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Business & Personal Insurance Solutions
ONLINE PRIVACY POLICY
Effective Date: 12/21/2022
Last Updated: 12/21/2022
SCOPE
This Privacy Policy (“Policy”) describes how Chubb Group of Insurance Companies,
and our brands, affiliates, and subsidiaries (“Chubb,” “we,” “us” and “our”)
collect, use, and disclose your information, including Personal Information,
when you visit our websites, including www.chubb.com (the “Sites”), download our
mobile applications, or use any of our products or services that link to or
otherwise reference this Policy (collectively, the “Services”). This policy does
not apply to www.combinedinsurance.com (except when Combined insurance products
are sold under the Blink℠ by Chubb brand), www.rainhail.com,
or www.streamlabswater.com, nor to any non-Chubb websites or mobile applications
that you may access via the Services. Those websites and services are governed
by the privacy policies that appear on those sites and applications. Depending
upon your relationship with us, you may receive other privacy notices from us
providing additional detail about our privacy practices. If you are a California
resident, please see the Additional Notice to California Residents below for
more information.
Your use of the Services is subject to this Policy and the Chubb Terms of Use,
including applicable terms of limitations on liability and the resolution of
disputes.
TABLE OF CONTENTS
Scope
Personal Information We Collect
How We Use Personal Information
How We May Disclose Personal Information
How We Collect, Use and Protect Social Security Numbers
Cookies and Other Tracking Mechanisms
Your Cookie and Marketing Choices
Children’s Information
External Links
Blogs and Other Features
Security
Changes to This Policy
Contact Us
Consent
Additional Notice to California Residents
PERSONAL INFORMATION WE COLLECT
We collect information that identifies, describes, or is reasonably capable of
being associated with you (“Personal Information”). Personal Information does
not include publicly available information, such as information lawfully made
available from government records, information we have a reasonable basis to
believe is lawfully made available to the general public by you or by widely
distributed media, or by a person to whom you have disclosed the information and
not restricted it to a specific audience, or deidentified or aggregated
information.
As described below, we collect Personal Information directly from you,
automatically through your use of the Sites and Services, and from third-party
sources. To the extent permitted by applicable law, we may combine the
information we collect from publicly available or third-party sources. The
Personal Information we collect varies based on your relationship with us.
Personal Information We Collect Directly From You
In order to access certain Services, we may collect Personal Information
directly from you, including throughout the quoting, application, or claims
handling processes. The Personal Information you provide directly to us may
include:
* Identifiers and Contact Information. We may collect personal identifiers and
contact information such as your name, address, email address, phone number.
* Government-Issued Identifiers. We also may collect information such as your
driver’s license number, social security number, or other government-issued
identifiers.
* Account Details. If you register an account with us, we collect information
such as your email, phone number, or user ID, and password used to login to
your account.
* Policy or Claims Information. This includes policy information, claim
information, including materials you submit as part of your claim,
information provided for roadside assistance services, or other information
you choose to provide us.
* Payment Information. If you pay a bill, we may collect information necessary
to process your payment such as bank account information, billing address,
and any other related information.
* Commercial Information. We may also collect information about the products,
services, or coverage you purchase.
* Message Contents. If you contact our customer service team, including through
our online web forms, we may collect your messages, emails, or any other
information you so choose to provide.
* Audio or Similar Information. If you speak with our customer service team by
phone, we may collect a recording for quality assurance and training
purposes.
* Preferences. We may also collect information about the types of Services you
use, your communications preferences, wish lists and other preferences you
may select in your account or profile.
* Other Information. We also collect information when you complete online
forms, surveys, or leave us product reviews. We also collect any other
information you so choose to provide.
Personal Information We Collect Automatically
As described below in the “Cookies and Other Tracking Mechanisms” section, when
you visit our Sites or use our Services, we may automatically collect certain
Personal Information, including:
* Device Identifiers. We automatically collect IP address, unique device ID,
device type, browser type, location information, and information about your
browser and browser language.
