Privacy notice for California Consumers
Church Mutual means Church Mutual Insurance Company, S.I. and its affiliate, CM Vantage Specialty Insurance Company.
PRIVACY POLICY FOR CALIFORNIA RESIDENTS
Last Updated: November 30, 2023
Last Reviewed: November 30, 2023
This privacy policy is for our customers, users and website visitors who are California consumers, as defined below (this "California Privacy Policy") and supplements the information contained in Church Mutual Privacy Practices Disclosure Notices.
In the event of a conflict between this privacy notice and other Church Mutual privacy notices or policies, this privacy notice will prevail as to California consumers' rights under the CCPA.
- OVERVIEW OF THIS CALIFORNIA PRIVACY POLICY
The California Consumer Privacy Act of 2018 ("CCPA"), as amended and supplemented by the California Privacy Rights Act of 2020 ("CPRA"), gives California consumers certain privacy rights related to their personal information. This document describes the rights that California consumers may have under the CCPA.
What is "personal information"? For the purposes of this California Privacy Policy, "personal information" is defined as information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular California consumer or California household.
Personal information does not include:
- Publicly available information from government records.
- De-identified or aggregated information.
- Other regulated information that is excluded from the CCPAs scope, such as:
- medical information governed by the California Confidentiality of Medical Information Act (CMIA)
- protected health information collected by a covered entity or business associated governed by the Health Insurance Portability and Accountability Act of 1996 (HIPAA)
- clinical trial data subject to the Federal Policy for the Protection of Human Subjects
- personal information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FRCA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver's Privacy Protection Act of 1994.
Who are "California consumers"? A "California consumer" is a natural person who resides in California. For the purposes of this California Privacy Policy, a California consumer does not include persons to the extent they are (i) acting as an employee, owner, director, officer or contractor of a company, partnership, sole proprietorship, nonprofit or government agency that is doing business with Church Mutual . or (ii) acting as a job applicant to, an employee of, owner of, director of, officer of, medical staff member of, or contractor of Church Mutual.
- HOW WE COLLECT, USE, AND SHARE PERSONAL INFORMATION
Church Mutual may collect personal information from you in different ways and for different purposes, as described further below. The table below describes the categories of personal information we may have collected about California consumers in the twelve (12) months prior to the date of this California Privacy Policy and thereafter, the sources from which we may have collected that personal information, the purposes for which we may have used that personal information, and the third parties with whom we may have shared that personal information. It is important to note that the types of personal information we collect will depend on your interaction with us, including the types of products or services you use.
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Category of Personal Information Collected
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Categories of Source(s) from which Personal Information Was Collected
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Business or Commercial Purpose(s) for which Personal Information Was Collected or Used
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Categories of Third Parties with whom Personal Information Was Shared
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1. Identifiers.
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A real name, postal address, unique personal identifier, online identifier Internet Protocol address, email address, account name, social security number, driver's license number, passport number, or other similar identifiers.
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Provide policy and premium quotes, process underwriting applications, administer claims, answer questions or concerns about our insurance products, account administration, reporting, investigating, or preventing fraud or material representation, processing premium billing payments, processing and defending insurance claims, administering insurance benefits (including utilization review activities) and as otherwise required or permitted by federal or state law.
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A third-party vendor if it is reasonably necessary to enable the party to perform services for us, such as claims investigations, appraisals or the detection of fraud or material misrepresentations any of our affiliated companies who provide services to you insurance regulatory authorities, reporting agencies or, if applicable, involuntary market administrators state motor vehicle department to obtain a report of any accidents or convictions law enforcement agencies or other governmental authorities to protect our interest or to report illegal activities persons or organizations conducting insurance actuarial or research studies, subject to appropriate confidentiality agreements and as otherwise permitted or required by law.
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2. Personal information categories listed in the California Customer Records status (Cal. Div. Code § 1798.80 (e)).
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A name, signature, social security number, physical characteristics or description, address, telephone number, passport number, driver's license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number or any other financial information, medical information, or health insurance information.
Some personal information included in the category may overlap with other categories.
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Provide policy and premium quotes, process underwriting applications, administer claims, answer questions or concerns about our insurance products, account administration, reporting, investigating, or preventing fraud or material representation, processing premium billing payments, processing and defending insurance claims, administering insurance benefits (including utilization review activities) and as otherwise required or permitted by federal or state law.
