CCPA

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STANDARD CASUALTY COMPANY PRIVACY NOTICE FOR CALIFORNIA RESIDENTS
Effective Date: 7/1/2020
Last Reviewed on: 7/1/2020
Standard Casualty Company including, Standard Insurance Agency, Inc., and Standard Direct Insurance Agency (“Standard Casualty,” “Company” or “we,” “our” or “us”) respects the privacy of every individual visiting our website(s) (the "Website"), and recognizes that protecting the privacy and security of the personal information we collect about you in the course of using our services (“Services”) is an important responsibility. This CCPA Privacy Notice governs the Company’s subsidiaries, affiliates, and associated companies and their websites, their subdomains, and all portals, applications, products, services, events, and any interactive features, applications, or other services.  This CCPA Privacy Notice does not apply to other websites or platforms that have a different privacy policy.
Our Website and the Services collect information in a manner that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer, device, or household ("personal information").  The CCPA, however, does not apply to certain information, such as information subject to the Gramm-Leach-Bliley Act (“GLBA”). 
The specific personal information that we collect, use, and disclose relating to a California resident covered by the CCPA will vary based on our relationship or interaction with that individual. For example, this CCPA Privacy Notice, and in particular, your rights under this CCPA Privacy Notice, does not apply with respect to information that we collect about California residents who apply for or obtain our financial products and services for personal, family, or household purposes. In general,  the CCPA does not apply to personal information subject to the GLBA that may relate to the following:

• Transaction and experience information  - Information generated from consumer accounts and transactions with a financial services business;
• Joint products or services: Information collected by a financial services business and transferred to a second financial services business in the course of providing joint financial products or services likely is exempt for both financial services businesses, because both are engaged in providing a financial product or service to the same consumer; and/or
• Account website information: IP addresses and information collected through cookies and similar tracking technologies when such information is obtained in connection with providing a financial product or service.  Therefore, such information collected through webpages or mobile apps that allow consumers to access their accounts or use financial products or services is exempt under the CCPA.

For more information about how we collect, disclose, and secure information relating to these customers, please refer to our General Privacy Notice.
Examples of personal information under the CCPA that are likely not exempt under the GLBA:

• General advertising and website marketing: the CCPA applies to of IP addresses that are independent of purposes relating to providing a financial product or services, which may include but is not limited to marketing and other related advertising;
• Information obtained from non-financial institution partners: Generally, information obtained from third parties that are not subject to GLBA, including marketing lists and profiles, are considered personal information under GLBA. The exception to this is consumer reports obtained from a consumer reporting agency, because that information is obtained when a consumer applies for, or already has, a financial product or service provided by the financial services business.
• Information shared with, or obtained from, an affiliate:  When a financial services business receives personal information from an affiliated financial services business, outside the context of providing a joint product or service, the GLBA does not apply to the shared data set.  However, this information may be exempt under California’s Financial Information Privacy Act (FIPA).

 

We have collected the following categories of personal information from our consumers within the last twelve (12) months:

Category	Examples	Collected
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. Please note that Standard Casualty only collects certain personal information categories listed in the California Consumer Records statute to: maintain consumer relationships, provide policy quotes, administer insurance policies, for marketing and advertising, and for Services research purposes.	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). Please note that Standard Casualty only collects certain personal information categories listed in the protected classification characteristics under California or federal law to: maintain consumer relationships, provide policy quotes, administer insurance policies, for marketing and advertising, and for Services research purposes.	[YES/NO]
D. Commercial information.	Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.	[YES/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. Please note that Standard Casualty only collects internet or similar network activity to: provide consumers with the most appropriate policy quotes and insurance policies, customize your products and Services preferences, and to display relevant advertising.	YES
G. Geolocation data.	Physical location or movements. Please note that Standard Casualty only collects geolocation data to: provide consumers with the most appropriate policy quotes and insurance policies, customize your products and Services preferences, and to display relevant advertising.	[YES/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. Please note that Standard Casualty only collects professional or employment-related information from prospective job applicants and current employees. Standard Casualty does not collect this category of personal information on a widespread basis from general Website or Services users.	[YES/NO]
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. Please note that Standard Casualty only collects non-public education information from prospective job applicants and current employees. Standard Casualty does not collect this category of personal information on a widespread basis from general Website or Services users.	[YES/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

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), as explained above, the GLBA or FIPA, and the Driver's Privacy Protection Act of 1994.

