California Specific Disclosure

California Specific Disclosure

This California Consumer Privacy Act (the “CCPA”) Privacy Policy (the “CA Policy”), as amended by the California Privacy Rights Act (“CPRA”),  describes how GSR collects, why we collect it, how we collect it, and how you can exercise your rights, with respect to your personal information , for California residents.  This CA Policy also serves as notice at collection under the CCPA and CPRA, and their implementing regulations.  This CA Policy is provided in addition to any other privacy notices and materials you may receive with your policy documentation and applies only to the extent that California law applies.

1. What Personal Information Do We Collect?

The type of personal information we collect may vary depending on your relationship with us, such as if you are a customer or a third party filing a claim. We may have collected the following categories of personal information:

1. Identifiers, such as name, contact information, online identifiers and Social Security numbers and other government-issued ID numbers;
2. Personal information, as defined in the California customer records law, such as insurance policy number, education, employment, employment history and biometric information;
3. Characteristics of protected classifications under California or federal law, such as sex, age, race, religion, national origin, citizenship, immigration status and marital status;
4. Commercial information, such as transaction information and history;
5. Cookies and internet or network activity information, to the extent you visit our Sites or use our software applications, such as browsing history and interactions with our Sites and systems;
6. Geolocation data, to the extent you use our mobile applications and choose to share your device geolocation data;
7. Audio, electronic, visual, thermal, olfactory, and similar information, such as photographs or video recordings created in connection with our business activities, and recordings of calls to our representatives;
8. Professional or employment-related information, such as work history, prior employer, information relating to references, details of qualifications, skills and experience, human resources data, and data necessary for benefits and related administration services; and
9. Inferences drawn from any of the personal information listed above to create a profile or summary about, for example, an individual’s preferences and characteristics.

2. What Are Our Sources of Personal Information?

We collect the personal information described above directly from you such as through your transactions with GSR and our business partners, and your interactions with us on our Sites. We also collect this personal information from other categories of sources such as publicly available databases, consumer reporting agencies, commercially available sources, individual businesses, third-party service providers, third parties authorized by you such as doctors, agents, and prior and current employers, when they share the information with us.

3. How Do We Use Personal Information?

Depending on your relationship with us, we may use the personal Information described above for the following purposes:

• To operate, manage, and maintain our business, such as to make insurance decisions, communicate with you and others as part of our business, provide our products and services, and maintain records.
• To develop and improve our products and services, such as to undertake quality and safety assurance measures, audit customer interactions, facilitate social sharing functionality, resolve complaints, and evaluate customer service.
• For our employment and vendor management purposes.
• For security purposes, such as to maintain our facilities and infrastructure, protect against malicious, deceptive, or fraudulent activity, and conduct internal investigations.
• For monitoring purposes, such as to establish the existence of facts, maintain compliance with regulatory or self-regulatory practices, or for other purposes permissible under applicable law.
• To perform other necessary and appropriate internal functions, such as accounting and auditing.
• To report to credit bureaus.
• To conduct research, analytics, and data analysis, and for marketing purposes, such as to personalize, advertise, and market our products and services and administer contests and promotions, in accordance with applicable law.
• To comply with legal and regulatory requirements, defend legal claims, and assist with legal processes such as investigations, and regulatory requests, litigation, and arbitration.
• For other legitimate purposes.

4. How Do We Share Personal Information?

Depending on your relationship with us, we may share your personal information for the purposes described in Section 3 with the following categories of recipients: GSR affiliates; insurance and distribution parties; service providers; providers of internet-connected devices and associated software; governmental authorities and third parties involved in court action; parties to a merger or acquisition; and our business partners or other third parties as may be required and where we have obtained the appropriate authorization.

The following categories of personal information may have been disclosed as described above:

1. Identifiers, such as name, contact information, online identifiers and Social Security numbers and other government-issued ID numbers;
2. Personal information, as defined in the California customer records law, such as insurance policy number, education, employment, employment history and biometric information;
3. Characteristics of protected classifications under California or federal law, such as sex, age, race, religion, national origin, citizenship, immigration status and marital status;
4. Commercial information, such as transaction information and history;
5. Internet or network activity information, to the extent you visit our websites or use our software applications, such as browsing history and interactions with our and other websites and systems;
6. Geolocation data, to the extent you use our mobile applications and choose to share your device geolocation data;
7. Audio, electronic, visual, thermal, olfactory, and similar information, such as photographs or video recordings created in connection with our business activities, and recordings of calls to our representatives;
8. Professional or employment-related information, such as work history, prior employer, information relating to references, details of qualifications, skills and experience, human resources data, and data necessary for benefits and related administration services; and
9. Inferences drawn from any of the personal information listed above to create a profile or summary about, for example, an individual’s preferences and characteristics.

When we share personal information with non-affiliated third parties, those third parties cannot use the information except to perform services for us, or as may be permitted or required by law.

Because we do not sell or share personal information in exchange for monetary consideration, we do not provide any opt-out mechanism, except to opt-out of receiving marketing information.  In addition, GSR already limits the use and disclosure of your sensitive personal information, so there is no need for you to request that we do so.

5. What Are Your Rights?

If you are a California resident and this CA Policy applies to you, you may request that we:

1. Disclose to you the following information covering the 12 months preceding your request:
   • The categories of personal information we collected about you and the categories of sources from which we collected such personal information.
   • The specific pieces of personal Information we collected about you.
   • The business or commercial purpose for collecting personal information about you.
   • The categories of personal information about you that we otherwise shared or disclosed, and the categories of third parties with whom we shared or to whom we disclosed such personal information (if applicable).
2. Delete certain personal information we collected from you. In the event that you choose to exercise this right, please note that we may nevertheless retain your personal information as permitted under applicable law, including but not limited to the following purposes:
   • To provide goods or services within the context of our relationship with you.
   • To detect security incidents or other fraudulent or illegal activity.
   • To comply with our legal and regulatory obligations.
   • To enable other uses that are compatible with your expectations or appropriate given the context in which the personal information was collected.
   • Make other internal and lawful uses of that information that are compatible with the context in which you provided it.

In order to make the requests listed above, please submit a request via email to info@greenshieldrisk.com or send a letter to Green Shield Risk Solutions, LLC, c/o Privacy Info, 159 N. Sangamon, Suite 200, Chicago, IL 60607. We may require that you or your authorized representative provide certain identifying information prior to processing any request to confirm that the request has been validly made, including that authorized representatives provide proof of their authority to act on your behalf. If we are unable to verify your identity, or confirm that you have authorized the request, we may not be able to respond to your request in full.  You are entitled to exercise the rights described above without receiving discriminatory treatment.