Last Update: September 1, 2023
Privacy Statement – Highlights
Your privacy is important to us, and we know that you care about what happens to the information you provide to us or that we collect through our website, mobile applications, online advertisements, telephone and email communications, and other online and offline interactions (our “Systems”). We have provided highlights below regarding how we collect, use, and share your information. This statement applies only to our Systems and does not apply to third-party sites. Click [here] to see our full Privacy Statement.
As an insurance broker, SR-22 Adviser primarily handles information subject to financial privacy laws, such as the Gramm-Leach-Bliley Act and similar state laws (“Financial Information”). The privacy notice on this page contains information about how we handle such Financial Information and other information collected through our Systems. In the limited situations when we handle non-Financial Information about California residents subject to the California Consumer Privacy Act (“CCPA”), please see our separate CCPA Privacy Notice for more information about our data practices.
What Information Do We Collect?
We collect the following types of information:
- Information we receive from you on applications or other forms, or in communications with you, in order to provide you with a quote or place insurance, or service your policy.
- Information about your transactions and relationships with us, our affiliated companies, and others.
- Content you submit or post.
- Information we receive from consumer reporting agencies, insurance-support organizations and other third parties.
- Information that is automatically collected when you use our Systems, such as when you visit our website.
How Do We Use Your Information?
We use your information in a number of ways, including:
- To provide you with products and services, such as to determine your eligibility for insurance; service your policy; administer policy benefits; process claims; process, service and enforce transactions (including credit or debit card transactions); respond to your inquiries or comments; or contact you about your policy; establish and verify the identity and eligibility of users; open, maintain, administer, manage, and service users’ profiles or accounts; provide users with product, service, or company updates; conduct special events, sweepstakes, surveys, programs, contests, and other offers (and communicate with you about such events).
- For our own internal business purposes, such as to analyze and improve our products, services, or Systems; improve safety; manage our communications; analyze our products; perform market research; perform data analytics; perform accounting, auditing and other internal functions; and communicate with you about or through external social networking platforms.
- For marketing. To market and advertise our products or services or those of third-parties.
- For legal, safety or security reasons, such as to maintain the security and integrity of our Systems and internal records; conform to legal requirements or industry standards; respond to regulators; comply with subpoenas and legal process; detect and prevent fraud or criminal activity; defend our legal rights; or protect others.
- In an anonymized or aggregated format. We may use information we collect about you to create anonymized or aggregated data sets for any purpose, and information may be aggregated and merged or enhanced with data from other sources.
How We Share Your Information?
We share your information as follows:
- With third-party service providers or business partners that help us with our business functions and help us service or process insurance transactions.
- With affiliated companies and non-affiliated business partners for their marketing or business purposes.
- If necessary to protect the safety, property, or other rights of us, our users, or employees, or when required by law.
- With your consent.
Privacy Statement – Full Statement
We respect your concerns about privacy, and we value the relationship we have with you. This Privacy Statement describes the types of information we collect about you, how we use the information, with whom we share it, the choices available to you regarding our use of the information, and how you can contact us about our privacy practices.
- What Information Does This Privacy Statement Apply To?
This Privacy Statement applies to our collection, use, and disclosure of information from and about you through this website, our mobile applications, online advertisements, telephone and email communications, and other online and offline interactions (collectively, our “Systems”).
This Privacy Statement does not apply to third-party websites that may be accessible through hyperlinks on this website. Third-party websites have their own privacy statements that we encourage you to review. Linking to a third-party site does not mean that we endorse the site, any products or services described on the site, or any other material contained on that site. To the extent any linked websites you visit are not owned or controlled by us, we are not responsible for the sites’ content, any use of the sites, or the privacy practices of the sites. Please review the privacy statements on those other websites to see how they handle your information.
We may update or modify this Privacy Statement from time to time at our sole discretion, and the date of the most recent update will be displayed at the top of this page. We encourage you to visit this area frequently to stay informed. We will notify you of any material changes to this Privacy Statement by posting an update on our website or in another appropriate manner.
- What Information Do We Collect?
We may obtain information about you from various sources. We may collect information when you provide it directly at or through our Systems. We may also collect information about you from third parties. When you use our Systems, we may also collect certain information about your device or usage by automated means or by using technologies such as cookies, web server logs, and web beacons.
