We think transparency is important. In this overview, we summarize the personal information we collect and how we use it, which is further explained in our Policy below. Keep in mind that the actual personal information we collect and how we use it varies depending upon the nature of our relationship and interactions with you. Also, in some cases (such as where required by law), we ask for your consent or give you certain choices prior to collecting or using certain personal information.
Categories of Personal Information Collected. Generally, we may collect the following categories of personal information:
- Customer Records
- Commercial Information
- Usage Data
- Geolocation Data
- Audio, Video and Electronic Data
- Professional information
- Education Information
- Protected Classifications
Use of Personal Information. In general, we may use and disclose the personal information we collect for the following business and commercial purposes:
- Providing our Services
- Communicating with you
- Personalizing content and experiences
- Marketing and advertising
- Analyzing and improving the Services and our business
- Complying with legal obligations
- Protection of rights
- In support of our general business operations
- Securing and protecting assets and rights
California Residents: If you are a California resident, please refer to the “Additional Information for California Residents” section below for important information about the categories of personal information we collect and disclose, as well as your rights under California privacy laws.
Information We Collect About You
We collect information about you directly from you, from third parties, and automatically through your use of our Sites or Services.
Information We Collect Directly From You. The information we collect from you depends on how you use our Services. For example, when you use our Services to request a potential quote for or other information about insurance, we collect your first and last name, address, age, spouse’s name, spouse’s age, email address, and phone number. In addition, on some of our Sites, we provide an open comments field for you to provide us with any additional information you would like to include in your submission. Please do not include any sensitive personal information in this field, including any health-related information.
Information We Collect From Third Parties. We collect certain information from third parties, such as data brokers. This includes your contact information and certain demographic information such as your income.
Information We Collect Automatically. We automatically collect information about your use of our Sites through cookies, web beacons, and other technologies, such as: domain name, your browser type and operating system, web pages you view on the Sites, links you click on the Sites, your IP address, the length of time you visit our Sites or use our Services, and the referring URL or the webpage that led you to our Sites.
How We Use Your Information
We may use and disclose your information, including your personal information, for the following business and commercial purposes:
- Providing our Services: to provide and operate our Sites and Services, including to contact you regarding insurance quotes or other information you request, to provide troubleshooting and technical support, to fulfill your orders and requests, and to protect and secure our Services.
- Communicating with you: to communicate with you about your use of our Services, to administer surveys and questionnaires, such as for market research or member satisfaction purposes; and for other customer service purposes.
- Personalizing content and experiences: to tailor the content and information that we may send or display to you, to offer location customization, and to otherwise personalize your experiences while using the Services.
- Marketing and advertising: to send you newsletters or other information we think may be of interest you; to contact you about our Services or information we think may be of interest you; to administer promotions and contests; to assist us in advertising on third-party websites, mobile apps, and other online services; and to evaluate the success of our marketing and adverting campaigns (including our online targeted advertising on third party sites and platforms and our offline promotional campaigns). Where required by applicable law, we will obtain your consent to use your personal information for marketing and related purposes. You may unsubscribe from our mailing lists at any time by using the “unsubscribe” feature in any marketing emails you receive from us.
- Analyzing and improving the Services and our business: to better understand how users access and use the Site and our Services, as well as other products and offerings, both on an aggregated and individualized basis; and to administer, monitor, and improve our Services, for our internal purposes and for other research and analytical purposes. For example, we may evaluate which features of our Sites are most used by users.
- Complying with legal obligations: to comply with legal obligations, as part of our general business operations, and for other business administration purposes.
- In support of our general business operations: relating to audits and assessments of our business operations, security controls, financial controls, records and information management program, and otherwise relating to the administration of our general business, accounting, record keeping and legal functions.
