Last Updated: December 19, 2019

Privacy Notice for California Consumers

This Privacy Notice applies solely to consumers who reside in the State of California. Brotherhood Mutual Insurance Company adopts this privacy notice to comply with the California Consumer Privacy Act of 2018 (“CCPA”) and any related regulations issued by the California Attorney General.

 

Personal Information We Collect

We have collected the following categories of personal information from consumers within the last twelve (12) months:

  • Identifiers. For example, a real name, alias, 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.
  • Personal information categories described in California Civil Code section §1798.80. For example, 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.
  • Protected classification characteristics under California or federal law. For example, age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information).
  • Internet or other electronic network activity information. For example, browsing history, search history and information regarding interaction with an Internet Web site, application, or advertisement.
  • Sensory data. For example, audio, electronic, visual, thermal, olfactory, or similar information.
  • Professional or employment-related information. For example, information related to a person’s current or past job history, wage information or performance evaluations.
  • Education information, 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. section 1232g, 34 C.F.R. Part 99). For example, grades, transcripts, student financial information or student disciplinary records.

Personal information does not include publicly available information.

How We Collect Personal Information

In the preceding twelve (12) months, we obtained the personal information described above from the following categories of sources:

  • You.
  • Independent sales agents.
  • Consumer reporting agencies.
  • Our service providers.
  • Public databases.
  • Your employer.
  • Other third parties whom you have authorized to provide us information or as otherwise permitted by law.

How We Use Personal Information

We use or disclose the categories of personal information described above for one or more of the following business purposes:

  • To offer insurance products and related services.
  • To maintain or service accounts.
  • To communicate with you and respond to your inquiries.
  • To underwrite, rate or otherwise manage an insurance policy.
  • To process, investigate, adjust and administer claims.
  • With respect to employees of Brotherhood Mutual, to manage your employment relationship with us.
  • For strategic purposes or to perform service functions such as record keeping or computer related services.
  • To conduct research about your use of our products.
  • To help offer you other products, features, or services that may be of interest.
  • To provide you with information about our products, manage your registration for and attendance at our events and webinars, provide you with customer support or otherwise communicate with you.
  • To enhance your customer experience and improve our products and services.
  • To develop and offer new products and services.

Disclosure of Personal Information

We may disclose the personal information described under Personal Information We Collect to one or more of the following categories of third parties for business purposes:

  • Our subsidiaries, affiliates and alliance partners.
  • Independent sales agents.
  • Our contractors and service providers.
  • Other third parties whom you have authorized us to disclose your information to or as permitted by law.

In the preceding twelve (12) months, we have not sold any personal information.

How We Secure Your Information

We are committed to keeping the personal information collected from our customers and prospects confidential and secure. We maintain security standards to protect your personal information, whether written, spoken, or electronic.

Information collected through the secure portion of our website is encrypted for your protection. We update and test our systems regularly to ensure the protection and integrity of information that we maintain.

Your California Privacy Rights

The CCPA provides California residents with the right to request that we disclose what personal information we collect, use, disclose and sell.

Right to Know

You have the right to request that we disclose the following information regarding the preceding twelve (12) months:

  • The categories of personal information we collected about you.
  • The categories of sources from which we collected personal information about you.
  • Our business or commercial purpose for collecting or selling that personal information.
  • The categories of third parties with whom we share that personal information.
  • The specific pieces of personal information we collected about you.
  • If we disclosed your information for a business purpose, a list identifying the personal information categories that each category of recipient obtained.
  • If we sold your information, a list identifying the personal information categories that each category of recipient purchased. However, we do not sell personal information.

Right to Request Deletion

You have the right to request that we delete any personal information that we collected from you. Once we receive and confirm your verifiable consumer request, we will delete (and direct our service providers to delete) your personal information from our records, unless an exception applies.

We may deny your request if retaining the information is necessary for us or our service providers to:

  1. Complete the transaction for which we collected the personal information, provide a good or service that you requested or that is reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you.
  2. Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity; or prosecute those responsible for that activity.
  3. Debug systems to identify and repair errors that impair existing intended functionality.
  4. Exercise free speech, ensure the right of another consumer to exercise his or her right of free speech, or exercise another right provided for by law.
  5. Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 seq.).
  6. 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 is likely to render impossible or seriously impair the research's achievement, if you previously provided informed consent.
  7. Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
  8. Comply with a legal obligation.
  9. Otherwise use the information, internally, in a lawful manner that is compatible with the context in which you provided it.

Exercising Your Privacy Rights

You may exercise any of your privacy rights by either:

You may only make a verifiable consumer request to access personal information twice within a twelve (12) month period. The verifiable consumer request must:

  • Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative (e.g., full name, phone number and e-mail address).
  • Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

Only you, or a person legally authorized to act on your behalf (an “Authorized Agent”), may make a verifiable consumer request related to your personal information. You may also make a verifiable consumer request on behalf of your minor child.

We cannot respond to your request or provide you with the requested information if we cannot verify your identity or authority to make the request and confirm that the requested information relates to you. We will only use personal information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.

Authorized Agents

If you use an Authorized Agent to submit a request to know or a request to delete, we may require the Authorized Agent to submit proof that they have been authorized to act on your behalf. We may accept as proof either:

  • Written permission from you; or
  • A power of attorney pursuant to the California Probate Code §§ 4000 to 4465.

We may also require the Authorized Agent to verify their identity directly with us.

Confirmation and Response to Your Request

We will send you a confirmation of receipt within ten (10) days of receiving your request to know or request to delete. We endeavor to respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time (up to ninety [90] days), we will inform you of the reason and extension period in writing. We will deliver our written response by mail or electronically, at your option. Any disclosures we provide will only cover the twelve-month period preceding the verifiable consumer request’s receipt. The response we provide will also explain the reasons we cannot comply with a request, if applicable. We will select a format to provide your personal information that is readily usable and should allow you to transmit the information from one entity to another entity without hindrance. We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will inform you of why we made that decision and provide you with a cost estimate before completing your request.

Non-discrimination

We will not discriminate against you for exercising any of your rights under the CCPA. Unless permitted by the CCPA, we will not:

  • Deny you goods or services.
  • Charge you different prices or rates for goods or services, including through the use of discounts or other benefits or imposing penalties.
  • Provide you with a different level or quality of goods or services.
  • Suggest that you will receive a different price or rate for goods or services or a different level or quality of goods or services.

Updates to our Privacy Notice

We recognize and respect the privacy concerns of our customers. We are committed to safeguarding your personal information. As a member of the financial services industry, we are posting this privacy notice for informational purposes and will update and post subsequent notices as changes are made or as required by law. When we make changes to this privacy notice, we will revise the “last updated” date at the top of the notice.

How to Contact Us

If you have any questions or comments about this privacy notice, or if you would like to receive a copy of this notice in an alternative format, you may contact us at:

Phone: 1-888-674-6018
Email:consumerdataprivacy@brotherhoodmutual.com
Address:
Brotherhood Mutual Insurance Company
Attn: Legal Department
6400 Brotherhood Way
Fort Wayne IN 46825