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Elite Insurance Group Privacy Notice for California Residents

Last Updated: October 1, 2020

This Privacy Notice for California Residents of Elite Insurance Group, Inc. (“EIG”) supplements the information contained in EIG's general Privacy Notice and applies solely to all visitors, users, and others who reside in the State of California (“consumers” or “you”). Any terms defined in the California Consumer Privacy Act of 2018 (“CCPA”) have the same meaning when used in this notice.

Information We Collect

EIG has collected the following categories of consumer personal information within the last twelve (12) months:

CategoryExamples
A. Identifiers.A real name, postal address, unique personal identifier, Internet Protocol address, email address, phone number, date of birth, driver's license number, or other similar identifiers.
B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).A name, address, telephone number, driver's license or state identification card number, insurance policy number, education, employment, credit card number, or any other financial information.
Some personal information included in this category may overlap with other categories.
C. Protected classification characteristics under California or federal law.Age (40 years or older), marital status, or sex (including gender, gender identity, gender expression).
D. Commercial information.Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.
F. Internet or other similar network activity.Search history, information on a consumer's interaction with a website, application, or advertisement while using or interacting with EIG’s websites and applications.
I. Professional or employment-related information.Current or past job history.
K. Inferences drawn from other personal information.Profile reflecting a person's preferences, characteristics, predispositions, and behavior.

Personal information does not include:

  • Publicly available information from government records.
  • Deidentified or aggregated consumer information.
  • Information excluded from the CCPA's scope, like:
    • health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and the California Confidentiality of Medical Information Act (CMIA) or clinical trial data;
    • personal information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FRCA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver's Privacy Protection Act of 1994.

EIG obtains the categories of personal information listed above from the following categories of sources:

  • Directly from you. For example, from forms you complete or products and services you request or purchase.
  • Indirectly from you. For example, from observing your actions on our website and through cookies and other similar technology.
  • From other businesses that EIG works with to provide consumers services, including our corporate affiliates.
  • From sources generally available to the public, such as websites.

Use of Personal Information

We may use, disclose, or share the personal information we collect. EIG works with our corporate affiliates, our service providers, other businesses, and third parties to serve our customers. We share personal information that we collect with our corporate affiliates in connection with the data, technical, accounting, and other services provided within, and for shared marketing purposes to support, our family of companies. In addition, we may share your personal information with our service providers, other businesses and third parties with your consent, including upon your request for information, products, or services offered by them. In addition, EIG also allows tracking technology such as cookies and pixels on our site, which allows other companies to receive data about your activity on EIG that is associated with your browser or device. The other companies may use that data to serve you more relevant ads on our site and others. We may use, disclose, or share personal information for one or more of the following business purposes:

  • To fulfill or meet the reason you provided the information. For example, if you share your name and contact information to request an insurance quote or ask a question about our services, we will use that personal information to respond to your inquiry and, in the case of requests to purchase insurance, to connect you with the selected insurance company. If you provide your personal information to purchase insurance, we will use that information to process your payment and facilitate fulfillment. We may also save your information to facilitate new service requests or the offer of other products and services that may be of interest to you.
  • To provide, improve, support, personalize, and develop our website and services.
  • To process your requests, purchases, and payments and prevent transactional fraud.
  • To provide you with support, to respond to your inquiries, and to otherwise communicate with you and manage the customer relationships, including to investigate and address your concerns and monitor and improve our responses.
  • To personalize your website experience and to deliver content and product and service offerings relevant to your interests, including targeted offers and ads through our website, third-party sites, and via email or text message (with your consent, where required by law).
  • To optimize our and our partners’ advertising and marketing campaigns and analyze their effectiveness.
  • To run and to help maintain the safety, security, and integrity of our website and services, databases and other technology assets (including shared services, databases and assets run by our corporate affiliates), and business.
  • To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.
  • To detect, investigate and prevent fraud and abuse and activities that may be illegal or violate our policies, and to otherwise protect our users, service providers, and business.
  • As described to you when collecting your personal information or as otherwise set forth in the CCPA.
  • To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of EIG's assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by EIG about our users is among the assets transferred.

EIG will not collect additional categories of personal information or use the personal information we collected for materially different, unrelated, or incompatible purposes without providing you notice.

Sharing Personal Information

EIG may disclose your personal information to insurance companies, our corporate affiliates, other businesses, or third parties for a business purpose. As noted above, EIG allows cookies and pixels to share activity data to serve you more relevant ads, and we limit sharing of personal information with non-affiliated businesses or third parties upon your consent or request for information, products, or services offered by the other business or third party. When we disclose personal information to a non-affiliated company for a business purpose, we enter a contract that describes the purpose and requires the recipient to both keep that personal information confidential and not use it for any purpose except performing the contract or as otherwise allowed under the CCPA.

Disclosures of Personal Information for a Business Purpose

In the last twelve (12) months, EIG has disclosed the following categories of personal information for a business purpose to the following categories of third parties:

Personal Information CategoryThird Party Categories
Category A: IdentifiersService Providers
Third parties upon the consumer’s request
Corporate affiliates
Category B: California Customer Records personal information categoriesService Providers
Third parties upon the consumer’s request
Corporate affiliates
Category C: Protected classification characteristics under California or federal lawService Providers
Third parties upon the consumer’s request
Corporate affiliates
Category D: Commercial informationService Providers
Third parties upon the consumer’s request
Corporate affiliates
Category F: Internet or other similar network activityService Providers
Third parties upon the consumer’s request
Corporate affiliates
Advertising networks
Category I: Professional or employment-related informationService Providers
Third parties upon the consumer’s request
Corporate affiliates
Category K: Inferences drawn from other personal informationNone

Sales of Personal Information

In the last twelve (12) months, EIG has not “sold” personal information under the CCPA. EIG will continue to evaluate its disclosure and sharing of personal information and update this Notice if necessary when additional implementing regulations or other guidance is provided.

Your Rights and Choices

This section describes consumer CCPA rights and explains how to exercise those rights.

Access to Specific Information and Data Portability Rights

Consumers have the right to request that EIG disclose certain information to you about our collection and use of your personal information over the past 12 months.

Deletion Request Rights

Consumers have the right to request that EIG delete any of your personal information that we collected from you and retained, subject to certain exceptions.

Exercising Rights

To exercise the access, data portability, and deletion rights described above, please submit a verifiable consumer request to us by either:

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.

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.

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

Non-Discrimination

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

Changes to Our Privacy Notice

EIG reserves the right to amend this privacy notice at our discretion and at any time. When we make changes to this 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.