Effective Date: January 1, 2020
Last Reviewed on: December 29, 2019
This Notice does not apply to employment-related personal information collected from California-based employees, job applicants, contractors, or similar individuals (see our California Employee Privacy Notice, which can be found at www.norcal-group.com/privacy/CA/employee).
Where noted in this Notice, the CCPA temporarily exempts personal information reflecting a written or verbal business-to-business communication or transaction (“B2B personal information”) from some of its requirements.
INFORMATION WE COLLECT
We collect information that identifies, relates to, describes, references, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer, household, or device (“personal information”). 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); and
- personal information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FCRA).
In particular, we have collected the following categories of personal information from consumers within the last twelve (12) months:
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.
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.
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).
D. Commercial information.
Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.
E. Internet or other similar network activity.
Browsing history, search history, information on a consumer’s interaction with a website, application, or advertisement.
F. Geolocation data.
Physical location or movements.
G. Sensory data.
Audio, electronic, visual, thermal, olfactory, or similar information.
H. Professional or employment-related information.
Current or past job history or performance evaluations.
I. Inferences drawn from other personal information.
Profile reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.
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 telephone calls with you.
- Indirectly from you. For example, from using cookies to observe your actions on our website.
- From third parties. For example, from insurance agents or government agencies.
- From publicly available sources. For example, from organizational websites.
Please note the foregoing will not limit what B2B personal information we collect or from whom we collect it.
USE OF PERSONAL INFORMATION
We may use each of the categories of personal information we collect for one or more of the following purposes:
- To develop NORCAL Group’s vision and strategy. This involves defining our business concept and long-term vision, as well as developing our business strategy and managing strategic initiatives. For example, personal information may be gathered in surveys and used to assess customer needs and wants. We may also use personal information to evaluate the effectiveness of strategic initiatives.
- To develop and manage NORCAL Group’s products and services. This involves governing and managing our product and service development program; generating and defining new product and service ideas; and developing products and services. For example, personal information may be used for testing, research, analysis, and product development, including developing and improving our products and services. Personal information may be used to evaluate the performance of existing products and services and for quality assurance purposes.
- To market and sell NORCAL Group’s products and services. This involves understanding our market, customers, and capabilities; developing sales and marketing strategies; developing, managing, and executing marketing plans; and managing sales partners and alliances. For example, personal information may be used to identify sales opportunities, to manage customer relationships, and to develop relationships with insurance agencies.
- To deliver NORCAL Group’s products and services. This involves identifying strategies for performing product and service delivery, managing resources, and delivering products and services to our customers. For example, we may use personal information to identify which resources will be assigned to which customers. Personal information may also be used to deliver our products and services.
- To manage NORCAL Group’s customer service. This involves developing customer service practices; managing customer service contacts; servicing our products and services after sale; and evaluating customer service operations and customer satisfaction. For example, we may use personal information obtained via surveys and customer service calls to measure customer satisfaction and assess our performance. We also use personal information to provide customer support and to process customer requests or complaints.
- To develop and manage NORCAL Group’s human resources processes. This involves managing employee performance, rewarding employees, and developing and training employees. For example, personal information may be used in assessing an employee for promotion or demotion.
- To manage NORCAL Group’s information technology (IT). This involves managing information and developing and managing customer relationships, IT business strategy, IT resilience and risk, and IT services and solutions. For example, personal information may be used when conducting IT compliance assessments. We may also use personal information to help maintain the safety, security, and integrity of our website; products and services; databases and other technology assets; and business. Personal information may also be used in the development of certain IT products and solutions.
- To manage NORCAL Group’s financial resources. This involves overseeing key back-office processes related to accounting and reporting, payroll, accounts payable and expense reimbursements, treasury operations, internal controls, and tax management. For example, personal information may be used to invoice customers, to process payments or credits, and to prepare tax documents. We may also use personal information to prevent transactional fraud.
- To acquire, construct, and manage NORCAL Group property and assets. This involves the design, construction, acquisition, and management of our properties and assets. For example, personal information may be used to manage office operations, including maintenance of security protocols.
- To manage NORCAL Group’s enterprise risk, compliance, remediation, and resiliency. This involves ensuring that we effectively manage our risk, compliance, remediation efforts, and business resiliency. For example, personal information may be used to test business operations and identify risks. We may also use personal information in the investigation and management of legal and compliance matters, and as otherwise required by applicable law, court order, or governmental regulations.
- To manage NORCAL Group’s external relationships. This involves managing banking and investment relationships, government and industry relationships, board of directors relations, legal and ethical issues, and our public relations program. For example, personal information may be used when we work with outside counsel and advisors. We may also use personal information to respond to governmental inquiries and law enforcement requests, and for regulatory reporting purposes.
- To develop and manage NORCAL Group’s business capabilities. This involves portfolio, program, and project management, business process management, quality management, change management, benchmarking, knowledge management, and data analytics. For example, personal information may be used in the development, execution, and assessment of our programs and projects. We may also use personal information when we collect, analyze, and report on our data.
