Privacy Notice
Companies trading under the Farm Family Insurance brand are subsidiaries of Clearbrook Group Holdings Inc.
Clearbrook Group Holding Inc., its subsidiaries and affiliates (“Clearbrook” or “we,” “us” or “our”) respect your privacy. This general Privacy and Data Protection Notice (“Privacy Notice”) applies globally to all affiliated Clearbrook Group companies. A list of the current Clearbrook Group companies is provided below.i The Clearbrook Group company that was originally responsible for collecting your personal information will be principally responsible for your personal information. In the event of any conflict between the terms of this Privacy Notice and any prior notice, this Notice shall take precedence.
This Privacy Notice explains how, when, and why we collect and use your personal information, including:
- When you access any of our websites or mobile applications, regardless of how you access or use the website, whether via personal computers, mobile devices or otherwise
- When you, directly or as a representative of a company, apply for or purchase an insurance policy underwritten by us
- When you or someone on your behalf submits or notifies us of a claim against any of our policies or policyholders
- When you purchase an insurance policy from a third-party insurance company that enters into a reinsurance arrangement with us, which is referred to as “reinsurance”
It is also important that you show this Privacy Notice to any other person who is insured under your insurance policy and whose personal information may be shared with us as a result. This Privacy Notice is not intended to override the terms of any insurance policy or contract you have with us, nor rights you are afforded under applicable privacy and data protection laws.
Certain rights, requirements and disclosures in this Privacy Notice may be subject to exemption or otherwise may not apply to you based, for example, on applicable privacy and data protection laws or regulations. Specifically:
- If you reside in the United Kingdom (U.K.) or the European Economic Area (EEA), it is important that you review the section called “Additional Information Regarding Individuals in the U.K./EEA”
- If you reside in the United States (U.S.) and are defined as a “consumer” under or otherwise protected by applicable U.S. data privacy laws, it is important that you review the section called “Additional Information Regarding U.S. Consumers”
This Privacy Notice does not apply to the practices of third-parties, including our third-party partners and/or advertisers. When you access a third-party’s website through links on our websites, information collected from you by others on those third-party websites, are governed by those entities’ privacy policies. Please read such third-party’s privacy policies carefully.
What Personal Information Do We Collect?
When we use the term “personal information,” we mean any information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with relating to an identified or identifiable natural person. An identifiable natural person is one who can be identified, directly or indirectly, by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.
Personal information is sometimes referred to as personal data or personally identifiable information, depending on the applicable privacy or data protection law.
Certain pieces of information that are not personal information include publicly available information, de-identified information or aggregate information. By “aggregate information” or “de-identified information,” we mean information that does not allow us to identify or contact a specific individual. For example, the number of users of our website is aggregate information that does not reveal who those users are.
Data Types and Collection Purpose
Applicants and Policyholders
To provide insurance quotes, issue insurance policies, and administer your insurance, we collect and process personal information about you or others that you may provide to us. If you do not provide the information we need, we may not be able to offer you a quote or provide our services to you. If you subsequently revoke or limit our use of your personal information, we may have to cancel our services. The types of personal information we collect may include:
- Individual details – Name, address, gender, marital status, date of birth, nationality, marketing preferences, vehicle details, employment information, and background check information
- Identification details – Identification numbers issued by government bodies or agencies, including your driver’s license number
- Credit and anti-fraud data – Credit history, credit score, sanctions, and criminal offenses and convictions, and information from various anti-fraud databases related to you
- In certain circumstances and when necessary for the transaction, personal data that may be considered sensitive data with added protections in certain jurisdictions, such as:
- Data concerning:
- your health
- sexual orientation, and
- criminal offenses and convictions
- Social security, driver’s license, state identification card, or passport number
- Account log-in, financial account, debit card, or credit card number in combination with any required security or access code, password, or credentials allowing access to an account
- Precise geolocation
- Contents of mail, email, and text messages not directed to Clearbrook
- Racial or ethnic origin, religious or philosophical beliefs, or union membership
- Data concerning:
Claimants
In order to receive and process claims, we need to collect and process personal and claims information about you. If you do not provide the information we need, we may not be able to handle the claim.
The types of personal information may include:
- Individual details such as name, address, bank account details, and vehicle details
- Identification details such as government or agency-issued identification numbers, including your driver’s license number
- Credit and anti-fraud data such as credit history, credit score, sanctions, criminal offenses and convictions, and information from various anti-fraud databases related to you
- Sensitive personal information – In some jurisdictions, certain categories of personal information may have additional protection under applicable data protection laws. What is considered sensitive personal information varies by jurisdiction but may include personal information revealing racial or ethnic origin, political opinions, trade union membership, genetic data, biometric data for purposes of uniquely identifying you, or data concerning health, and sexual orientation.