- Securing and protecting assets and rights: to protect our business operations, secure our network and information technology assets and services; to prevent and detect fraud, unauthorized activities, access, and other misconduct; where we believe necessary to investigate, prevent or take action regarding suspected violations of our Terms and other agreements, as well as fraud, illegal activities, and other situations involving potential threats to the rights or safety of any person or third party; and as necessary to defend our legal interests and rights.
Aggregate, De-identified or Anonymous Data. We also create and use aggregate, anonymous, and de-identified data to assess, improve and develop our business, products and the Services, and for similar research and analytics purposes. This information is not generally subject to the restrictions in this Policy, provided it does not identify, and could not be used to identify, a particular individual.
How We Share Your Information
We may disclose the personal information we collect as follows:
- Service providers: to service providers, contractors, or agents who perform functions on our behalf. These service providers include information technology service providers and other professional services service providers.
- Affiliates and agents: to our affiliates or subsidiaries and independent insurance agents so that they can provide you with information about goods and services that may be of interest to you.
We also may disclose the personal information we collect for the following business and commercial purposes:
- Mergers, acquisitions, and business transfers: to another company, where (i) we or our affiliates are or may be acquired by, merged with, or invested in by such company or (ii) if any of our assets are or may be transferred to such company, whether as part of a bankruptcy or insolvency proceeding or otherwise. As part of the business transfer process, we also may disclose certain personal information with lenders, auditors, and third party advisors, including attorneys and consultants, subject in each case to our compliance with applicable laws.
- Compliance and legal process: to comply with the law, a judicial proceeding, court order, or other legal process, such as in response to a court order or a subpoena.
- To protect us and others: when we believe it is appropriate to do so to investigate, prevent, or take action regarding illegal activities, suspected fraud, situations involving potential threats to the safety of any person, violations of our Terms of Service or this Policy, or as evidence in litigation in which we are involved.
Aggregate and de-identified information. We also may share aggregate, anonymized, or de-identified information about users with third parties for marketing, advertising, research, or similar purposes.
Cookies. Cookies are alphanumeric identifiers that we transfer to your device’s hard drive through your web browser for record-keeping purposes. Some cookies allow us to make it easier for you to navigate our Sites and Services, while others are used to enable a faster log-in process or to allow us to track your activities at our Sites and Service. Most web browsers automatically accept cookies, but if you prefer, you can edit your browser options to block them in the future. The Help portion of the toolbar on most browsers will tell you how to manage your cookie selections. Visitors to our Sites and Services who disable cookies will be able to browse certain areas of the Sites, but some features may not function.
Pixels. Pixels are tiny graphics with a unique identifier, similar in function to cookies. In contrast to cookies, which are stored on your computer’s hard drive, pixels are embedded invisibly on web pages. We may use pixels (also referred to as web beacons, web bugs, or clear GIFs), in connection with our Sites to, among other things, help us manage ads and content and compile statistics about usage of our Services. We may also use pixels in HTML emails to our customers.
Do-Not-Track. Currently, our systems do not recognize browser “do-not-track” requests. You may, however, disable certain tracking as discussed in this section (e.g., by disabling cookies); you also may opt-out of targeted advertising by following the instructions in the Third Party Ad Network section directly below.
Users in the United States may opt out of many third-party ad networks. For example, you may go to the Digital Advertising Alliance (“DAA”) Consumer Choice Page for information about opting out of interest-based advertising and their choices regarding having information used by DAA companies. You may also go to the Network Advertising Initiative (“NAI”) Consumer Opt-Out Page for information about opting out of interest-based advertising and their choices regarding having information used by NAI members.
Opting out from one or more companies listed on the DAA Consumer Choice Page or the NAI Consumer Opt-Out Page will opt you out from those companies’ delivery of interest-based content or ads to you, but it does not mean you will no longer receive any advertising through our Sites, Services, or on other websites. You may continue to receive advertisements, for example, based on the particular website that you are viewing (i.e., contextually based ads). Also, if your browsers are configured to reject cookies when you opt out on the DAA or NAI websites, your opt out may not be effective. Additional information is available on the DAA’s website at www.aboutads.info or the NAI’s website at www.networkadvertising.org.
