1. Introduction
InsuranceWay (including our affiliates and subsidiaries) (“we”, “us” or “our”) respects your privacy and takes our privacy responsibility very seriously and is committed to protecting it in a manner consistent with applicable law and this statement. This Policy and notice applies to your Personal Information that we may collect, use, receive, and disclose and describes our practices for collecting, using, maintaining, protecting and disclosing that information in the course of providing our services. Please read this Policy carefully to understand our policies regarding your Personal Information and how we will treat it. If you should have any questions regarding this privacy Policy please contact us at info@steadfast-insurance.com, +1 (239) 427-1787. Please review our California Privacy Policy for information about our privacy practices regarding personal information of residents of the State of California.
2. Personal Information We Collect
“Personal Information” is information that identifies you as an individual or relates to you, an identifiable individual. The Personal Information we may collect about you from our clients (or receive directly from you) will depend on the type of service we have been engaged to provide. The following provides a general overview of the categories of Personal Information we may collect. Such Personal Information include, but are is not limited to:
- Name, contact information, and other identifiers (real name, alias, address, unique personal identifier, online identifier, Internet Protocol (IP) address, email address, account name, Social Security number, driver’s license number, or other similar identifiers);
- Personal identification documentation (Social Security Number, driver’s license number, passport number, employee identification numbers, insurance policy number, bank account number, etc.);
- Assets and income, occupation and employment status, dependent information and other relevant financial information;
- Information related to the provision of services to you, such as policy information, claims information, and information relating to any of your past claims and related losses;
- Information relating to your account activity and premium payment history;
- Information from reporting agencies and state and federal government agencies, such as state motor vehicle departments;
- Information from other sources, such as medical or health care providers and other third parties with which you or we maintain a relationship;
- Statements made by or about you;
- Records of communications; and
- Usage data (internet or other electronic network activity information including, but not limited to, browsing history, search history, and information regarding a consumer’s interaction with our websites, or with the Internet, application, or advertisement, including information obtained through the use of internet “cookies”.
Some of the categories of Personal Information that we may collect are special categories of information protected by federal law including your health records (such as your medical history and reports on medical diagnoses, injuries, and treatment) and information about your personal characteristics and circumstances of a sensitive nature such as race, color, sex, age, religion, national origin, disability, citizenship status, and genetic information.
3. How We Collect Personal Information
We generally collect your Personal Information only to the extent that is required for us to perform services on your behalf. In performing such services we collect, use and disclose your Personal Information in a variety of ways. The Personal Information we collect about you or from our clients (or directly from you) will depend on the type of service we are providing and the nature of the service. We may collect your Personal Information in a variety of ways, including:
- By you directly within insurance applications or in connection with other communications;
- From public sources;
- We may receive Personal Information from third parties, including insurance carriers and other industry service providers, and other third parties with which you maintain a relationship (i.e., your employer, financial service, or medical or health providers);
- Through our websites and use of tracking technologies; and
- Third-party use of Cookies or other tracking technologies.
4. Purpose for Collecting Your Personal Information
We collect your Personal Information for everyday business purposes in order to perform services on your behalf. We would generally be unable to perform our services on your behalf without collecting, using or disclosing such Personal Information.
5. Use and Disclosure of Your Personal Information
We use the Personal Information that we collect about you to perform services on your behalf and to provide you with the insurance products and services you expect from us.
From time to time, we may share your Personal Information. We share such information for the following reasons:
- To fulfill any purpose for which you provided your Personal Information;
- To fulfill our everyday business purposes;
- To present our website and its contents to you;
- For legal responses;
- For any other purpose with your consent; and
- For other purposes as may be permitted by law.
We may disclose aggregated information that does not identify any individual, without restriction.
We may disclose Personal Information that we collect, or that you provided as described in this Policy for the following reasons:
- To our subsidiaries and affiliates;
- To a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution or other sale or transfer of some or all of our assets. Whether as a going concern or as part of bankruptcy, liquidation or similar proceeding, in which Personal Information held by us about our website users is among the assets transferred;
- To third parties to market their products or services to you if you have consented to these disclosures (for example, for an insurance quote);
- For any other purpose disclosed by us when you provide the information;
- With your consent.
We may also disclose your Personal Information for the following reasons:
- To comply with any court order, law or legal process, including to respond to any government or regulatory request;
- To enforce or apply our terms of use and other agreements, including for billing and collection purposes; and
- If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of InsuranceWay, our customers or others.
