Effective: February 1, 2020
Last updated: September 15, 2023
This Policy applies when you interact with us by visiting the Acrisure website ("www.Acrisure.com"); participate in our events, promotions, offerings, or partner activities; or interact or communicate with us as part of our marketing practices or outreach. We offer a variety of products and services (collectively, the "Services"). As part of providing the Services, we collect and receive information in a variety of ways, including information on our websites, from our organizational customers and/or prospective customers, and from individuals that use the Services.
California Consumer Notice of Collection
This Notice of Collection is provided to all California consumers subject to this Policy. You can access specific topics in this Policy by clicking on the relevant links below:
Categories Information We May Collect
Sources of Personal Information
How We Use Your Personal Information
To Whom We Disclose Your Personal Information
Cookies And Similar Tracking Technologies
Your Choices and Rights
Opt Out Of The "Sale" Or "Sharing" Of Personal Information
How We Protect Your Personal Information
How Long We Retain Your Information
Transfers Of Information To Other Countries
Third Parties And Links To Other Websites And Services
Commercially Recognized Opt out Signal
CATEGORIES OF INFORMATION WE MAY COLLECT
The types of personal information we collect about you depends on how you interact with us. "Personal information" refers to information that identifies, relates to, describes, or can be associated with you. Depending on the Services you use, the following are the categories and specific types of personal information that we may collect:
Contact Information/Identifiers, including name, email address, postal address, phone number, username, business contact information, or other similar identifiers.
Government Identifiers, including driver's license number and social security number (in certain instances may be considered sensitive personal information).
Information Specific to the Services, including, in certain instances, marital status, family member information, policy information (e.g., policy number, policy type, coverage(s) and limit(s)) and underwriting, exposure or claims-related data).
Demographic Information, including age, gender, race, ethnicity, and household information, some of which may include characteristics of protected classifications under state or federal law.
Device Information and Other Unique Identifiers, device identifier, internet protocol (IP) address, or similar unique identifiers.
Internet or Other Network Activity, including browsing or search history, and information regarding your interactions with our websites, mobile applications, emails, or advertisements.
Geolocation Data, including information that permits us to determine your location, such as if you manually provide location information or enable your mobile device to send us precise location information.
Vehicle Information, including vehicle identification number and other vehicle information that permits us to determine products sold by us related to your vehicle.
Telematics Information, including information relating to global positioning system ("GPS"), geofencing, and other information gathered from your vehicle security system or other purchased telematics devices.
Payment Information, including credit or debit card number, or other financial information.
Inferences, inferences drawn from or created based on any of the information identified in this section.
Sensitive Personal Information (where permitted and in accordance with applicable law), of the information listed above, social security number, racial or ethnic origin, username, and password, and/or health information are also sensitive personal information.
The provision of the sensitive personal information listed above is voluntary. In certain instances, we will not be able to process your request for our Services without the requested personal information.
SOURCES OF PERSONAL INFORMATION
We collect your personal information in the following ways, pursuant to applicable law:
Directly From You, when you use our Services, register for an account, contact us, respond to a survey, sign up to receive emails, text messages, and/or postal mailings.
Through Purchased Equipment, when you purchase a security system or other device for your motor vehicle, such device may (depending on which device is purchased) be capable of collecting telematics, GPS, and other information about your motor vehicle and its location.
From Our Third Party Partners, including from third parties that we have partnered with to provide you the Services that you have requested from us.
Other Sources, including publicly available sources.
HOW WE USE YOUR PERSONAL INFORMATION
We use your personal information and, in limited instances, your sensitive personal information for the following business purposes (collectively, "Processing Purposes") associated with our general business operations. We may collect your personal information:
Providing the Services
- To provide you the Services, including insurance, real estate, cybersecurity, information technology, motor vehicle finance & insurance (commonly referred to as "F&I"), and consulting services.
- To provide you non-insurance products or services that may be of interest or at your request.
- To process your premium payments and send notifications to you related to your account.
- To enable you to access and use our websites.
Communicating With You
- To communicate with you and to respond to your requests, questions, comments, and other inquiries.