* Network Activity. We may also collect information related to how you interact
with the Services and advertisements, such as page views, links and items
clicked and other activity information, referring URL, browsing history, and
other similar information. We may use analytics providers and technologies,
including cookies and similar tools, to collect this information.
* Geolocation. We may also collect geolocation information, such as physical
location or movements. Additionally, depending on your device settings, if
you visit our Sites or use our mobile applications, we may collect
geolocation information from your IP address which links to the region you
live in.
Personal Information We Collect from Other Sources
We may collect information about you through our affiliates, business partners,
and vendors, including from administrators, adjusters, agents, brokers, or other
representatives who provide services or products on our behalf. For example, we
may collect information about your policies, including coverage or claim
information, through these sources. We may also receive information from
consumer reporting agencies, including motor vehicle reports or information
about your credit or creditworthiness, and from other, publicly available
sources.
HOW WE USE PERSONAL INFORMATION
We may use the Personal Information we collect for the following purposes:
* Operate Our Business. We use the Personal Information we collect to allow you
to maintain your account and otherwise run our day-to-day operations.
* Provide You Products and Services. We use the Personal Information we collect
to provide you with, renew or modify products and services. We also use this
information to maintain your coverage and memberships, including to set up a
product or service, service your policy, change your policy, handle a claim,
or complete a transaction.
* Communicate With You. We use the Personal Information we collect to
communicate with you about your use of our Sites and Services, to respond to
your inquiries, to provide you with the information and documents you
request, and for other customer service purposes.
* Evaluate and Improve Our Products and Services. We use the Personal
Information we collect to evaluate, analyze, improve, and develop our
products and Services, including this Site. We also use this information to
tailor the content and information that we may send or display to you, to
offer location customization and personalized help and instructions, and to
otherwise personalize your experiences while using our Services.
* Analytics Models to Support our Business. We use the Personal Information we
collect in analytics models, including actuarial, underwriting, claims, and
loss control models, to facilitate and service our business (e.g., to create
new products and features). We may also use this information to conduct
actuarial or research studies to maintain and develop our products and
Services, and to create new offerings or features. We also use this
information to administer surveys and questionnaires, such as for market
research or member satisfaction purposes.
* Marketing and Advertising. We may use your Personal Information for marketing
and promotional purposes, including to send you promotional communications
about products, services, features, and options we believe may interest you.
We may send communications via e-mail, regular mail or may send push
notifications via a mobile device. We may also use your information to serve
you advertisements or customized content online.
* Inferences. We may use the information we collect to better understand how
you access and use our Sites and the products and Services available on our
Sites, both on an aggregated and individualized basis.
* Find Locations on Request. At your request, we may use your information to
obtain your location from the mobile device or the network using your
device’s Global Positioning System (GPS) functionality, or directly from you.
We may use your location information to help you search for information,
including searching for an agent, searching for a service provider,
identifying the location of an accident or identifying the location of a
roadside event you are reporting. If you do not want location information
used, you can disable the GPS functionality on your mobile device.
* Fraud and Security Purposes. We may use the Personal Information we collect
to mitigate fraud and protect Chubb and others. We also use this information
to prevent and detect fraudulent, malicious, deceptive, infringements of our
policies and contracts and other potential misuse of or illegal activity
relating to our products, assets, and Services.
* Legal Requirements. We use the Personal Information we collect to
investigate, enforce, and apply this Policy and our Terms of Use, and to
otherwise protect our own rights and interests, such as to resolve any
disputes or to respond to requests from law enforcement, court orders,
regulators, or other legal processes.
* Business Transfers. We may also use the Personal Information we collect and
receive to consider and implement mergers, acquisitions, reorganizations,
refinancing, and other business transactions, and for the administration of
our general business, accounting, recordkeeping, and other legal functions.
* Other Operational and Business Purposes. We may use your Personal Information
for other operational purposes, including to refer you to our third-party
partners as part of a referral program, to comply with contracts related to
products or services that we provide to you.
We also may combine or aggregate any of the information we collect through the
Services or elsewhere for any of these purposes or for analyzing usage
statistics and trends.
