Last revised: Sept 9, 2022
California Consumer Privacy Act Notice
Personal Information Defined
For purposes of this Privacy Notice “Personal Information” means any information that identifies, relates to, describes, references, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer, household, or device.
Not all information we collect is Personal Information under this definition. For example, Personal Information does not include publicly available information collected from government records or information that has been de-identified or aggregated in a way that no longer allows identification of a particular person.
Disclosures Regarding Personal Information
Personal Information We Collect
We have collected Personal Information from consumers within the last twelve (12) months in the categories shown in the table below. Our listing of these categories does not mean that all categories or the examples listed in each category are collected about everyone who uses our services or interacts with our systems. We are providing a full list here to comply with disclosure obligations because some of the information may have been collected about some consumers.
|A. Identifiers||A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, Social Security number, driver’s license number, passport number, or other similar identifiers.||YES|
|B. Personal Information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).||A name, signature, Social Security Number, physical characteristics or description, address, telephone number, passport number, driver’s license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information. Some personal information included in this category may overlap with other categories.||YES|
|C.Protected classification characteristics under California or federal law.||Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information).||YES|
|D. Commercial Information.||Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.||YES|
|E. Biometric Information.||Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as, fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data.||NO|
|F. Internet or other similar network activity.||Browsing history, search history, information on a consumer’s interaction with a website, application, or advertisement.||YES|
|G. Geolocation Data.||Physical location or movements.||YES|
|H. Sensory data.||Audio, electronic, visual, thermal, olfactory, or similar information.||NO|
|I. Professional or employment-related information.||Current or past job history or performance evaluations.||NO|
|J. Non-public education information||Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records.||NO|
|K. Inferences drawn from other personal information.||Profile reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.||NO|
Sources of Personal Information We Collect
We collect the categories of Personal Information listed above from various sources. This section lists and describes those sources.
Directly from our clients, claimants, or their agents. This includes insurance application information and additional information that you provide to us, including when you complete certain forms, post or comment, upload or submit any material, request information or contact us with inquiries, or when you use other aspects of our services, may be collected and stored.
Indirectly from our clients, claimants, or their agents. We may automatically collect Personal Information from you when you use our services or interact with our systems through the use of tracking technologies or by other passive means. This “passively collected” information helps us to improve our services and allows us to ensure our systems work as designed and in a way that meets your expectations.
From third parties. We may collect Personal Information about you from third parties, either at your request or for our business purposes.
Directly from publicly available sources. We may collect information directly from publicly available sources, such as county property tax databases.
Use of Information
We use both Personal Information and non-Personal Information to deliver services to you, to help improve your interaction with our systems, and to support our business purpose. Some examples of ways in which we may use or disclose Personal Information include:
- To identify you when you sign on to your account
- To create and maintain your account and online profile
- To respond to your questions or inquiries
- To ask you to participate in surveys, or otherwise provide feedback
- To improve, upgrade or enhance our systems and our services
- To develop new products and services
- To create de-identified or aggregated lists of information for any the uses stated above
- To operate our systems or provide our services
- To carry out other purposes that are disclosed to you and/or to which you consent
The categories of Personal Information disclosed for a business purpose within the past twelve (12) months include any of the categories of Personal Information identified as “Collected” in the table at the beginning of this section.
We disclose your Personal Information to the following categories of other parties for a business purpose:
- Our affiliates
- Service providers
- Third parties to whom you or your agents authorize us to disclose your personal information in connection with services we provide to you
- Entities involved in the sale or purchase of all or a portion of our business
Additionally, we will cooperate with government and law enforcement officials or private parties to enforce and comply with the law. In doing so, we may disclose information about you to government or law enforcement officials or private parties as we, in our sole discretion, believe necessary or appropriate: (i) to respond to claims or legal processes (including subpoenas or other lawful government request for data); (ii) to protect our property, rights and safety and the property, rights and safety of a third party or the public in general; (iii) to detect or prevent fraud or security concerns; and (iv) to stop activity that we consider illegal, unethical or legally actionable.
We have not sold any Personal Information in the last twelve (12) months.
Consumer Rights Regarding Personal Information
Right to Know the 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 over the past 12 months. When you request that we provide you with the information we collect or disclose we will provide you with an individualized response about our collection and use of your Personal Information. That response will include:
- Specific pieces of Personal Information we have collected about you
- The categories of Personal Information we have collected (for reference see the table above for categories and examples of Personal Information that we may collect)
- The sources from which we have collected your Personal Information
- Our business purpose for collecting or selling your Personal Information
- The categories of third parties to whom we have disclosed Personal Information
- Whether we have disclosed or sold Personal Information for a business purpose.
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, subject to certain exceptions. When you request that we delete your Personal Information, we will delete Personal Information we maintain about you from our records as of the date of your request subject to certain limitations. We will also request that any service providers that we know maintain your data on our behalf also delete your Personal Information. In some cases, deletion may be accomplished through de-identification of the information.
Please note that certain information may be excepted from your deletion request. For example, we may keep your information where necessary to detect and resolve issues related to system security and fraud detection. We will also keep information needed to provide services to you.
Exercising Your Right to Know or Delete
If you have questions or would like to exercise the right to know and deletion described above, please use the Contact Us information at the end of this notice.
We cannot respond to your right to know or deletion if we cannot verify your identity or the authority of your agent to make the request and confirm that the Personal Information we maintain relates to you. When you make a request, we will verify your identity by matching data points that you provide with data points that we maintain and have determined to be reliable for the purposes of verification.
You must also describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it. If we have questions regarding your request you must make an effort to respond to our inquiries. If we do not understand your request, we may not be able to comply. You may only exercise your Right to Know and Right to Request Deletion twice within a 12-month period.
Where possible, we will respond to a verified right to know or delete request within 45 days of receipt. If we require more time, we will inform you of the reason and the need for an extension.
Any disclosures we provide will only cover the 12-month period preceding the verified consumer request’s receipt. The response we provide will also explain the reasons we cannot comply with a request, if applicable.
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.
You may designate an authorized agent to make requests on your behalf. We will require verification that you did in fact give that person your authorization. Unless the law requires otherwise, your authorized agent must provide contact details for you. We will contact you to confirm that you authorized the agent to act on your behalf. Once you confirm, we will promptly respond to the rights request.
We will not discriminate against you for exercising any of the rights listed in this section. Unless permitted by regulation, we will not:
- Deny you services, except to the extent that not having Personal Information prevents us from providing you services.
- Provide you a different level or quality of service, except to the extent that not having Personal Information limits our ability to provide you service.
- Charge or suggest that we will charge you different prices or rates for services, including through granting discounts or other benefits, or imposing penalties.
Updates to this Privacy Notice
We may change or update our services or any of our policies and procedures without prior notice. The date at the top of this notice reflects the date of the most recent update. Your continued participation in our insurance program signifies your continued assent to the terms of this Privacy Notice, as updated or amended at that time.
If you have any questions or comments about this Privacy Notice, the ways in which we collect and use information, your choices and rights regarding such use, or if you wish to exercise the rights outlined above, please contact us as provided below.
National Real Estate Insurance Group
11500 NW Ambassador Dr, Ste 310
Kansas City, MO 64153