- To understand what partner resources you use, if any, and to connect you to additional resources at your request.
- To offer you personalized advertisements, which you may be able to opt out of as explained in the "Your Choices" section.
- To send marketing and promotional materials, including information relating to our products, services, sales, or promotions or those of a third party.
Analytics and Administration of Websites
- To administer, maintain, evaluate, and improve our websites and the Services, and to develop new products and services.
- To conduct research and analytics related to our websites and the Services.
Marketing and Promotional Purposes
- We may use personal information for marketing and promotional purposes to show you advertisements for products and/or services tailored to your interests on social media and other websites.
Core Business Functions
- To manage our business operations, perform our obligations and exercise our rights under any agreement that you or your organization has with us.
- For other purposes with your consent, or as otherwise permitted or required by applicable law.
Legal and Regulatory Obligations
- We use personal information to comply with our legal or regulatory obligations, to establish or exercise our rights, and to defend against a legal claim.
Security and Fraud Prevention
- We use personal information to detect, investigate, prevent, or take action regarding possible malicious, deceptive, fraudulent, or illegal activity, including fraudulent transactions, attempts to manipulate or violate our policies, procedures, and terms and conditions, security incidents, and harm to the rights, property, or safety of Acrisure and our users, customers, employees, or others.
Use of Your Sensitive Personal Information
- With regard to sensitive personal information, we only use your sensitive personal information to provide you with the requested products or Services and to administer your account.
TO WHOM WE MAY DISCLOSE YOUR PERSONAL INFORMATION
In addition to the specific situations discussed elsewhere in this Policy, we may disclose information in the following situations, as permitted by applicable law or regulation:
- Within Acrisure. We may share your personal information with our corporate affiliates (e.g., parent company, sister companies or subsidiaries, and other companies under common control) or joint ventures to which we are a party.
- Partners. We may disclose your personal information (including sensitive personal information) to our partners with your consent, where required.
- Third Parties. Certain services are provided by third parties on Acrisure's website. By selecting or purchasing a third-party service, you instruct Acrisure to disclose your name, email address, and other contact information with the applicable third party. If you do not desire for Acrisure to disclose your personal information to these third parties, do not select or purchase these third-party services. Their use of your information is not governed by this Policy.
- Other Disclosures with Your Consent. We may ask if you would like us to share your information with other unaffiliated third parties who are not described elsewhere in this Policy.
- Service Providers. We disclose information to service providers as necessary for them to assist us with our business operations and provide services to us, subject to appropriate confidentiality and data protection agreements. Among other things, service providers assist us with website hosting, data storage, data analytics, helping with addressing security, fixing errors, processing payments, providing identity verification services, providing technical support, sending communications (including SMS/text messages), providing assessments, fulfilling user requests, and other activities related to the management of our business and services.
- Government Entities or Regulators. We may disclose information for legal reasons as we believe to be necessary or appropriate to: (a) satisfy any applicable law, legal process, or proper governmental request; (b) enforce any agreement we may have entered into with you or your organization, including investigating any violations or asserting remedies; (c) detect, prevent, or otherwise address fraud, security or technical issues; (d) protect against harm (whether tangible or intangible) to the rights, property, or safety of Acrisure, our users, or the public as required or permitted by law; and (e) establish or exercise our rights, defend against a legal claim, and investigate, prevent, or take action regarding possible illegal activities or a violation of our policies.
- Business Transaction. We may disclose personal information to a potential or actual buyer in the event of any reorganization, merger, sale, joint venture, assignment, transfer, or other disposition of all or any portion of our business, assets, or stock (including in connection with any bankruptcy or similar proceedings), including any due diligence related to such a transaction.
- Sharing with Affiliates and Non-Affiliates for Marketing and Other Purposes. We may share your information with affiliates and non-affiliates for marketing and other purposes. Under certain circumstances, you may opt-out of such sharing with respect to certain data you have provided to us. Please refer to the Privacy Notice received from us for information relating to the sharing of your nonpublic personal information.
- Social Media Platforms and Networks: Some of our websites have features such as, plugins, widgets, or and other tools made available by third parties that may result in information being collected or shared between us and the third party. The third party's use of your information is not governed by this Policy. You may have the right to opt out of our use of these technologies, as further described in this Policy.
