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"Family First Life Privacy Notice for California Residents

 

Effective Date: Aug 31st, 2020

Last Reviewed on: Aug 31st, 2020

This Privacy Notice for California Residents supplements the information contained in Family First Life Priority Life Independence Team Privacy Policy, and applies solely to all visitors, users, and others who reside in the State of California ("consumers" or "you"). This policy applies to the collection of personal information by Family First Life Priority Life Independence through its website in addition to offline collection methods including but not limited to telephone correspondence. We adopt this notice to comply with the California Consumer Privacy Act of 2018 (CCPA) and any terms defined in the CCPA have the same meaning when used in this Notice.

 

Information We Collect

 

We collect information that identifies, relates to, describes, references, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer, household, or device ("personal information"). Personal information does not include:

  • Publicly available information from government records.

  • Deidentified or aggregated consumer information.

  • Information excluded from the CCPA's scope, including but not limited to:

    • health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and the California Confidentiality of Medical Information Act (CMIA) or clinical trial data;

    • personal information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FCRA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver's Privacy Protection Act of 1994.

 

In particular, we have collected the following categories of personal information from consumers within the last twelve (12) months:

 

Category

-Examples. (Collected)

 

A. Identifiers.

-A real name, alias, postal address, email address, Social Security number, or other similar identifiers. (YES)

 

B. Personal information categories as defined in the California Customer Records statute

-Contact information, signature, physical characteristics or description, financial information, or other similar personal information. Some personal information included in this category may overlap with other categories. (YES)

(Cal. Civ. Code § 1798.80(e)).

 

C. Protected classification characteristics under California or federal law

-Age (40 years or older), citizenship, medical condition, sex, or other similar characteristics of protected classifications. (YES)

 

D. Commercial information.

-Products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies. (YES)

 

E. Biometric information.

-Fingerprints or other identifier or identifying information. (NO)

 

F. Internet or other similar network activity.

Browsing history, search history, information on a consumer's interaction with a website, application, or advertisement. (NO)

 

G. Geolocation data.

-Physical location or movements. (NO)

H. Sensory data.

-Audio, electronic, visual, and similar information. e.g. telephone recordings. (NO)

 

I. Professional or employment-related information.

-Current or past job history or performance evaluations. (YES)

 

J. Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)).

-Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records. (NO)

K. Inferences drawn from other personal information.

-Profile reflecting a person's preferences, characteristics, or other similar information. (NO)

We obtain the categories of personal information listed above from the following categories of sources:

  • Directly from you. For example, from forms you complete or products and services you purchase.

  • From affiliates, independent contractor insurance agents, and other third parties including but not limited to staff or employees of independent contractor insurance agents

  • From publicly available sources of information such as government records or information voluntarily made public.

 

Use of Personal Information

 

We may collect, use, sell, or disclose the personal information collected for various business and commercial purposes including for one or more of the following:

  • To fulfill or meet the reason you provided the information;

    • For example, if you share your name and contact information to request a potential insurance quote or seek more information including, but not limited to, seeking information about becoming a state licensed independent contractor insurance agent, we will use that personal information to respond to your inquiry.

  • To operate, manage, and maintain regular business activities;

  • To provide products and services offered by our contracted insurance carriers and our independent contractor insurance agents;

  • To accomplish our business purposes and objectives;

  • To develop, personalize, and market products and services offered by our contracted carriers and our independent contractor insurance agents;

  • To facilitate communication;

  • To verify your identity;

  • To comply with laws, law enforcement and regulatory requirements, legal processes, and internal policies based on or reflecting legal or regulatory guidance, codes, or opinions; and

  • As described to you when collecting your personal information or as otherwise set forth in the CCPA.

 

Sharing Personal Information

 

We share your personal information with the following categories of third parties:

  • Independent contractor insurance agents.

  • Service Providers.

  • Other authorized third parties including but not limited to staff or employees of independent contractor insurance agents or certain insurance carriers.

 

Disclosures of Personal Information for a Business Purpose

 

In the preceding twelve (12) months, Family First Life has disclosed the following categories of personal information for a business purpose:

  • Category A: Identifiers.

  • Category B: California Customer Records personal information categories.

