CALIFORNIA ONLINE PRIVACY POLICY

 

SullivanCurtisMonroe Insurance Services, LLC (“SCM”) has developed this Privacy Policy out of respect for the privacy of visitors to our Website. This policy describes the personal information we collect, use, and disclose about individual consumers who do business with us directly or visit or interact with this Website and are California residents. This policy applies only to California residents who are natural persons; it does not apply to any entities (whether business, non-profit or governmental) or to any person who is not a California resident. For our general privacy policy, please visit https://sullivancurtismonroe.com/privacy-policy/.

Whenever you visit our Website, we will collect some information from you automatically simply by you visiting and navigating through this site, and some voluntarily when you submit information using any interactive form on the Website. Through this Website, we will collect information that can identify you and/or your activity.

And whenever you communicate, interact or do business with us, whether online or offline, we will be collecting personal information from you or about you in the course of our interaction or dealings with you.

SCM may collect the following categories of personal information about you based on your specific transactions and interactions with SCM or our Website. For each category of information, we identify examples of the category, the business purposes for which we use the information in that category, the categories of sources from which the information is collected, and the categories of third parties with whom we have shared the information in the last 12 months.

Category of Personal Information Personal Identifiers & Contact Information
Examples Name, alias, mailing address, email address, phone number, account name, social security number, driver’s license number, passport number, signature
Business Purpose(s) for Which Information is Used
  • To fulfill or meet the reason you provided the information;
  • To comply with, or exercise rights under, applicable law;
  • To market to you products and services, including through the use of targeted or similar advertising on the internet;
  • To provide or receive shared organizational services;
  • To evaluate or effect a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, in which personal information held by us about our consumers is among the assets evaluated or transferred.;
  • Responding to inquiries through Website; and
  • Verifying and responding to consumer requests.
Categories of Sources from Which Information Received Visitors of our Website; Directly from a Consumer through insurance applications, communications, etc.; from Third Parties, such as insurance carriers or industry providers.
Categories of Third Parties to Whom Info Was Disclosed in Last 12 Months
  • Service Providers;
  • Insurance Carriers or other Industry Providers; and
  • As required by law.
Category of Personal Information Internet Activity
Examples Date and time of your visit to this Website; webpages visited; links clicked on the Website; browser ID; browser type; browser history; device ID; operating system; form information downloaded; domain name from which our site was accessed; and cookies
Business Purpose(s) for Which Information is Used
  • Improving the Website experience for all visitors;
  • Understanding the demographics of our Website visitors;
  • Operating and maintaining the Website;
  • Detecting security incidents;
  • Debugging to identify and repair errors that impair existing intended functionality of the Website;
  • Protecting against malicious or illegal activity and prosecuting those responsible; and
  • Verifying and responding to consumer requests.
Categories of Sources from Which Information Collected Visitors of our Website and the device and browser used to access the Website
Categories of Third Parties to Whom Info Was Disclosed in Last 12 Months We do not share this information with any third party, unless required to do so by law or government agency or for the purpose of defending or prosecuting legal claims.
Category of Personal Information Commercial Information
Examples Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies
Business Purpose(s) for Which Information is Used
  • To fulfill or meet the reason you provided the information;
  • To comply with, or exercise rights under, applicable law;
  • To market to you products and services, including through the use of targeted or similar advertising on the internet;
  • To provide or receive shared organizational services;
  • To evaluate or effect a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, in which personal information held by us about our consumers is among the assets evaluated or transferred;
  • Responding to inquiries through Website; and
  • Verifying and responding to consumer requests.
Categories of Sources from Which Information Received Visitors of our Website and the device and browser used to access the Website; Directly from a Consumer through insurance applications, communications, etc.; from Third Parties, such as insurance carriers or industry providers.
Categories of Third Parties to Whom Info Was Disclosed in Last 12 Months
  • Service Providers;
  • Insurance Carriers or other Industry Providers; and
  • As required by law.
Category of Personal Information Professional or Employment-Related Information
Examples Current or past job history
Business Purpose(s) for Which Information is Used
  • To fulfill or meet the reason you provided the information;
  • To comply with, or exercise rights under, applicable law;
  • To market to you products and services, including through the use of targeted or similar advertising on the internet;
  • To provide or receive shared organizational services;
  • To evaluate or effect a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, in which personal information held by us about our consumers is among the assets evaluated or transferred.;
  • Responding to inquiries through Website; and
  • Verifying and responding to consumer requests.
Categories of Sources from Which Information Received Visitors of our Website; Directly from a Consumer: through insurance applications, communications, etc.
Categories of Third Parties to Whom Info Was Disclosed in Last 12 Months
  • Service Providers;
  • Insurance Carriers or other Industry Providers; and
  • As required by law.
Category of Personal Information Financial Information
Examples Bank account number, credit card number, debit card number, or any other financial information
Business Purpose(s) for Which Information is Used
  • To fulfill or meet the reason you provided the information;
  • To comply with, or exercise rights under, applicable law;
  • To provide or receive shared organizational services;
  • To evaluate or effect a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, in which personal information held by us about our consumers is among the assets evaluated or transferred.;
  • Responding to inquiries through Website; and
  • Verifying and responding to consumer requests.
Categories of Sources from Which Information Received Visitors of our Website; Directly from a Consumer through insurance applications, communications, etc.; from Third Parties, such as insurance carriers or industry providers.
Categories of Third Parties to Whom Info Was Disclosed in Last 12 Months
  • Service Providers;
  • Insurance Carriers or other Industry Providers; and
  • As required by law.

