MEMIC’s California Privacy Notice
Effective Date: January 1, 2020
This California Privacy Notice applies solely to individual residents of the state of California (“consumers” or “you”) and supplements our Website Privacy Notice by providing additional information about how we collect, use, disclose and otherwise process personal information of consumers within the scope of the California Consumer Privacy Act of 2018 (“CCPA”).
Unless otherwise expressly stated, all terms defined in this Privacy Notice have the same meaning as defined in our Website Privacy Notice or as otherwise defined in the CCPA.
For purposes of this Privacy Notice, “personal information” means information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household. It does not include, and this Privacy Notice does not cover, information excluded from the CCPA’s notice requirements, including:
- Information that is made publicly available from government records,
- Information that is deidentified or aggregated such that it is not reasonably capable of being associated with or reasonably linked to you,
- Information reflecting communications or transactions between us and representatives of our policyholders and other third-party entities in connection with us considering, providing or receiving a product or service to or from the policyholder or other third-party entity,
- Information that we process solely on behalf of our policyholders as a “service provider,” which includes claims and other information relating to individual workers covered by the insurance policies of our policyholders, and
- Information relating to job applicants, employees and other MEMIC personnel.
Collection, Use and Disclosure of Personal Information
In the last 12 months, we have not knowingly sold personal information about you, but we have collected and disclosed for a business purpose the following categories of personal information:
- Identifiers, such as full name, alias, account name and password, social media handle, IP address and other unique personal identifiers;
- California Customer Records (Cal. Civ. Code § 1798.80(e)), such as e-mail address, physical address, fax number and telephone number;
- Protected Classification Characteristics, such as age;
- Commercial Information, such as workers’ compensation and insurance products or services you may be interested in;
- Internet/Network Information, such as log data (including IP address) and analytics data (including your usage and activity on our website);
- Geolocation Data, such as your general geographic location based on the log data we or our third-party providers collect;
- Sensory Information, such as audio recordings of phone calls you have with us or photographs and video footage you choose to provide or we otherwise record as permitted by law;
- Professional/Employment Information, such as current occupation, job title, company/employer and employment history;
- Non-Public Education Information (20 U.S.C. § 1232g, 34 C.F.R. Part 99), such as education information you choose to provide us in connection with a scholarship application;
- Other Personal Information, such as messages or requests you provide to us directly or through a third-party service, such as social media;
- Inferences, such as deriving insurance products of interest from other personal information we have collected about you.
We collect this information directly from you, from your browser or device when you interact with our website, from third parties including our prospective and actual policyholders, agents, and service providers, and from public third-party platforms such as social media websites, online databases or online directories.
We collect personal information for the purposes described in the How We Use the Information We Collect section of our Website Privacy Notice, as well as to examine your eligibility for a scholarship (where applicable).
The categories of third parties to whom we disclose personal information for a business purpose may include our subsidiaries, contractors, claims providers, medical/pharmaceutical providers, data storage providers, communications providers, marketing and analytics providers, payment processors, event coordinators, other service providers and other third parties we use to support our business, this website and our scholarship program, such as colleges and universities. For more information, please refer to the Personal Information We Disclose section of our Website Privacy Notice.
Your California Privacy Rights
As a California resident, you may be able to request to exercise the following rights in relation to the personal information about you that we have collected (subject to certain limitations at law):
- Right to Know: You have the right to request any or all of the following information relating to your personal information we have collected and disclosed in the last 12 months, upon verification of your identity:
- The specific pieces of personal information we have collected about you;
- The categories of personal information we have collected about you;
- The categories of sources of the personal information;
- The categories of personal information that we have disclosed to third parties for a business purpose, and the categories of recipients to whom this information was disclosed;
- The categories of personal information we have sold about you (if any) and the categories of third parties to whom the information was sold; and
- The business or commercial purposes for collecting or, if applicable, selling personal information about you.
- The Right to Request Deletion: You have the right to request the deletion of personal information we have collected from you, subject to certain exceptions.
You also have the right to be free from discrimination for exercising these rights. However, please note that if the exercise of these rights limits our ability to process personal information (such as in the case of a deletion request), we may no longer be able to provide you our products and services or engage with you in the same manner.
To Exercise Your Rights for Information We Process on Behalf of Policyholders
We often act as a “service provider” under the CCPA by processing information solely on behalf of our policyholders. If you would like to request to exercise any rights you may have under the CCPA in relation to information we process as a service provider, please direct your request to your employer who holds a policy with us. Your employer will determine the extent to which the CCPA and its associated consumer rights apply to you.
To Exercise Your Right to Know or Right to Deletion
Please submit a request specifying the right you wish to exercise by:
- Emailing email@example.com with the subject line “California Rights Request,” or
- Calling our toll-free U.S. phone number: 1-800-660-1306.
In certain circumstances, you are permitted to use an authorized agent to submit requests on your behalf where (i) you provide sufficient evidence to show that the requestor is an authorized agent with written permission to act on your behalf and (ii) you successfully verify your own identity with us.
Changes to our California Privacy Notice
We may amend our California Privacy Notice from time to time and will post the date of the last revision at the beginning of this Privacy Notice. You are responsible for periodically checking for changes to this Privacy Notice by visiting our website.
If you have any questions about this California Privacy Notice or our privacy practices, please contact our Director of Risk Management at firstname.lastname@example.org or call 1-800-660-1306.