Information that You or Others Provide
You may choose to provide information to us in a number of ways, such as when you request a quote, apply for a policy, purchase insurance, contact us, file a claim, request service, register on our Systems, post or provide content, or otherwise interact on or with our Systems. In the course of an insurance transaction, we may collect information about you from third-parties. The types of information you or others may provide to us include:
- Information we receive from you on applications or other forms, or in communications with you, in order to provide you with a quote or issue a policy (such as name, address, city, state, Zip Code, email address, telephone number, birth date, household information, marital status, vehicle information, driver’s license number, property information, employer, occupation, education, previous insurance, information about your business, and information about beneficiaries).
- Information about your transactions and relationships with us, our affiliated companies, and others (such as your insurance coverages, claims, premiums, and payment history).
- Financial and payment information (such as social security number, income, payment card number, expiration date, account number, and billing address).
- Medical information (such as information about your health status or condition, treatment or payment for health care).
- Product preferences, advertising preferences, and other information about how you use our Systems.
- Content you submit or post (such as photographs, videos, reviews, articles, comments, or any other information you provide to us or post).
- Records and copies of your communications with us.
- Information we receive from consumer reporting agencies, insurance-support organizations and others (such as driving records, motor vehicle reports, creditworthiness, credit history or score, claims history, and vehicle data).
If you provide us with information regarding another individual, we will assume that you have that person’s consent to give us his or her information.
Information Collected Automatically
When you visit our Systems or our online advertisements, utilize our services, open an email that we send you, or interact with communication features on our Systems, we may collect information about your usage or device by automated means. Some of the technologies we use to collect information automatically include:
- Cookies: Cookies are small text files that websites send to your computer or other Internet-connected device to uniquely identify your browser or to store information or settings in your browser. Some cookies exist only during a single session, and some are persistent over multiple sessions over time.
- Web server logs: In conjunction with obtaining information through cookies, our web servers may log details regarding your device, operating system, or information about your usage of our Systems.
- Web beacons and pixels: We may place tags on our Systems or in emails called “web beacons” or “pixels.” These are computer instructions that link web pages to particular web servers and their cookies. Web beacons and pixels can be used to track the pages you view, links that you click, or other online behavior.
- Other: In addition to cookies, web server logs, and web beacons, we may use other technologies to collect information for the purposes described in this Privacy Statement. For example, we may use session replay tools, which record your interactions with our Systems, such as how you move throughout our Systems and engage with our webforms. In addition to the uses described below, this information helps us improve our Systems and identify and fix technical issues visitors may be having with our Systems.
These technologies may collect information about your or your device, such as demographic data, browser type, MAC address and other device information, operating system type and settings, domain, the address of the web page that linked you to our Systems, IP address, cookie ID, device ID, AdID, pages visited, whether you have visited us before or are new to the Systems, activities conducted on the page (such as search queries), and the day and time of your visit. This information may be correlated to other data that identifies you specifically. We also collect information about you and your interactions with social media and other third-party websites, which we may merge or enhance with other information we collect about you for the purposes described in this Privacy Statement.
We may disclose information to third parties or allow third parties to directly collect information using these technologies on our Systems, such as social media companies, advertising networks, companies that provide analytics including ad tracking and reporting, security providers, and others that help us operate our business and Systems.
At this time, we do not honor “do not track” signals from website browsers. However, you may refuse or delete cookies using your browser settings. If you do, some of the functionality of our Systems may be impaired. Please refer to your browser Help instructions to learn more about how to manage cookies and similar technologies. If you change computers, devices, or browsers; use multiple computers, devices, or browsers; or delete your cookies, you may need to repeat this process for each computer, device, or browser. Some of the third parties we work with participate with the Digital Advertising Alliance (“DAA”) and Network Advertising Initiative (“NAI”). The DAA and NAI provide mechanisms for you to opt out of interest-based advertising performed by participating members at http://www.aboutads.info/choices/ and https://optout.networkadvertising.org/. Opting out of interest-based advertising will not opt you out of all advertising, but rather only interest-based advertising from VW or its agents or representatives.
- How Do We Use Your Information?
