Privacy Notice – California Residents
This section supplements our Privacy Notice and Notice of Information Practice. This notice provides specific information for residents of California (“consumers” in this section), as required under California privacy laws, and is intended to satisfy the California Consumer Privacy Act (“CCPA”), which requires that we provide certain information to California consumers about how we handle certain kinds of your personal information that we have collected, whether online or offline. Under the CCPA, “personal information” is any 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, including the categories identified below to the extent they identify, relate to, describe, are reasonably capable of being associated with, or could be reasonably linked, directly or indirectly, with a particular consumer or household.
In this policy, when we refer to “we”, “us” or “our”, it means KW Specialty Insurance Company.
When we refer to “you” or “your” in this policy, we mean a resident of the state of California who is a potential customer, job applicant, employee, contractor, claimant or other person related to an insurance policy or claim, and whose personal information we may collect.
Personal Information:
Below are the categories of personal information that we may collect.
- Identifiers– such as real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, social security #, driver’s license #, passport #, or other similar identifiers.
- Any categories of personal information described in subdivision (e) of Section 1798.80 of the California Civil Code, such as signature, telephone #, insurance policy #, bank account number, credit card number, etc.
- Other Sensitive Information under California Law – Examples: physical description, financial information, medical information, etc.
- Characteristics of protected classifications under California or federal law – Examples: race, sex, color, religion, national origin, marital status, etc.–
- Biometric information – Examples: fingerprints, keystroke patterns, gait patterns, sleep/health data, etc.
- Geolocation Data – Information to identify physical location
- Audio, electronic, visual, thermal, olfactory, or similar information – Examples: audio and video recordings
- Professional or employment-related information – Example: job history, education history, etc.
- Education information – information not publicly available as defined as information that is not publicly available personally identifiable information as defined in the Family Educational Rights and Privacy Act (20 U.S.C. Sec. 1232g; 34 C.F.R. Part 99).
- Commercial information – Examples: records of personal property, products, and services purchased or obtained, etc.
- Internet or other electronic network activity information – Examples: browsing/search history, visitor’s interaction with a website, etc.
- Inferences drawn from any of the information identified in this subdivision to create a profile about a consumer reflecting the consumer’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.
Sensitive Personal Information Collected
Below are the categories of sensitive personal information that we may collect.
- A consumer’s social security, driver’s license, state identification card, or passport number.
- A consumer’s precise geolocation.
- A consumer’s racial or ethnic origin, religious or philosophical beliefs, or union membership.
- The contents of a consumer’s mail, email and text messages, unless the business is the intended recipient of the communication.
- A consumer’s genetic data.
- The processing of biometric information for the purpose of uniquely identifying a consumer.
- Personal information collected and analyzed concerning a consumer’s health.
- Personal information collected and analyzed concerning a consumer’s sex life or sexual orientation.
Sources of Personal Information
Below are the categories of sources we may use to collect personal information and sensitive personal information. Not every operating unit uses all of these sources to collect personal information and sensitive personal information.
- Directly from you;
- From other individuals;
- From service providers;
- From policyholders;
- From third parties you select to provide services to you or represent you, such as medical providers, lawyers, contractors, and public insurance adjusters.
- Other third parties, such as government entities and information reporting services.
The Purposes for Collecting Personal Information
We may collect, use, and disclose personal information for the purposes listed below.
- To perform insurance services for policyholders, beneficiaries, and claimants;
- To offer insurance products and services;
- For processing of employment related functions and benefits;
- To maintain and improve quality of services;
- For purposes of security;
- To detect and prevent fraud and improper use;
- To conduct internal research;
- To identify and repair errors;
- To comply with laws and regulations;
- To provide customer support and respond to requests for information;
- To manage customer and supplier relationships;
- To advertise and market our products and services, and personalize user experiences;
- To conduct analytics and data analysis;
- To facilitate and implement any reorganization, financing transaction, merger, sale, joint venture, partnership, 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);
- To perform accounting, audit, and other internal functions, such as internal investigations; and
- To maintain records, comply with internal policies, and exercise and defend legal claims.
Use or Disclosure of Sensitive Personal Information
We only use or disclose sensitive personal information for the purposes listed below. .
- To perform the services reasonably expected by an average consumer who requests such services.
- Helping to ensure security and integrity to the extent the use of the consumer’s personal information is reasonably necessary and proportionate for these purposes.
- For short-term, transient use.
- To perform services on behalf of KW Specialty Insurance Company.
- Undertaking activities to verify or maintain the quality or safety of a service that is owned or controlled by KW Specialty Insurance Company and to improve, upgrade, or enhance the service that is owned or controlled by KW Specialty Insurance Company.