- De-identified or Aggregate Information. We may aggregate and anonymize information you provide to us in such a way as to ensure it will no longer be identifiable to you. This data may be used for statistical, analytic, and administrative purposes, including analyzing our website traffic and trends, tailoring our Services, or conducting product analysis. We may share anonymized or aggregated data at our discretion, in accordance with applicable laws.
COOKIES AND SIMILAR TRACKING TECHNOLOGIES
We differentiate between cookies that are essential for the technical features of the Services and optional analytics and advertising cookies.
These are cookies that the Services need in order to function, and that enable you to move around and use the Services and features. Without these essential cookies, the Services will not perform as smoothly for you as we would like them to and we may not be able to provide the Services or certain services or features you request. Examples of where these cookies are used include to determine when you are signed in, to determine when your account has been inactive, and for other troubleshooting and security purposes.
Analytics cookies allow us to understand more about how many visitors we have to our Services, how many times they visit us, and how many times a user viewed specific pages within our Services. Although analytics cookies allow us to gather specific information about the pages that you visit and whether you have visited our Services multiple times, we cannot use them to find out details such as your name or address. We use Google Analytics. For more information about Google Analytics, please refer to "How Google Uses Information From Sites or Apps that Use Our Services," which can be found at www.google.com/policies/privacy/partners/, or any other URL Google may provide from time to time.
You may be able to make the following choices regarding your personal information:
- Promotional Emails. You may choose to provide us with your email address for the purpose of allowing us to send free newsletters, surveys, offers, and other promotional materials to you, as well as targeted offers from third parties. You can stop receiving such promotional emails by following the unsubscribe instructions in emails that you receive. If you decide not to receive promotional emails, we may still send you service-related communications.
- Promotional Mailings. If at any time you do not want to receive offers and/or circulars from us, you can remove yourself from our mailing lists by emailing us (our contact information is below) with "NO SNAIL MAIL" in the subject line, along with your name, address and zip code. Please note that our mailings are prepared in advance of their being sent. Although we will remove your name from our mailing list after receiving your request, you may still receive mailings from us that had been initiated prior to your name being removed.
- Promotional Text Messages. If you receive a text message from us that contains promotional information you can opt-out of receiving future text messages by replying "STOP."
Data Subject Rights
- You may have certain rights regarding your personal information. The rights available to you depend on our reason for processing your personal information and the requirements under applicable law (e.g., your rights will vary depending on whether you are a resident in, for example, California). Specifically, you may have the following rights:
- Access: You have the right to request access to the personal information we hold about you, along with other information such as the purposes of the processing, the recipients or categories of recipients to whom the personal information has been or will be disclosed, the sources of the personal information, retention, and transfers of personal information.
- Correction: You have the right to request correction of inaccurate personal information we have about you. Depending on the purposes of the processing, you may have the right to have incomplete personal information completed, including by means of providing a supplementary statement. As noted above, you may also be able to correct your information in your account or profile.
- Deletion: You have the right to request that we delete your personal information.
- Data Portability: You have the right to receive the personal information about you that you have provided to us, in a structured, commonly used, and machine-readable format.
- The following categories of personal information disclosed are considered "sale"/ "sharing" under California law: direct identifiers, device information, and geolocation data.
- The following categories of third parties to whom personal information was disclosed are considered "sale"/ "sharing" under California law: social media platforms and networks.
- Right of Non-Discrimination/Retaliation: We do not discriminate against individuals who exercise any of their rights described in this Policy, nor do we retaliate against individuals who exercise these rights.
- Right to Opt Out of our Use of your Sensitive Personal Information (in certain instances and if permissible under applicable law). You have the right to request the restriction of processing of your sensitive personal information. At the current time, however, we do not use or disclose sensitive personal information for purposes other than those expressed in this Notice or as otherwise permitted by applicable law, and these uses cannot be limited under California law.
