For California Residents Only
Effective January 1, 2020
Your Rights and Choices
Personally Identifiable Information (“personal information”) is defined for purposes of this section of the Policy as information that identifies, relates, describes, references, is reasonably capable of being associated with, or could reasonably be linked to, directly or indirectly, you as an individual. Personal information includes information collected directly from you if you choose to purchase products, use certain services available on our sites or personal information that you voluntarily provide, such as information included in response to a questionnaire or survey, or if you apply for a job on our Careers sites.
Under the CCPA and the unique consumer rights described below, personal information does not include:
Sharing of Personal Information
We may disclose personal information we collect for one or more of business purposes described in the Policy.
In the preceding twelve (12) months, we have not sold any of your personal information unless a transfer of this information to an advisor, broker or third-party insurance marketer was authorized by you.
Personal information covered by the CCPA shared in the preceding twelve (12) months includes:
Access to Specific Information and Data Portability Rights
Subject to the exceptions set forth in the CCPA, you have the right to request that we disclose certain information to you about our collection and use of your personal information covered over the past 12 months. Once we receive and confirm your verifiable consumer request, we will disclose to you:
Deletion Request Rights
Subject to the exceptions in the CCPA, you have the right to request that we delete any of your personal information collected from you and retained by us. Once we receive and confirm your verifiable consumer request, we will delete (and direct our service providers to delete) your personal information from our records, unless an exception applies.
We may deny your deletion request if retaining the information is necessary for us or our service provider(s) to:
Exercising Access, Data Portability, and Deletion Rights
Only you, or a person registered with the California Secretary of State that you authorize 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 12-month period. The verifiable consumer request must:
Response Timing and Format
We endeavor to respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time (up 90 days), we will inform you of the reason and extension period in writing. We will deliver our written response by mail or electronically, at your option. Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request’s receipt. The response we provide will also explain the reasons 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 and should allow you to transmit the information from one entity to another entity without hindrance, specifically by electronic mail communication.
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.
We will not discriminate against you for exercising any of your CCPA rights.
Changes to Our Privacy Notice
We reserve the right to amend this California privacy notice at our discretion and at any time. When we make changes to this California privacy notice, we will post the updated notice on the Website and update the notice’s effective date. Your continued use of our Website following the posting of changes constitutes your acceptance of such changes.
The effective date of the rights for California residents described in this California privacy notice is January 1, 2020. Changes to this California privacy notice will not affect our use of previously provided personal information.
If you have any questions about this California privacy notice, the ways in which we collect and use your information described in this notice, your choices and rights regarding such use, please feel free to contact us as follows:
Last reviewed date: December 1, 2019