- Claims Information – Information about previous and current claims (including other unrelated insurances), which may include data concerning your health (e.g., injuries and relevant pre-existing conditions), relevant criminal offenses and convictions, or other sensitive personal information.
Business Partners
If you are a business partner, we may collect your business contact details. We may also collect information about your professional expertise and experience. We may also collect online identifiers and information about your internet activity when you browse our websites. We may also collect audio, electronic, visual, or biometric data, depending on how we interact with you, such as if you attend a webinar or enter our offices.
Website and Mobile Application Users
If you are a website or mobile application user, you may voluntarily provide us with personal information (e.g., to contact us). You can visit the website without revealing who you are or providing any personal information about yourself. However, there will be times, such as when you request information or a publication from us through the website, when we will need to obtain personal information from you or about you. We may collect this personal information through various forms and in various places on the website, including application forms, contact us forms or when you otherwise interact with the website. Additionally, we may also make certain online services available, such as an online portal that permits our customer account holders to access their business accounts.
We and our third-party service providers may use a variety of technologies that automatically (or passively) store or collect certain information whenever you visit or interact with the website based on your use of the website (“usage information”). This usage information may be stored or accessed using a variety of technologies that may be downloaded to your personal computer, browser, laptop, tablet, mobile phone or other device whenever you visit or interact with our website. You may have other options regarding tracking and/or targeting. Please see the section on “Cookies and Similar Technologies” in this Privacy Notice for further information.
We may, from time to time, supplement the information we collect directly from you on the website with outside records from third parties for various purposes, including to enhance our ability to serve you, to tailor our content to you and to offer you opportunities that may be of interest to you. We will apply this Privacy Notice to such supplemental information, and where such supplemental information amounts to personal information (and/or the combined information amounts to personal information), it will be treated as personal information.
When Do We Collect Your Personal Information?
Applicants and Policyholders
We will collect your personal information:
- Directly from you when you apply for an insurance policy
- From third parties such as an intermediary (e.g., an insurance broker), other third-party insurance company (e.g., if you are a policyholder with an insurance company that has a reinsurance arrangement with an Clearbrook Group company) or your employer where, for example, they apply for an insurance policy under which you will be a beneficiary
- From other sources (e.g., credit reference agencies and government agencies) and other public sources where necessary to, for example, comply with applicable sanctions and anti-money laundering laws
Claimants
We will collect your personal information:
- When you or a third party (e.g., your employer or attorney) notifies us of a claim either directly or through an intermediary (e.g., an insurance broker or third-party claims administrator) or other third-party insurance company (e.g., if you are a policyholder with an insurance company that has a reinsurance arrangement with an Clearbrook Group company)
- From other sources (e.g., credit reference agencies and government agencies) and other public sources where necessary to, for example, validate the claim or comply with applicable sanctions and anti-money laundering laws
Business Partners and Website Users
We will collect your personal information:
- Where you or your employer provides your contact or other information to us while working with us, either directly as a business partner or as a representative of your company
- Where you attend meetings, events or conferences that we organize or sponsor
- Where you visit and/or contact us through our website or one of our online portals
How We Use Your Personal Information
Applicants and Policyholders
To provide insurance quotes and policies, administer your insurance, and provide other services, we may use your personal information:
- To consider an application for an insurance policy, assess, evaluate, and manage risk, and, where applicable, provide you with insurance coverage
- To manage and administer insurance policies (including dealing with your queries) with you or your employer
- For reinsurance purposes
- To improve our insurance products and services, to carry out market research, to perform data analytics, for general risk modeling purposes, for transferring books of business, company sales and reorganizations, and for statistical analyses
- For the prevention and detection of fraud, money laundering or other crimes
Claimants
To receive and handle applicable claims, we may process your personal information for the following purposes:
- For claims processing, including assessing and evaluating the merits of a claim, and to pay a settlement
- For statistical analyses
- For the prevention and detection of fraud, money laundering or other crimes
Business Partners
As part of our business activities, we may process your personal information for the following purposes:
- To manage our relationship with you and to, for example, invite you to events
- To administer our contract with you or your employer
Website Users
As part of our business activities, we may process your personal information for the following purposes:
- To improve the website or our services, to customize your experience on the website, or to serve you specific content that is relevant to you
- To contact you in connection with your use of the website and, at our discretion
- For internal business purposes, including to help us understand how our website is navigated and used
Job Applicants
When you submit personal information in connection with a career opening or by submitting a resume through the website, we will use that information in accordance with the HR Privacy Notice posted on our website and only for the purpose of evaluating your application.