Please note that many of the above rights are subject to exceptions and limitations. Your rights and our responses will vary based on the circumstances of the request. If you choose to assert any of these rights under applicable law or regulation, we will respond within the time period prescribed by such law or regulation. In some cases, we may limit or deny your requests to access or delete your information. This may occur because the law permits or requires us to do so, or if we are unable to adequately verify your identity.
Please note that we must be able to verify your identity to make sure you are the person about whom we have collected personal information or an authorized representative. Depending on the type of request, we may conduct the verification process by email or phone using information that matches our records. The information you must provide as part of the verification process may include: name, contact information (such as email address or phone number), relationship with us, and residency. We may also ask for additional information as needed based on your relationship with us.
You may also designate an authorized agent to submit a request on your behalf to access or delete your personal information. To do so, you must (1) provide that authorized agent written and signed permission to submit such request, and (2) verify your own identity directly with us. You can download an Authorized Agent Designation Form here. Please note, we may deny a request from an authorized agent that does not submit proof that they have been authorized to submit such request.
To submit a request to exercise any such rights (if they apply to you), please use the Data Subject Privacy Rights request portal applicable to you.You may also contact us at: 877-504-9487 or send us an email at [email protected].
HOW WE PROTECT YOUR PERSONAL INFORMATION
No method of transmission over the Internet, or method of electronic storage, is fully secure. While we use reasonable efforts to protect your personal information from unauthorized access, use, or disclosure, we cannot guarantee the security of your personal information. In the event that we are required by law to inform you of a breach to your personal information we may notify you electronically, in writing, or by telephone, if permitted to do so by law.
Some of our websites may permit you to create an account. When you do, you will be prompted to create a password. You are responsible for maintaining the confidentiality of your password, and you are responsible for any access to or use of your account by someone else that has obtained your password, whether or not such access or use has been authorized by you. You should notify us of any unauthorized use of your password or account by using one of the methods listed below under "Contact Information."
HOW LONG WE RETAIN YOUR INFORMATION
We retain information about you and your use of our Services for as long as is needed to fulfill our legitimate business purposes outlined in this Policy. The specific periods for which we keep information about you vary depending on the nature of the information, why we need it, and whether the personal information is de-identified. We also consider the minimum necessary retention period prescribed by applicable laws, recommended by industry standards, and stated in contracts and other legal obligations.
TRANSFERS OF INFORMATION TO OTHER COUNTRIES
We are based in the United States. If you are located outside of the United States, you should be aware that your personal information may be transferred to, stored, and processed in a country other than the one in which it was collected, including the United States, and the laws may be less stringent than the laws in your country. Where required by applicable law, we will provide appropriate protections for personal information transferred to the United States, including by implementing appropriate contractual controls.
Our Services are not intended for persons under 13 years of age. We do not knowingly collect or maintain personal information from persons under 13 years of age. If we learn that we have collected personal information from persons under 13 through our Services, we will take appropriate steps to delete this information.
THIRD PARTIES AND LINKS TO OTHER WEBSITES AND SERVICES
Our websites and Services may contain links to websites, content, or services owned or operated by third parties. Please note, we have no control over the privacy practices of websites or services that we do not own. We encourage you to review the privacy policies of any third-party website or application for details about what information is collected and how it is used and/or disclosed.
COMMERCIALLY RECOGNIZED OPT OUT SIGNAL
Acrisure generally recognizes commercially recognized opt-out preference signals (e.g., Global Privacy Controls). Recognition of this signal applies only to the specific device and/or browser that communicates the signal and does not cross over to all devices/browsers you use to access the Services.
CHANGES TO THIS POLICY
We may update this Policy from time to time to reflect changes to our practices, technology, legal requirements, and other factors. When changes are made to this Policy, they will become effective immediately upon posting. You can check the date at the top of this page to see when this Policy was last revised. We encourage you to review this Policy periodically for the latest information on our information processing practices.
If you have any questions, comments, or complaints concerning our privacy practices, or, where required by law, if you would like to submit a request based on a right listed in this Policy, please contact us at the appropriate address below. We will attempt to respond to your requests and to provide you with additional privacy-related information.
100 Ottawa Avenue SW
Grand Rapids, MI 49503
Attention: Acrisure Privacy Office