We use your information in a number of ways, including:
- To offer you products and services, determine your eligibility for insurance, service your policy, administer policy benefits, to process, service and enforce transactions (including credit or debit card transactions) and to provide users with product, service, or company updates.
- To respond to your inquiries or comments, or to contact you about your policy.
- To establish and verify the identity and eligibility of users.
- To open, maintain, administer, manage, and service users’ profiles or accounts.
- To analyze and improve our products, services, or Systems, improve safety; manage our communications; perform market research; perform data analytics; and perform accounting, auditing and other internal functions.
- To communicate with you about or through external social networking platforms.
- To conduct special events, sweepstakes, surveys, programs, contests, and other offers (and communicate with you about such events).
- To market and advertise our products and services or those of third-parties.
- To maintain the security and integrity of our Systems and internal records.
- To conform to legal requirements or industry standards, respond to regulators, comply with subpoenas or legal process, detect and prevent fraud or criminal activity, defend our legal rights, or protect others.
- To create anonymized or aggregated data sets.
- In connection with a merger, acquisition, bankruptcy, transfer, sale, corporate change, or any other transaction involving all or a portion of our business.
- How Do We Disclose Your Information?
We may disclose aggregated, de-identified, or anonymized data about you that does not identify you directly with third parties for any purpose, including marketing. We disclose information that specifically identifies you as described below and as permitted by law.
- We may disclose information to third-party service providers that help us to provide our products and services to you, service or maintain your policy, effect, administer or enforce a transaction that you request or authorize, and to run our day-to-day business. Such third-party may include insurance companies, marketing firms, entities that process credit card payments, lawyers, accountants, reinsurance companies, companies that assist in the printing or delivering of statements and notices, or entities that provide web hosting or analytic services. Such third parties are not authorized to use or disclose your information except as necessary to perform services on our behalf or comply with legal requirements.
- We may disclose information to third-parties, such as your bank, to effect, administer or enforce a transaction that you request or authorize.
- We may disclose information to third-parties for their own marketing or other business purposes. Such third-parties may include:
- Our affiliates so they may market their products and services to you.
- Other financial institutions with which we have joint-marketing agreements.
- Non-affiliated companies for their marketing or other business purposes as permitted by law, such as insurance companies, insurance agencies, mortgage brokers, bankers, securities broker-dealers, retailers, airlines, and others.
- We may disclose information to other third parties, as permitted by law, such as:
- When necessary to protect the safety, property, or other rights of us, our customers, or employees;
- To comply with federal, state, and local laws;
- To comply with any court order, law, or legal process, including to respond to any government or regulatory inquiry, subpoena, or legal process;
- To state or federal regulators;
- To prevent or detect fraud or criminal activity;
- To medical care institutions or providers to verify coverage or determine the reasonableness of medical services for audits, peer reviews, or to inform individuals of medical problems;
- For research and actuarial studies;
- To protect the confidentiality or security of our records;
- To consumer-reporting agencies;
- To auditors;
- To insurance rate-advisory organizations, guaranty funds, or rating agencies, and persons that assess our compliance with industry standards;
- In connection with a merger, acquisition, bankruptcy, transfer, sale, corporate change, or any other transaction involving all or a portion of our business.
- With your consent in certain circumstances.
- What About External Social Media Platforms?
Our Systems may embed plugs-ins, widgets or other apps of various external social media platforms. When you encounter those embedded objects, your internet browser may make a direct connection to the social media platform and may share with the social media platform information, such as which of our Systems you have visited, information about your public profile, or content you have posted.
- Is Your Information Secure?
We take reasonable precautions to protect your information from loss, misuse, or alteration. Access to information in our possession is limited to those employees who need it to perform business services, process your transactions, or to market on our behalf. Please be aware, however, that any email or other transmission you send through the Internet cannot be completely protected against unauthorized interception.
- Do We Collect Information from Children?
We do not intentionally collect information from children under 13 years of age, and children under age 13 should not submit any information to us. If we become aware that a child has provided us with information without parental consent, or a parent or guardian of a child contacts us through the contact information provided below, we will use reasonable efforts to delete the child’s information from our databases.
- How Can You Limit Information Sharing?