How We Disclose Your Personal Information
We may disclose the personal information we have collected about you to provide our services and comply with legal obligations with certain third parties, as described below. We do not disclose your personal information with third parties for their direct marketing purposes unless you have consented to such disclosure.
Clearbrook Group Affiliates
We may disclose your personal information with our affiliated entities to assist in the delivery of services to you, and for other purposes authorized under this Privacy Notice. We also reserve the right to disclose and transfer such personal information. Transfers between Clearbrook Group entities are covered by intra-organizational agreements, which provide specific requirements designed to ensure your personal information receives adequate protection whenever it is transferred within Clearbrook Group.
Third-party Intermediaries
We may disclose your personal information to intermediaries (e.g., brokers, managing general agents, third-party administrators) and other (re)insurers, in and outside of the U.K./EEA, to assist us in managing our business.
Third-Parties Providing Services On Our Behalf
We may use third-party processors, service providers and/or vendors to perform certain services on our behalf, such as technical support and back-office services, loss adjustors and claims experts, hosting services and website activity tracking and analytics. We may also disclose your personal information to our professional advisors (e.g., attorneys and other professional services firms), in and outside of the U.K./EEA. Transfers to our third-party intermediaries and service providers are protected by contractual agreements that require an adequate level of data protection.
Judicial, Regulatory, and Law Enforcement Bodies
We may disclose your personal information to judicial, regulatory, and law enforcement bodies, for reasons including but not limited to: (1) satisfying any applicable law, regulation, subpoenas, governmental requests or legal process if in our good faith opinion, such disclosure is required or permitted by law; (2) protecting and/or defending our rights, property and/or interests (including the enforcement of the Terms and Conditions of any of our websites); (3) protecting the safety, rights, property or security of Clearbrook Group or any third party where we are legally required or advised to do so; and (4) detecting, preventing or otherwise addressing fraud, security or technical issues. Such disclosures may be carried out without notice to you.
Corporate Transactions
Subject to applicable law, we reserve the right to transfer some or all personal information in our possession to a successor organization in the event of a merger, acquisition, bankruptcy, or other sale or transfer of all or a portion of our assets. If any such transaction occurs, the purchaser will be entitled to use and disclose the personal information collected by us in the same manner that we are able to, and the purchaser will assume the rights and obligations regarding personal information as described in this Privacy Notice.
Your Rights Regarding Your Personal Information
Legal Basis for Processing Personal Data of Individuals in the U.K./EEA
We will only use your personal information for the purposes outlined in this Privacy Notice and as further detailed in the section below, unless we need to use it for another purpose that is compatible with the original purpose. If we need to further process your personal information for a purpose that is not compatible with the original purpose for collection, we will notify you and provide an explanation of the legal basis that allows us to do so.
| Processing Purpose | Legal Basis for Processing |
|---|---|
| To consider an application for an insurance policy, assess, evaluate, and manage risk, and where applicable, provide you with insurance coverage | The processing is necessary to perform a contract or enter into a contract with you (e.g., the insurance policy) |
| To comply with legal and regulatory obligations | The processing is necessary for us to comply with legal and regulatory obligations |
| For claims processing, which includes assessing and evaluating the merits of a claim and, where relevant, paying a settlement | The processing is necessary to support our legitimate interests in managing our business (or those of a third party), provided such interests are not overridden by your interests and rights |
| For reinsurance | The processing is necessary to support our legitimate interests in managing our business (or those of a third party), provided such interests are not overridden by your interests and rights |
| For statistical analysis | The processing is necessary to support our legitimate interests in managing our business (or those of a third party), provided such interests are not overridden by your interests and rights |
| To improve our insurance products and services, to carry out market research, to perform data analytics, for general risk modeling purposes, for transferring books of business, company sales and reorganizations, and for statistical analyses | The processing is necessary to support our legitimate interests in managing our business (or those of a third party), provided such interests are not overridden by your interests and rights |
| For the prevention and detection of fraud, money laundering or other crimes | The processing is necessary for us to comply with legal and regulatory obligations or as authorized by applicable law |
| To manage our relationship with you | The processing is necessary to perform a contract or enter into a contract with you The processing is necessary to support our legitimate interests in managing our business (or those of a third party), provided such interests are not overridden by your interests and rights |
