
4. Provide you with a copy of your personal information, in a portable, readily usable format, if requested.
Under California law, you are entitled to exercise your rights without experiencing any discriminatory treatment.
To make any of the requests listed above, please contact us using either of the methods below:
(1) Call 1-888-978-5371; or
(2) Submit a request at Pcs.privacy@privateclientselect.com
We may need to verify you to respond to your request consistent with applicable law. Either method above will include instructions about how to submit a verifiable request, which will require that you or your authorized representative provide certain identifying information. For policy/contract owners, we request that you provide as much of the following information as possible so that we can locate you in our records:
- Relationship to Us–policy/contract/account owner, claimant, insurance applicant, beneficiary;
- Request type–receive details on Personal Information, delete Personal Information, obtain copies of Personal Information;
- First and last name;
- Date of birth;
- Email address;
- Address, including state;
- Telephone number;
- Policy/Contract/Claim/Certificate/Quote number; and
- Product name.
We will also ask you to certify under penalty of perjury by typing your name in the electronic form that you are the individual or the authorized representative of the individual whose information is the subject of the request. We may follow up with you for more information if necessary. If we do not receive this information, we will close your request due to our inability to verify your identity.
Authorized representatives will also be required to provide proof of their authority to act on your behalf by uploading relevant documents to the online form, such as a court order or a written power of attorney. If an authorized representative submits a request on your behalf, we will contact you to confirm their representation. If we are unable to verify your identity, or confirm that you have authorized the request, we may not be able to respond to your request in full.
De-Identified Information
Where we maintain or use de-identified data, we will continue to maintain and use the de-identified data only in a de-identified fashion and will not attempt to re-identify the data.
5. Changes to this CCPA Notice
We may change or update this CCPA Notice from time to time. When we do, we will post the revised CCPA Notice on this page with a new “Published” date.
If you have any questions or concerns about this CCPA Notice or our privacy practices, please contact Pcs.privacy@privateclientselect.com.
Published June 2023