Our Sites and Services may contain links to third-party websites. Any access to and use of such linked websites is not governed by this Policy, but instead is governed by the privacy policies of those third party websites. We are not responsible for the information practices of such third party websites.
Security of My Personal Information
We have implemented reasonable precautions to protect the information we collect from loss, misuse, and unauthorized access, disclosure, alteration, and destruction. Please be aware that despite our best efforts, no data security measures can guarantee security.
Changes to My Personal Information
You may modify personal information that you have submitted by contacting us – see the Contact Us section below. Please note that copies of information that you have updated, modified or deleted may remain viewable in cached and archived pages of the Sites for a period of time.
We may send periodic promotional emails to you. You may opt-out of promotional emails by following the opt-out instructions contained in the email. Please note that it may take up to 10 business days for us to process opt-out requests. If you opt-out of receiving promotional emails, we may still send you emails about your account or any services you have requested or received from us.
Children Under 13
Our Services are not designed for children under 13. If we discover that a child under 13 has provided us with personal information, we will delete such information from our systems.
If you have questions about the privacy aspects of our Services or would like to make a complaint, please contact us at email@example.com.
Changes to this Policy
This Policy is current as of the Effective Date set forth below. We may change this Policy from time to time, so please be sure to check back periodically. We will post any changes to this Policy on our Sites. If we make any changes to this Policy that materially affect our practices with regard to the personal information we have previously collected from you, we will endeavor to provide you with notice in advance of such change by highlighting the change on our Sites and/or emailing you at the email address we have for you.
Additional Information for California Residents
In this section, we provide additional information to California residents about how we handle their personal information, as required under California privacy laws including the California Consumer Privacy Act (“CCPA”). This section does not address or apply to our handling of publicly available information lawfully made available by state or federal government records or other personal information (including protected health information) that is exempt under the CCPA.
A. Categories of Personal Information Under the CCPA
While our collection, use, and disclosure of personal information varies based upon our relationship and interactions with you, in this section we describe, generally, how we have collected and disclosed personal information about consumers in the prior 12 months (from the Last Updated date listed at the beginning of this Policy).
Categories of Personal Information Collected and Disclosed. The table below identifies the categories of personal information (as defined by the CCPA) we have collected about consumers, as well as how we have disclosed such information for a business purpose. For more information about the business and commercial purposes for which we collect, use and disclose personal information, please see the “How We Use Your Information” and “How We Share Your Information” sections above.
|Personal Information Collected||Do We Disclose this Information?||Categories of Third Parties to Whom We May Disclose this Information|
|Identifiers||Includes direct identifiers, such as Name, alias user ID, username, account number or unique personal identifier; email address, phone number, address and other contact information; IP address and other online identifiers; SSN, driver’s license number, passport number, tax ID and other government identifiers; and other similar identifiers.||YES||
|Customer Records||Includes personal information, such as name, account name, user ID, contact information, education and employment information, SSN and government identifiers, account number, and financial or payment information), that individuals provide us in order to purchase or obtain our products and services. For example, this may include information collected when an individual registers for an account, purchases or orders our products and services, or enters into an agreement with us related to our products and services.||YES||
|Commercial Information||Includes records of personal property, products or services purchased, obtained, or considered, or other purchasing or use histories or tendencies. For example, this may include demographic information that we receive from third parties in order to better understand and reach our customers.||YES||
|Usage Data||Includes browsing history, clickstream data, search history, access logs and other usage data and information regarding an individual’s interaction with our websites, mobile apps and other Services, and our marketing emails and online ads.||YES||
|Geolocation Data||Includes precise location information about a particular individual or device.||NO||