We do not sell your personal information to third parties, other than in connection with a merger, sale, or other transfer of organizational assets where Personal Information held by us about our clients is among the assets transferred.
6. Data Security and Retention
We have implemented measures reasonably designed to protect and secure your Personal Information from accidental loss, misuse, and from unauthorized access, use, alteration, and disclosure. Unfortunately, the transmission of information via the Internet is not completely secure, and although we do our best to safeguard such Personal Information using reasonably designed measures, the security of information cannot be guaranteed. Please immediately notify us using the contact details provided below if you have reason to believe that your Personal Information maintained by us is no longer secure.
7. Lead Generation Practices
Our website may collect information through various lead generation methods, including:
- Online Forms: When you submit your information via forms on our website.
- Advertising Campaigns: When you click on ads or sponsored content that direct you to our site.
- Third-Party Lead Providers: We may work with third-party providers to generate leads and may receive your information from these partners. We ensure these partners are committed to protecting your privacy and adhere to relevant data protection laws.
8. Changes and Updates to Our Privacy Policy and Notice
We may modify or update this Policy from time to time. Your continued use of our website constitutes your acceptance of such changes with respect to our privacy policy.
Additional Disclosures for California Residents
This Privacy Policy and Notice for California Residents (this “Notice”) supplements the information contained in the Privacy Policy and Notice (“Privacy Policy”), and is provided by InsuranceWay and its subsidiaries (in total, “InsuranceWay”, “we”, “us” or “our”) in a manner consistent with applicable law.
In this Notice we provide information for California residents, as required by the California Consumer Privacy Act (“CCPA”), about how we collect, use, receive, and disclose their Personal Information. This Notice also explains certain rights that California residents have under the CCPA and how residents of California can exercise such rights. The CCPA, and accordingly this Notice, apply solely to residents of the State of California.
1. Categories of Personal Information Collected and Disclosed
For purposes of this Notice, “Personal Information” means information that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly, with you or your household.
Personal Information in the context of the CCPA and this Notice does not include:
- Publicly available information made lawfully available by federal, state, or local government records;
- Personal Information that is subject to an exemption under Section 1798.145(c) – (f) of the CCPA, and thereby excluded from the CCPA’s scope, such as protected health or medical information that is subject to and covered by the Health Insurance Portability and Accountability Act of 1996 (“HIPAA”) and the California Confidentiality of Medical Information Act (“CMIA”), and non-public information subject to the Gramm-Leach-Bliley Act (“GLBA”) or the California Financial Information Privacy Act (“FIPA”); and
- Deidentified or aggregated consumer information.
We have collected the following categories of Personal Information from consumers within the last twelve (12) months:
- Identifiers potentially including, without limitation, a Consumer’s real name, alias, address, unique personal identifier, online identifier, Internet Protocol (IP) address, email address, account name, Social Security number, driver’s license number;
- Personal Information Categories listed in the California Customer Records Statute (Cal. Civ. Code. Section 1798.80(e)) potentially including, without limitation, a Consumer’s name, signature, Social Security number, driver’s license number, passport number, employee identification numbers, insurance policy number, bank account number, as well as medical and health information for insurance related purposes;
- Protected Classification Characteristics under California or federal law potentially including, without limitation, a Consumer’s race, color, sex, age (40 years or older), religion, national origin, disability, citizenship status, and genetic information or ancestry;
- Commercial Information potentially including, without limitation, a Consumer’s records of personal property, products or services purchased, and transaction histories;
- Internet or other similar network activity potentially including, without limitation, a Consumer’s information regarding interaction with our website, applications, or advertisement;
- Professional or Employment Related potentially including, without limitation, a Consumer’s current and past job history, education information.
The Personal Information we collect, use, receive, or disclose about a specific California resident depends on our relationship and interaction with that individual, and the type of service we are providing. The categories listed above are the general categories of Personal Information about California residents that we collect and disclose for a business purpose. In the preceding twelve (12) months, we have disclosed all of the categories of Personal Information as noted above for the business purposes described above. We will disclose Personal Information for a business purpose only to service providers, or, where required by law, or in response to valid legal process compelling disclosure.
We do not and have not sold Personal Information in the preceding twelve (12) months.
2. Sources of Personal Information
We obtain the categories of Personal Information listed above from the following categories of sources:
- Directly from you – from insurance applications, from any form you may complete and submit through our website, or in connection with your other communications with us;
- From third parties – from insurance carriers, other industry service providers, other third parties with which you maintain a relationship, such as an employer or financial service or medical or health providers; and
- Through our website and use of “cookies”.
