Privacy Notice

‍This Privacy Notice describes how Commonwealth Casualty Company and its affiliates(“Commonwealth Insurance,” “we,” “us,” or “our”) collect, disclose, and otherwise use (“Process”) information about you. We recognize the importance of our customers’ trust, keeping personal information confidential is a top priority. This Privacy Notice (“Notice”) describes our practices in connection with information we collect through our digital services (“Services”), including our websites, social media accounts, marketing partners, and mobile applications (“Apps”) that include a link to this Privacy Notice, and through any of our other activities, both online and offline. By interacting with these Services, you agree to this Privacy Notice and the collection and use of information according to its terms. Our privacy practices may vary among the states in which we operate to reflect applicable state and local privacy requirements.

Consumer Notice of Collection
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‍This Notice of Collection is provided to all consumers subject to this Privacy Notice. Specific topics in this Privacy Notice are listed below:

• Information We Collect
• Sources of Personal Information
• How We Use Your Personal Information
• Personal Information We Disclose
• Cookies and Other Tracking Technologies
• Your Privacy Rights
• Security and Retention
• Linked Third-Party Sites
• Children’s Privacy
• Changes to Our Privacy Notice
• Contact Us

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Information We Collect

The type of personal information that we collect and the extent to which it is used varies based on the products and services we provide to you, such as the type of insurance for which you apply and your business relationship with the company, among other factors.

We may collect some or all of the below categories of personal information from consumers within the last twelve (12) months. The examples are not exhaustive, and personal information collected may fall into multiple categories.
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Sources of Personal Information

We collect and have collected in the preceding twelve (12) months, personal information about you from various sources. For example, we collect and obtain information:

‍Directly from You. We collect information you provide when you interact with us, such as when you fill out an insurance application and related forms; submit an application for employment; submit an application for agency appointment; register for, use, or make a payment for a product or service; contact us with a question or request; provide a testimonial or story; post or submit a photo, review, or comment; participate in a competition, promotional activity, or sweepstakes; “Like,” “Follow” or otherwise connect with or post to one of our Social Media Accounts; or send us a text or SMS message in order to obtain more information about a product or service.
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Using Cookies and Other Automatic Data Collection Technologies. When you visit our website, open or click on emails we send you, interact with our mobile applications, or interact with our advertisements, we or third parties we work with automatically collect certain information using technologies such as cookies, web beacons, clear GIF, pixels,internet tags, web server logs, and other data collection tools. For more information, please review the Cookies and Other Tracking Technologies section of this notice.

From Our Affiliates. We obtain personal information, including transaction information, from our affiliates.

From Third Parties. We obtain personal information, including transaction information, from non-affiliated third parties that we transact business with or have partnered with.

From Other Sources. We obtain personal information from other sources, such as consumer reporting agencies and publicly available sources.

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How We Use Your Personal Information

We process Personal Information to operate our Services and Applications, and to deliver the products and services you have requested. This processing may involve the use of artificial intelligence.

Specifically, we process personal information collected for the following business purposes:

• Responding to your inquiries and fulfilling your requests;
• Processing employment and agency applications;
• Administering promotional events, sweepstakes, and contests;
• Personalizing your experience of the Services by presenting products and offers tailored to you;
• Maintaining records that include, but are not limited to, insurance policy coverages, premiums, and payment history;
• Transacting business including underwriting, rating, claims     handling, claims investigations, and policy sales and administration;
• For marketing and advertising purposes, including providing you with     information related to our products and services;
• Conducting research and analytics related to our website and Services;
• Fulfilling legal and regulatory obligations, to establish or exercise our rights, and to defend against legal claims;
• To ensure the technical functions of our network, including 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 Commonwealth Casualty Company and our users,     policyholders, employees, or others;
• To improve and customize the content and layout of the Services.

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SMS & Text Message Comunications

‍Opt-In Consent  

By providing your mobile phone number and opting in through a web form or paper consent form, you expressly consent to receive recurring automated and non-automated transactional text messages from Commonwealth Casualty Company at the mobile number provided. These messages include policy alerts, billing reminders, claims updates, and appointment confirmations. Messages will only relate to your policy, billing, claims, or service requests. Commonwealth Casualty Company does not send marketing or promotional SMS messages.

Consent is not a condition of any purchase or policy issuance.