HOW WE MAY DISCLOSE PERSONAL INFORMATION
When permitted by applicable law, including in cases that require your consent,
we may disclose your Personal Information to our affiliates, business partners,
vendors and services providers, and others as follows:
* Affiliates, Subsidiaries, and Business Partners. We may disclose the Personal
Information we collect with our affiliates, subsidiaries, and agents and
brokers. Chubb also partners with other businesses to offer products and
services, and we may disclose your Personal Information to those
organizations, including those that play a role in insurance transactions
such as independent claims adjusters, repair shops, and other claims related
companies. If required by law, we will obtain consent prior to disclosing
Personal Information.
* Vendors and Service Providers. We may disclose the Personal Information we
collect with vendors and service providers who perform functions on our
behalf, such as helping complete transactions and process payments, handling
claims, servicing your policy or membership, and engaging in credit
reporting. We may also disclose your information to vendors and service
providers who provide website hosting and analytics, marketing and
advertising, email or other communication services, development and research
or actuarial studies, customer support, and tax, accounting, and legal
services.
* Marketing and Advertising Partners. We may also disclose your Personal
Information, such as name and contact information, with our marketing and
advertising partners to send you content about certain products and Services.
We also may disclose your Personal Information in the following circumstances:
* Business Transfers. As we continue to develop our business, we may buy,
merge, or partner with other companies. We may disclose Personal Information
as part of those commercial transactions (e.g., mergers, acquisitions,
financings, asset sales or transfers, bankruptcy or reorganization or other
similar business transactions), as well as in contemplation of such
transactions (e.g., due diligence). Where possible we will do so under
appropriate confidentiality agreements. Similarly, if all or part of our
business, assets, or Sites are merged with or sold to another company, or as
part of a bankruptcy proceeding, your Personal Information may be transferred
to the surviving or acquiring company.
* In Response to Legal Process. Personal Information may be disclosed to third
parties, as required by law or subpoena, or if we reasonably believe such
action is necessary to comply with the law and the reasonable requests of
regulators, law enforcement or other public authorities. We also may disclose
the information we collect in order to comply with a judicial proceeding,
court order, or other legal process, including responding to national
security or law enforcement disclosure requirements.
* To Prevent Fraud and Protect Us and Others. We also may disclose the Personal
Information we collect from you where we believe it is necessary to
investigate, prevent, or take action regarding illegal activities, suspected
fraud, situations involving potential threats to the safety of any person,
violations of this Policy or our Terms of Use, or as evidence in litigation
in which we are involved. We may also disclose Personal Information to
protect our rights and the rights of others. This may include exchanging
information with other companies and organizations for fraud prevention,
spam/malware mitigation, and similar purposes.
* Aggregate and De-Identified Information. We may disclose aggregate or
de-identified information about users with third parties for marketing,
advertising, research or other purposes.
* With Your Permission. We may disclose Personal Information in other ways not
described above. If we do so, we will notify you and, if necessary, obtain
your consent.
HOW WE COLLECT, USE AND PROTECT SOCIAL SECURITY NUMBERS
Chubb may collect Social Security numbers (“SSNs”) in the course of our
business. We strive to protect the confidentiality and security of SSNs in our
possession, custody or control by: (i) limiting access to SSNs and (ii)
maintaining reasonable administrative, technical and physical safeguards to
protect against the loss, misuse or unlawful disclosure of SSNs. We do not
share SSNs for marketing purposes.
COOKIES AND OTHER TRACKING MECHANISMS
We and our third-party service providers use cookies, pixels, tags, and other
similar tracking mechanisms to automatically collect information about browsing
activity, type of device and similar information within our Services and to
target advertising and content across our Services and third-party sites and
services. We use this information to, for example, analyze and understand how
users access, use and interact with others through our Services, as well to
identify and resolve bugs and errors in our Services and to assess, secure,
protect, optimize and improve the performance of our Services.
Cookies. “Cookies” are alphanumeric identifiers we transfer to your device’s
hard drive through your web browser for tracking purposes. Some cookies allow us
to make it easier for you to navigate our Services, while others are used to
enable a faster log-in process, support the security and performance of the
Services, or allow us to track activity and usage data within our Service.
