ICW Group Holdings, Inc. and the California Department of Insurance want insurance customers and consumers located in California to understand your rights related to your personal information. This notice is specifically intended for use in the State of California. Any rights that a consumer, claimant, or beneficiary may have as described in this Notice of Informational Practices for California Insurance Customers and Consumers are not limited by any other or standard notice issued by ICW Group. However, additional information for individuals residing in California is also set forth in ICW Group’s California Privacy Policy.
Important Privacy Choices
California insurance laws and regulations contain provisions governing disclosures of privacy choices. This notice includes information concerning the categories of nonpublic personal and financial information that we may disclose, categories of nonaffiliated third parties to which we may disclose your information, and that you have certain rights to limit disclosures if you are a consumer residing in California who obtains insurance products or services from ICW Group. ICW Group reserves the right to disclosure nonpublic personal financial information about consumers to nonaffiliated third parties. However, California consumers have the right to opt out of such disclosures under certain circumstances. Your rights are summarized in the notice below, which includes an explanation of how you may exercise your rights to opt out or limit our sharing of your information.
Categories of Information We Collect and Disclose to Others
In providing products and services to you, we collect information about you. We may share this data for business and legal reasons, both during and after our relationship with you. Here are some examples of the types of personal information we may collect:
- Identifiers, such as your Social Security Number or tax ID number, real name, alias, street address, mailing address, email address, IP address, online identifiers, unique personal identifiers, account name, account number, date of birth, passport number, driver license or state identification, number, or other similar identifiers;
- Personal Information, including Identifiers noted above, signature, physical characteristics or description, telephone numbers, insurance policy numbers, insurance claim numbers, education, employment information including job history and earnings, employment performance information, banking account numbers, credit or debit card numbers, financial data and account numbers, health and medical information, health insurance information, driving and motor vehicle records, accident history, consumer reporting agency, investigative and credit bureau reports;
- Geolocation and Sensory Data, including data reflecting physical location and/or movements; audio, electronic, visual, thermal, olfactory, or similar information;
- Inferences drawn from personal data that may reflect on your personal preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities and aptitudes;
- Protected Classification Characteristics, such as age, race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, or genetic information (including familial genetic information);
- Claims Data, including insurance claim history, transaction or loss history, data about past and present claims, which may include data regarding your health, injuries, physical, personal and financial damages suffered, criminal convictions, third party reports, and other personal data;
- Internet and Network Activity, and Commercial Information, including browsing history, search history, data associated with your interaction with websites, computer or digital applications, responses to advertisements, purchasing or consuming histories or tendencies; and
- Insurance, Business, and Financial information, including financial information, personal property records, billings, account balances and payment histories, account transactions and transaction histories, credit and overdraft histories, information obtained in connection with any application for insurance or renewal of insurance, and information concerning products and services applied for, considered, purchased or obtained.
How We Collect Your Information
ICW Group may collect your personal information from you, both directly and indirectly, as well as from some third parties. For example:
- Much of the data we collect about you comes from you, your application, your agent or broker, and your representatives assisting you with insurance-related matters.
- We get data from your transactions with us. For example, the insurance you purchase, your account balances and your payment history, claims and losses.
- If you make a claim for benefits under an insurance policy issued by ICW Group, we may obtain information from third parties having information about the circumstances of your claim, your injuries, medical care, or losses you suffered. If you work for a company that has obtained an insurance policy from ICW Group, we may also obtain information from your employer.
- We may also get data from consumer reports, insurance-support organizations, credit bureaus, healthcare providers, investigators, and claims adjusters and examiners. This may include claim history reports, motor vehicle reports or credit reports. In some cases, information from a report prepared by an insurance-support organization may be retained by that organization and disclosed to others.
How We Use Your Information
Some of the ways ICW Group uses your information may include:
- We use your information for our everyday business purposes, such as to process insurance transactions, maintain accounts, respond to court orders and legal investigations, or report to credit bureaus.
- We may use your information for marketing purposes to tell you about ICW Group products or services, which may include products or services we jointly market with other financial companies.
- We may use or share your information with our affiliates for everyday business purposes, to review your creditworthiness, or for marketing.
- We may use your information as permitted by law.
- We do not share your medical information except to provide insurance services or as allowed by law.
Information We Share
ICW Group may use your information as permitted by law and only shares your personal information as allowed by law.
Certain disclosures of personal information are permitted by law, and in some circumstances may be disclosed for permitted purposes without prior authorization from the person whose information is being disclosed. Although not a complete list of every potential instance in which information may be lawfully disclosed, following are some examples of circumstances in which an insurer may disclose information without your prior authorization:
- To enable the person receiving the information to perform a business, professional or insurance function for you, ICW Group, our policyholder, or an insurance agent or insurance-support organization;
- To enable the person receiving the information to perform functions related to detecting or preventing criminal activity, fraud, or similar misconduct;
- To a medical care professional or facility to verify insurance coverage or benefits, or for audit purposes;
- To insurance regulatory authorities, law enforcement or other governmental authorities, in response to a subpoena or other legal order;
- An insurer may disclose information for purposes of conducting actuarial or research studies as permitted by law;
- An insurer may disclose information to third-parties for marketing purposes under limited circumstances, but you will be given an opportunity to op-out of our sharing with nonaffiliated third parties for marketing purposes if the information to be disclosed contains any medical or privileged information, or any personal information regarding an individual’s character, habits, mode of living or general reputation, or any classification derived from your information;
- An insurer may disclose information to its affiliates for audit or marketing purposes. California insurance laws permits an insurer to disclose nonpublic financial information to its affiliates for marketing purposes without your prior authorization. California insurance laws do not allow customers to restrict such disclosures. Some consumers may have rights to restrict or opt-out of sharing your information for marketing purposes under other laws; and
- To others as otherwise permitted or required by law.