Types of Messages. All text messages sent by Commonwealth Casualty Company are strictly transactional in nature. You may receive:

• Policy & Account Alerts — Policy updates, coverage changes, renewal notices, and account notifications.
• Billing & Payment Reminders — Payment due dates, payment confirmations, and billing notifications.
• Claims Status Updates — Status changes, required documentation requests, and resolution notifications related to your claim.
• Appointment Confirmations — Scheduling confirmations and reminders for inspections or agent meetings.
• Customer Support — Responses and updates related to your service or claims inquiries.

‍Commonwealth Casualty Company does not send marketing or promotional SMS messages. We will never use our text messaging program to send advertisements, promotional offers, or solicitations.

Message frequency varies based on your account activity and preferences. Message and data rates may apply depending on your mobile carrier and plan.  

Messages may also be sent by automated technology. We obtain and maintain prior express consent as required by applicable law.  

Our SMS program is available on most major U.S. carriers including AT&T, Verizon, T-Mobile, and US Cellular. Carrier availability is not guaranteed for all carriers or plans.

You may cancel SMS communications at any time by replying STOP to any message from us. You may also contact us at privacy@cccinsurance.com or (877) 603-1310, to opt-out.  After opting out, you will receive one final confirmation message. No further messages will be sent unless you re-enroll. For assistance, reply HELP or contact us at privacy@cccinsurance.com or (877) 603-1310.  

SMS communications are subject to applicable federal and state laws. We will honor your opt-out request promptly.

‍Sample Messages

"Commonwealth Casualty: Your policy #CCC-12345 renewal is due in 14 days. Questions? Call (877) 603-1310. Reply
STOP to opt out."

"Commonwealth Casualty: Your payment of 42.00 has been received. Thank you! View your account: [link]. Reply STOP to
opt out."

"Commonwealth Casualty: Your claim #CLM-67890 has been updated. Log in to view details: [link]. Msg&Data; rates may
apply. Reply STOP to cancel." 

"Commonwealth Casualty: Your inspection is confirmed for Mon, June 2 at 10:00 AM. Reply STOP to opt out."

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No Third-Party Sharing of SMS Opt-In Data.

Your mobile phone number and SMS opt-in information will never be sold, rented, leased, or shared with third parties for their own marketing or advertising purposes. Commonwealth Casualty Company may share your mobile number with service providers (such as SMS platform vendors) who act solely on our behalf, under strict confidentiality agreements, for the limited purpose of operating our messaging program. These service providers are prohibited from using your information for any purpose other than providing services to us.  

We retain records of your SMS opt-in consent and message history for as long as required by applicable law and as necessary to demonstrate compliance with carrier regulations and our obligations under this Privacy Notice. We maintain consent logs and you may be asked to reconfirm for certain workflows. You may request deletion of your SMS data by contacting us at Privacy@cccinsurance.com, subject to our legal retention obligations.

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Cookies and Other Tracking Technologies

Every time you come to our website, our website’s web server automatically collects information, including, in some instances, Personal Information, through cookies, web beacons, and other similar tracking technologies (collectively “cookies”). Our website also uses virtual assistants and session replay technology.

Cookies. Please see our Cookie Policy for more information about cookies and how we use them.

Web Chat. We log user conversations with our Virtual Assistant chatbot to provide customer support to you. Our Virtual Assistant chatbot is administered by one of our Service Providers. When you type information into the chat, messages may be recorded and/or transcribed for record keeping and other purposes.

Session Replay Technology. We use a specific type of analytics tool called “session replay technology.”Session replay technology enhances user experience by optimizing the efficiency, design and quality of the Services. By using session replay technology, we can collect and analyze information related to user behavioral metrics on the Services, such as mouse movements, clicks, user inputs,scrolling, access times, visit duration, pages viewed, IP address (including approximate location), operating system, and page reloading. These tools provide insight into what works and what doesn’t work for website visitors, and they allow us to, for example, identify and repair technical errors such as broken links that impair the Services’ functionality.

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Your Privacy Rights

You may request access to your personal information, or ask that we correct, amend, or delete it, by contacting us at (877) 603-1310 or Privacy@cccinsurance.com.

Customers may also update their information by contacting their agent.

‍If you are a California resident, California law may provide you with additional rights regarding your personal information.To learn more about your California privacy rights, please see our California Consumer Privacy Act Privacy Notice (“CCPA Notice”).

