California Privacy Notice
Updated June 2023
Overview
Maintaining the
privacy and security of your personal information is integral to the culture of
CRC Group and its subsidiaries (also referred to collectively and individually
as “CRC,” “we,” “our,” “us”). In doing so, we want to provide transparency
regarding how and why your data is collected, how it is used, and with whom it
may be shared. This document, as well as our
Statement of Online Privacy Practices, set forth how we will interact with your
personal information.
It is important to
note that we do not sell your personal information. Since such sales do not
occur, there is no link on our websites to opt-out of such activity.
This notice is
directed to California residents and relates to the collection, use, and
disclosure of consumer personal information covered by the California Consumer
Privacy Act (CCPA). This notice also provides further information about
our practices, along with details concerning “Right to Know”, “Right to
Correct” and “Right to Delete” requests.
Collection and Use
We are in the business
of acting as an insurance wholesaler. As such, it is necessary for us to collect
certain personal information to fulfill that role, comply with federal and
state laws, and other legal obligations.
We may collect, and
have collected in the past 12 months, the following categories of personal
information:
• Personal identifiers (ex: name, contact information);
• Background data (ex. marital status, education
information);
• Government issued data (ex: passport, driver’s
license, SSN);
• Commercial information (ex: purchase histories,
transaction information);
• Professional or employment-related information;
• Geolocation (ex: your IP address when visiting a CRC
website);
• Internet or other electronic network activity
information (ex: browsing history);
• Audio, electronic, or visual, information (ex: voice
recordings when you contact a call center);
• Personally identifiable health information;
• Background/criminal records;
• Marketing opt-out/preference information;
•
Inferences
drawn from any of the above information
It is necessary for us
to share certain personal information with affiliates and/or trusted service
providers to provide our products and services, and to comply with legal,
regulatory, and contractual obligations. We may disclose each of the categories
of personal information described above to such external or affiliated
companies for the reasons noted above. Below are categories of third
parties with whom we share personal information:
• Affiliates and other entities in the CRC family;
• Businesses with which we partner to offer products
and services for our clients or prospective customers, such as joint marketing
or bill pay partners;
• Service providers that provide various services to
us, such as those we use to help detect and prevent fraud, improve our online
services, and to better market and advertise our services to you;
•
• Credit reporting agencies to report on or learn about
your financial circumstances and as permitted by law;
• Government entities and other third parties as needed
for legal or similar purposes, such as:
·
To respond to requests
from our regulators;
·
To respond to a
warrant, subpoena, governmental audit or investigation, law enforcement
request, legal order or other legal process;
·
To facilitate a
merger, acquisition, sale, bankruptcy, or other disposition of some or all of
our assets;
·
To exercise or defend
legal claims.
Purpose for Collection and Use
We collect and use
personal information to conduct business as an insurance wholesaler. In the
past 12 months, we have collected and used personal information for the
following purposes:
• Deliver, manage, and support products and services
(ex: account information, statements, and notifications);
• Manage business operations;
• Assess and manage risk, manage internal financials;
• Meet legal, regulatory, or compliance requirements;
• Manage fraud and financial crimes;
• Support and optimize channels and interactions (ex:
improving website performance);
• Identify and recommend new products and services;
• Perform services on behalf of another entity or
business (ex: processing data for healthcare providers);
• Provide employee benefits and other services (ex:
retirement, health), manage hiring, employment, performance, and staffing.
Sources of Personal Information
In general, we may
collect personal information about you, directly and indirectly, depending on
your relationship with us—whether as an agent, broker, policyholder, claimant,
employee of our corporate clients, family member of any such person, or other
person who we employ or with whom we do business.
Specifically, we may
collect your personal information from the following sources:
• Directly from you or your family member;
• Outside service providers, vendors, and third parties
(such as insurance companies, intermediaries, brokers, or agents) from which we
collect personal information or market data as part of providing products and
services, completing transactions, or supporting operations;
• Outputs from analytics;
• Websites, mobile applications, and social media;
• Our affiliates or subsidiaries;
• Outside merchants or business partners such as
corporate clients;
• Public records or publicly available data.
No Sale Policy
As noted above, we do
not sell personal information. As such, there is no link on our websites
to opt-out of such activity.
Notice of Right to Limit Use of Sensitive
Personal Information
Sensitive
Personal Information is not used for inferences.
Right to Know
Consumers under the
CCPA may exercise their “Right to Know” to request that we disclose certain
information we may have collected about them over the last 12 months, the
categories of sources from which that information was collected, the business
or commercial purpose(s) for which the information was collected, and the
categories of third parties with whom we share personal information.
Right to Correct
You
have the right to request correction of inaccurate information maintained by CRC. In many instances, such updates are best made
by
emailing salessupportteam@crcgroup.com or
by calling 888-219-0464, and some corrections may require specific
documentation to be provided as required by law. If you provide us
documentation, it will only be used or maintained for the purpose of correcting
the information and complying with our recordkeeping requirements under the CCPA.
CRC also provides privacy request links as described below.
Right to Delete
You
have the right to request deletion of personal information that CRC has
collected, subject to certain exceptions. For example, we may deny your request
if retaining the information is necessary for us to complete a transaction you
requested or comply with our legal obligations.
Consumers are welcome
to submit requests for more information by visiting our Consumer Rights Request
Portal, hosted by OneTrust:
• To submit a request for yourself, click here.
• To submit a request on behalf of another
individual,
click here.
Consumers may also
submit requests by calling 888-219-0464
All requests must be
verified prior to receiving a response. Requesters will be asked to supply
certain basic personal information to enable us to validate that the requestor
is the consumer who is subject of the request. Information submitted for verification
purposes will only be used to verify the requestor’s identity and/or authority
to make a request on another’s behalf. Requests made on another person’s
behalf can only be accepted upon receipt of documentation that the requestor is
an authorized agent, parent, or legal guardian of the consumer whose
information is being requested.
Upon submission of a
request, CA consumers will receive an initial response confirming receipt
within 10 days. A full response will be provided to CA consumers within 45 days
(unless an extension of up to 45 additional days is requested, upon which the
consumer will receive notice and an explanation for the extension).
Non-Discrimination
The submission of a
"Right to Know" or "Right to Delete" request will have no
impact on the service and/or pricing you receive from us. It will not
result in any denial of goods or services, or different prices, rates or
quality of goods or services, nor will it result in retaliation against an
employee, applicant, or independent contractor.
Consumers Under 16 years of Age
CRC products and services are not intended for consumers under
the age of 16, and we do not knowingly collect information from children under
the age of 16 without consent. CRC does not knowingly share the personal
information of minors under the age of 16 for cross-contextual advertising.
Updates
This notice may be
revised from time to time, so please review this page periodically. Any changes
will become effective when we post the revised notice on the site.
Contact Us
If you have any
questions or comments on this notice or our privacy practices generally, please
contact us at
salessupportteam@crcgroup.com or 888-219-0464.