Privacy

‍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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Categories of Personal Information

Examples

Personal Identifiers

Name, date of birth, social security number, telephone number, address,driver’s license number, passport number, electronic signature, account credentials, passwords, email address, online identifier, IP address, unique identifiers such as “cookies” or other similar technologies, device specific-information such as hardware model, operating system version, unique device identifiers, and unique application numbers if included within the respective service.

Demographics

Age, race, gender identification, disability status, citizenship, family relationships, veteran or military status.

Financial Information

Personal Identifiers

Credit history, bank account numbers, investment or brokerage account numbers, information regarding estate or tax planning, debts, trusts, credit or debit card numbers.

Medical and Health Information

Medical history, medical questionnaires, information regarding paymentfor health care services.

Internet or Network Activity

Browser history, search history, interactions with website, Apps and advertisements. Social media account information, social media usage.

Telematics Data

Miles driven, driving habits and vehicle use including geolocation, speed, acceleration, braking and cornering combined with weather, traffic, time of day and other contextual data with your consent.

Audiovisual Information

On-site security cameras, pictures, video and audio recordings where relevant.

Commercial Information

Records of products or services purchased, obtained or considered, or other purchasing or consuming histories or tendencies.

Consumer Information

Credit history, credit score, insurance score, driving records, claims history, or other similar information reflecting on character, general reputation, personal characteristics or mode of living that is furnished by consumer reporting agencies.

Our Product Information

Policy and billing account numbers, payment history, payment and billing information, your insurance coverage selections and premiums, policy benefits and values, beneficiary, ownership arrangements, transaction history.

Sensitive Personal Information

Social security number, driver’s license number, state identification card or passport number; account login, financial account debit or credit card number in combination with any required security or access code; precise geolocation if you opt in to our telematics program (e.g., within 1,850 feet). Sensitive Personal Information that is publicly available is not considered Sensitive Personal Information or Personal Information.

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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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Personal Information We Disclose

In addition to the specific situations discussed else where in this Privacy Notice, we disclose, and may have disclosed in the preceding twelve (12) months, some or all of the categories of Personal Information referenced above in the following situations:

Service Providers. We may disclose your Personal Information to certain companies engaged to perform services on our behalf (“Service Providers”). Service Providers’ access to Personal Information is strictly limited to the purpose of providing us with such services. They are required to perform the services based on our instructions,are not permitted to use the Personal Information for any other purpose and are required to protect the Personal Information.

Other Third-Party Vendors. We may also disclose Personal Information to Third Party Vendors, such as our external auditors, attorneys, accountants, and similar professionals to assist us with the operation of our business and our obligations to comply with applicable laws and regulations. These Third-Party Vendors may use your Personal Information to provide services to us and to comply with their legal,regulatory and/or fiduciary obligations.

Authorized Agents or Brokers. Commonwealth Casualty Company works with agents and brokers who sell our services and products on our behalf. We may disclose your Personal Information to those agents or brokers to provide you with the services you’ve requested. They may use your Personal Information in the manner described in this Privacy Notice.

Companies Involved in Insurance Related Transactions. We disclose your Personal Information to other companies that play a role in an insurance transaction with you, such as other insurance institutions, financial institutions, independent claims adjusters, repair shops, and other claims related companies. We may also disclose your Personal Information to consumer reporting agencies and to participate in insurance support organizations.Information disclosed to an insurance support organization may be retained by the organization and disclosed to other persons.

Affiliates and Acquisitions. We may disclose Personal Information to our corporate affiliates (e.g., parent company, sister companies, operating companies, subsidiaries, joint ventures,or other companies under common control). Our affiliates are only permitted to use Personal Information we disclose to them for authorized business purposes,and they are required to protect the information in accordance with approved data security plans. If another company acquires our company, business, or our assets, we will also disclose Personal Information to that company.

Marketing and Advertising Partners. We may disclose Personal Information to third party marketing and advertising partners or permit these partners to collect Personal Information from you directly on our Services to personalize online advertising. Our Cookies and Other Tracking Technologies page has more information about these activities.We also may disclose Personal Information to other financial institutions or other companies with whom we have a joint marketing agreement.

Compliance with Law or Other Legal Process. We may disclose information in response to subpoenas, warrants, or court orders,or in connection with any legal process, or to comply with relevant laws, which may include disclosures made to law enforcement, insurance regulatory authorities, or other government authorities. We may also disclose your information in order to establish or exercise our rights, to defend against legal claims, to investigate, prevent, or take action regarding possible illegal activities, suspected fraud, safety of person or property, or a violation of our policies, or to comply with your request for the shipment of products to you or for the provision of services by a third-party intermediary.

Other Disclosures with Your Consent. We may share Personal Information with companies, organizations or individuals outside of Commonwealth Casualty Company, for purposes not specified else where in this Privacy Notice, when we have your consent to do so.

We may sell the Personal Information we obtain.

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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:

Cookie Type

Description

Essential Cookies

These are cookies that our website needs inorder to function and that enable you to move around and use the website andfeatures. Without these essential cookies, the website will not perform assmoothly for you as we would like it to, and we may not be able to provide thewebsite or certain services or features you request. Examples of where thesecookies are used include: to determine when you are signed in, to determinewhen your account has been inactive, and for other troubleshooting and securitypurposes.

Analytics Cookies

Analytics cookies provide us with information regarding how visitors navigate and interact with our website. Such cookies allow us to understand, for example, more about how many visitors we have to our website, how many times they visit us and how many times a user viewed specific pages within our website. Among other Analytics cookies, we use Google Analytics cookies for these purposes. For more information about Google Analytics, please refer to “How Google Uses Information From Sites or Apps that Use Our Services,” which can be found at www.google.com/policies/privacy/partners/ or any other URL Google may provide from time to time.

Advertising Cookies

Advertising cookies may be placed by us or third parties to enable third party ad networks to recognize a unique cookie on your computer or mobile device. The information that is collected and shared by these types of cookies may also be linked to the device identifier of the device you are using to allow us to keep track of all the websites you have visited that are associated with the ad network. This information may be used for the purpose of targeting advertisements on our website and third-party sites based on those interests.

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.