Categories of Personal Information Disclosed to Third Parties
We may disclose any or all of the categories of personal information to the following categories of third parties. (See “Personal Information Collected” above for the full descriptions.)
Personal Information Category Title
1. Identifiers
- Government entities.
- Parties in litigation as part of a legal proceeding.
- Parties you select to provide services to you, when those third parties are providing services related to a transaction between the operating unit and you.
- Outside parties in connection with providing services, completing transactions, supporting business operations.
2. Any categories of personal information described in subdivision (e) of Section 1798.80 of the California Civil Code
- Government entities.
- Parties in litigation as part of a legal proceeding.
- Parties you select to provide services to you, when those third parties are providing services related to a transaction between the operating unit and you.
- Outside parties in connection with providing services, completing transactions, supporting business operations.
3. Other Sensitive Information under California Law
- Government entities.
- Parties in litigation as part of a legal proceeding.
- Parties you select to provide services to you, when those third parties are providing services related to a transaction between the operating unit and you.
- Outside parties in connection with providing services, completing transactions, supporting business operations.
4. Characteristics of protected classifications under California or federal
- Government entities.
- Parties in litigation as part of a legal proceeding.
- Parties you select to provide services to you, when those third parties are providing services related to a transaction between the operating unit and you.
- Outside parties in connection with providing services, completing transactions, supporting business operations.
5. Biometric information
- Government entities.
- Parties in litigation as part of a legal proceeding.
- Parties you select to provide services to you, when those third parties are providing services related to a transaction between the operating unit and you.
- Outside parties in connection with providing services, completing transactions, supporting business operations.
6. Geolocation Data
- Government entities.
- Parties in litigation as part of a legal proceeding.
- Parties you select to provide services to you, when those third parties are providing services related to a transaction between the operating unit and you.
- Outside parties in connection with providing services, completing transactions, supporting business operations.
7. Audio, electronic, visual, thermal, olfactory, or similar information
- Government entities.
- Parties in litigation as part of a legal proceeding.
- Parties you select to provide services to you, when those third parties are providing services related to a transaction between KW Specialty Insurance Company and you.
- Outside parties in connection with providing services, completing transactions, supporting business operations.
8. Professional or employment-related information
- Government entities.
- Parties in litigation as part of a legal proceeding.
- Parties you select to provide services to you, when those third parties are providing services related to a transaction between KW Specialty Insurance Company and you.
- Outside parties in connection with providing services, completing transactions, supporting business operations.
9. Education information
- Government entities.
- Parties in litigation as part of a legal proceeding.
- Parties you select to provide services to you, when those third parties are providing services related to a transaction between KW Specialty Insurance Company and you.
- Outside parties in connection with providing services, completing transactions, supporting business operations.
10. Commercial information
- Government entities.
- Parties in litigation as part of a legal proceeding.
- Parties you select to provide services to you, when those third parties are providing services related to a transaction between KW Specialty Insurance Company and you.
- Outside parties in connection with providing services, completing transactions, supporting business operations.
11. Internet or other electronic network activity information
- Government entities.
- Parties in litigation as part of a legal proceeding.
- Parties you select to provide services to you, when those third parties are providing services related to a transaction between KW Specialty Insurance Company and you.
- Outside parties in connection with providing services, completing transactions, supporting business operations.
12. Inferences drawn from personal information
- Government entities.
- Parties in litigation as part of a legal proceeding.
- Parties you select to provide services to you, when those third parties are providing services related to a transaction between KW Specialty Insurance Company and you.
- Outside parties in connection with providing services, completing transactions, supporting business operations.
Categories of Sensitive Personal Information Disclosed to Third Parties
We may disclose any or all of the categories of sensitive personal information to the following categories of third parties.
A consumer’s social security, driver’s license, state identification card, or passport number.
- Government entities.
- Parties in litigation as part of a legal proceeding.
- Parties you select to provide services to you, when those third parties are providing services related to a transaction between KW Specialty Insurance Company and you.
- Outside parties in connection with providing services, completing transactions, supporting business operations.
A consumer’s precise geolocation.
- Government entities.
- Parties in litigation as part of a legal proceeding.
- Parties you select to provide services to you, when those third parties are providing services related to a transaction between KW Specialty Insurance Company and you.
- Outside parties in connection with providing services, completing transactions, supporting business operations.
A consumer’s racial or ethnic origin, religious or philosophical beliefs, or union membership.
- Government entities.
- Parties in litigation as part of a legal proceeding.
- Parties you select to provide services to you, when those third parties are providing services related to a transaction between KW Specialty Insurance Company and you.