Clear GIFs, Pixel Tags, and Other Technologies. In addition to cookies, we may
also use pixel tags (sometimes called web beacons or “clear GIFs”) to collect
information about you and your use of our Services. While cookies are stored
locally on your device, pixel tags are embedded invisibly within web pages and
online content. We may use these, in connection with our Services to, among
other things, track the activities of users, help us manage content and compile
usage statistics. We may also use these in HTML e-mails we send, to help us
track e-mail response rates, identify when our e-mails are viewed, and track
whether our e-mails are forwarded.
Third-Party Analytics and Tools. We use third party tools, such as Google
Analytics, which are operated by third party companies. These third-party
analytics companies may collect usage data (using cookies, pixels and similar
tools) about our Services in order to provide us with reports and metrics that
help us evaluate usage of our Services, improve our Sites, and enhance
performance and user experiences. To learn more about Google’s privacy
practices, please review the Google Privacy Policy at
https://www.google.com/policies/privacy/partners/. You can also download the
Google Analytics Opt-out Browser Add-on to prevent your data from being used by
Google Analytics at https://tools.google.com/dlpage/gaoptout.
Cross-Device Tracking. We and our third-party providers may use the information
that we collect about you within our Services and on other third-party sites and
services to help us and these third parties to identify other devices that you
use (e.g., a mobile phone, tablet, other computer, etc.).
Targeted Advertising. We work with third parties, such as ad networks, channel
partners, mobile ad networks, analytics and measurement services and others to
personalize content and display advertising within our Services. We may share
certain information with these organizations, and we and them may use cookies,
pixels tags, and other tools to collect usage and browsing information within
our Services such as IP address, location information, device ID, cookie and
advertising IDs, and other identifiers, as well as browsing information. We and
these organizations use this information to provide you more relevant ads and
content within our Services, and to evaluate the success of such ads and
content.
Do Not Track. We do not currently respond to web browser “Do Not Track” signals.
YOUR COOKIE AND MARKETING CHOICES
We make available several ways for you to manage choices about your Personal
Information, including preferences regarding cookies, advertising, whether you
want to receive marketing and promotional emails from us, and choices regarding
your account and profile information.
* Cookie Settings. If you wish to prevent cookies from tracking your activity
on our Sites or visits across multiple websites, you can set your browser to
block certain cookies or notify you when a cookie is set; you can also delete
cookies. The “Help” portion of the toolbar on most browsers will tell you how
to prevent your device from accepting new cookies, how to have the browser
notify you when you receive a new cookie, or how to delete cookies. Visitors
to our Sites who disable cookies will be able to browse the Sites, but some
features may not function.
* Industry Ad Choice Programs. You can also control how participating
third-party ad companies use the information that they collect about your
visits to our websites and use of our mobile applications, and those of third
parties, in order to display more relevant targeted advertising to you. If
you are in the U.S., you can obtain more information and opt out of receiving
targeted ads from participating third-party ad networks at
aboutads.info/choices (Digital Advertising Alliance). You may also download
the DAA AppChoices tool (https://youradchoices.com/appchoices) in order to
help control interest-based advertising on apps on your mobile device.
* Marketing Communications. You can opt out of receiving marketing emails from
us by using the unsubscribe feature in any such email we send you.
* Account and Profile Information. You may access, update, or correct your
account and profile information at any time by logging in to your account and
updating the Personal Information we maintain. We may keep a copy of your
prior information for a period of time, as part of our business records and
our backup data.
CHILDREN’S INFORMATION
Our Services are not designed for children, and we do not knowingly collect
Personal Information from children under the age of thirteen (13). If we learn
that we have received information directly from a child who is under the age of
13, we will delete such information from our systems. If you are a parent or
legal guardian and you believe we have collected your child’s information in
violation of applicable law, please contact us using the contact information
below.
EXTERNAL LINKS
When you use our Services, you may find links to other websites that we do not
own or control. We are not responsible for the privacy practices of these other
sites, including their collection of your Personal Information. You should
review the terms and conditions and privacy policies of these other sites before
providing your information.
