Privacy Policy

Effective: January 26, 2021

1. The Scope of this Policy
2. The Information We Collect
3. How We Use Your Information
4. How We Share Your Information
5. Your Rights and Choices Regarding Your Information
6. How We Store and Safeguard Your Information
7. California Residents Privacy Rights
8. Changes to this Privacy Policy
9. Contact Us

1. The Scope of this Policy

Warner Pacific Insurance Services, Inc. (“Warner Pacific,” “we,” “us” or “our”) is committed to respecting the privacy rights and concerns of all users of the Warner Pacific website where this Privacy Policy is posted (the “Site”), and for all services made available by us (collectively with the Site, the “Service”). As such, we have established and implemented this Privacy Policy to inform visitors to the Site and users of the Service how we use and protect the information we collect. By accessing the Site or using the Service, you consent to our collection, use, storage, deletion and disclosure of information relating to you as set forth in this Privacy Policy. This Privacy Policy is effective as of the date set forth above and is only applicable to the Service and not to any other website that you may be able to access from the Service which may have its own data collection and use practices and policies.

2. The Information We Collect

Types of Identifying Personal Information We Collect

Personal information means information that can be used to identify and contact you. You do not need to submit personal information to access the Service generally. However, you may be required to submit personal information to access certain aspects of the Service.

When you create an account, use our Services, or when you enter information on our Site, we may collect personal information from you, including your:

• First and last name
• Online identifier
• Email address
• Physical address
• Phone numbers
• Username/Password
• Fax numbers
• IP address
• Date of birth
• Social security number
• Driver’s license number or ID card number
• Gender
• Race
• National Origin
• Familial status
• Location information
• Health insurance information
• Health insurance policy number
• Bank account information
• Geolocation information
• Signature
• Employment history
• Education information
• Photograph
• Geolocation information
• Internet or other electronic network activity information

By submitting personal information through the Service, you authorize us to share this personal information for the purposes identified herein, such as responding to user inquiries, processing transactions, providing services, and requesting feedback.

Device Information We Collect

We may also collect non-identifying personal information such as your browser type, domain names, mobile device operating system, when you accessed the Service and from what location you access the Service. This information may be aggregated to measure the number of visits, average time spent, page views, and other statistics about users of the Service. We may use this data to monitor the Service’s performance and to make the Service easier and more convenient to use.

We collect personal information when you create an account through the Service; receive customer or technical support; use our products, such as, benefit recommendations, quoting, our tech tools, employer enrollment, or other services; participate in components of the Service through which you may post content.

3. How We Use Your Personal Information

The personal information you provide to us will allow us to communicate with you and provide the Service to you, depending on the aspects of the Service you utilize. This includes, but is not limited to, handling your enrollment in insurance coverage; customer service questions or issues; alerting you of new products, services, features, or enhancements to the Service; verifying your identity; requesting feedback and upon your consent, connecting you providers, insurance referral networks or affiliates thereof. We may also use your email address as part of the Service in sending you messages about the Service and other general announcements. We keep track of your interactions with us, including but not limited to your activity within the Service. Except as set forth in this Privacy Policy, or unless we have your consent, we will not share your personal information with any person or entity other than those affiliated with us, entities acting on our behalf, and relevant third parties such as those needed to collect and maintain our servers and perform technology and related services.

We may use your personal information with non-personal information that we have collected in a manner such that the end-product does not personally identify you or any other user of the Service. We may make your personal information non-personally identifiable by either combining it with information about other users (aggregating your personal information with information about other users), or by removing characteristics (such as your name or email address) that make the information personally identifiable. This process is known as de-personalizing your information. You grant us a royalty-free, worldwide, perpetual, irrevocable and fully transferable right and license to use your personal information in connection with the creation and development of analytical and statistical analysis tools relating to the use of the customer data we collect in providing the Service (the “Analytical Data”). We are expressly authorized to make any commercial use of the Analytical Data, including without limitation, supplementing our valuation products, sharing the Analytical Data with third parties, and otherwise exploiting the Analytical Data, provided that we do not sell, trade, or otherwise transfer from us any part of the Analytical Data that personally identifies any Service users.

Do Not Track

In compliance with California legislation, AB370, effective January 1, 2014, our practices in responding to “do not track” signals and collecting user information over time and across a network of websites when you visit the Site are as follows: we do not honor the request of “do not track” signals sent by your browser when you visit the Site. Additionally, we may collect user information about your online activities over time and across different websites, or authorize third parties to do so.

