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California Consumer Privacy Act

California Residents’ Rights

If you are a California resident, you may have rights under the California Consumer Privacy Act of 2018 (“CCPA”). Information about rights under the CCPA can be found below.

I.California Consumer Privacy Act of 2018

The following applies to California residents, supplements this Policy, and is provided as part of our efforts to comply with the CCPA. Information concerning the CCPA may be found here: https://oag.ca.gov/privacy/ccpa.

Please note that the CCPA does not currently apply in all respects to personal information that We collect from a person in the course of the person acting as a job applicant, employee, owner, director, officer, or contractor of M&A to the extent that the person’s personal information is collected and used by Us solely within the context of the person’s role, or former role, as a job applicant, employee, owner, director, officer, or a contractor of M&A. The CCPA also does not apply to personal information that We collect that constitutes emergency contact information of a person acting in any of the aforementioned roles to the extent that the personal information is collected and used solely within the context of having an emergency contact on file. Lastly, the CCPA does not apply to personal information that is necessary for Us to retain in order to administer benefits relating to a person’s capacity in any of the aforementioned roles to the extent that the personal information is collected and used by M&A solely within the context of administering those benefits.

a.Collection of Personal Information

The categories of personal information identified in this Policy may constitute “Personal Information” as defined in the CCPA. The disclosures and explanations of your rights in this section apply only to the personal information that We collect about you or that We may collect about you in the future.

Please note that the categories of information including any personal information that We collect may vary by individual.

b.Sources of the Personal Information We Collect

We may collect personal information from the following sources:

  1. We may collect personal identifiers from you, publicly available databases, government databases, data aggregators, and third parties from whom We received data;
  2. We may collect protected classifications information from you or from medical providers as part of your application process for life and other insurance;
  3. We may collect commercial information from you directly or from your use of Our Website or mobile apps, from credit reporting companies, and from consumer reporting companies;
  4. We may collect internet, browsing, or other network activity from your use of Our Website or mobile apps;
  5. We may collect geolocation data from your use of Our mobile apps or in connection with your use of Our Website;
  6. We may collect audio recordings when you call Our customer service call centers;
  7. We may collect professional or employment information from job applications, resumes, or recruiters;
  8. We may collect education information from job applications, transcripts, resumes, or recruiters; and
  9. We may collect inferences from your use of Our Website, Our mobile apps, or from information provided by credit or consumer reporting companies if you have applied for a financial product.

Please note that We may not collect personal information about every individual from each of the foregoing sources.

We may obtain personal information about you from third parties and may combine this information with other personal information We maintain about you. If We do so, this Policy governs any combined information that We maintain in personally identifiable format.

c.Purposes for Which We Collect Personal Information

We use personal information to support Our business functions including with respect to the following:

  1. Auditing;
  2. Detecting security incidents;
  3. Protecting against and prosecuting malicious, deceptive or illegal activity (such as fraud);
  4. Debugging;
  5. Short-term, transient use of personal information;
  6. Performing services on behalf of M&A, another business, or a service provider (such as maintaining or servicing accounts or providing customer service);
  7. Undertaking internal research; and
  8. For other business purposes.

Other examples of business purposes include the following:

  1. Personal identifiers are collected and used to respond to questions, requests, and emails, track applications, provide customer service, market and provide products and services to you, set up, manage and service policies and accounts, conduct website or other surveys, verify your identity, and update Our records;
  2. Protected classifications are collected and used to provide products and services to you;
  3. Commercial information is collected and used to market products or services to you;
  4. Internet, browsing, or other network activity is collected and used to conduct website and mobile app analysis, conduct research and analytics, develop Our websites and mobile apps, market and provide products or services to you, manage Our online advertising and its effectiveness, remember your preferences and interactions, respond to questions and emails, manage and service policies and accounts, conduct website and other surveys, and offer products and service programs to you;
  5. Geolocation data are collected and used to conduct website and mobile app analysis, develop Our websites and mobile apps, and market products or services to you;
  6. Audio recordings may be collected and used to improve customer service;
  7. Professional or employment information is collected and used to process job applications and offers or denials of employment;
  8. Education information is collected and used for processing your job application; and
  9. Inferences are collected and used to market products or services to you and help predict your future claims.