We obtain the categories of personal information listed above from the following categories of sources:

• Directly from you. For example, from forms you complete or services you engage with or purchase from our Website or from the Services.
• Indirectly from you. For example, from observing your actions on our Website or from the Services.
• From our affiliates, in particular, other Standard Casualty entities.
• From our network of independent insurance agents that interact directly with you.

• Use of Personal Information

In the past 12 months, we have used personal information relating to California residents to operate, manage, and maintain our business, to provide our products and services, which include providing policy quotes when requested and administering insurance policies,  and to accomplish our business purposes and objectives, including the following:

• Performing services, including maintaining or servicing accounts, providing customer service, processing or fulfilling transactions, verifying customer information, [processing payments], providing financing, providing advertising or marketing services, providing analytic services, or providing similar services;
• Detecting security incidents, protecting against malicious, deceptive, fraudulent, or illegal activity, and prosecuting those responsible for that activity;
• Short-term, transient use where the information is not disclosed to a third party and is not used to build a profile or otherwise alter an individual consumer’s experience outside the current interaction, including, but not limited to, the contextual customization of ads shown as part of the same interaction;
• Auditing related to a current interaction and concurrent transactions, including, but not limited to, counting ad impressions to unique visitors, verifying positioning and quality of ad impressions, and auditing compliance with this specification and other standards;
• Undertaking activities to verify or maintain the quality or safety of a service controlled by us, and to improve, upgrade, or enhance the service controlled by the business;
• Debugging to identify and repair errors that impair existing intended functionality;
• Undertaking internal research for technological development and demonstration; and
• Complying with laws and regulations and to comply with other legal process and law enforcement requirements (including any internal policy based on or reflecting legal or regulatory guidance, codes or opinions)

Sharing Personal Information
We will only share your personal information as described here and as provided in our General Privacy Notice. 

• In an emergency situation, we may use or disclose your personal information if required to do so by law or in the good-faith belief that such action is necessary to (a) conform to applicable law or comply with legal process served on us or the Website, or the Services; (b) respond to requests from public and government authorities; (c) protect and defend our rights or property, the Website, the Services, or our users; or (d) act under emergency circumstances to protect the personal safety of us, our affiliates, agents, the users of the Website or Services, or the public.
• We may disclose all of the information we collect about you to our affiliates and to nonaffiliated third-parties that perform services on our behalf, including contractors, vendors, marketing and advertising companies, etc.
• We may disclose information we collect about you to our network of independent insurance agents.
• We may transfer your personal information if we sell all or part of our business, or make a sale or transfer of our assets, or are otherwise involved in a merger or transfer of all or a material part of our business, or are involved in a bankruptcy to the party or parties involved as part of the transaction.
• We may share your personal information with a third party entity that offers financial products and services, at your request.  Such third party use of your personal information will be subject to that entity’s privacy policy.

We do not sell any personal information to mailing list companies or telemarketing companies but please be aware that Standard Casualty may use such information you supply about yourself for promotional or marketing purposes.
Disclosure of Personal Information
In the preceding twelve (12) months, we have disclosed the following categories of personal information for a business purpose:
Category A: Identifiers.
Category B: California Customer Records personal information categories.
Category C: Protected classification characteristics under California or federal law.
Category D: Commercial information.
Category F: Internet or other similar network activity.
Category G: Geolocation data.
Category I: Professional or employment-related information.
Category J: Non-public education information.
We disclose your personal information for a business purpose to the following categories of third parties:

• Our affiliates
• Service providers
• Independent insurance agents
• Sales of Personal Information

In the preceding twelve (12) months, we have not sold your personal information. However, to the extent that the CCPA’s broad definitions of “sale” and “personal information” may deem the common flow of information, not excluded by application of the GLBA, from Standard Casualty to our independent insurance agents we are currently treating our sharing with these independent insurance agents in the preceding twelve (12) months as a “sale” under the CCPA.
In the preceding twelve months (12) months, we may have shared the following categories of personal information in the manner described above:
Category A: Identifiers.
Category B: California Customer Records personal information categories.
Category C: Protected classification characteristics under California or federal law.
Category D: Commercial information.
Category G: Geolocation data.
Category I: Professional or employment-related information.
Category J: Non-public education information.
We share your personal information in the manner described above to the following categories of third parties:

• Independent insurance agents

Your Rights and Choices
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.
Access to Specific Information and Data Portability Rights
You have the right to request that we disclose certain information to you about our collection and use of your personal information, not excluded by application of the GLBA, over the past 12 months.  Once we receive and confirm your verifiable consumer request, we will disclose to you:

• The categories of personal information we collected about you.
• The categories of sources for the personal information we collected about you.
• Our business or commercial purpose for collecting or selling that personal information.
• The categories of third parties with whom we share that personal information.
• The specific pieces of personal information we collected about you (also called a data portability request).
• If we sold or disclosed your personal information for a business purpose, two separate lists disclosing:
• sales, to the extent that the common flow of information from Standard Casualty to our independent insurance agents is considered as such, identifying the personal information categories that each category of recipient purchased; and
• disclosures for a business purpose, identifying the personal information categories that each category of recipient obtained.

Do Not Sell My Information

To the extent that the common flow of information, not excluded by application of the GLBA, from Standard Casualty to our network of independent insurance agents is considered a “sale,” under the CCPA, you have the right to opt of a sale of your personal information to a third-party. Please note that this does not stop us from distributing this information within our organization, across business units and affiliates.  Additionally, your right to opt out does not stop all transfers to third parties as we can continue to provide your personal information to our service providers pursuant to a written contract that meets requirements within the CCPA.  Furthermore, we can continue to provide data that does not meet the definition of personal information.
This right to opt out applies to all California consumers ages 16 or older and may be exercised at any time. We will honor all such requests unless you subsequently decide to opt in to the sale of your personal information.
The sale of personal information does not include if you direct us to interact with a third-party, any third-party alerts that you have opted out of, the sharing of information is necessary to perform a business purpose and meets the other conditions specified, or the information is transferred as part of an asset in a merger, acquisition, bankruptcy or other change of control of Standard Casualty.
If you wish to exercise your right to opt out, please submit a request via Do Not Sell My Personal Information.   We will honor your request for twelve (12) months before we ask you to opt-in to the sale of your personal information.
Deletion Request Rights
You have the right to request that we delete any of your personal information, not excluded by application of the GLBA, that we collected from you and retained, subject to certain exceptions.  Once we receive and confirm your verifiable consumer request, 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 providers to:

• Complete the transaction for which we collected the personal information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you;
• Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities;
• Debug products to identify and repair errors that impair existing intended functionality.
• Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law;
• Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 seq.);
• Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information's deletion may likely render impossible or seriously impair the research's achievement, if you previously provided informed consent;
• Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us;
• Comply with a legal obligation; and
• Make other internal and lawful uses of that information that are compatible with the context in which you provided it.

Exercising Access, Data Portability, and Deletion Rights
To exercise the access, data portability, opt out, and deletion rights described above, please submit a verifiable consumer request to us in one of the following ways:
By Website:    https://stdins.com

By Phone:       1 (833) 555-0170 

By Email:        techsupport@stdins.com

 

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.
You may only make a verifiable consumer request for access or data portability twice within a 12-month period. The verifiable consumer request must:

• Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative; and
• Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

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.
Response Timing and Format
We endeavor to respond to a verifiable consumer request within forty-five (45) days of its receipt.  If we require more time (up to 45 days), we will inform you of the reason and extension period in writing.  If you have an account with us, we will deliver our written response to that account.  If you do not have an account with us, we will deliver our written response 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 we provide will also explain the reasons we cannot comply with a request, if applicable.  For data portability requests, we will select a format 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 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.
Non-Discrimination
We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not:

• Deny you goods or services.
• Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.
• Provide you a different level or quality of goods or services.
• Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.

Changes to Our CCPA Privacy Notice

The effective date of this CCPA Privacy Notice is set forth at the top of the Website.  We will notify you of any material change by posting notice on the Website.  Your continued use of the Website after the effective date constitutes your acceptance of the amended CCPA Privacy Notice.  We encourage you to periodically review this page for the latest information on our privacy practices.  Any amended Privacy Policy supersedes all previous versions.  IF YOU DO NOT AGREE TO FUTURE CHANGES TO THIS CCPA PRIVACY NOTICE, YOU MUST STOP USING THE SERVICES AFTER THE EFFECTIVE DATE OF SUCH CHANGES.
Contact Information
If you have any questions or comments about this CCPA Privacy Notice, the ways in which we collect and uses your information described in this policy your choices and rights regarding such use, or wish to exercise your rights under California law, please do not hesitate to contact us at:

By Mail:
Communications Department
100 Northwoods Drive
New Braunfels, TX 78132

By Email:        techsupport@stdins.com

By Phone:       1 (833) 555-0170