BLOGS AND OTHER FEATURES
We may offer blogs, online forums or other interactive features in connection
with our Services that enable you to share information about the Services or
other issues of interest. You should be aware that any communications you submit
or post to any such interactive features on the Services may be viewable by
other participants or users. By submitting or posting to such interactive
features you acknowledge and agree that you have no expectation of privacy or
confidentiality in the content you submit for such features, whether or not it
contains Personal Information about you.
SECURITY
We have implemented safeguards designed to protect Personal Information from
loss, misuse, and unauthorized access, disclosure, alteration, and destruction.
Please be aware that despite our efforts, no data security measures can
guarantee security.
CHANGES TO THIS POLICY
This Policy is current as of the Effective Date set forth above. We may change
this Policy at any time and from time to time. Any amendments or modifications
to this Policy will become effective immediately upon posting. We will let you
know of amendments or modifications by appropriate means such as by posting the
revised statement on this page with a new “Last Updated” date. Your continued
use of any of our Services following the posting of a revised version of this
Policy will constitute your acceptance of the revised Policy. If you do not
agree with the revised Policy, do not use any of our Services.
CONTACT US
If you have questions about this Policy or our privacy practices, please contact
us using the contact information provided below.
Chubb Group
Attention: Privacy Inquiries
202 Hall’s Mill Road, P.O. Box 1600
Whitehouse Station, NJ 08889-1600
Telephone: 1-800-258-2930
E-mail: privacyinquiries@chubb.com
CONSENT
By using the Services or by consenting using a consent mechanism where provided
you signify your consent to this Policy and this site’s Terms of Use. If you do
not agree to this Policy or the site’s Terms of Use, please do not use the
Services. The Services are not for use within any country or jurisdiction or by
any persons where such use would constitute a violation of law. If this applies
to you, you are not authorized to access or use any of the Services.
ADDITIONAL NOTICE TO CALIFORNIA RESIDENTS
If you would like to exercise your rights under the California Consumer Privacy
Act of 2018, as amended by the California Privacy Rights Act of 2020 ("CCPA"),
please visit us at our Data Subject Request web page or call us at the following
toll-free telephone number 1-833-3249798.
You can find Chubb's CCPA Notice at Collection below.
This section of our Privacy Policy provides additional information for
California residents pursuant to the CCPA and applies to "Personal Information"
as defined in the CCPA, whether collected online or offline. This section of our
Privacy Policy applies to www.chubb.com and other websites or mobile
applications that link to this Privacy Policy (the “Services”), as well as
offline activities where California residents are directed to this section of
the Privacy Policy. It does not apply to www.combinedinsurance.com (except when
Combined insurance products are sold under the Blink℠ by Chubb
brand), www.rainhail.com, www.streamlabswater.com and any non-Chubb websites or
mobile applications that you may access via the Services. Those services are
governed by the privacy policies that appear on those sites and applications.
As used in this section of our Privacy Policy, “Personal Information” means any
information that identifies, relates to, describes, is reasonably capable of
being associated with, or could reasonably be linked, directly or indirectly,
with a particular California resident or household.
Service Provider
Some Chubb business units and groups act as service providers under the CCPA.
This means that they collect and use Personal Information on behalf of another
company (for example, where ESIS, a wholly-owned subsidiary of Chubb, provides
claims management services to third party insurers and insureds). Where your
Personal Information is processed by ESIS or another Chubb company acting as a
service provider, that other company’s privacy policy will explain its privacy
practices, and you should submit any request to exercise CCPA rights directly to
that company. Please note that in some instances, ESIS and other Chubb
companies or business units may be acting as a service provider for other
members of the Chubb Group of Insurance Companies, and, in those instances, this
section of the Policy will apply. If you make a request to exercise CCPA rights
to Chubb where it acts as a service provider under the CCPA, we may be required
to disclose your request to the relevant company.