Google Analytics

We use third-party service providers such as Google Analytics to help us learn about who visits the Site and what pages are being viewed. For more information about Google Analytics, please visit www.google.com/policies/privacy/partners/. You can opt out of Google Analytics’ collection and use of data generated by your use of the Services by going to http://tools.google.com/dlpage/gaoptout.

Cookies

“Cookies” are small bits of electronic information that a website sends to a visitor’s browser and are stored on the visitor’s hard drive. Like many websites, we employ cookies in certain areas of the Site to allow us to provide information to make your online experience more convenient. For example, when you return to the Site after logging in, cookies provide information to the Site so that the Site will remember who you are on subsequent visits, speeding up or enhancing your experience of the Service by, for instance, tailoring content to you or keeping track of your login name and password. While we may use cookies to track your visit to the Site, this information does not identify you personally and you remain anonymous, even if you have previously submitted personal information to us through the Site or otherwise.

Third parties whose websites are accessible through links on the Site may also use their own cookies when you link to their site or service. We do not control these third parties’ use of cookies and cannot guarantee that they will uphold the same privacy standards as us. We expressly disclaim any and all liability related to the collection, use or disclosure of information by third parties. You should review the privacy policies of any third-party sites that you visit through a link from the Site to understand how these third parties use cookies and the information they collect through cookies. Most cookies are “session cookies” which means that they are automatically deleted at the end of each session. Most browsers are initially set to accept cookies. You can set your browser to notify you when you receive a cookie, giving you a chance to decide whether or not to accept it.

Log Information

Our servers automatically record information that your browser or mobile device sends whenever you visit the Site or use the Service. This information includes, among other things, your Internet Protocol address, mobile device operating system, your browser type and version, which aspects of the Service you use and from where, and when and how long you use them. We use this information to monitor and analyze how users use the Service, to provide customer service and to maintain and improve the Service. We may also collect similar information from emails we may send to you which then help us track which emails are opened and which links are clicked by recipients. The information allows for more accurate reporting and improvement of the Service.

Children’s Privacy

We do not knowingly collect personal information from children under 13 or allow them to create an account through the Site. We take children’s privacy seriously, and encourage parents to play an active role in their children’s online experience at all times.

4. How We Share Your Information

Sharing Your Information

We use your personal information to provide the Service to you, deliver products and services you request, complete transactions, handle your customer service questions or issues, request feedback, and send communications to you about promotions, updates, or special offers from us that may be of interest to you. The personal information uploaded by you through the Service will be shared only with authorized persons to whom you specifically grant access or direct us to share with. We may also use your depersonalized personal information to provide analyses of our users in the aggregate (including Analytical Data subject to the terms of this Privacy Policy) to prospective partners and other third parties. We will also share the personal information we collect from you under the following circumstances, and you expressly authorize us to share your information as follows:

• Service Providers. We may share your personal information with service providers (including our affiliates that provide services on our behalf) that we engage for the purpose of processing information on our and your behalf. Additionally, we may partner with other companies to process, analyze, and/or store data, including, but not limited to, Analytical Data. While providing services for us, these companies may access your personal information. To the extent applicable, we require these parties to comply with this Privacy Policy and appropriate confidentiality and security measures.
• Protection of Rights. We will share personal information if we have a good faith belief that (i) access, use, preservation or disclosure of such information is reasonably necessary to satisfy any applicable law, regulation, legal process, such as a court order or subpoena, or a request by law enforcement or governmental authorities, (ii) such action is appropriate to enforce our Terms of Use for the Service, including any investigation of potential violations thereof, (iii) such action is necessary to detect, prevent, or otherwise address fraud, security or technical issues associated with the Service, or (iv) such action is appropriate to protect the rights, property or safety of us, our employees, users of the Service or others.
• Asset Transfers. If we become involved in a merger, acquisition or other transaction involving the sale of some or all of our assets, user information, including personal information collected from you through your use of the Service, could be included in the transferred assets. You expressly consent to such transfer. Should such an event occur, we will use reasonable means to notify you through email and/or a prominent notice on the Site.