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Security and Retention

We strive to maintain the privacy and integrity of information collected by using appropriate measures designed to protect our systems, applications, products, and services. However, we cannot guarantee the security of any information that is disclosed online.

Only authorized workers, agents, and staff of Commonwealth Casualty Company who need to know Personal Information while doing business are provided access. Their right to disclose or use this information is limited by our code of conduct, applicable laws, and non-disclosure agreements where appropriate. Individuals who violate our policies are subject to disciplinary actions.

Organizations that provide services involving Personal Information on behalf of Commonwealth Casualty Company are contractually required to protect your Personal Information.

We retain personal information for the periods required by applicable laws and/or as specified in our records retention policies and procedures and our Privacy Notice. The period chosen takes account of applicable legal requirements to retain data and specific business use cases.We maintain records management and retention policies and procedures so that,where required, personal information is disposed of after a reasonable time inconsideration of the following retention criteria:

• We retain your personal information for as long as needed to carry out the business purposes set forth in this Privacy Notice, or to support     our business functions and operations.
• We retain your personal information as long as we have an ongoing relationship with you or for as long as needed to provide products or     services to you.
• We retain your personal information for as long as needed to comply with our legal and contractual obligations or as necessary to defend our rights.

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Linked Third-Party Sites

We may provide links to other third-party websites through the Services available to you. However, such linking does not mean, and should not be interpreted to mean, that we endorse, are affiliated with or make any representations concerning such third-party websites. We do not review, do not control, and are not responsible for these third-party sites or any content therein. By using such links, you will leave the Services. Please note that any Personal Information that you provide to such third parties will be governed by their privacy policies, and we have no control over or responsibility for their privacy practices. If you decide to access any of the third-party sites linked to the Services, you do so entirely at your own risk. We shall not be liable for any consequences arising from use of any third-party websites to which the Services link. 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 prior to providing any Personal Information.

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Children’s Privacy

Our Services are not directed to children under 13. We do not knowingly collect personal information from children without parental consent. If you believe we may have collected such information, please contact us at Privacy@cccinsurance.com, and we will promptly remove it unless legally required to retain it.

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Changes to Our Privacy Notice

We reserve the right at our discretion to amend this Privacy Notice at any time. Any changes will be effective immediately upon the posting of the revised Privacy Notice. When we make changes to this Privacy Notice, we will post the updated notice on our website www.commonwealthcasualty.com and update the notice's effective date. We encourage you to review this page periodically for the latest information on our privacy practices. Your continued use of our website following the posting of changes constitutes your acceptance of such changes.

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Contact Us

If you have any questions or comments about this notice,the ways in which we collect and use your information, or your choices and
rights regarding such use, please contact us at:

Phone: (877) 603-1310

Email: Privacy@cccinsurance.com

Postal Address:
Commonwealth Casualty Company
Attn: Privacy Office
P.O. Box 37847
Phoenix, AZ 85069

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California Consumer Privacy Act Privacy Notice (“CCPA Notice”)

If you are a California resident and the California Consumer Privacy Act, as amended by the California Privacy Rights Act (collectively "CCPA"), applies to your Personal Information, we provide this additional information so you can understand and exercise your rights under the CCPA.

‍Access Request Rights. You have the right to request that we disclose certain information to you about our collection, disclosure and use of your Personal Information.

Deletion Request Rights. Subject to certain exceptions, you have the right to request that we delete any of the Personal Information that we collected from you and have retained.

Correction Request Rights. You have the right to request we correct inaccurate Personal Information.

Opt Out of the Sale or Sharing of Personal Information. In certain circumstances we may sell the personal information we obtain. In addition, our use of certain types of cookies or other tracking technologies may be deemed a “sharing” of Personal Information (in this context “sharing”means cross-contextual behavioral advertising). You can opt out of the sale of your Personal Information or our use of certain types of tracking technologies and cookies by either:

• Emailing Privacy@cccinsurance.com; or
• Calling us toll-free at (877) 603-1310.

Opt Out of Certain Uses and Disclosures of Sensitive Personal Information. You have the right to opt-out of certain uses and disclosures of your Sensitive Personal Information. However, we do not use or disclose Sensitive Personal Information for purposes other than those which cannot be limited under California law.