We also collect and use all categories of personal information listed in this policy to comply with Our legal obligations, resolve disputes, enforce our agreements, provide you with Our products or services you have purchased, for everyday servicing purposes, and as otherwise described to you at the point of collection.

d.The Categories of Third Parties with Whom, and Purposes for Which, We Share Personal Information

Categories of personal information that We collect may be shared in limited circumstances with third parties for business purposes. We do not sell your personal information. While M&A does not sell information we collect, we may share your information for the business purposes listed above and for the following reasons:

  1. Personal identifiers may be shared with entities that provide Us with customer service, account setup, account management and servicing, and data verification services;
  2. Protected classifications information may be shared with entities that provide Us with services to provide products and services to you;
  3. Commercial information may be shared with entities that help Us offer insurance programs to you, or help market products or services to you;
  4. Internet, browsing, or other network information may be shared with entities that assist Us with conducting website and mobile app analysis, conducting research and analytics, developing our websites and mobile apps, collecting information about Our website and mobile app usage and email responses, marketing and providing products or services to you, managing Our online advertising and its effectiveness, responding to questions and emails, managing and servicing policies and accounts;
  5. Geolocation data may be shared with entities that assist Us in conducting website and mobile app analysis, developing Our websites, mobile apps, or insurance programs, and marketing products or services to you;
  6. Audio recordings may be shared with entities that provide Us with services to improve customer service or for authentication or fraud investigation purposes;
  7. Professional or employment information may be shared with recruiters or with entities that help Us with processing job applications or offers or denials of employment;
  8. Education information may be shared with entities that provide Us with human resources, job application, or recruitment services; and
  9. Inferences may be shared with entities that provide Us with services to market products or services to you and help predict your future.

M&A may also share all categories of personal information as part of corporate transactions, such as mergers, acquisitions, or divestitures, as well as with Our affiliates and subsidiaries. We may be required to share all categories of personal information with law enforcement, regulatory agencies, or litigants based on enforceable requests for this information.

e.Access to Personal Information

You have the right to request, in accordance with applicable law, that We disclose certain information to you about Our collection and use of your personal information over the past twelve (12) months. Please note that the CCPA limits Our ability to provide you with the requested information only after We receive a verifiable consumer request from you or a person registered with the Secretary of State that is authorized by you to act on your behalf. Once We receive a verifiable consumer request, We will disclose to you:

  • The categories of personal information We collected about you
  • The categories of sources for the personal information We collected about you
  • Our business or commercial purpose for collecting that personal information
  • The categories of third parties with whom We share that personal information
  • The specific pieces of personal information We collected about you (also called a data portability request)
  • If We disclosed your personal information for a business purpose, and the personal information categories that each category of recipient obtained

Please note that the CCPA does not require Us to retain any personal information collected for a single, one-time transaction, if that personal information is not sold or retained by Us. It also does not require Us to reidentify or otherwise link information that is not maintained in a manner that would be considered personal information.

f.Deletion Requests

You may request, in accordance with applicable law, that M&A delete the personal information that We collected about you and retained, subject to certain exceptions. Once We receive a verifiable consumer request, We will delete (and direct Our service providers to delete) your personal information from Our records, unless an exception applies in support of Our business need to retain some or all of your personal information.

We may deny your deletion request if retaining the personal information is necessary for Us or Our service provider(s) to:

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

g.Access, Data Portability, and Deletion Requests

To access, seek data portability, or request that We delete your personal information, please submit a verifiable consumer request to Us by either:

Only you, or someone legally authorized to act on your behalf, may make a verifiable consumer request related to your personal information. You may also make a verifiable consumer request on behalf of your minor child.

You may only make a verifiable consumer request for access or data portability twice within a twelve (12) month period. The verifiable consumer request must:

  • Provide sufficient information that allows Us to reasonably verify you are the person about whom We collected personal information or an authorized representative
  • Describe your request with sufficient detail that allows Us to properly understand, evaluate, and respond to it

After We receive a verifiable consumer request from you, We will take steps to determine whether the request being made is a verifiable consumer request. Given the nature of the personal information requested, We will require authentication of your identity. We cannot respond to your request or provide you with personal information if We cannot verify your identity or authority to make the request and confirm the personal information relates to you. Making a verifiable consumer request does not require you to create an account with Us.

We will only use personal information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.

h.Response Timing and Format

We will make every effort to respond to a verifiable consumer request within forty-five (45) days of its receipt. If We require more time, We will inform you of the reason and extension period in writing.

Any disclosures We provide will only cover the twelve (12) month period preceding our receipt of your verifiable consumer request. The response We provide will also explain the reason(s) We cannot comply with a request, if applicable. For data portability requests, We will select a format to provide your personal information that is readily useable to allow you to transmit the information from one entity to another entity without hindrance.

We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If We determine that the request warrants a fee, We will tell you why We made that decision and provide you with a cost estimate before completing your request.

i.Personal Information Sales Opt-Out and Opt-In

M&A does not sell your personal information. Because We do not sell your information, We do not have an opt-out.

j.Non-Discrimination

We will not discriminate against you for exercising any of your privacy rights. We will not:

  • Deny you goods or services;
  • Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties;
  • Provide you a different level 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.

II.California Shine The Light Law

M&A does not share your information with non-affiliated third parties for their own marketing use without your consent. M&A does share your information with corporate affiliates.

M&A may revise this policy from time to time as permitted by law. M&A will provide you the revised policy on this website, a website that replaces this website, in person, via email, or using other methods.