Additional Information You Should Know About Third Parties

The Service may contain direct links to websites operated by our partners and other entities. These third-party websites may collect information about you when you visit them or otherwise communicate with them. This Privacy Policy does not cover the information practices of third-party websites linked to the Site or accessible through the Service. Although we encourage such third parties to adopt and follow their own privacy policies, we are not responsible for their collection and use of your personal information. You should refer to the privacy policies and statements of other websites or contact the respective webmasters of those websites to obtain information regarding their information collection, use and disclosure policies.

5. Your Rights and Choices Regarding Your Information?

Control of Your Information

You may update or delete your personal information or modify your account preferences for the Service by accessing the account interface provided through the Service. Please note that if you disable your account, we will keep the information we receive as described in this Privacy Policy for as long as necessary to fulfill the purpose(s) for which it was collected, resolve disputes, establish legal defenses, conduct audits, pursue legitimate business purposes, enforce our agreements, and comply with applicable laws.

Your Choice to Opt Out

If you no longer want to receive our emails or other announcements, you may unsubscribe by writing to us at marketing@warnerpacific.com or following the instructions provided through the Service or the “unsubscribe” link at the bottom of our emails. Please note that you cannot unsubscribe from certain correspondence from us, including messages relating directly to your plan or account.

6. How We Store and Safeguard Your Information

The personal information that you provide to us is stored on servers which, to our knowledge, are located in secured facilities with restricted access and are protected by protocols and procedures designed to ensure the security of such information. We restrict access to personal information to our employees, independent contractors and agents who need to know this information in order to develop, operate and maintain the Service. All of our personnel who have access to this information are trained in the maintenance and security of such information. Access to such personal information is minimized whenever possible. Logs are kept of access to application data, which can be monitored for unauthorized activities. However, no server, computer or communications network or system, or data transmission over the Internet can be guaranteed to be 100% secure. As a result, while we strive to protect user information, we cannot ensure or warrant the security of any information you transmit to us or through the use of the Service and you acknowledge and agree that you provide such information and engage in such transmissions at your own risk. Once we receive a transmission from you, we will endeavor to maintain its security on our systems.

In the event that personal information you provide to us is compromised as a result of a breach of security, when appropriate we will take reasonable steps to investigate the situation, notify you and take the necessary steps to comply with any applicable laws and regulations.

7. California Residents Privacy Rights

The California Consumer Privacy Act of 2018 (the “CCPA”) is a California law that gives California residents (“consumers”), the right to learn about and control certain aspects of how a business handles the personal information that a business collects about them. For purposes of this addendum, Warner Pacific is referred to as “we” or “our”. Pursuant to the CCPA, effective January 1, 2010, consumers have certain rights, including:

• The right to know the categories of personal information we’ve collected and the categories of sources from which we got the information;
• The right to know the business purposes for collecting, using, or selling personal information;
• The right to know the categories of third parties with whom we’ve shared personal information;
• The right to access the specific pieces of personal information we’ve collected, used, disclosed, and/or sold;
• The right to opt-out of the sale of your personal information;
• The right to delete/anonymize your information, with limited exceptions; and
• California residents also have the right to not be discriminated against if they choose to exercise their privacy rights.

Your Personal Information

In the past 12 months, we may have collected the following information about you depending on your interaction with us:

For more information on the personal information we collect, from where we collect this information, and how we use this information, please see the sections The Information We Collect and How We Use Your Personal Information above.

We may share your personal information with the third parties list above in section How We Share Your Information. In addition to the above, California law requires that we provide you with information about certain disclosures to such third parties within the past 12 months, particularly, where the disclosure involves monetary or other consideration. California treats these disclosures as “sales” of information, even where no money is exchanged. We do not sell personal information, and we do not sell, or have actual knowledge of any sale of, the personal information of minors under 16 years of age.

We may, however, have disclosed, in the past 12 months, the following categories of personal information to the following third parties for our operational business purposes in accordance with California law:

Your Rights Under the CCPA

Right to Opt-Out of Sale of Your Personal Information
Consumers have the right to request that a business that sells the consumer’s personal
information, or that discloses it for a business purpose, inform the consumer of what has been collected about them and who it has been sold or disclosed to. Consumers also have the right, at any time, to direct a business that sells personal information about them not to sell their personal information.

• Warner Pacific does not sell or share your personal information for monetary or other valuable consideration.

Right to Access / Data Portability
Consumers have the right to request that a business that collects personal information about them disclose the following: (1) The categories of personal information it has collected about that consumer; (2) The categories of sources from which the personal information is collected; (3) The business or commercial purpose for collecting or selling personal information; (4) The categories of third parties with whom the business shares personal information; (5) The specific pieces of personal information it has collected about that consumer.