 

Do we sell any of your personal information?

SCM does NOT and will not sell your personal information, including the data of any minors. We do not sell or otherwise trade the personal information that we collect from our site visitors at any point or under any circumstance.

 

Third-party vendors

SCM may use other companies and individuals to perform certain functions on our behalf. Examples include administering technology services and administrative support services. Such parties only have access to the personal information needed to perform these functions and may not use or store the information for any other purpose. Subscribers or site visitors will never receive unsolicited e-mail messages from vendors working on our behalf.

 

Business transfers

In the event SCM sells or transfers a particular portion of its business assets, consumer information may be one of the business assets transferred as part of the transaction. If substantially all of the assets of SCM are acquired, consumer information may be transferred as part of the acquisition.

Compliance with law/safety

SCM may disclose specific personal information based on a good faith belief that such disclosure is necessary to comply with or conform to the law or that such disclosure is necessary to protect the users of our Website, the site itself, or the public.

 

Use of cookies and other tracking technologies

Cookies are small files that a Website may transfer to a user’s computer that reside there for either the duration of the browsing session (session cookies) or on a permanent (until deleted) basis (persistent cookies) that may be used to identify a user, a user’s machine, or a user’s behavior. We make use of cookies under the following circumstances and for the following reasons:

  • Compile data about site traffic to offer a better Website experience
  • Understand and save visitor preferences for future visits

 

Do Not Track (DNT) is a privacy preference that users can set if they do not want web services to collect information about their online activity. However, there is currently no universal standard for sending and receiving DNT signals. Due to this lack of universal standards, it would be impossible for us to promise that we comply with all known and unknown DNT standards.

Therefore, we do not respond to DNT signals or other mechanisms that provide a choice regarding the collection of personal information about activities over time and across different Web sites or online services. If a universal standard for DNT becomes available, we may revisit our DNT Policy.

 

External links

Our website contains links to other sites. SCM is not responsible for the privacy practices or the content of such websites. To help ensure the protection of your privacy, we recommend that you review the privacy policy of any site you visit via a link from our website.

 

Your Rights as a California Consumer

If you are a California resident, you have the following rights:

  1. Right to Know. The right to request, up to 2 times in a 12-month period, that we identify to you (1) the categories of personal information we have collected, disclosed or sold about you in the last 12 months, (2) the categories of sources from which the personal information was collected, (3) the business purpose for which we use this information, and (4) the categories of third parties with whom we share or have shared your personal information in the last 12 months;
  2. Right to Access. The right to request, up to 2 times in a 12-month period, that we provide you access to or disclose to you, free of charge, the specific pieces of personal information we have collected about you in the last 12 months;
  3. Right to Delete. The right to request, up to 2 times in a 12-month period, that we delete personal information that we collected from you, subject to certain exceptions;
  4. Right to Opt-Out. The right to opt-out of the sale of your personal information to third parties;
  5. The right to designate an authorized agent to submit one of the above requests on your behalf; and
  6. The right to not be discriminated against in receiving different or less favorable pricing, service or financial incentive for exercising any of the above rights.

 

How to submit a request

You can submit any of the above 4 types of consumer requests by any of the 2 options below:

  1. Submit an online request on our website by completing the request form here and email to ccpa@sullicurt.com.
  2. Call our privacy toll-free line at 833-214-5105

 

How we will verify that it is really you submitting the request

When you submit a Right to Know, Right to Access, or Right to Delete consumer requests through one of the methods provided above, we will ask you to provide some information in order to verify your identity and respond to your request. Specifically, we will ask you to verify information that can be used to link your identity to particular records in our possession, which depends on the nature of your relationship and interaction with us. For example, if your sole interaction with us was as a website visitor, then in order to verify your identity, we will need to ask you to provide your name, email, phone number, IP address, device ID, browser ID, and/or a cookie ID.

 

How to authorize an agent to act on your behalf

You can authorize someone else as an Authorized Agent who can submit a consumer request on your behalf. To do so, you must either (a) execute a valid, verifiable, and notarized Power of Attorney or (b) provide other written authorization that we can then verify. When we receive a consumer request submitted on your behalf by an Authorized Agent, that person will be asked to provide written proof that they have your permission to act on your behalf, and we will also contact you and ask you for information to verify your own identity directly with us and not through your Authorized Agent.

 

Responding to your Right to Know, Right to Access, and Right to Delete requests

We endeavor to respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time (up to 45 days or 90 days total from the date we receive your request), 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 your verifiable consumer request. The response we provide will also explain the reasons we cannot comply with a request, if applicable. We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, 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.

 

Children under the age of 16

Our Website is not intended for children under 16 years of age. No one under age 16 may provide any personal information on the Website. We do not knowingly collect personal information from children under 16. 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.

 

How we protect the information that we collect

The protection of the information that we collect about visitors to this Website is of the utmost importance to us and we take every reasonable measure to ensure that protection, including:

  • We use internal encryption on all data stores that house voluntarily captured data.
  • We use commercially reasonable tools and techniques to protect against unauthorized access to our systems.
  • We restrict access to private information to those who need such access in the course of their duties for us.

 

Questions about this policy

If you have any questions about this Privacy Policy, you should contact us by phone at 949-852-4803 or via email at pbraccini@sullicurt.com

 

Consent to Terms and Conditions

By using this Website, you consent to all Terms and Conditions expressed in this Privacy Policy.

 

Changes

From time to time we may modify and/or update this Privacy Policy and so we encourage you to check back on a regular basis to determine if any changes have been made.

 

Effective Date (last updated on):  March 11, 2020