California Consumer Privacy Act (CCPA) Request
Phone: 833.395.9288; Attn: Gail Wolfe
Privacy Statement – California
This privacy notice for California residents applies solely to visitors, policyholders, and others who reside in the state of California (“consumers”, “you” or “your”). We adopt this notice to comply with the California Consumer Privacy Act of 2018 (“CCPA”).
Information We Collect
Our goal is to professionally and respectfully serve the personal, professional, and business insurance needs of our policyholders and claimants. The information that you provide us when you apply for insurance, search our website, or when you file a claim helps us achieve that goal. It enables us to provide valuable coverage to you or to service your claim promptly and fairly.
To that end, some of the information we collect, or that you provide us is identified as personally identifiable information, such as information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or device. Please be aware that the information we collect does overlap with other categories. In particular, we have collected the following categories of personal information from consumers within the last twelve (12) months:
- Identifiers: We may collect information that identifies you, such as your name, postal address, Internet Protocol (IP) address, email address, account name, social security number, driver’s license number, or other similar identifiers.
- Personal information categories: We may collect your name, birth date, signature, social security number, physical characteristics or description, address, telephone 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, claim history, or any other financial information and medical information.
- Protected classification characteristics: We may collect age, race, color, national origin, marital status, medical condition, physical or mental disability, gender, or veteran or military status.
- Commercial information: We may collect records of personal information, or products or services purchased with Pharmacists Mutual or any of our subsidiaries, or by purchasing a list from pharmacy or dental state associations.
- Biometric information: We do not collect biometric information.
- Geolocation data: We use geofencing technology with our digital marketing, which is a location-based service that we use to engage our designated audience by sending relevant ads to smartphone users who enter a pre-defined location or geographical area.
- Sensory data: We may collect audio data for recorded statements and for quality control purposes. We may also collect visual and electronic data. We do not collect thermal or other similar information.
- Professional or employment-related information: We may collect current or past job history.
- Inferences drawn from other personal information: We may collect information from behavioral targeting, which refers to the content that is searched online that aligns with insurance policy and/or related websites that you visit.
We may obtain the categories of personal information listed above from the following categories of sources:
- Directly from you or your broker. For example, depending on the insurance for which you are applying for, we collect information from insurance applications and questionnaires in the underwriting process. We would also collect information directly from you in our claims investigations.
- Directly or indirectly from activity on our website (phmic.com) or through our subsidiary website https://pmca.agency. For example, from submissions through our website or website usage details, which are collected automatically.
- From third parties that interact with us in connection with the services we perform. An example is collecting motor vehicle reports from consumer reporting agencies, or disclosing information for wildfire risk management solutions before, during, and after a wildfire event.
Personal information does not include publicly available information, de-identified or aggregate consumer information, and personal information covered by sector-specific privacy laws, including the Fair Credit Reporting Act, the Gramm-Leach-Bliley Act, the California Financial Information Privacy Act, and the Driver’s Privacy Protection Act of 1994.
Use of Personal Information
We may use or disclose the personal information we collect for one or more of the following business purposes:
- To fulfill the objectives for which the information is provided. For example, when you provide us with payroll information to complete your workers’ compensation audit.
- To provide you with information, products, or services that you request from us. For example, the information you provide to us on the insurance application and questionnaires.
- To provide you with our Risk Management email alerts or marketing notices to update you on our products or services that may be of interest to you.
- To carry out our obligations and enforce our rights arising out of our insurance policy contract.
- To improve our website and present additional content that may be of interest to you.
- For analysis and product development to continually offer products that remain current or relevant with the professions we serve.
- To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.
- As described to you when collecting your personal information or as otherwise set forth in the CCPA.
We will not collect additional categories of personal information or use the personal information we collected for materially different, unrelated purposes without providing you notice.
Sharing Personal Information
We may disclose your personal information to a third party for a business purpose. When we disclose personal information for a business purpose, we enter a contract that describes the purpose and requires the recipient to keep both that personal information confidential and not use it for any purpose except in performing the contract.
In the preceding twelve (12) months, we may have disclosed the categories of personal information for a business purpose to our affiliates, third party service providers, and third parties to whom you authorize us to disclose your personal information in connection with products or services we provide to you.
In the preceding twelve (12) months, we have not sold any of your personal information.
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
You have the right to request that we disclose certain information to you about our collection and use of your personal information over the past twelve (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 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.
- If we sold or disclosed your personal information for a business purpose, two separate lists disclosing:
- Sales, identifying the personal information categories that each category of recipient purchased; and
- Information shared for a business purpose, identifying the personal information categories that each category of recipient obtained.
Deletion Request Rights
You have the right to request that we delete any of your personal information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request to delete your personal information, 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 product 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.
- 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.
- Make other internal and lawful uses of that information that are compatible with the context in which you provided it.
Exercising Access and Deletion Rights
To exercise the access and deletion rights described above, please submit a verifiable consumer request to us by either:
Only you or an authorized user who can 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 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.
- 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 that 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 strive to respond to a verifiable consumer request within 45 days of its receipt. If we require more time we will inform you in writing regarding the reason for the extension. 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.
We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive or repetitive. 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 prior to completing your request.
We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not:
- Deny you products or services
- Charge you different prices or rates for goods or services
- 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
We reserve the right to amend this privacy notice at our discretion and at any time. When we make changes to this privacy notice, we will notify you by mail or through a notice on our website homepage.
If you have any questions or comments about this notice, the ways in which we collect and use your personal information, your choices and rights regarding this notice, or you wish to exercise your rights under California law, please do not hesitate to contact us at:
PM 378-CA 0120
Edition date 1.1.2020