We may share your information, during and after our relationship with you, with the following:
- ICW Group Affiliates, including but not limited to ICW Group Holdings, Inc., Insurance Company of the West, ICW National Ins. Col, ICW Casualty Ins. Co., ICW Premier Ins. Co, Explorer Insurance Company, VerTerra Insurance Company, On Point Risk Solutions, Inc., and Risk Insurance Brokers;
- Insurance agents or brokers;
- Other insurers to respond to your application for insurance;
- Reinsurance companies;
- Claims administrators, adjusters and examiners;
- Insurance regulators or law enforcement officials;
- Lienholders, assignees, lessors, or other persons having a beneficial or legal interest in an insurance policy or policy proceeds;
- Others to evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of ICW Group’s assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by ICW Group about our users is among the assets transferred;
- Others to respond to law enforcement requests and as required by applicable law, court order, or governmental regulations;
- Others to investigate or prevent fraud;
- Others to help maintain the safety, security, and integrity of our systems, services, databases and other assets;
- Companies that provide motor vehicle reports, credit reports or claims history;
- Auto repair shops, medical providers, building contractors or others providing services covered by your insurance policy; and
- Contractors, service providers, and other third parties who require such information to support our business.
We May Share with Affiliated Companies
ICW Group reserves the right to share your nonpublic personal and financial information with its affiliates for marketing purposes or for other permitted purposes without getting your prior written consent where permitted by law.
Practices to Protect Confidentiality and Security
We have physical, electronic, and procedural safeguards to protect your information. We only share your information with employees and third parties who need to see it. Their use of your information is limited by law and written agreements, where appropriate.
Unfortunately, the transmission of information via the internet is not completely secure. Although we do our best to protect your information, we cannot guarantee the security of your information transmitted to our website. Your transmission of information is at your own risk.
How To Submit Requests Concerning Your Personally Identifiable Data
Per Calif. Insurance Code §791.08(a), if an individual California resident with proper identification submits a written request to an insurance company for access to recorded personal information about that individual, which information is reasonably described by the individual when making the request, the insurance company will respond to such request within 30 Business Days. If the requested information is reasonably locatable and retrievable, the insurance company will inform the individual of the nature and substance of such recorded personal information. Subject to exceptions established by law, the insurance company will permit the individual to see and obtain a copy of the information requested, which may include the source of the information and names of parties to whom the information was disclosed in the preceding two years.
If you are an individual residing in California and would like to know what information ICW Group has that is personally identifiable to you, or if you want to request correction, amendment or deletion of any such recorded information, you may submit your request by calling (866) 442-9477, by email to dataprivacy@ICWgroup.com, or you may submit a request online at https://www.icwgroup.com/consumerprivacy/.
- Your request must describe the records you want to see. If you are requesting that information about you be corrected, amended or deleted, you must describe the information and the changes you want made in ICW Group records.
- If we can reasonably locate and retrieve the requested records, your personal information will be provided to you in accordance with applicable laws.
- ICW Group may charge a reasonable fee to cover the costs in providing records.
- We may not be able to provide information if it is privileged or relates to investigations, claims, litigation, civil or criminal proceedings, or similar or related matters.
- If you request that ICW Group correct, amend or delete records about you, we will respond to you in writing with a statement as to what records, if any, were located and whether ICW Group has changed, amended or deleted your information per your request. If your personally identifiable information is changed, amended or deleted at your request, we will also notify any other person specifically designated by you who may have received such information from ICW Group within the preceding two years. ICW Group may also notify insurance-support organizations of corrections, amendments or deletions of your personal information if required or as permitted by law.
If you are a policyholder, you may send a written request to your agent or broker asking for copies or your records or information concerning your insurance policy or account. If you are a policyholder and have established an online account with or through ICW Group, you may be able to change or correct information by signing into your account. You may also send correction or data deletion requests to your agent or broker. Requests for information, corrections, amendments or deletion of your information may also be submitted by email to dataprivacy@ICWgroup.com.
Responses to requests for information will normally be completed within 30 Business Days of the request. If we are unable to locate or provide the records you have requested, or if ICW Group does not make requested corrections, amendments or deletions, we will notify you in writing. If you disagree with ICW Group’s response, you have the right to file a statement to explain the reasons why you disagree with our determination. Any such statement should be concise, setting forth what you think is the correct, relevant or fair information, and a concise statement of the reasons why you disagree with our decision regarding your request for correction, amendment or deletion. If you file such a statement, ICW Group may provide copies of your statement to any other person specifically designated by you who may have received such information from ICW Group within the preceding two years, as well as others who may have access to your information. ICW Group may also notify insurance-support organizations of corrections, amendments or deletions of your personal information if required or as permitted by law.
You May Request Changes in How ICW Group Uses or Shares Your Data: If you are an individual residing in California and want to limit how ICW Group uses or shares your personally identifiable information, or to obtain copies of your information or request corrections or changes in the information ICW Group has about you, you may submit your request by calling (866) 442-9477, by email to dataprivacy@ICWgroup.com, or by submitting your request online at https://www.icwgroup.com/consumerprivacy
Contact Us: For questions about ICW Group privacy policies and informational practices, you may contact us at:
ICW Group Holdings, Inc.
Attention: Law Department
15025 Innovation Drive
San Diego, CA 92128
Toll-free Telephone: (866) 442-9477
Email: dataprivacy@icwgroup.com