‍Exercising Your Access, Deletion or Correction Rights. You may submit an access, deletion or correction request by either:

• Emailing Privacy@cccinsurance.com; or
• Calling us toll-free at (877) 603-1310.

Only you, or an authorized agent appointed to act on your behalf, may make a request related to your Personal Information. You may also make a request on behalf of your minor child. If you are submitting a request on behalf of someone else, you will need to provide proof that you have been authorized by the consumer to make the request for them.

You may only make an access request twice within a 12-month period.

We cannot respond to your request or provide you with Personal Information if we cannot verify your identity or authority to make the request and confirm the Personal Information relates to you. In order to verify your identity, we need information that allows us to reasonably verify that you are the person about whom we collected Personal Information. Information we request may include, but not be limited to:

• First, middle, and last name
• Date of birth
• Phone number
• Address
• Policy, quote or claim number

We will only use the Personal Information provided to us in a request in order to verify your identity or your authorized agent’s identity.If our verification process is successful, we will respond to your request within the time and in the manner required by applicable law. If we cannot validate your identity or your authorized agent’s identity, or obtain proof that you have given your authorized agent permission to act on your behalf, we will attempt to contact you to inform you.

If you choose to exercise your CCPA rights, we will not discriminate against you. However, we may require use of your Personal Information to provide access to the Services. Therefore, when you exercise your deletion right, in particular, you may lose access to certain aspects of the Services that require your Personal Information.

Residents of California may ask us to provide them with a list of the types of Personal Information that we have disclosed during the preceding year to third parties for their direct marketing purposes, and the identity of those third parties. If you are a California resident and would like such a list, please contact us at the email address provided in the “Contact Us” section below. For all such requests, please indicate "CA Shine the Light" in the subject field of your request. You must also include your full name, email address, street address, city, state, zip code and quote or policy number.

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Contact for CCPA Requests

If you are a California resident and the California Consumer Privacy Act, as amended by the California Privacy Rights Act (collectively "CCPA"), applies to your Personal Information, we provide this additional information so you can understand and exercise your rights under the CCPA.

‍Access Request Rights. You have the right to request that we disclose certain information to you about our collection, disclosure and use of your Personal Information.

Deletion Request Rights. Subject to certain exceptions, you have the right to request that we delete any of the Personal Information that we collected from you and have retained.

Correction Request Rights. You have the right to request we correct inaccurate Personal Information.

Opt Out of the Sale or Sharing of Personal Information. In certain circumstances we may sell the personal information we obtain. In addition, our use of certain types of cookies or other tracking technologies may be deemed a “sharing” of Personal Information (in this context “sharing”means cross-contextual behavioral advertising). You can opt out of the sale of your Personal Information or our use of certain types of tracking technologies and cookies by either:

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Cookie Policy

Cookies are small text files that are placed on your computer or mobile device when you visit a website. Cookies help the website remember information about your visit, which can make it easier to visit the website again and make the website more useful to you. Some cookies are deleted once you close your browser (session cookies), while other cookies are retained even after you close your browser so that you can be recognized when you return to a website (persistent cookies). More information about cookies and how they work is available at www.allaboutcookies.org. Cookies on our website are generally divided into the following categories:

We may use the information collected through cookies and related tracking technologies for the following purposes:

• To make our website easier to use and generally improve its performance.
•  To gather metrics about how you interact with our website.
• For security reasons.
• To provide personalized content. For example, we may store user preferences, your default language, device and browser information, and     your profile information, which includes the level of your usage of the website so we can identify you across devices and personalize the content you see.
• To advertise to you via behavioral-based/targeted advertising and allow others to do the same.

Most web browsers automatically accept cookies, but you can usually change your browser settings to prevent this. If you disable cookies,your ability to use some features of the website may be limited. For mobile devices, you may be able to manage certain cookies using your built-in mobile device settings and controls. Any choices concerning cookies are browser and/or device specific. If you clear your cookies from your browser on any of your devices, your choices will need to be reset. You should check how to do this on your device(s) and operating systems.

Some cookie providers offer opportunities to control your preferences. To learn how to opt-out of Google Analytics, an Analytics cookie,please visit: https://tools.google.com/dlpage/gaoptout.