Individuals who obtain financial products and services from us (“Financial Customers”) may have different rights with respect to their Financial Information depending on their state of residence. Please check the “State Specific Rights and Information” section of this privacy statement.
- Non-Affiliated Third Parties: If you prefer that we not disclose nonpublic personal information about you to non-affiliated third parties, you may opt out of those disclosures; that is, you may direct us not to make those disclosures (subject to the exceptions described below). If you wish to opt out of disclosures to non-affiliated third parties, you may call us at 877-214-0149 toll free. Note that you can only opt out of sharing your nonpublic personal information with non-affiliated third parties for certain purposes; you cannot opt out of sharing such information with non-affiliated third parties who are service providers to us, who engage in joint marketing efforts with us, who assist us with processing and servicing transactions, or as otherwise permitted by law.
- Affiliated Third Parties: If you prefer that we not share consumer report information that is used for insurance eligibility purposes with our affiliated companies for them to market their products and services to you, you may opt-out of such marketing by calling us at 877-214-0149 toll free.
- Review and Correction: You have the right to review and request correction of your information. To make a request, please send a written request to us at one the following addresses:
ATTN: Customer Service Escalations Team
4630 Border Village Rd., STE 2018 San Ysidro, CA 92173
The request must include your name, address, policy number, and your notarized signature.
- State Specific Rights and Information for Financial Customers
If you are a Financial Customer and a resident of one of the following states, you may have additional rights with respect to your Financial Information as described in this section.
CALIFORNIA RESIDENTS. Important Privacy Choices for California Residents. If you are a resident of California, we will not disclose your Financial Information with any non-affiliated companies for marketing unless the disclosure is otherwise permitted by law or you give us your express prior consent. We may also disclose your Financial Information for marketing purposes to affiliated companies, and to non-affiliated companies with which we have contracts to provide financial products or services to you, but not until we provide you with an opportunity to opt-out of such disclosure and you do not opt-out. Nothing in this Privacy Statement limits any rights California residents may have under California state law.
To exercise your California opt-in and opt-out rights related to our disclosure of your Financial Information for marketing purposes, please click here.
MONTANA RESIDENTS. If you are a resident of Montana, we will not disclose your Financial Information to non-affiliated companies for their marketing purposes unless the company has an insurance license, you authorize us to do so, or as permitted by law.
NEVADA RESIDENTS. If you are a resident of Nevada and do not want to receive sales calls from us, you may ask to be placed on our internal do-not-call list. You may make this request by emailing us at email@example.com providing your name, address, and the telephone numbers you wish to include on the list. If you have questions, you may contact us or you may contact the Nevada Attorney General at: 555 E. Washington Avenue, Suite 3900, Las Vegas, NV 89101; 800-434-9989; or BCPINFO@ag.state.nv.us.
RESIDENTS OF NEW MEXICO, NORTH DAKOTA, AND VERMONT. If you are a resident of New Mexico, North Dakota, or Vermont, we will not disclose your Financial Information to non-affiliated companies unless you expressly authorize us to do so. This does not prohibit us from disclosing your Financial Information to third parties that perform business services for us or that assist us in servicing your policy or fulfilling a request made by you, or as otherwise permitted by law.
- Other Choices
You may also “opt-out,” or unsubscribe, from our newsletters, special offers or discounts, or other marketing communications by following the unsubscribe instructions in any e-mail or other communication you receive from us. After doing so, you will not receive future promotional emails unless you purchase a new policy, enter a contest, or sign up to receive newsletters or emails. Please note that even after you unsubscribe, we may still disclose information as permitted or required by law including, but not limited to, service-related announcements, important information about your policy, state-required notices, and other non-marketing communications about your account or insurance, and you may continue to receive marketing emails from third parties with whom we have shared your information. You will need to contact those third parties in order to opt out of future email marketing communications from them.
We store data for as long as it is necessary to provide the products and services described in this Privacy Statement and for our internal business purposes. If you would like us to delete information, you may contact us using the information below and we will take reasonable efforts to accommodate your request.
We are committed to working with you to obtain a fair and rapid resolution of any queries, complaints, or disputes about privacy. If you have any other questions or comments regarding our privacy practices, please call us at 877-214-0149 toll free for more informationn.
Effective Date: January 1, 2023