Personal Information Not Covered by this California Section of the Privacy
Policy
There are a number of exemptions from the application of the CCPA. The
following sets out some of the categories of Personal Information that are not
subject to the CCPA, and therefore are not covered by this California section of
the Privacy Policy. Note that other sections of the Privacy Policy may still
apply in addition to other privacy notices that we may issue addressing our
specific relationship with you, including privacy notices that are sent to
individuals.
* Health or medical information that we collect and that is subject to the
Health Insurance Portability and Accountability Act of 1996 (“HIPAA”), the
California Confidentiality of Medical Information Act or the Health
Information Technology for Economic and Clinical Health Act. For example,
where we provide you with a covered health insurance plan. Chubb provides a
separate HIPAA privacy notice to certain individual consumers as required
under applicable laws and regulations.
* Information we collect in connection with the issuance of financial products
or services to you that are to be used primarily for your personal, family,
or household purposes and that is subject to the Gramm-Leach-Bliley Act
(“GLBA”) or the California Financial Information Privacy Act. For example,
where we provide you with a personal insurance policy, or where we handle a
claim from you as an individual. Note that this exclusion may not apply to
all of your Personal Information, including to personal information collected
before you become a customer. Chubb provides a separate GLBA privacy notice
to certain individual consumers as required under applicable laws and
regulations.
* Information we collect and provide for use that is subject to the Fair Credit
Reporting Act.
* Information we collect as a motor vehicle record and that is subject to the
Driver's Privacy Protection Act of 1994.
* Publicly available information from government records, and information we
have a reasonable basis to believe is lawfully made available to the general
public by you or by widely distributed media, or by a person to whom you have
disclosed the information and not restricted it to a specific audience.
* Deidentified or aggregated information.
CALIFORNIA NOTICE AT COLLECTION
Categories of Personal Information Collected & Disclosed
The following identifies the categories of Personal Information we may collect
about you (and may have collected in the prior 12 months). Note that our
collection, use and disclosure of Personal Information about you will vary
depending upon the circumstances and nature of our interactions or relationship
with you. Depending on how you use our Services, we may collect the following
categories of Personal Information:
* Identifiers, such as real name, alias, job title, address, email address,
date of birth, policy number, salary information, social security number,
driver’s license number, other government identifiers, credit card number,
and tax ID.
* Online Identifiers, such as unique personal identifiers, device IDs, ad IDs,
IP addresses, and cookie data.
* Customer or Claimant Records, such as paper or electronic customer or
claimant records containing Personal Information, as well as information
provided by an insurance broker/agent or reinsurer for underwriting purposes
and information included in a list of claims, such as name, signature,
physical characteristics or description, address, telephone number,
education, current employment, employment history, social security number,
passport number, driver’s license or state identification card number,
insurance policy number, bank account number, payment card number, gender,
height, weight, medical information (including reports and medical bills),
health insurance information, details about home address, security and travel
plan arrangements, records of personal property, products or services
purchased or obtained.
* Financial Information, such as your bank account or credit card number and
other payment details.
* Characteristics of Protected Classifications under California Law, such as
age (40 years or older), race, national ancestry, national origin,
citizenship, religion or creed, marital status, pregnancy, medical condition,
physical or mental disability, sex, sexual orientation, and veteran or
military status.
* Usage Data, such as Internet or other electronic network activity information
regarding a California resident's interaction with portals, Internet
websites, applications, or advertisements, including, but not limited to,
browsing history, clickstream data, search history and content of public
posts.
* Biometric Information, such as individual biological or behavioral
characteristics including measurements of physical characteristics such as
height, weight and blood pressure, sleep, health, or exercise data that
contain identifying information.
* Education Information, such as education records directly related to a
student maintained by an educational institution or party acting on its
behalf, such as grades, transcripts, class lists, student schedules, student
identification codes and student disciplinary records.
* Geolocation Data, such as physical location or movements.
* Audio, Video and Other Electronic Data, such as audio information including
call recordings, video and photographs, recorded meetings and webinars, and
CCTV footage to secure our offices and premises.
* Professional or Employment-Related Information, such as employment history,
qualifications, licensing, and disciplinary record.