| To improve the website or our services, to customize your experience on the website, or to serve you specific content that is relevant to you | The processing is necessary to support our legitimate interests in managing our business (or those of a third party), provided such interests are not overridden by your interests and rights |
| To contact you regarding changes to the website or the website policies | The processing is necessary to support our legitimate interests in managing our business (or those of a third party), provided such interests are not overridden by your interests and rights |
| For internal business purposes, including to help us understand how our website is navigated and used | The processing is necessary to support our legitimate interests in managing our business (or those of a third party), provided such interests are not overridden by your interests and rights |
| To evaluate your application and qualifications where you submit personal data in connection with a career opening or by submitting a resume through our website | The processing is necessary to support our legitimate interests in managing our business (or those of a third party), provided such interests are not overridden by your interests and rights |
Criminal Offenses and Convictions Data and Special Categories of Personal Data of Individuals in the U.K./EEA
Criminal Offenses and Convictions Data
We will only process personal information relating to criminal offenses and convictions for the following purposes: (1) to underwrite risk appropriately, calculate a quote or policy renewal, and in the context of motor insurance, to risk assess any person who will be driving the insured vehicle (e.g., a risk assessment); (2) for fraud detection or prevention; or (3) where required for claims handling. We will only carry out such processing where it is authorized by applicable law.
Special Categories of Personal Information
Where we process your special categories of personal information, as defined by applicable privacy and data protection law, for any of the above purposes, we will only do so where: (1) you have given explicit consent to the processing of your special categories of personal information for these purposes – which you may withdraw at any time; (2) the processing is necessary to protect your vital interests (or those of a third party); (3) you have manifestly made your special categories of personal information public; (4) the processing is necessary for the establishment, exercise or defense of legal claims; or (5) the processing is necessary for reasons of substantial public interest on the basis of applicable law.
What additional rights do you have if you are in the U.K./EEA?
If you are in the U.K./EEA, you have several rights in relation to your personal information under applicable privacy and data protection law, which may be subject to certain limitations and restrictions. We aim to respond to any valid requests within one month unless it is particularly complicated, or you have made repeated requests, in which case we aim to respond within three months. We will inform you of any such extension within one month of receipt of your request, together with the reasons for the delay. You will not be charged a fee to exercise any of your rights unless your request is clearly unfounded, repetitive or excessive, in which case we will charge a reasonable fee in the circumstances or will refuse to act on the request.
| Your Right | What It Means |
|---|---|
| Right to withdraw consent | If we are processing your personal information on the legal basis of consent, you are entitled to withdraw your consent at any time. Please see our contact details below. However, the withdrawal of your consent would not invalidate any processing we carried out prior to your withdrawal and based on your consent. |
| Right of access | You can ask us to confirm whether we are processing your personal information and request a copy of that personal information. You can also ask that we provide additional information, including:
|
| Right to rectification | You have the right to request that we correct any inaccuracies in the personal information we hold about you and to complete any personal information that is incomplete. |
| Right to erasure (“right to be forgotten”) | You have the right to request that your personal information be deleted in certain circumstances, including any of the following reasons:
|
| Right to restrict processing | You can ask that we restrict the processing of your personal information (i.e., keep but not use it) for any of the following reasons:
|
| Right to data portability | Where you have provided personal information to us, you have a right to receive such personal information back in a structured, commonly used and machine-readable format. Where one or both of the following conditions are met, you also have the right to have your personal information transmitted to a third-party data controller without hindrance:
|
| Right to object | You have a right to object where we are processing your personal information:
|
| Automated decision-making | You have a right not to be subject to decisions based solely on automated processing (including profiling) when such decisions produce legal effects concerning you or similarly significantly affects you other than where the decision is any of the following:
|
| Right to complain | If you are not satisfied with our use of your personal information or our response to any request made by you to exercise any of your rights, you have the right to lodge a complaint with the local data protection supervisory authority at any time. |
To exercise any of your applicable rights, please contact us at the email listed below or visit Clearbrook Group Personal Information Query to submit your request.
Transfers of personal information outside of the U.K./EEA
If you are a resident of the U.K./EEA, the personal information we collect from you may be transferred to and stored at locations outside of the U.K./EEA (including Bermuda and the United States) for the purposes described above.