- To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of NORCAL Group’s assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding.
- As otherwise described to you when collecting your personal information or as 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, or incompatible purposes without providing you notice.
Please note, however, that the foregoing will not limit how we collect or use B2B personal information.
SHARING PERSONAL INFORMATION
We may disclose your personal information to a third party for a business purpose.
Disclosures of Personal Information for a Business Purpose
In the preceding twelve (12) months, NORCAL Group has 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 E: Internet or other similar network activity.
- Category F: Geolocation data.
- Category G: Sensory data.
- Category H: Professional or employment-related information.
- Category I: Inferences drawn from other personal information.
We disclose your personal information for a business purpose to the following categories of third parties:
- NORCAL Group companies. Other NORCAL Group companies may have access to and use of personal information in connection with the conduct of our business where appropriate.
- Other insurance and distribution parties. In the course of marketing and providing our products and services, NORCAL Group may make personal information available to third parties such as other insurers; reinsurers; insurance and reinsurance brokers and other intermediaries and agents; appointed representatives; distributors; affinity marketing partners; and financial institutions, securities firms, and other business partners.
- Service providers. External third-party service providers, such as accountants, actuaries, auditors, experts, lawyers and other outside professional advisors; IT systems, support and hosting service providers; printing, advertising, marketing and market research and analysis service providers; banks and financial institutions that service our accounts; document and records management providers; claim investigators and adjusters; engineers; examiners; jury consultants; translators; and similar third-party vendors and outsourced service providers that assist us in carrying out business activities.
- Governmental authorities and third parties involved in court action. NORCAL Group may also share personal information with governmental or other public authorities (including, but not limited to, courts, law enforcement, tax authorities and criminal investigations agencies); and third-party civil legal process participants and their accountants, auditors, lawyers and other advisors and representatives as we believe to be necessary or appropriate: (a) to comply with applicable law; (b) to comply with legal process; (c) to respond to requests from public and government authorities; (d) to enforce our terms and conditions; (e) to protect our operations; (f) to protect our rights, privacy, safety or property, and/or that of you or others; and (g) to allow us to pursue available remedies or limit our damages.
- Other third parties. We may share personal information with payees; emergency providers (including police); medical networks, organizations, and providers; credit bureaus; credit reporting agencies; and other people involved in an incident that is the subject of a claim; as well as purchasers and prospective purchasers or other parties in any actual or proposed merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of NORCAL Group’s assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding.
Sales of Personal Information
In the preceding twelve (12) months, NORCAL Group has not sold personal information.
Please note the foregoing will not limit how we share B2B 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 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 over the past 12 months*. Once we receive and confirm your verifiable consumer request (see Exercising Access, Data Portability, and Deletion 0), 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 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
- disclosures for a business purpose, identifying the personal information categories that each category of recipient obtained.
*Please note that we do not provide these access and data portability rights for B2B personal information.
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 (see Exercising Access, Data Portability, and Deletion 0), 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 provider(s) 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, fulfill the terms of a written warranty or product recall conducted in accordance with federal law, 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.
- Make other internal and lawful uses of that information that are compatible with the context in which you provided it.
*Please note that we do not provide these deletion rights for B2B personal information.
Exercising Access, Data Portability, and Deletion Rights
To exercise the access, data portability, and deletion rights described above, please submit a verifiable consumer request to us by either:
Only you, or someone legally authorized 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 of such person.
- Provide the requested detail to allow 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 (a) verify the requestor’s identity or authority to make the request and (b) communicate with the requestor regarding 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, we will inform you of the reason and extension period in writing.
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 our receipt of a verifiable consumer request. 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.
We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not take any of the following actions in response to you exercising your rights:
- Deny you products or services.
- Charge you different prices or rates for products or services, including through granting discounts or other benefits, or imposing penalties.
- Provide you a different level or quality of products or services.
- Suggest that you may receive a different price or rate for products or services or a different level or quality of products or services.
However, we may offer you certain financial incentives permitted by the CCPA that can result in different prices, rates, or quality levels. Any CCPA-permitted financial incentive we offer will reasonably relate to your personal information’s value and contain written terms that describe the program’s material aspects. Participation in a financial incentive program requires your prior opt-in consent, which you may revoke at any time.
CHANGES TO OUR PRIVACY NOTICE
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 post the updated Notice on our website and update the Notice’s effective date. Your continued use of our website following the posting of changes constitutes your acceptance of such changes.
If you have any questions or comments about this Notice, the ways in which NORCAL Group collects and uses your information, or your choices and rights regarding such use, or if you would like to request access to this Notice in an alternative format, please do not hesitate to contact us at:
Phone: 844.4NORCAL (844.466.7225)
Attn: Compliance & Legal Dept.
P.O. Box 2080
Mechanicsburg, PA 17055