Effective Date: January 1, 2023

Last Updated on: January 1, 2023

InterWest Insurance Services LLC (“InterWest,” “we,” “our,” or “us”) is committed to protecting your privacy. This Privacy Policy for California Residents supplements the information in InterWest Insurance Service’s General Privacy Policy and applies solely to all visitors, users, and others who reside in the State of California (“consumers” or “you”). 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 Policy.

This Policy also applies to workforce-related personal information collected from California-based employees, job applicants, contractors, or similar individuals.

Information We Collect and Retain

We collect information that identifies, relates to, describes, references, is reasonably capable of being associated with, or could be reasonably 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.

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

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.
• Indirectly from you. For example, from observing your actions on our Sites (including the timing, frequency, and pattern of service use) including but not limited to traffic data, location data, weblogs, and other communication data, the resources you access, and how you reached our Sites.
• From third parties on our behalf. (See Information Collected from Third Parties)
• Cookies, web beacons, and other tracking technologies.

We rely on partners to provide many features of our Sites and Services using data about your use. Much of this information is collected through cookies, web beacons, and other tracking technologies, as well as through your web browser or device. We use cookies and similar tacking technologies for the following purposes:

• Analytics: Allowing us to understand how our services are being used, track site performance and make improvements.
• Site Operations: Enabling features that are necessary for providing you the services on our Sites, such as identifying you as being signed in, tracking content views, and remembering your preferences.

Specifically, Google Analytics, through the use of cookies or other tracking technologies, helps us analyze how users interact with and use our website, compiles reports on website activity, and provides other services related to our website activity and usage. The technologies used by Google may collect information such as your location, time of visit, whether you are a return visitor, and any referring website. You can learn more about Google’s partner services and to learn how to opt out of tracking of analytics by Google on Google’s Privacy and Terms website.

Your browser or device may include “Do Not Track” functionality. At this time, we do not alter our Sites’ data collection and use practices in response to Do Not Track signals.

Information Collected from Third Parties

We may collect personal information from individuals other than those proposed for coverage. Some of this information may be collected by external parties on our behalf. For example, we use payment processors when you engage in transactions related to our Sites and Services. We also collect the following information about you from other sources:

• Information about your transactions with us from the insurance companies we contact to underwrite your insurance;
• Contact information we receive from our marketing partners;
• Information we receive from the Department of Motor Vehicles;
• Information we receive from consumer reporting agencies; and
• Information contained in medical records or from medical professionals that is related to your insurance claims.

Use of Personal Information

We may use, or disclose the personal information we collect for one or more of the following purposes:

• To fulfill or meet the reason you provided the information. For example, if you share your name and contact information to request a price quote or ask a question about our products or services, we will use that personal information to respond to your inquiry. If you provide your personal information to purchase a product or service, we will use that information to process your payment and facilitate delivery.
• To provide you with our products and services, including to provide you with quotations for insurance or other insurance or financial industry services (including those procured proactively and/or in connection with the movement of a book of business from one provider to another) on your behalf; to provide you with insurance or to facilitate the performance of related services.
• To make reports to credit bureaus.
• To process your requests, transactions, and payments and prevent transactional fraud.
• To distribute newsletters and promotional material, invite you to events, and market products and services to you.
• To assess, improve and develop our business, products and services, prepare benchmarking reports and for other research and analytics purposes.
• To comply with, or exercise rights under, applicable law – for example to make required or advisable reports to insurance regulatory, law enforcement or other similarly situated authorities; to respond to and comply with court orders, applicable law and other legal requirements; and to defend ourselves against claims and to enforce our rights or protect our employees or property.
• To market products and services to you.
• To provide or receive shared organizational services, such as claim and risk management services.
• To evaluate or effect a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, in which personal information held by us about our consumers is among the assets evaluated or transferred.
• To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by us about our [Website users/consumers] is among the assets transferred.

We will not collect additional categories of personal information or use the personal information we collected for materially different, unrelated, or incompatible purposes without providing you notice.

Sharing Personal Information

We may share your personal information by disclosing it to a third party for a business purpose. We only make these business purpose disclosures under written contracts that describe the purposes, require the recipient to keep the personal information confidential, and prohibit using the disclosed information for any purpose except performing the contract. In the preceding twelve (12) months, Company has not disclosed personal information for a business purpose to the categories of third parties indicated in the chart below.

We do not sell personal information. In the preceding twelve (12) months, Company has not sold personal information to the categories of third parties indicated in the chart below.