Transfers within Clearbrook Group are covered by a data transfer agreement designed to ensure the protection of your personal data when it is transferred outside of the U.K./EEA, in accordance with Article 46(2) (c) of the General Data Protection Regulation ((EU) 2016/679) (“GDPR”) (“Model Clauses”), and equivalent provisions in the U.K. GDPR.
Transfers to service providers and other third parties will comply with applicable data protection laws (e.g., under Model Clauses or the EU) in accordance with applicable privacy and data protection law. Our websites are hosted in the U.S.
We may also transfer your personal information outside of the U.K./EEA when required by law (e.g., if we receive a request from a foreign judicial, regulatory or law enforcement body). Such transfers will be made in accordance with applicable data protection laws.
If you would like further information about the safeguards we have implemented, please contact us using the contact details below.
U.S. Consumer Privacy Rights
The provisions of this section apply to residents of any U.S. state that has implemented a consumer privacy law, and who meet the definition of consumers, or who are otherwise entitled to the protection of the applicable U.S. state privacy law.
The personal information about you that we collect includes personal information within the categories of data in the table below. These categories also represent the categories of personal information that we have collected over the past 12 months.
Note: the categories listed below are defined by applicable U.S. state privacy law. Inclusion of a category in the list below indicates only that, depending on the services and products we provide you, we may collect or disclose some information within that category. It does not necessarily mean that we collect or disclose all personal information listed in a specific category for applicable consumers.
We do not sell or share personal information for monetary or other valuable considerations, as those terms are defined under applicable U.S. state privacy law, nor do we intend to do so. We also have not done so for the last 12 months.
| Category | Source | Purpose of Processing | Types of Third Parties Shared With |
|---|---|---|---|
| Identifiers such as 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 | Collected directly from you, your agent or our service providers | This data is processed in connection with a number of our operational functions to provide you with services, including to assess and evaluate risk, to issue policies and to administer claims. It is also processed in order to help manage and administer your account, as well as to detect security incidents, protect against malicious, deceptive, fraudulent or illegal activity, for compliance management, data analytics and technological development of our systems. In addition, this data is also used for marketing purposes, including offering you products that may interest you through both direct and partner advertising. | Affiliates, service providers and intermediaries |
| Information that identifies, relates to, describes, or is capable of being associated with a particular individual, including, but not limited to, 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 | Collected directly from you, your agent, consumer reporting agencies, our service providers or public records | This data is processed in connection with a number of our operational functions to provide you with services, including to assess and evaluate risk, to issue policies and to administer claims It is also processed in order to help manage and administer your account, as well as to detect security incidents, protect against malicious, deceptive, fraudulent or illegal activity, for compliance management, data analytics and technological development of our systems. In addition, this data is also used for marketing purposes, including offering you products that may interest you through both direct and partner advertising. | Affiliates, service providers and intermediaries |
| Characteristics of classes protected under federal or California law, including familial status, disability, sex, national origin, religion, color, race, sexual orientation, gender identity and gender expression, marital status, veteran status, medical condition, ancestry, source of income, age or genetic information | Collected directly from you, your agent, consumer reporting agencies or our service providers | This data is processed in connection with a number of our operational functions to provide you with services, including to assess and evaluate risk, to issue policies and to administer claims. It is also processed in order to help manage and administer your account. | Affiliates, service providers and intermediaries |
| Commercial information, including records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies | Collected directly from you, your agent, consumer reporting agencies, our service providers or public records | This data is processed in connection with a number of our operational functions to provide you with services, including to assess and evaluate risk, to issue policies and to administer claims. It is also processed in order to help manage and administer your account, as well as to detect security incidents, protect against malicious, deceptive, fraudulent or illegal activity, for compliance management, data analytics and technological development of our systems. In addition, this data, as well as information regarding your purchasing tendencies obtained from our business partners, is also used for marketing purposes, including offering you products that may interest you through both direct and partner advertising. | Affiliates, service providers and intermediaries |
| Internet or other electronic network activity information, including, but not limited to, browsing history, search history, and information regarding a consumer’s interaction with a website, application or advertisement | Collected directly from you or from our service providers, via cookies or similar technologies | This data is processed for marketing purposes, including offering you products that may interest you through both direct and partner advertising. It is also processed in order to help manage and administer your account, as well as to detect security incidents, protect against malicious, deceptive, fraudulent or illegal activity, for compliance management, data analytics and technological development of our systems | Affiliates, service providers and intermediaries |