|Audio, Video and Electronic Data||Includes audio, electronic, visual, thermal, olfactory, or similar information such as photographs and images (e.g., that you provide us or post to your profile) and call recordings (e.g., of customer support calls).||YES||
|Professional Information||Includes professional and employment-related information (such as current and former employer(s) and position(s), business contact information and professional memberships).||YES||
|Education Information||Information about an individual’s educational history (such as the schools attended, degrees you were awarded, and associated dates).||NO||
|Protected Classifications||Includes characteristics of protected classifications under applicable/federal and state/federal and California laws, such as disability information and medical conditions (e.g., which we may collect in order to make available appropriate accommodations for events and other activities or TTY services).||YES||
|Inferences||Includes inferences drawn from other personal information that we collect to create a profile reflecting an individual’s preferences, characteristics, predispositions, behavior, attitudes, intelligence, abilities or aptitudes. For example, we may analyze personal information in order to identify the offers and information that may be most relevant to customers, so that we can better reach them with relevant offers and ads.||NO||
Sources of Personal Information. As further described in the “Information We Collect About You” section above, we may collect personal information from the following sources:
- directly from the individual
- advertising networks
- data analytics providers
- government entities
- data brokers
B. California Residents’ Rights
CCPA Rights. In general, California residents have the following rights with respect to their personal information:
- Do-not-sell (opt-out): To opt-out of our sale of their personal information. We do not sell personal information about California consumers, including those we have actual knowledge are younger than 16.
- Right of deletion: To request deletion of their personal information that we have collected about them and to have such personal information deleted (without charge), subject to certain exceptions.
- Right to know With respect to the personal information we have collected about them in the prior 12 months, to require that we disclose the following to them (up to twice per year and subject to certain exemptions):
- categories of personal information collected;
- categories of sources of personal information;
- categories of personal information about them we have disclosed for a business purpose or sold;
- categories of third parties to whom we have sold or disclosed for a business purpose their personal information;
- the business or commercial purposes for collecting or selling their personal information; and
- a copy of the specific pieces of personal information we have collected about them.
- Right to non-discrimination: The right not to be subject to discriminatory treatment for exercising their rights under the CCPA.
Submitting CCPA Requests. California residents or their authorized agents may submit CCPA requests to know (access) and requests to delete their personal information through one of the following methods:
- Online at http://www.ltcglobal.com/privacy-compliance.html
- By phone at (888) 413-0444 (toll free)
When you submit a request to know or a request to delete, we will take steps to verify your request by email or telephone call. In some cases, we may request additional information in order to verify your request or where necessary to process your request. If we are unable to adequately verify a request, we will notify the requestor. Authorized agents will be required to provide proof of their authorization and we may also require that the relevant consumer directly verify their identity and the authority of the authorized agent.
Your Privacy Rights Under California Shine the Light Law. Under California’s “Shine the Light” law, California residents who provide us certain personal information are entitled to request and obtain from us, free of charge, information about the personal information (if any) we have shared with third parties for their own direct marketing use. Such requests may be made once per calendar year for information about any relevant third-party sharing in the prior calendar year. To submit a “Shine the Light” request, email firstname.lastname@example.org, and include in your request a current California address and your attestation that you are a California resident.
Below are metrics regarding Access, Delete and Do Not Sell My Personal Information requests submitted pursuant to the CCPA that we have received, fulfilled (in whole or in part), and denied between January 1, 2021 and December 31, 2021:
- Number of Requests Received: 0
- Number of Requests Fulfilled: 0
- Number of Requests Denied/Unverified: 0
- Average Number of Days to Respond: N/A
- Number of Requests Received: 2
- Number of Requests Fulfilled: 0
- Number of Requests Denied/Unverified: 2
- Average Number of Days to Respond: 4
Do Not Sell Requests
- Number of Requests Received: 0
- Number of Requests Fulfilled: 0
- Number of Requests Denied/Unverified: 0
- Average Number of Days to Respond: N/A
For more information about our privacy practices, you may contact us as set forth in the “Contact Us” section above.
EFFECTIVE DATE: September 9, 2020