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A third-party vendor if it is reasonably necessary to enable the party to perform services for us, such as claims investigations, appraisals or the detection of fraud or material misrepresentations any of our affiliated companies who provide services to you insurance regulatory authorities, reporting agencies or, if applicable, involuntary market administrators state motor vehicle department to obtain a report of any accidents or convictions law enforcement agencies or other governmental authorities to protect our interest or to report illegal activities persons or organizations conducting insurance actuarial or research studies, subject to appropriate confidentiality agreements and as
otherwise permitted or required by law.
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3. Protected classification characteristic under California or federal law.
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Age, ethnicity, citizenship, religion or creed, marital status, physical illness, mental illness or disabilities, gender, or veteran status.
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Provide policy and premium quotes, process underwriting applications, administer claims, answer questions or concerns about our insurance products, account administration, reporting, investigating, or preventing fraud or material representation, processing premium billing payments, processing and defending insurance claims, administering insurance benefits (including utilization review activities) and as otherwise required or permitted by federal or state law.
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A third-party vendor if it is reasonably necessary to enable the party to perform services for us, such as claims investigations, appraisals or the detection of fraud or material misrepresentations any of our affiliated companies who provide services to you insurance regulatory authorities, reporting agencies or, if applicable, involuntary market administrators state motor vehicle department to obtain a report of any accidents or convictions law enforcement agencies or other governmental authorities to protect our interest or to report illegal activities persons or organizations conducting insurance actuarial or research studies, subject to appropriate confidentiality agreements and as otherwise permitted or required by law.
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4. Commercial information.
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Records of personal property.
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Provide policy and premium quotes, process underwriting applications, administer claims, answer questions or concerns about our insurance products, account administration, reporting, investigating, or preventing fraud or material representation, processing premium billing payments, processing and defending insurance claims, administering insurance benefits (including utilization review activities) and as otherwise required or permitted by federal or state law.
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A third-party vendor if it is reasonably necessary to enable the party to perform services for us, such as claims investigations, appraisals or the detection of fraud or material misrepresentations any of our affiliated companies who provide services to you insurance regulatory authorities, reporting agencies or, if applicable, involuntary market administrators state motor vehicle department to obtain a report of any accidents or convictions law enforcement agencies or other governmental authorities to protect our interest or to report illegal activities persons or organizations conducting insurance actuarial or research studies, subject to appropriate confidentiality agreements and as otherwise permitted or required by law.
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5. Biometic information.
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Physiological, biological or behavioral characteristics.
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Provide policy and premium quotes, process underwriting applications, administer claims, answer questions or concerns about our insurance products, account administration, reporting, investigating, or preventing fraud or material representation, processing premium billing payments, processing and defending insurance claims, administering insurance benefits (including utilization review activities) and as otherwise required or permitted by federal or state law.
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A third-party vendor if it is reasonably necessary to enable the party to perform services for us, such as claims investigations, appraisals or the detection of fraud or material misrepresentations any of our affiliated companies who provide services to you insurance regulatory authorities, reporting agencies or, if applicable, involuntary market administrators state motor vehicle department to obtain a report of any accidents or convictions law enforcement agencies or other governmental authorities to protect our interest or to report illegal activities persons or organizations conducting insurance actuarial or research studies, subject to appropriate confidentiality agreements and as otherwise permitted or required by law.
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6. Internet or other similar network activity.
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Browsing history, search history, information on a consumer's interaction with an Internet Web Site, application, or advertisement.
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Provide policy and premium quotes, process underwriting applications, administer claims, answer questions or concerns about our insurance products, account administration, reporting, investigating, or preventing fraud or material representation, processing premium billing payments, processing and defending insurance claims, administering insurance benefits (including utilization review activities) and as otherwise required or permitted by federal or state law.
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A third-party vendor if it is reasonably necessary to enable the party to perform services for us, such as claims investigations, appraisals or the detection of fraud or material misrepresentations any of our affiliated companies who provide services to you insurance regulatory authorities, reporting agencies or, if applicable, involuntary market administrators state motor vehicle department to obtain a report of any accidents or convictions law enforcement agencies or other governmental authorities to protect our interest or to report illegal activities persons or organizations conducting insurance actuarial or research studies, subject to appropriate confidentiality agreements and as otherwise permitted or required by law.
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7. Geolocation data.
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Physical location or movements.
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Provide policy and premium quotes, process underwriting applications, administer claims, answer questions or concerns about our insurance products, account administration, reporting, investigating, or preventing fraud or material representation, processing premium billing payments, processing and defending insurance claims, administering insurance benefits (including utilization review activities) and as otherwise required or permitted by federal or state law.