| Geolocation data | Collected directly from you or from our service providers, via cookies or similar technologies | This data is processed for marketing purposes, including offering you products that may interest you through both direct and partner advertising. It is also processed in order to help manage and administer your account, as well as to detect security incidents, protect against malicious, deceptive, fraudulent or illegal activity, and for compliance management. | Affiliates, service providers and intermediaries |
| Audio, electronic, visual, thermal, olfactory or similar information | Collected directly from you, your agent or our service providers | This data (e.g., voice signatures for e-applications as well as recordings of customer service calls) is processed in connection with a number of our operational functions to provide you with services, including policy issuance and to administer claims. It is also processed in order to help manage and administer your account, as well as to detect security incidents, protect against malicious, deceptive, fraudulent or illegal activity, and for compliance management. | Affiliates, service providers and intermediaries |
| Professional or employment-related information | Professional or employment-related information | This data is processed in connection with a number of our operational functions to provide you with services, including to assess and evaluate risk, to issue policies and to administer claims. It is also processed in order to help manage and administer your account, as well as to detect security incidents, protect against malicious, deceptive, fraudulent or illegal activity, and for compliance management. | Affiliates, service providers and intermediaries |
| Inferences drawn from any of the above categories of information to create a profile about a consumer that reflects the consumer’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities and aptitudes | Collected from consumer reporting agencies, our partners or our service providers | This data is processed in connection with a number of our operational functions to provide you with services, including to assess and evaluate risk, to issue policies and to administer claims. It is also processed in order to help manage and administer your account, as well as to detect security incidents, protect against malicious, deceptive, fraudulent or illegal activity, for compliance management, data analytics and technological development of our systems | Affiliates, service providers and intermediaries |
Privacy Rights Under Applicable U.S. State Privacy Law
Residents of certain U.S. states may have the rights described below with respect to their personal information. We may also provide these rights even if we are not required to do so. Subject to certain conditions and limitations, you may have the following rights with respect to personal information about you:
- Right to know or request access – You may be entitled to request that we disclose, to you, the personal information we have collected about you, the categories of sources from which the information was collected, the purposes of collecting the information, the categories of third parties we have shared the information with, and the categories of personal information that have been shared with third parties for a business purpose. Data retained solely for data backup purposes is generally excluded.
- Right to request data portability – In some instances, you may have the right to request to receive the personal information about you in a portable and readily usable format. Before providing this information, we must be able to verify your identity. Data retained solely for data backup purposes is generally excluded.
- Right to request deletion – Subject to certain conditions, you may be entitled to request that we delete personal information about you. We will not delete personal information about you when the information is required to fulfill a legal obligation, is necessary to exercise or defend legal claims, or where we are required or permitted to retain the information by law. For example, we cannot delete information about you while continuing to provide you with insurance products or where required to be retained for regulatory purposes. Data retained solely for data backup purposes is generally excluded.
- Right to correct inaccurate information – You may be entitled to request correction of inaccurate personal information in the situations set forth by applicable data protection law and upon receipt of a verifiable request. In complying with your request to correct, Clearbrook Group will notify third parties who may have received your personal information to correct your information, as required subject to certain legal exceptions.
- Right to request to limit use of Sensitive Personal Information – You may be entitled to request that Clearbrook Group limit the use of your sensitive personal information to fulfill a specified purpose (i.e., to provide services), however, we only use your sensitive personal information for operational purposes as allowed by law.
- Right to non-discrimination/non-retaliation – As defined under applicable U.S. Privacy Law, you have a right to non-discrimination/non-retaliation in the Services or quality of Services you receive from us for exercising your rights. We may, however, charge a different rate or provide a different level of Service to the extent permitted by law.
If you would like to appoint an authorized agent to make a request on your behalf, and that agent is not already authorized to access your account in your profile, you may be asked to provide a notarized power of attorney or a letter from your attorney.
To exercise any of your applicable rights, please contact us at the email listed below or visit Clearbrook Group Personal Information Query to submit your request. Please note that we may ask you to verify your identity before responding to your requests.
California “Shine the Light” Law
Under Section 1798.83 of the California Civil Code, residents of California have the right to request from a business, with whom the California resident has an established business relationship, certain information with respect to the types of personal information (as defined by California law) the business shares with third parties for those third parties’ direct marketing purposes, and the identities of the third parties with whom the business has shared such information during the immediately preceding calendar year. To exercise your rights, you may make one request each year by emailing us as described below with “Request for California Privacy Information” in the subject line and in the body of your message. Please be sure to provide enough information to properly identify you and/or the members of your family.