* Inferences and Preferences, such as inferences drawn from any of the
information described in this section about a consumer including inferences
reflecting the consumer’s preferences, characteristics, behavior and
abilities.
* Sensitive Personal Information, such as social security number, driver’s
license number, racial or ethnic origin, religious or philosophical beliefs,
medical condition, and physical or mental disability.
Sources of Personal Information
We generally collect Personal Information from the following categories of
sources:
* Directly from you and automatically;
* Our affiliates and subsidiaries;
* Brokers and agents;
* Corporate policyholders; and
* Our vendors and service providers (e.g., third party administrators).
Purposes for Collecting and Disclosing Personal Information
As described in the “How We Use Personal Information” section above, in general,
we collect and otherwise process the personal information we collect for the
following business or commercial purposes:
* Operate our business;
* Provide you products and services;
* Communicate with you;
* Evaluate and improve our products and services;
* Analytics models to support our business;
* Marketing and advertising;
* Inferences;
* Find locations on request;
* Fraud and security purposes;
* Legal requirements;
* Business transfers; and
* Other operational and business purposes.
Sensitive Personal Information
Notwithstanding the purposes described above, we do not collect, use, or
disclose “sensitive personal information” beyond the purposes authorized by the
CCPA. Accordingly, we only use and disclose sensitive personal information as
reasonably necessary and proportionate: (i) to perform our services requested by
you; (ii) to help ensure security and integrity, including to prevent, detect,
and investigate security incidents; (iii) to detect, prevent and respond to
malicious, fraudulent, deceptive, or illegal conduct; (iv) to verify or maintain
the quality and safety of our services; (v) for compliance with our legal
obligations; (vi) to our service providers who perform services on our behalf;
and (vii) for purposes other than inferring characteristics about you.
Retention of Personal Information
We retain the Personal Information we collect only as reasonably necessary for
the purposes described in this Privacy Policy or otherwise disclosed to you at
the time of collection. For example, we will retain certain identifiers for as
long as it is necessary to comply with our tax, accounting and recordkeeping
obligations, to administer certain policies and coverage, and for research,
development and safety purposes, as well as an additional period of time as
necessary to protect, defend or establish our rights, defend against potential
claims, and to comply with our legal obligations. From time to time, we may also
deidentify your Personal Information, retain it and use it for a business
purpose in compliance with CCPA.
Disclosure of Personal Information to Third Parties and Other Recipients
The categories of Personal Information we have disclosed for a business purpose
in the preceding twelve (12) months include: identifiers, online identifiers,
customer records, financial information, characteristics of protected
classifications, usage data, biometric information, education information,
geolocation data, audio, video, and other electronic data, professional or
employment-related information, inferences, and sensitive personal information.
The categories of third parties and other recipients to whom we may disclose
personal information for a business purpose may include:
* Affiliates, subsidiaries, and business partners;
* Vendors and service providers;
* Acquirers of business assets;
* Advisors, auditors, consultants, and representatives;
* Agents and brokers;
* Reinsurers;
* Regulators, government entities, and law enforcement;
* Operating systems and platforms; and
* Others as required by law.
Additionally, the CCPA defines “sale” as disclosing or making available personal
information to a third-party in exchange for monetary or other valuable
consideration, and “sharing” includes disclosing or making available personal
information to a third-party for purposes of cross-contextual behavioral
advertising. While we do not “sell” Personal Information, we may “share” the
following categories of Personal Information: online identifiers, and usage
data. We disclose this information to third-party advertising networks,
analytics providers, and social networks for purposes of marketing and
advertising. We do not sell or share “sensitive personal information,” nor do we
sell or share any Personal Information about individuals who we know are under
sixteen (16) years old.
