CALIFORNIA PRIVACY POLICY
Effective Date
This California Privacy Policy is effective as of Jan. 1, 2023, and was last updated on July 12, 2023.
Scope
In addition to the information contained in our General Website Privacy Policy, this California Privacy Policy provides you with information regarding SullivanCurtisMonroe Insurance Services, LLC, and its affiliated entities (collectively, “SCM,”“we,” “us,” and “our”) treatment of your personal information, except to the extent that it was obtained within the scope of our relationship with you as either an employee, director, officer, independent contractor, or part-time worker, or as an applicant for those positions. To understand how we treat that personal information, please see our California Applicant/Employee Privacy Policy.
“Personal information” is information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked to a particular person or household. In addition to personal information, we may collect, use, and/or disclose aggregate, anonymized, or deidentified data. This data cannot reasonably be linked to any particular individual or household and our collection, use, and disclosure of it is not within the scope of this privacy policy. We only maintain and use such data in deidentified form, and we will not attempt to reidentify it, except to test deidentification and ensure it cannot be associated with anyone.
Your Rights
Under the California Consumer Privacy Act, as amended by the California Privacy Rights Act (collectively, “CCPA”), California residents, including via an authorized agent, have the following rights:
- The right to know what personal information we have collected about you, including the categories of personal information, categories of sources from which we collected the personal information, the purpose for our collection of your personal information, the categories of third parties to whom we disclose personal information, and the specific pieces of personal information we have collected about you;
- The right to delete personal information we have collected from you, subject to certain exceptions;
- The right to correct inaccurate personal information that we maintain about you; and
- The right to not receive discriminatory treatment for exercising your privacy rights.
How to Submit a Request to Know, Access, Correct, or Delete
If you are a California resident and you or your authorized agent would like to submit a request to know, access, correct, or delete your personal information, you can email your request to ccpa@sullicurt.com, call us toll-free at 833-214-5105, or submit the webform available at
https://sullivancurtismonroe.com/wp-content/uploads/2020/07/ccpa-request-form_07012020-1.pdf
What Happens After You Submit a Request to Know, Access, Correct, or Delete
Following a request to know, access, correct, or delete your personal information, we will take commercially reasonable steps to verify your identity, such as asking you to provide information matching what we have in our files (e.g., name, address, email address). If you are an agent authorized to make a request on a California resident’s behalf, please indicate that when submitting your request. Agents must generally provide a signed authorization evidencing their authority to act on behalf of another individual.
Any requests that can be processed by us will be done so in no more than 45 days from the date we receive your request, unless we notify you that an extension is required. In case of an extended completion period, we will process your request in no more than 90 days from the date of your original request. Consumers are limited to two requests to know or access within a 12-month period.
Personal Information Collected and Used Within the Past 12 Months
Below you will find a chart that generally describes the categories of personal information we have collected, where that information came from, and the purpose for the collection of that information all within the past 12 months from the effective date of this notice. Please note that these are categories of personal information as they are set forth under California law and across our various product lines. We did not necessarily collect all of the specific pieces of personal information listed for any given person or product.
For purposes of this privacy policy:
- Personal information collected from you or from others on your behalf means that we receive that information from you or from your employer (e.g., if we administer your employer’s employee benefits plan)
- Operational functions include things like rating, underwriting, and issuing insurance policies, administering benefits, providing services under your or your employer’s insurance contract
| What Personal Information Do We Collect? | Where Do We Get It? | Why Do We Collect It? |
| Identifiers and contact information (e.g., you and your beneficiaries’ names, alias, postal address, unique personal identifier, IP address, email address, account name, Social Security Number, driver’s license number) |
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| Categories of personal information described in Section 1798.80(e) (e.g., name, signature, Social Security number, physical characteristics or description, mailing address, telephone number, driver’s license, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, any other financial information, medical information, health insurance information) | Same as above | Same as above |
| Characteristics of protected classifications under California or federal law (e.g., sexual orientation, gender identity and gender expression, sex, medical conditions, disability, age, genetic information, marital status, military or veteran status, | Same as above |
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| Commercial information (e.g., records of personal property, products or service purchased, obtained, or considered) | Same as above |
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| Audio, electronic, visual, thermal, olfactory, or similar information |
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| Professional or employment-related information |
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Personal Information Disclosed Within the Past 12 Months
Below you will find a chart that generally describes the categories of personal information we have disclosed and the purpose for the disclosure of that information, all within the past 12 months from the effective date of this notice.
| What Personal Information Do We Disclose? | To Whom Do We Disclose It? | Why Do We Disclose It? |
| Identifiers and contact information (e.g., you and your beneficiaries’ names, alias, postal address, unique personal identifier, IP address, email address, account name, Social Security Number, driver’s license number) |
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| Categories of personal information described in Section 1798.80(e) (e.g., name, signature, Social Security number, physical characteristics or description, mailing address, telephone number, driver’s license, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, any other financial information, medical information, health insurance information) | Same as above |
Same as above
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| Characteristics of protected classifications under California or federal law (e.g., sexual orientation, gender identity and gender expression, sex, medical conditions, disability, age, genetic information, marital status, military or veteran status, | Same as above |
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| Commercial information (e.g., records of personal property, products or service purchased, obtained, or considered) | Same as above |
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| Audio, electronic, visual, thermal, olfactory, or similar information |
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| Professional or employment-related information |
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We have not, and do not, sell or share your personal information, as those terms are defined by California law, and we do not use or disclose your sensitive personal information for any purposes other than those permitted by the CCPA (e.g., as necessary to provide goods or services you’ve requested, legal compliance, etc.).
Children under the age of 16
Our website is not intended for children under 16 years of age. No one under the age 16 may provide any personal information on the website. We do not knowingly collect personal information from children under 16 and therefore, we do not sell or share such personal information, as those terms are defined by California law. If you are under 16, do not use or provide any information on this website. If we learn we have collected or received personal information from a child under 16 without verification of parental consent, we will delete that information. If you believe we might have any information from or about a child under 16, please contact us at the email address below.
Document Retention
We will not retain your personal information for longer than reasonably necessary for the purpose(s) we collected it. How long we retain your personal information depends on a number of criteria, including the nature of our relationship with you, whether you or your employer purchases one of our products, which product, when you last interacted or were insured with us, the type of personal information at issue, and legal considerations.
Contact for More Information or Questions
If you have any questions about our privacy policy, information practices, or exercising the rights described above, please contact us at ccpa@sullicurt.com or at 833-214-5105.