Cookies and Similar Technologies
Our websites utilize standard technologies called “cookies” and similar technologies, such as tracking pixels, to understand how you navigate through and interact with our website to improve user experience, for performance and analytics, and to improve our content, products and services. We also use cookies and similar technologies for purposes of marketing and advertising, including interest-based advertising. For more information on interest-based advertising, see the “Interest-Based Advertising” section.
A “cookie” is a small file placed on the hard drive of your computer. A browser sends cookies to a server when the browser makes a connection to the server (for example, when requesting a webpage from the same domain that created the cookie). The purpose of cookies is to remember the browser over time and to distinguish one browser instance (or user) from all others. Some cookies and other technologies may track personal information previously entered by a user on the website. Most browsers allow you to control cookies, including whether to accept them or not, and explain how to remove them. Cookies can remember login information, preferences and similar information.
There are generally four categories of cookies. We may use all four categories of cookies on our websites. You can find out more about each category below:
- Strictly necessary cookies – These cookies are essential, as they enable you to move around our sites and use features, such as accessing logged-in or secure areas and documenting certain system and browser preferences (including cookie-based opt-out preferences).
- Performance cookies – These cookies collect information about how you have used our sites; for example, information related to the unique username you have provided. We also use cookies to track aggregate site usage and experiment with new features and changes on the site. The information collected is used to improve how our sites work.
- Functionality cookies – These cookies allow us to remember how you have logged in to an account on our sites. These cookies also allow us to tailor our sites to provide enhanced features and content for you. The information these cookies collect may be anonymous, and they are not used to track your browsing activity on other sites or services.
- Targeting cookies – Clearbrook Group and our authorized advertising partners may use these types of cookies to deliver advertising that is relevant to your interests. These cookies can remember that your device has visited a site and may also be able to track your device’s browsing activity on other websites. This information may be shared with third parties we have engaged with, such as advertisers and/or advertising networks, to deliver the advertising, and the cookies may be used to help measure the effectiveness of an advertising campaign.
Cookies, as well as other tracking technologies such as HTML5 local storage and Local Shared Objects (such as “Flash” cookies) and similar mechanisms, may record information such as a unique identifier, information you enter in a form, IP address and other categories of data.
We may also use web beacons or “pixels,” and in certain circumstances may collect IP addresses, screen resolution and browser software and operating system types, clickstream patterns, dates and times that our site is accessed, and other categories of data.
If you want to block the use and saving of cookies from our websites onto your computer’s hard drive, you should take the necessary steps within your web browser’s settings to block all cookies from the website and external serving vendors. Please note that if you choose to erase or block your cookies, certain parts of our websites may not function correctly. For information on how to disable cookies, refer to your browser’s documentation.
You may opt-out of the use of third-party cookies and tracking technologies used for targeted advertising by clicking here: Do Not Sell or Share My Personal Information.
Opting Out
- To stop Google from collecting your analytical data, use the following link to opt out of all Google analytics: https://tools.google.com/dlpage/gaoptout
- To opt-out of Meta from using information it collects or receives from us and elsewhere on the internet to provide measurement services, target, and deliver ads, use this link: http://www.aboutads.info/choices
- You may review Vimeo’s privacy policy here: https://vimeo.com/privacyYou may review Twitter’s privacy policy here: https://twitter.com/en/privacy and you may review Twitter’s privacy options here: https://help.twitter.com/en/safety-and-security/privacy-controls-for-tailored-ads You may review LinkedIn’s privacy policy here: https://www.linkedin.com/legal/privacy-policy and you may review LinkedIn’s privacy options here: https://www.linkedin.com/help/linkedin/answer/a1342443/manage-your-advertising-preferences?lang=en To opt out of all cookies, please use your browser’s settings to block them. For more information, see https://www.aboutcookies.org/
Interest-Based Advertising
Interest-based advertising is advertising that is targeted to you based on your web browsing and app usage over time and across websites or apps. You have the option to restrict the use of information for interest-based advertising and to opt out of receiving interest-based ads.
The opt-outs for interest-based advertising require that strictly necessary cookies are not blocked by the settings in your web browser. We support the Self-Regulatory Principles for Online Behavioral Advertising of the Digital Advertising Alliance in the U.S., the Canadian Digital Advertising Alliance in Canada, and the European Digital Advertising Alliance in the EU. If you live in the United States, Canada or the European Union, you can visit Ad Choices(U.S.), Your Ad Choices (Canada) or Your Online Choices (EU) to find a convenient place to opt out of interest-based advertising with participating entities for each region. These websites also provide detailed information about how interest-based advertising works. Opting out does not mean that you will no longer receive advertising from us or when you use the internet. It just means that the data collected from our website will not be used for interest-based advertising and that the advertising you see displayed on websites will not be customized to your interests.