1. 1. To exercise your right to access, submit a Verifiable Consumer Request by calling us toll free at (800) 801-2300, or by sending an email to compliance@warnerpacific.com. Please include “Request for Access” in the subject line.

1. If you submit your response via email, we will reach out within 10 days to confirm that we have received your request.
2. We will then take steps to determine whether your request is a valid Verifiable Consumer Request. If we possess appropriate information about you on file (e.g., name, phone number, email), we will attempt to verify your identity using that information. We will not ask you to create an account if you do not already have one, and we will only ask for information that is reasonable in light of the nature of your request. If it is not reasonably possible to identify you adequately, we may not be able to respond to your request.
3. When you submit a request for access:
   a. Within 45 days, we will provide you with a copy of the information listed in “Right to Access / Data Portability,” above, by mail or electronically. To the extent possible, this information shall be provided in a portable and useable format.
   b. In the event we need additional time, we will inform you within the initial 45-day period of our need for an additional 45 days (for a maximum of 90 days between request and provision of information).
   c. We are not required to provide personal information to a consumer more than twice in a 12-month period.
   d. Please note, the CCPA does not apply to protected health information that is collected by a covered entity or business associate governed by the Health Insurance Portability and Accountability Act of 1996 (HIPAA). Much of the information we collect and maintain is governed by HIPAA, and as such, may not be provided upon submission of a request for access. If you would like to learn more about your rights to access protected health information, please visit the U.S. Department of Health & Human Services at: https://www.hhs.gov/hipaa/for-professionals/privacy/guidance/access/index.html.

Right to Deletion
Consumers have the right to request that a business delete any personal information about them. However, there are exceptions to this rule. For example, a business does not have to delete information if it is necessary: a) to complete a transaction; b) to prevent illegal activity; c) to exercise free speech; d) to comply with a legal obligation; e) to identify or repair errors that impair functionality; f) for internal uses that are reasonably aligned with the expectations of the consumer based on the consumer’s relationship with us, or g) for internal purposes, that are compatible with the context in which the consumer provided that information.

1. To exercise your right to deletion, submit a Verifiable Consumer Request by calling us toll free at (800) 801-2300, or by sending an email to compliance@warnerpacific.com. Please include “Request for Deletion” in the subject line
2. We will reach out within 10 days to confirm that we have received your request.
3. We will then take steps to determine whether your request is a valid Verifiable Consumer Request. If you have an account, we may ask you to login to confirm this information. If you do not have an account, but we possess appropriate information about you on file (e.g., name, phone number, email), we will attempt to verify your identity using that information. We will not ask you to create an account if you do not already have one, and we will only ask for information that is reasonable in light of the nature of your request. If it is not reasonably possible to identify you adequately, we may not be able to respond to your request.
4. When you submit a request for deletion:
   a. After you submit the initial request, we will ask that you separately confirm that you would like your information deleted.
   b. If your request does not fall within one of the exceptions to deletion listed in “Right to Deletion,” above, we will confirm deletion within 45 days. If we are not required to delete your information, we will also let you know within 45 days.

Right to Non-Discrimination
A business cannot discriminate against a consumer because the consumer exercised any of the consumer’s rights listed above.

Authorized Agents

To use an authorized agent to make a request on your behalf, you will need to directly confirm with us that you provided the authorized agent permission to submit the request and provide us with signed permission for the authorized agent to act on your behalf. You will also need to verify your identity, directly with us.

Questions:

If you have any questions about this California Privacy Rights, or any Warner Pacific privacy practices, please reach out to us at compliance@warnerpacific.com. You can also call us at (800) 801-2300, or write to us at: 32110 Agoura Road, Westlake Village, CA 91361.

8. Changes to this Privacy Policy

We may change this Privacy Policy from time to time. Laws, regulations, and industry standards evolve, which may make those changes necessary, or we may make changes to our services or business. We will post the changes to this page and encourage you to review our Privacy Policy to stay informed. If we make changes that materially alter your privacy rights, We will provide additional notice, such as via email or through the Services. If you disagree with the changes to this Privacy Policy, you should deactivate your account and cease use of our Services.

9. Contact Us

If you have any questions about our privacy practices or this Privacy Policy, please contact us by email at compliance@warnerpacific.com.