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A third-party vendor if it is reasonably necessary to enable the party to perform services for us, such as claims investigations, appraisals or the detection of fraud or material misrepresentations any of our affiliated companies who provide services to you insurance regulatory authorities, reporting agencies or, if applicable, involuntary market administrators state motor vehicle department to obtain a report of any accidents or convictions law enforcement agencies or other governmental authorities to protect our interest or to report illegal activities persons or organizations conducting insurance actuarial or research studies, subject to appropriate confidentiality agreements and as otherwise permitted or required by law.
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8. Sensory data.
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Audio, electronic, visual, thermal, olfactory or similar information.
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Provide policy and premium quotes, process underwriting applications, administer claims, answer questions or concerns about our insurance products, account administration, reporting, investigating, or preventing fraud or material representation, processing premium billing payments, processing and defending insurance claims, administering insurance benefits (including utilization review activities) and as otherwise required or permitted by federal or state law.
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A third-party vendor if it is reasonably necessary to enable the party to perform services for us, such as claims investigations, appraisals or the detection of fraud or material misrepresentations any of our affiliated companies who provide services to you insurance regulatory authorities, reporting agencies or, if applicable, involuntary market administrators state motor vehicle department to obtain a report of any accidents or convictions law enforcement agencies or other governmental authorities to protect our interest or to report illegal activities persons or organizations conducting insurance actuarial or research studies, subject to appropriate confidentiality agreements and as otherwise permitted or required by law.
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9. Professional or employment- related information.
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Current or past job history or performance evaluations.
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Provide policy and premium quotes, process underwriting applications, administer claims, answer questions or concerns about our insurance products, account administration, reporting, investigating, or preventing fraud or material representation, processing premium billing payments, processing and defending insurance claims, administering insurance benefits (including utilization review activities) and as otherwise required or permitted by federal or state law.
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A third-party vendor if it is reasonably necessary to enable the party to perform services for us, such as claims investigations, appraisals or the detection of fraud or material misrepresentations any of our affiliated companies who provide services to you insurance regulatory authorities, reporting agencies or, if applicable, involuntary market administrators state motor vehicle department to obtain a report of any accidents or convictions law enforcement agencies or other governmental authorities to protect our interest or to report illegal activities persons or organizations conducting insurance actuarial or research studies, subject to appropriate confidentiality agreements and as otherwise permitted or required by law.
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10. Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99).
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Student records.
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Provide policy and premium quotes, process underwriting applications, administer claims, answer questions or concerns about our insurance products, account administration, reporting, investigating, or preventing fraud or material representation, processing premium billing payments, processing and defending insurance claims, administering insurance benefits (including utilization review activities) and as otherwise required or permitted by federal or state law.
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A third-party vendor if it is reasonably necessary to enable the party to perform services for us, such as claims investigations, appraisals or the detection of fraud or material misrepresentations any of our affiliated companies who provide services to you insurance regulatory authorities, reporting agencies or, if applicable, involuntary market administrators state motor vehicle department to obtain a report of any accidents or convictions law enforcement agencies or other governmental authorities to protect our interest or to report illegal activities persons or organizations conducting insurance actuarial or research studies, subject to appropriate confidentiality agreements and as otherwise permitted or required by law.
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11. Inferences drawn from other personal information.
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Profile reflecting a person's preferences, characteristics, psychological trends, preferences, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.
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Provide policy and premium quotes, process underwriting applications, administer claims, answer questions or concerns about our insurance products, account administration, reporting, investigating, or preventing fraud or material representation, processing premium billing payments, processing and defending insurance claims, administering insurance benefits (including utilization review activities) and as otherwise required or permitted by federal or state law.
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A third-party vendor if it is reasonably necessary to enable the party to perform services for us, such as claims investigations, appraisals or the detection of fraud or material misrepresentations any of our affiliated companies who provide services to you insurance regulatory authorities, reporting agencies or, if applicable, involuntary market administrators state motor vehicle department to obtain a report of any accidents or convictions law enforcement agencies or other governmental authorities to protect our interest or to report illegal activities persons or organizations conducting insurance actuarial or research studies, subject to appropriate confidentiality agreements and as otherwise permitted or required by law.
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- NO SALE OF PERSONAL INFORMATION
We have not sold or disclosed personal information about you to third parties that are not our service providers in the twelve (12) months prior to the date of this California Privacy Policy, and will not sell personal information about you until further notice. If we change our practices in the future for any new information that we collect from you, we will notify you by updating this California Privacy Policy.
- CCPA RIGHTS FOR CALIFORNIA CONSUMERS
The CCPA provides California consumers with certain rights with regard to their personal information. This Section explains those rights. If you are a California consumer and would like to exercise any of those rights, please see Section [4.F] below for more information on how to submit a request.
