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Effective Date: January 1, 2020
Last Reviewed on: April 16, 2020
This Privacy Notice for California Residents supplements the information contained in Parker, Smith & Feek Insurance, LLC (“PS&F”)’s legal Disclaimer and applies solely to all visitors, users, and others who reside in the State of California (“consumers” or “you”), whether they provide information to PS&F digitally (via email, chat, or the website) or as hardcopy. We adopt this notice (“Notice”) to comply with the California Consumer Privacy Act of 2018 (the “CCPA”) and any terms defined in the CCPA have the same meaning when used in this Notice.
Where noted in this Notice, the CCPA temporarily exempts personal information reflecting a written or verbal business-to-business communication (“B2B personal information“) from some of its requirements.
We collect information that identifies, relates to, describes, references, is reasonably capable of being associated with, and/or could reasonably be linked (directly or indirectly) with a particular consumer or household (“personal information“). Personal information does not include:
Within the last twelve (12) months, we have collected personal information from consumers, as outlined below, across the following categories:
|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.
|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.||NO|
|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.||NO|
|G. Geolocation data.||Physical location or movements.||NO|
|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.||YES|
|J. Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)).||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.||YES|
We obtain personal information outlined by category above from the following sources:
We may use or disclose the personal information we collect for one or more of the following purposes:
We will not collect additional categories of personal information, or use the personal information collected for materially different, unrelated, or incompatible purposes without providing you notice.
We may disclose your personal information to a third party for a business purpose. When we disclose personal information for a business purpose, we enter into a contract with that third party. This contract describes the purpose of sharing the personal information and requires the recipient to (1) keep that personal information confidential and (2) not use it for any purpose except performing the contract. The CCPA prohibits third parties who purchase the personal information we hold from reselling it, unless you have received explicit notice and an opportunity to opt-out of further sales.
We share your personal information with the following categories of third parties:
In the preceding twelve (12) months, PS&F has disclosed the following categories of personal information for a business purpose:
We disclose your personal information for a business purpose to the following categories of third parties:
In the preceding twelve (12) months, PS&F has not sold personal information, even when PS&F receives commissions when you purchase insurance coverage through our services. By way of explanation, a “sale” under the CCPA does not include a situation when a consumer “uses or directs” a business to intentionally disclose personal information, or to interact with a third party. Therefore, when you provide your personal information to PS&F for the purpose of asking us to assist you in finding insurance coverage, PS&F does not “sell” that personal information.
The CCPA provides consumers (California residents) with specific rights regarding their personal information. This section describes your CCPA rights and explains how to exercise those rights.
PS&F IS A SERVICE PROVIDER: Note that PS&F acts as a Service Provider, most commonly on behalf of your employer. Accordingly, if you wish to exercise any of your rights under the CCPA and as described below, we recommend that you contact your employer directly. If you choose to contact us regarding these CCPA rights, be advised that we will first seek authority to comply with any such request from our customer (i.e. your employer). As described, we also may not be able to comply with such requests if we are required to retain your personal information under other applicable law. If you are a direct client of PS&F, this paragraph does not apply to you.
You have the right to request that we disclose certain information to you about our collection and use of your personal information within the past 12 months. Once we receive and confirm your verifiable consumer request (see Exercising Access, Data Portability, and Deletion Rights), we will disclose to you:
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. Once we receive and confirm your verifiable consumer request (see Exercising Access, Data Portability, and Deletion Rights), 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:
To exercise the access, data portability, and deletion rights described above, please submit a verifiable consumer request to us by either:
Be advised that PS&F may be a Service Provider with respect to your personal information and may not be able to comply with your request—even if otherwise valid and verifiable—without the consent of our relevant business partner.
Only you, or someone legally authorized 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. To designate an authorized agent, please contact us using the toll-free number above.
You may only make a verifiable consumer request for access or data portability twice within a 12-month period. The verifiable consumer request must:
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.
Making a verifiable consumer request does not require you to create an account with us.
We will only use personal information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.
For instructions on exercising sale opt-out rights, see Personal Information Sales Opt-Out and Opt-In Rights.
We endeavor to respond to a verifiable consumer request within forty-five (45) days of its receipt. If more time (up to 90 days) is required, we will inform you of the reason and extension period in writing.
If you have an account with us, a written response will be delivered to that account. If you do not have an account with us, the written response will be delivered 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 provided will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format by which 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.
We do not charge a fee to process or respond to your verifiable consumer request(s) unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, you will be notified as to why that decision was made and provided with a cost estimate before completing your request.
We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not:
However, we may offer you certain financial incentives permitted by the CCPA that can result in different prices, rates, or quality levels. Any CCPA-permitted financial incentive offered will reasonably relate to your personal information’s value and contain written terms that describe the program’s material aspects. Participation in a financial incentive program requires your prior opt in consent, which you may revoke at any time. We currently do not provide financial incentives.
California’s “Shine the Light” law (Civil Code Section § 1798.83) permits users of our Website that are California residents to request certain information regarding the disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please send an email to email@example.com.
We reserve 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 PS&F Website and update the notice’s effective date. Your continued use of our services following the receipt of changes constitutes your acceptance of such changes.