Rights Regarding Your Personal Information
The CCPA provides California residents with specific rights regarding Personal
Information. This section describes your rights under the CCPA and explains how
to exercise those rights. Subject to certain exceptions, California consumers
have the right to make the following requests:
Right to Know. With respect to the Personal Information we have collected about
you in the prior (twelve) 12 months, you have the right to request from us (up
to twice per year and subject to certain exemptions and carveouts):
* The categories of Personal Information we collected about you;
* The sources from which we have collected that Personal Information;
* Our business or commercial purpose for collecting, selling, or sharing that
Personal Information;
* The categories of third parties to whom we have disclosed that Personal
Information; and
* A copy of the specific pieces of your Personal Information we have collected.
Right to Correct. Subject to certain restrictions, you have the right to request
that we correct inaccuracies in your Personal Information.
Right to Delete. Subject to certain conditions and exceptions, you have the
right to request deletion of your Personal Information that we have collected
about you.
Right to Opt-Out. You have the right to opt-out of “sales” and “sharing” of your
Personal Information, as those terms are defined under the CCPA. While we do not
“sell” Personal Information, our use of certain third-party analytics and
advertising cookies may constitute “sharing” under the CCPA. To exercise your
right to opt-out of the “sharing” of your Personal Information, please use the
Do Not Sell or Share My Personal Information link at the bottom of our Site.
You also have the right to opt-out of “sales” and “sharing” of your Personal
Information through the use of an opt-out preference signal. If our Site detects
that your browser or device is transmitting an opt-out preference signal, such
as the “global privacy control”—or GPC— signal, we will opt that browser or
device out of cookies on our Site that result in a “sale” or “sharing” of your
Personal Information. If you come to our Site from a different device or from a
different browser on the same device, you will need to opt-out, or use an
opt-out preference signal, for that browser and/or device as well.
Right to Limit Use and Disclosure of Sensitive Personal Information. We do not
engage in uses or disclosures of Personal Information that would trigger the
right to limit use of sensitive personal information under the CCPA.
Right to Non-Discrimination. We will not discriminate against you for exercising
any of the rights described in this section.
Exercising Your Rights
If you are a California resident and would like to exercise your CCPA rights,
you may do so via any of the methods described below:
* Accessing our Data Subject Request web page; or
* Calling us at 1-833-324-9798
Authorized Agent. You may designate someone as an authorized agent to submit
requests and act on your behalf. Authorized agents will be required to provide
proof of their authorization in their first communication with us, and we may
also require that you directly verify your identity and the authority of your
authorized agent.
Businesses operating as an authorized agent on behalf of a California resident
must provide both of the following:
(1) Certificate of good standing with its state of organization; and
(2) A written authorization document, signed by the California resident,
containing the California resident’s name, address, telephone number, and valid
email address, and expressly authorizing the business to act on behalf of the
California resident.
Individuals operating as an authorized agent on behalf of a California resident
must provide a written authorization document, signed by the California
resident, containing the California resident’s name, address, telephone number,
and valid email address, and expressly authorizing the individual to act on
behalf of the California resident.
We reserve the right to reject (1) authorized agents who have not fulfilled the
above requirements, or (2) automated CCPA requests where we have reason to
believe the security of the requestor’s personal information may be at risk.
Verification. Before responding to your request, we must first verify your
identity using the Personal Information you recently provided to us. The
information we need in order to verify your identity differs depending on the
request made and our relationship with you and might include (as applicable)
your name, the email address you regularly use to interact with us, your phone
number, your date of birth, and, if available, your policy number. We will take
steps to verify your request by matching the information provided by you with
the information we have in our records. In some cases, we may request additional
information to verify your identity, or where necessary to process your request.
In some cases, we may also carry out checks, including with third party identity
verification services, to verify your identity before taking any action with
your Personal Information. If we are unable to verify your identity after a good
faith attempt, we may deny the request and, if so, will explain the basis for
the denial.
Contact Us
If you have any questions or comments about this section of the Privacy Policy,
the ways in which we collect and use your Personal Information, your choices and
rights regarding such use, or wish to exercise your rights under California law,
please do not hesitate to contact us at:
Chubb Group
Attention: Privacy Inquiries
202 Hall’s Mill Road, P.O. Box 1600
Whitehouse Station, NJ 08889-1600
Telephone: 1-833-324-9798
E-mail: NAPrivacyOffice@chubb.com
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