A. RIGHT TO KNOW ABOUT AND ACCESS YOUR PERSONAL INFORMATION
If you are a California consumer, you may have the right to request that Church Mutual provide you with information regarding what personal information about you we have collected, used, disclosed, or sold in the preceding twelve (12) months. Once we receive your request and verify your identity, we will disclose to you one or more of the following as requested:
- The categories of personal information we have collected about you in the preceding twelve (12) months.
- The categories of sources from which we collected your personal information in the preceding twelve (12) months.
- The business or commercial purposes for collecting your personal information in the preceding twelve (12) months.
- The categories of third parties with whom we shared your personal information in the preceding twelve (12) months.
- The specific pieces of personal information we collected about you in the preceding twelve (12) months.
B. RIGHT TO REQUEST DELETION OF YOUR PERSONAL INFORMATION
If you are a California consumer, you may have the right to request that Church Mutual delete any personal information that we have collected from you. However, this right to deletion does not apply to any of your personal information that is subject to an exception under the CCPA (as described below). Once we receive your request and verify your identity, we will delete (and direct our service providers to delete) your personal information in our records that is not subject to any of the CCPA exceptions.
CCPA Exceptions
- Complete the transaction for which we collected the personal information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you.
- Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
- Debug products to identify and repair errors that impair existing intended functionality.
- Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
- Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 seq.).
- Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information's deletion may likely render impossible or seriously impair the research's achievement, if you previously provided informed consent.
- Enable solely internal uses that are reasonably aligned with your expectations based on your relationship with us.
- Comply with a legal obligation.
- Make other internal and lawful uses of that information that are compatible with the context in which you provided it.
C. RIGHT TO OPT-OUT OF THE SALE OF YOUR PERSONAL INFORMATION
We have not sold personal information about you to third parties in the twelve (12) months prior to the date of this California Privacy Policy and will not sell personal information about you until further notice. If we change our practices in the future for any new information that we collect from you, we will notify you by updating this California Privacy Policy.
D. RIGHT TO REQUEST CORRECTION OF YOUR PERSONAL DATA
If you are a California consumer, you may have the right to request that Church Mutual correct any inaccurate personal information that we maintain from you. Once we receive your request and verify your identity, we will correct (and direct our service providers to correct) your personal information in our records that is not subject to any of the CCPA exceptions.
E. RIGHT TO NON-DISCRIMINATION
If writing in California, Church Mutual will not discriminate against any California consumer who exercises any of the rights described above. Specifically, except as permitted by the CCPA we will not deny you goods or services charge you different prices or rates, including through granting discounts or other benefits, or imposing penalties provide you with a different level of service or quality of goods or services or suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.
F. HOW TO SUBMIT A REQUEST
If you are a California consumer and would like to exercise any of the CCPA rights identified above, you may submit a request by either filling out this form or by calling us at 800-554-2642 (select Option 5).
G. SUBMITTING A REQUEST THROUGH YOUR AUTHORIZED AGENT
If you are a California consumer, you may have the option to designate an authorized agent to submit a request on your behalf, so long the authorized agent has your written permission to do so and you have taken steps to verify your identity directly with us. If you would like to designate an agent, your agent must register as such with the California Secretary of State and submit a copy of this registration along with your consumer request to us. We may need to contact you directly to verify the request.
H. HOW WE VERIFY YOUR REQUEST
We cannot fulfill your request or provide you with your personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you. Making a verifiable consumer request does not require you to create an account with us.
Requests may be verified by matching multiple pieces of information provided by the California consumer or by a more comprehensive process if the information requested is sensitive information such as a driver's license number, credit card, social security or health data.
Depending on your type of request or the information requested by you, we may require additional information in order to verify your identity and fulfill your request. If we cannot successfully verify your identity, we will inform you of that fact.
We will respond to your request within forty-five (45) days. However, in certain circumstances, we may require additional time to process your request, as permitted by the CCPA or other applicable law. We will advise you within forty-five (45) days after receiving your request if such an extension is necessary and why it is needed. Any disclosures we provide will only cover the twelve (12)-month period preceding our receipt of your request. If we cannot fulfill your request, our response to you will also explain the reason why we cannot fulfill your request.
We do not charge a fee to process or respond to your consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.
You may only make a consumer request to know about or access your personal information twice within a twelve (12)-month period.
If you have any questions or concerns about this California Privacy Policy or our privacy practices, or to request this California Privacy Policy in another format, you should contact Church Mutual by sending an email to ethics@churchmutual.com by writing to us at:
Sandra M. Woller
Assistant Vice President - Chief Compliance Officer Church Mutual Insurance Company, S.I.
3000 Schuster Lane
P.O. Box 357
Merrill, WI 54452-0357