Some of these cookies may be placed by third party service providers to help determine the effectiveness of our advertising campaigns or email communications. The use of cookies by third-party service providers is within their control and not ours. We do not control their websites or their policies and practices regarding your Personal Information, and you should be aware that different rules might apply to the collection, use or disclosure ofyour Personal Information by third parties in connection with theiradvertisements or promotions and other sites you encounter on the Internet. TheCookie Policy does not cover any use of Personal Information that a third-partyservice provider may directly collect from you, and we do not undertake toconfirm, investigate, or police their practices.

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Terms & Conditions of Use

These Terms and Conditions of Use ("Terms") govern your access to and use of the websites, mobile applications, and services ("Services") provided by Commonwealth Casualty Company and its affiliates ("Commonwealth Insurance," "we," "us," or "our"). By accessing or using our Services, you agree to be bound by these Terms. If you do not agree, please do not use our Services.

Acceptance of Terms

By using our Services, you represent that you are at least 18 years of age, have the legal capacity to enter into these Terms, and agree to comply with all applicable federal, state, and local laws. These Terms apply to all visitors, users, policyholders, claimants, and others who access our Services.

‍SMS & Text Message Terms
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‍By opting in to receive text messages from Commonwealth Casualty Company, you agree to the following: (1) You authorize Commonwealth Casualty Company to send recurring automated and non-automated transactional text messages to the mobile number you provide, including policy alerts, billing reminders, claims updates, and appointment confirmations. (2) Message frequency varies. (3) Message and data rates may apply. (4) You may opt out at any time by replying STOP to any message. (5) Reply HELP for assistance or contact us at (877) 603-1310. (6) Consent is not a condition of purchasing any product or service. (7) Your opt-in information will never be sold or shared with third parties for marketing purposes.

Permitted Use of Services
You agree to use our Services only for lawful purposes. You agree not to:

• Use our Services in any way that violates applicable federal, state, local, or international law
• Transmit unsolicited advertising, promotional material, spam, or junk mail
• Impersonate Commonwealth Casualty Company, an employee, agent, or any other person or entity
• Engage in conduct that restricts or inhibits any other person from using the Services
• Attempt to gain unauthorized access to any part of our systems, networks, or databases
• Use automated tools to scrape, crawl, or harvest data from our Services without written consent
• Introduce viruses, malware, or other harmful or disruptive material into our systems.

‍‍Intellectual Property All content, features, and functionality on our Services — including text, graphics, logos, icons, images, audio clips, and software — are the exclusive property of Commonwealth Casualty Company or its licensors and are protected by applicable intellectual property laws. You may not reproduce, distribute, modify, or create derivative works of any content from our Services without our prior written consent.

Disclaimers Our Services are provided on an "as is" and "as available" basis without warranties of any kind, either express or implied, including but not limited to implied warranties of merchantability, fitness for a particular purpose, or non-infringement. We do not warrant that our Services will be uninterrupted or error-free. SMS message delivery is subject to network availability and carrier conditions; we cannot guarantee delivery of every message.

Limitation of Liability To the fullest extent permitted by applicable law, Commonwealth Casualty Company shall not be liable for any indirect, incidental, special, consequential, or punitive damages arising out of or related to your use of our Services. Our total cumulative liability for any claims under these Terms shall not exceed the greater of (a) the total amount paid by you to us in the twelve months preceding the claim, or (b) one hundred dollars ($100.00). Nothing in these Terms limits liability that cannot be excluded under applicable insurance law.

Indemnification You agree to indemnify, defend, and hold harmless Commonwealth Casualty Company and its affiliates, officers, directors, employees, and agents from and against any claims, liabilities, damages, losses, costs, or expenses (including reasonable attorney’s fees) arising out of or relating to your violation of these Terms or your use of our Services.

Governing Law & Dispute Resolution These Terms are governed by the laws of the State of Arizona, without regard to its conflict of law provisions. Any dispute arising from these Terms shall be resolved exclusively in the state or federal courts located in Maricopa County, Arizona. For disputes involving insurance policy terms or claims, the terms of your individual policy and applicable state insurance regulations shall govern.

Changes to These Terms We reserve the right to modify these Terms at any time. Changes are effective immediately upon posting to www.commonwealthcasualty.com. Your continued use of our Services after any changes constitutes your acceptance of the revised Terms.

Contact for Terms Inquiries For questions about these Terms, contact us at Privacy@cccinsurance.com, (877) 603-1310, or write to: Commonwealth Casualty Company, Attn: Legal Department, P.O. Box 37847, Phoenix, AZ 85069.