3. Why We Collect Personal Information and How We Use It
The purposes for which we collect, use, receive, and disclose Personal Information depend on, among other things, our relationship or interaction with a specific California resident, and the type of service we are providing. We may use or disclose your Personal Information for one or more of the following purposes:
- To fulfill or meet the reason you provided the information and to perform services on your behalf;
- To support our business operations, including to meet risk, legal, and compliance requirements;
- To comply with, or exercise rights under, applicable law;
- To manage, improve, and develop our business; or
- To evaluate or effect a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, in which Personal Information held by us about our customers is among the assets evaluated or transferred.
We may also disclose your Personal Information for the following reasons:
- To comply with any court order, law or legal process, including to respond to any government or regulatory request;
- To detect and record security and network incidents
- To enforce or apply our terms of use and other agreements, including for billing and collection purposes; and
- If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of InsuranceWay, our customers or others.
We do not sell your personal information to third parties, other than in connection with a merger, sale, or other transfer of organizational assets where Personal Information held by us about our clients is among the assets transferred.
4. Categories of Third Parties with Whom We Share and Disclose Personal Information
We generally share your Personal Information to perform services on your behalf and to provide you with the insurance products and services you expect from us. We may disclose your personal information to a third party for a business or legal purpose. We share your personal information with the following categories of third parties:
- Service providers;
- Insurance carriers and other industry service providers;
- Other third parties with which you or we maintain a relationship regarding your insurance;
- Government agencies including to support regulatory and legal requirements;
- Outside companies or organizations, in connection with routine or required reporting, including consumer reporting agencies and other parties; and
- Affiliates.
5. Requests by California Residents
The CCPA provides California residents with certain and specific rights regarding their Personal Information and imposes restrictions on particular business practices.
- Right to Know about Personal Information Collected or Disclosed: you have the right to request that we disclose certain information to you about our collection and use of your Personal Information during the twelve (12) month period preceding the request. In response to such verifiable request, we will disclose to you:
- The categories of Personal Information we collected about you;
- The categories of sources from which we collected the Personal Information;
- The business or commercial purpose for collecting Personal Information from you;
- The categories of third parties to whom we disclosed Personal Information about you, and the categories of Personal Information disclosed;
- Right to Request Deletion of Personal Information: you have the right to request that we delete any of your Personal Information that we collected from you and retained. In response to the receipt and confirmation of your verifiable Deletion Request, we will delete your Personal Information from our records, unless an exemption applies. We may deny a Deletion Request for reasons described in the CCPA. For example, we will not delete Personal Information when it is necessary to maintain that Personal Information to comply with a legal obligation, or to complete a contract or transaction for which the personal information was collected.
6. Non-Discrimination
The CCPA prohibits discrimination against residents of California for exercising their rights provided to them pursuant to the CCPA. We will not discriminate against you for exercising any of your CCPA rights.
Discrimination may exist where a business denies or provides a different level or quality of goods or services, or charges (or suggests that it will charge) different prices, rates, or penalties on residents who exercise such rights afforded to them by the CCPA, unless doing so is reasonably related to the value provided to the business by the residents’ data.
7. Submitting Requests
To exercise the rights described above, residents of California may submit “Right to Know” and “Right to Delete” requests by:
- By contacting us at +1 (239) 427-1787
- By emailing us at info@steadfast-insurance.com
We will only respond to verifiable requests received from California residents as required by law. Only you, or someone legally authorized to act on your behalf, may make a verifiable consumer request related to your Personal Information. To designate an authorized agent, please contact us at the phone number and/or email address included above.
Verifiable consumer requests must (i) provide sufficient information as we may reasonably request to allow us to reasonably verify you are the resident of California about whom we collected Personal Information or an authorized representative of such resident, including personal and/or commercial identifiers such, and (ii) describe your request with sufficient detail to allow us to properly evaluate your request and respond to it.
We will respond to a verifiable consumer request within the time periods provided by law. Please note, however, that requests will be denied if we cannot verify the identity of the consumer making the request.
Any disclosures we provide in response to such verifiable consumer requests will only cover the twelve (12) month period preceding the receipt of such request.
For more information about our privacy policies, you may contact us as set forth in the Contact Information section above. California residents may make a Request to Know up to twice every twelve (12) months.
8. Changes to this Notice
We may modify or update this Notice periodically. When we do, the latest version of this Notice will be posted on this webpage indicating when the Notice was “Last Updated”.