Protecting Your Personal Information
We implement technical and organizational security measures designed to secure and protect personal information. Please note, however, that we cannot fully eliminate security risks associated with the storage and transmission of personal information. Our information security program is maintained and regularly assessed by our Chief Security Officer, who reports regularly to senior management.
Retaining Your Personal Information
We will retain your personal information for as long as is necessary to fulfill the purposes for which we obtained the personal information, including to provide our services, or for such longer period as may be required or permitted by applicable law. We will also retain your personal information as necessary to comply with our legal obligations, requests from law enforcement or insurance regulatory authorities, or warrants, subpoenas, discovery requests, judicial orders, or other administrative, criminal, or civil legal processes. We will also retain your personal information as necessary to protect our legal or beneficial interest in insurance policies, resolve disputes, and enforce our agreements and policies. We use the following criteria to set our retention periods: (1) the duration of our relationship with you; (2) the purposes for processing your personal information and associated legal bases; (3) the existence of a legal obligation as to the retention period; (4) our contractual obligations; and (5) the advisability of retaining the information in light of our legal position (for example, in light of applicable statutes of limitations, litigation or regulatory investigations).
Other Important Information
Access To and Correction of Your Personal Information
Our business partners that have logins to our online portals may access and update certain personal information within their account. You may also authorize someone to exercise the above rights on your behalf.
As permitted by law, certain data elements may not be subject to access, modification, portability, restriction and/or deletion.
Withdrawing Consent
Where consent is the basis of processing, you may at any time withdraw the consent you provided for the processing of your personal information for the purposes set forth in this Privacy Notice by contacting us as described in the Contact Us section below, if we are not required by applicable law or professional standards to retain such information. Please note that if you do not provide consent, if you withdraw your consent or object to processing, or if you choose not to provide certain personal information, we may be unable to provide some services to you.
Marketing Opt-Out
If you would like to stop receiving newsletters or other marketing or promotional messages, notifications, or updates, you may do so by following the unsubscribe instructions that appear in these email communications, or you may contact us as described in the Contact Us section below to opt out of direct marketing, if applicable. Please be advised that you may not be able to opt out of receiving certain service or transactional messages from us, including legal notices. For opting out of Cookies, please review cookies section above.
Children’s Privacy
Our websites and services are not targeted at children, as defined by local law, and we do not knowingly collect any personal information from children unless the child’s information is relevant for an insurance transaction. We will delete any personal information we determine to have been collected from a child or user under the applicable age of consent. If you are a parent or guardian of a child under the relevant digital age of consent and believe he or she has disclosed personal information to us, please contact us as described below.
Third-Party Content and Links to Third-Party Websites
Our websites may contain content that is supplied by a third party, and those third parties may collect usage information and your device identifier when webpages from the website are served to you. Our website may also contain links to third parties. We are not responsible for the data collection and privacy practices employed by any of these third parties on their websites. We encourage you to review their privacy policies. Our websites may include social network sharing widgets that may provide information to their associated social networks or third parties about your interactions with our webpages that you visit, even if you do not click on or otherwise interact with the plug-in or widget. Information is transmitted from your browser and may include an identifier assigned by the social network or third party, information about your browser type, operating system, device type, IP address, and the URL of the webpage where the widget appears. If you use social network tools or visit social networking sites, we encourage you to read their privacy disclosures to learn what information they collect, use and share.
Updates to Privacy Notice
This Privacy Notice is reviewed and updated periodically. The most recent version of the Privacy Notice is reflected by the version date located at the bottom of this page. We encourage you to review this Privacy Notice often to stay informed of how we may process your information.
Do Not Track
Please note that our websites do not alter their behavior or use practices when we receive a “Do Not Track” signal from browser software. You can learn more about Do Not Track here: https://allaboutdnt.com/ or here: Global Privacy Control (GPC).
Contact Us
If you have any question about this Privacy Notice or the practices described in it, or would like to contact us about any rights you may have with regards to your personal information, you can contact us via the Personal Information Query listed above, or postal mail as follows:
Privacy Office
Clearbrook Group
P.O. Box 469011
San Antonio, TX 78246
800-470-7958