Your Rights and Choices

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

Right 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 (the “right to know”). Once we receive your request and confirm your identity (see section “Exercising Your Rights”), we will disclose to you:

• The categories of personal information we collected about you.
• The categories of sources for the personal information we collected about you.
• Our business or commercial purpose for collecting that personal information.
• The categories of third parties with whom we share that personal information.
• If we disclosed your personal information for a business purpose, two separate lists disclosing:
• the category or categories of personal information sold or shared; and
• for disclosures for a business purpose, identifying the personal information categories that each category of recipient obtained.
• The specific pieces of personal information we collected about you.

Right 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 (the “right to delete”). Once we receive your request and confirm your identity (see section “Exercising Your Rights”), we will review your request to see if an exception allowing us to retain the information applies. We may deny your deletion request if retaining the information is necessary for us or our service provider(s) to:

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.

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 et. 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 consumer expectations based on your relationship with us.

• Comply with a legal obligation.

We will delete or deidentify personal information not subject to one of these exceptions from our records and will direct our service providers to take similar action.

Right to Correct Inaccurate Personal Information

You have the right to request that we correct inaccurate personal information that we maintain about you. Once we receive your request and confirm your identity (see https://www.iwins.com/california-consumer-privacy-act-request/), we will review your request and use commercially reasonable efforts to correct the inaccurate personal information as directed by you.

Right to Limit Use and Disclosure of Sensitive Personal Information

You have the right to direct us to limit the use and/or disclosure of your sensitive personal information to that use which is necessary to perform the services or provide the goods reasonably expected by an average consumer who requests those goods or services, to perform the services set forth in paragraphs (2), (4), (5), and (8) of subdivision (e) of Section 1798.140 of the California Civil Code, and as authorized by regulations adopted pursuant to subparagraph (C) of paragraph (19) of subdivision (a) of Section 1798.185.

To exercise the right to limit our use and/or disclosure of your sensitive personal information, you (or your authorized representative) may submit a request to us by visiting the following Internet Web page link: [https://www.iwins.com/california-consumer-privacy-act-request/]

Once you make a request to limit such use, we will wait at least twelve (12) months before requesting you authorize the use and disclosure of your sensitive personal information for additional purposes.

You do not need to create an account with us to limit use or disclosure of your sensitive personal information.

Right of No Retaliation & Non-Discrimination

We will not discriminate against you for exercising any of your CCPA rights. 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 discounts or other benefits, or imposing penalties.
• Provide you a different level or quality of goods or services.
• Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.
• Retaliate against an employee, applicant for employment, or independent contractor for exercising their rights under the CCPA.

However, we may offer you certain financial incentives permitted by the CCPA that can result in different prices, rates, or quality levels. Any CCPA-permitted financial incentive we offer will reasonably relate to your personal information’s value and contain written terms that describe the program’s material aspects. Participation in a financial incentive program requires your prior opt-in consent, which you may revoke at any time.

Exercising Your Rights

To exercise your rights described above, please submit a request by either:

• Calling us at 800-444-4134.
• By filing out a consumer data request form available here: https://www.iwins.com/california-consumer-privacy-act-request/.

Only you, or someone legally authorized to act on your behalf, may make a request relating to your personal information. You may also make a request on behalf of your minor child. You may only submit a request to know twice within a 12-month period. Any request relating to your personal information must:

• Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative, which may include:
  • Asking you to provide personal identifiers we can match against information we may have collected from you previously; and confirm your request using the email or telephone account stated in the request.
• Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

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.

You do not need to create an account with us to submit a request relating to your rights. However, we do consider requests made through your password protected account sufficiently verified when the request relates to personal information associated with that specific account.

We will only use personal information provided in the request to verify the requestor’s identity or authority to make it.

For instructions on exercising your sale opt-out rights or right to limit our use of sensitive personal information, see section “Right to Limit Use and Disclosure of Sensitive Personal Information”.

Response Timing and Format

We will confirm receipt of your request within ten (10) business days. If you do not receive confirmation within the 10-day timeframe, please contact us at helpdesk.corp@iwins.com

We endeavor to substantively respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time (up to another 45 days), we will inform you of the reason and extension period in writing.

Any disclosures we provide will only cover the 12-month period preceding our receipt of your request. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For requests to know, we will select a format to provide your personal information that is readily useable and should allow you to transmit the information from one entity to another entity without hinderance.

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 tell you why we made that decision and provide you with a reasonable cost estimate before completing your request.  

Changes to Our Privacy Policy

We reserve the right to amend this Privacy Policy at our discretion and at any time. When we make changes to this privacy policy, 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.

Contact Information

If you have any questions or comments about this notice, the ways in which we collect and use 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:

Phone: 800-444-4134
Website: www.iwins.com
Email: privacy@iwins.com
Fax: 916-979-7992

Postal Address:

InterWest Insurance Services LLC
P.O. Box 255188
Sacramento, CA 95865

If you need to access this Policy in an alternative format due to having a disability, please contact us at privacy@iwins.com and/or 800-444-4134.