- Outside parties in connection with providing services, completing transactions, supporting business operations.
The contents of a consumer’s mail, email and text messages, unless the business is the intended recipient of the communication.
- Government entities.
- Parties in litigation as part of a legal proceeding.
- Parties you select to provide services to you, when those third parties are providing services related to a transaction between KW Specialty Insurance Company and you.
- Outside parties in connection with providing services, completing transactions, supporting business operations.
A consumer’s genetic data.
- Government entities.
- Parties in litigation as part of a legal proceeding.
- Parties you select to provide services to you, when those third parties are providing services related to a transaction between KW Specialty Insurance Company and you.
The processing of biometric information for the purpose of uniquely identifying a consumer.
- Government entities.
- Parties in litigation as part of a legal proceeding.
- Parties you select to provide services to you, when those third parties are providing services related to a transaction between KW Specialty Insurance Company and you.
Personal information collected and analyzed concerning a consumer’s health.
- Government entities.
- Parties in litigation as part of a legal proceeding.
- Parties you select to provide services to you, when those third parties are providing services related to a transaction between KW Specialty Insurance Company and you.
- Outside parties in connection with providing services, completing transactions, supporting business operations.
We may disclose any or all of the categories of personal information and sensitive personal information listed above to our service providers. The service providers may include: insurance agents; entities that provide insurance policy and claim-related products and services; employee benefits providers (for employees); and, other individuals and entities that assist us in providing products and services or the operation of our business.
Information Regarding the Sale of Personal Information
We have not sold personal information, including sensitive personal information of California resident consumers to any third parties in the preceding 12-month period from the date of this Policy.
We have not “shared” personal information, including sensitive personal information with third parties for cross-context behavioral advertising in the preceding 12-month period from the date of this Policy.
To our actual knowledge, we do not sell or share personal information, including sensitive personal information of minors under 16 years of age.
Consumer Rights Under the CCPA
California residents have the following rights under the CCPA, relating to their personal information collected by operating units:
- The Right to request that we disclose what personal information about a consumer it collected, used, and disclosed, the categories of sources from which it was collected, the business or commercial purpose for collecting the personal information, and the categories of third parties to whom the business discloses the personal information;
- The Right to request a copy of the specific personal information we collected and hold;
- The Right to request that we delete the personal information we maintain about the individual consumer or household;
- The right to request that we correct inaccurate personal information we maintain about the consumer.
- The Right to Non-Discrimination for the exercise of a consumer’s privacy rights.
Methods for Exercising Your Rights
You may submit requests to receive information about, to correct, or to delete the personal information that we collected about you, in either of the following ways:
- Toll-Free Phone: Call KW Specialty Insurance Company toll-free phone number: 1-855-225-5597.
- Email us at Contactus@kwspecialty.com and request a form to complete.
OR
- Online Request Form: Access our website at www.kwspecialty.com and you can complete and submit a request form online.
In order to submit a request you will need to provide some basic information, including:
- Basic contact information (name, address, phone number, and email address);
- Provide your policy number or claim number, if you know that information);
- The type of request you are making – whether you want:
- (i) to know the categories of personal information collected about you;
- (ii) a copy of the specific personal information collected about you; or
- (iii) or request personal information collected about you be deleted;
- Whether you wish to receive a response to your request by email or regular mail.
Use of Authorized Agent: You may designate an authorized agent to make the requests identified above. To do so you will need to provide one of the following:
- Written Authorization: Provide us a written document authorizing another individual to submit a request on your behalf, and the verification information identified in the Request & Verification Process in this Policy;
OR
- Valid Power of Attorney: You or your authorized agent may provide a valid power of attorney that complies with the provisions of sections 4121-4130 of the California Probate Code.
The Request and Verification Process
Once you have submitted a request, we will contact you in order to confirm receipt of your request and to verify and match you to personal information that we may have collected about you. The degree of verification needed will depend on the type of request you make, and the nature of the personal information we have collected. It will usually need to match at least two or three pieces of personal information provided by you to the personal information contained in its records. We may also ask you to sign a form of sworn declaration in certain instances, if you request a copy of the specific pieces of personal information it has about you, or to delete certain types of personal information.
If we decline to fulfill your request, in whole or in part, for any reason required or permitted by the CCPA, we will notify you of the reason we are declining to fulfill your request. If we can partially fulfill your request, we will do so.
We will attempt to fulfill your request within 45 days. If we are unable to do so within the 45-day period, we will notify you that we need additional time (up to 45 additional days), along with an explanation why we need the extra time.
Contact Us
If you have any questions or concerns about KW Specialty Insurance Company’s privacy policy and information practices, please contact us at contactus@kwspecialty.com.