  • Category C: Protected classification characteristics under California or federal law.

  • Category D: Commercial information.

  • Category I: Professional or employment-related information

 

We disclose your personal information for a business purpose to the following categories of third parties:

  • Independent contractor insurance agents.

  • Service providers.

  • Other authorized third parties including, but not limited to, staff or employees of independent contractor insurance agents or certain insurance carriers.

 

Sales of Personal Information

 

In the preceding twelve (12) months, Family First Life has sold the following categories of personal information:

  • A. Identifiers.

  • B. California Customer Records personal information categories.

  • C. Protected classification characteristics under California or federal law.

  • D. Commercial information.

  • I. Professional or employment-related information

 

We sell your personal information to the following categories of third parties:

  • Independent contractor insurance agents.

  • Other authorized third parties including, but not limited to, staff or employees of independent contractor insurance agents.

 

Your Rights and Choices

 

The CCPA provides consumers (California residents) with specific rights regarding their personal information. This section describes your CCPA rights followed by a section explaining how to exercise those rights.

1. Request to Know

You have the right to request that we disclose certain information to you about our collection and use of your personal information over the past 12 months. Once we receive and confirm your verifiable consumer request, we will disclose to you any or all of the following, as requested by you:

  • The specific pieces of personal information we collected about you.

  • The categories of personal information we collected about you.

  • The categories of sources from which we collect personal information about you.

  • The categories of personal information that we have disclosed about you for a business purpose.

  • The categories of third parties to whom we have disclosed your personal information for a business purpose.

  • Our business or commercial purpose for collecting personal information.

 

2. Request to Delete

 

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

 

3. Request to Opt Out

 

As noted above, we may “sell” your personal information, as that term is broadly defined under the CCPA. You have the right to request that we not sell your personal information to third parties.

 

4. No Discrimination

 

You have a right to not receive discriminatory treatment by us for the exercise of the privacy rights conferred by the CCPA.

 

How to Exercise Your CCPA Rights

 

Submitting a Request to Know and Request to Delete

 

You may submit a Request to Know or Request to Delete using the following methods:

 

Verification Methods

 

Once you submit a request, we will verify that you are the consumer to which the request pertains by matching the identifying information provided by you (e.g., name, email address, telephone number) to the information we maintain. Depending on the type of request you submit, we will attempt to match either two or three of the data points you provided. If we are unable to verify your request with the data points you provided, we may reach out to you for additional information to verify your request.

 

Authorized Agents

 

You can select an “authorized agent” to submit requests on your behalf. We will require the authorized agent to have a written authorization confirming that authority. We may also require you to verify your own identity directly with us. Once your authorized agent is verified, they may submit a request in the typical way described above.

 

Personal Information Sales Opt-Out and Opt-In Rights

 

We do not sell the personal information of consumers under 16 years of age. Consumers who opt- in to personal information sales may opt-out of future sales at any time. To exercise the right to opt-out, you or your authorized representative may submit a request to us by visiting the following Internet Web page link:

DO NOT SELL MY PERSONAL INFORMATION

Other California Privacy Rights

 

California's "Shine the Light" law (Civil Code Section § 1798.83) permits users of our Website that are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please send an email to admin@fflindependence.com.

 

Changes to Our Privacy Notice

 

We reserve the right to amend this privacy notice at our discretion and at any time. When we make changes to this privacy notice, we will post the updated notice on the Website and update the notice's effective date. Your continued use of our Website following the posting of changes constitutes your acceptance of such changes.

 

Alternate Format of CCPA Notice

 

If you have a disability that prevents or limits your ability to access this CCPA Notice, please contact us using the contact information provided below. We will work with you to provide this notice in an alternative format.

 

Contact Information

 

If you have any questions or comments about this notice, the ways in which Family First Life Priority Life Independence Team collects and uses your information described here, your choices and rights regarding such use, or wish to exercise your rights under California law, please do not hesitate to contact us at:

With permission, the text and design of this Privacy Notice for California Residents has been provided by Family First Life (https://familyfirstlife.com/privacy-policy/ccpa) and adapted to this website, for the FFL Priority Life Independence Team (fflindependence.com).   

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