This California Consumer Privacy Act Policy of National Liability and Fire Insurance Company (“NL&F”) (collectively, “we,” “us,” or “our”) applies solely to individuals who reside in the State of California (“consumers” or “you”). We adopt this policy to comply with the California Consumer Privacy Act of 2018 (“CCPA”). Any terms defined in the CCPA have the same meaning when used in this policy.
Your Right to Know About Personal Information Collected, Disclosed, or Sold
You have the right to request that we disclose to you information about the collection and use of your personal information over the last 12 months, including:
- The categories of personal information we have collected about you;
- The categories of sources from which we have collected the personal information;
- The business or commercial purpose for collecting or selling personal information;
- The categories of third parties to whom we share personal information;
- The specific pieces of personal information we have collected about you;
- The categories of personal information we have disclosed about you for a business purpose; and
- The categories of third parties to whom your personal information is disclosed, or categories of personal information disclosed.
We have not sold personal information about consumers in the last 12 months.
How to Submit a Request
To exercise any of your rights described in this California Consumer Privacy Act Policy, please submit a request to us by contacting us via one of the following methods:
- Click here to complete a request. Return the completed form to us either via email at firstname.lastname@example.org or via U.S. mail following the instructions on the form.
Our Process to Verify Your Request
We will contact you to collect additional information to verify your identity. Depending on the nature of the request, we will require you to provide either two or three pieces of information to allow us to verify that you are the person about whom we collected personal information. We may also require you to submit a signed declaration under penalty of perjury that you are the consumer whose personal information is the subject of the request.
Any information we collect for purposes of verifying your identity will not be used for any other purpose. If we are unable to verify that you are the person about whom we collected personal information, or that you have authority to make the request on that person’s behalf, we will notify you that we will not be able to respond to your request.
We will endeavor to respond to your request within 45 days of the date you submit it. If we require additional time, we will notify you of the extension in writing.
We will not respond to more than two requests from the same consumer in any 12 month period.
Information We Collect
“Personal information” means information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household. Personal information does not include publicly available information.
We may collect the following categories of your personal information:
- Personal 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.
- Personal information under 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.
- Characteristics of protected classifications under Federal and California law: race, color, ancestry, national origin, religion, gender (including pregnancy, childbirth, or related medical conditions), disability, age (40 and older), genetic information, marital status, sexual orientation, gender identity and gender expression, AIDS/HIV status, medical conditions, political activities or affiliations, military or veteran status, and status as a victim of domestic violence, assault, or stalking.
- Commercial information: records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.
- Biometric information: physiological, biological or behavioral characteristics that can be used, singly or in combination with each other or with other identifying data, to establish individual identity. Biometric information includes, but is not limited to, imagery of the iris, retina, fingerprint, face, hand, palm, vein patterns, and voice recordings, from which an identifier template, such as a faceprint, a minutiae template, or a voiceprint, can be extracted, and keystroke patterns or rhythms, gait patterns or rhythms, and sleep, health, or exercise data that contain identifying information.
- Internet or other electronic network activity information: browsing history, search history, information regarding interaction with a website, application, or advertisement, and other similar information.
- Geolocation data: physical location.
- Sensory data: audio, electronic, visual, thermal, olfactory, telemetry data, data aggregation tools or similar information.
- Professional or employment-related information: job history or other employment information.
- Education information non-public education information as defined in 20 U.S.C. § 1232g, 34 C.F.R. Part 99, such as transcripts, grades, class schedules, financial aid, or other records, files, documents or materials containing non-public information directly related to a student and maintained by an educational agency or institution.
- Inferences drawn from other categories of personal information: to create a profile about a consumer reflecting the consumer’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.
We collect each category of personal information about consumers from the following categories of sources:
- Directly from you or someone providing information on your behalf, such as an insurance agent, broker and alike or your employer in connection with obtaining insurance;
- External data sources, such as consumer reporting agencies and other companies that provide data related to a specific consumer, business, or property;
- Sources used to facilitate the transaction of insurance and the investigation of associated claims including, but not limited to, medical providers, regulators, auditors, attorneys, investigators, adjusters, other insurance companies, other third parties, and affiliated companies.
We collect each category of personal information about consumers for the following business or commercial purposes:
- To facilitate the transaction of insurance and the investigation of associated claims;
- Auditing related to a current interaction with the consumer and concurrent transactions;
- Detecting security incidents, protecting against malicious, deceptive, fraudulent, or illegal activity, and prosecuting those responsible for that activity;
- Debugging to identify and repair errors that impair existing intended functionality;
- Undisclosed short-term, transient use;
- Performing services on behalf of the business or service provider;
- Undertaking internal research for technological development and demonstration;
- Undertaking activities to verify or maintain the quality or safety of a service;
- To confirm eligibility for insurance benefits or payments;
- To detect or prevent crime or fraud;
- In response to court orders or other legally required actions;
- For actuarial or research studies;
- In connection with a sale of our business;
- In connection with employment or application for employment;
- In connection with your provision of services to us;
- As otherwise required by law.
We will provide you notice if we collect additional categories of personal information or use the personal information we previously collected for materially different purposes.
Information We Disclose
In the last 12 months, we have disclosed the following categories of personal information about consumers for a business purpose:
- Personal identifiers;
- Personal information under Cal. Civ. Code § 1798.80(e);
- Characteristics of protected classifications under Federal and California law;
- Commercial information;
- Internet or other electronic network activity information;
- Geolocation data;
- Sensory data;
- Professional or employment-related information;
- Education information.
We share personal information about consumers with the following categories of third parties:
- Entities that facilitate our transaction of insurance and the investigation of associated claims;
- Third Party Administrators, independent adjusters, outside counsel, investigators, and other parties for purposes of investigating and resolving claims;
- Regulatory and other government agencies;
- Consumer reporting agencies or insurance support organizations;
- Entities that have an interest in policies issued by us, such as certificate holders, additional insureds, group policy owners, or lienholders;
- Entities who perform administrative, analytical, business, personal, professional, or employment functions on our behalf;
- To our lawyers, accountants and auditors;
- As otherwise required by law.
We have not sold personal information about consumers in the last 12 months.
Right to Delete
You have the right to request that we delete from our records the personal information we have collected about you, subject to certain exceptions. Once we receive and confirm your request, we will determine whether an exception applies. If an exception does not apply, we will delete your personal information from our records. We will also direct our service providers to delete your personal information from their records. If an exception applies, we will not delete your personal information from our records and we will notify you in writing of the reason that we are denying your request to delete your information from our records.
A business may not discriminate against a consumer because the consumer exercised any of the foregoing rights.
You may use an authorized agent to submit requests to us as described in this privacy notice. An authorized agent is a natural person or a business entity that you have authorized to act on your behalf. If you use an authorized agent to submit a request to us, we will require you to (1) provide the authorized agent with written permission to make requests on your behalf and then verify the consumer’s own identity directly with us; or (2) provide the authorized agent with a power of attorney pursuant to Probate Code sections 4000 to 4665. We may deny a request from an agent that does not submit proof that they have been authorized by you to act on your behalf.
Contact for More Information
For questions or concerns about our privacy policies or practices, please contact us at 1-844-549-2512. If you have a disability, you may contact us to access this notice in an alternative format.
Information Not Subject to CCPA