CALIFORNIA CONSUMER PRIVACY ACT DISCLOSURE
Last update: Jan 2022
Your privacy is important to us. This California Consumer Privacy Act Disclosure explains how Top of Insurance and its subsidiaries, and affiliates ( collectively, “we” or “us”) collect, use, disclose, and sell personal information relating to California residents that is subject to the California Consumer Privacy Act of 2018 (“CCPA”).
What is Personal Information?
Our Collection, Use, Disclosure, and Sale of Personal Information
We collect Personal Information relating to California residents in a variety of contexts. For example, we collect Personal Information relating to individuals who visit and interact with our websites, request or obtain our products or services, apply for employment with us or are our employees, vendors, contractors or similar personnel, or visit our locations or facilities. The specific Personal Information that we collect, use, disclose, and sell relating to a California resident will depend on our relationship or interaction with that individual.
Our Collection of Personal Information
In the past 12 months, we have collected the following categories of Personal Information relating to California residents:
- Personal Identifiers – Identifiers such as name and Social Security number;
- Personal Data – Personal Information, such as contact information, health and financial information;
- Protected Class Information – Characteristics of protected classifications under California or federal law, such as sex and marital status;
- Transaction information – Commercial information, such as transaction and account information;
- Biometric information – Biometric information, such as fingerprints and voiceprints;
- Online Use Information – Internet or network activity information, such as browsing history and interactions with our website;
- Geolocation Information – Geolocation data, such as device location;
- Audio/Video Information – Audio, electronic, visual, thermal, olfactory, and similar information, such as call and video recordings;
- Employment Information – Professional or employment-related information, such as work history, prior employer, and other information necessary for verifying employment eligibility;
- Education Information – Education information, such as school, degrees earned, and graduation data; and
- Inferences – Inferences drawn from any of the Personal Information listed above to create a profile/summary about, for example, an individual’s preferences and characteristics.
We collect this Personal Information directly from you and from the following types of sources: publicly available databases, social media platforms, providers of demographic information, advertising networks, internet service providers, data analytics providers, government entities, operating systems and platforms, educational institutions, former employers, and data brokers.
Our Use of Personal Information
The purposes for which we use the Personal Information that we collect depends on our relationship or interaction with a specific California resident. We use Personal Information:
- to operate, manage, and maintain our business,
- to provide our products and services,
- for our employment and vendor management purposes, and
- to accomplish our business purposes and objectives.
For example, we use Personal Information to personalize, develop, and market our products and services; conduct research and data analysis; maintain our facilities and infrastructure; operate and manage IT and communications systems; facilitate communications; conduct risk and security control and monitoring; detect and prevent fraud; perform identity verification; perform accounting, audit, and other internal functions, such as internal investigations; comply with law, legal process, and internal policies; maintain records; and exercise and defend legal claims.
Our Disclosure of Personal Information
In the past 12 months, we have disclosed the following categories of Personal Information relating to California residents to the following categories of third parties:
|Our affiliates||External Service Providers/Vendors||Governmental or other public authorities||As Part of a Corporate Change|
|Protected Class Information||X||X||X||X|
|Online Use Information||X||X||X|
|Audio Video Data||X||X||X|
Our Sale of Personal Information
In the past 12 months, we have sold the following categories of Personal Information relating to California residents to the following categories of third parties:
|Our Insurance and Financial Services Partners (i.e. Insurance Companies, Lenders, and Agents)||Data Brokers||Advertising Network/Social Media Platforms|
|Protected Class Information||X|
|Online Use of Information||X||X||X|
If you are a California resident, you may also request that we delete Personal Information we collected from you.
We do not knowingly sell the Personal Information of minors under 16 years of age.
Your CCPA Rights to Make Certain Requests
If you are a California resident, you may request that we disclose to you the following information covering the 12 months preceding your request:
- the categories of Personal Information we collected about you and the categories of sources from which we collected such Personal Information;
- the business or commercial purpose for collecting Personal Information about you;
- the categories of Personal Information about you that we disclosed or sold to third parties for a business purpose and the categories of third parties to whom we disclosed or sold Personal Information (if applicable);
- the specific pieces of Personal Information we collected about you.
Finally, if you are a California resident, you have the right to opt-out of the sale of your Personal Information.
We may decline to honor your request, in full or part, for certain reasons, such as a legal exception. For example, if the information you are requesting is subject to certain federal privacy laws, like the GLBA or HIPAA, that are outside the scope of the CCPA rights requests, we may decline to honor your request. We also may decline to honor your access or deletion request if we cannot verify your identity or confirm that the Personal Information that we maintain relates to you, or if we cannot verify that you have the authority to make a request on behalf of another individual.
You have the right to be free from unlawful discrimination for exercising your rights under the CCPA.
How to Make Requests
If you are a California resident, you may make a request for the disclosures described above, make a request to delete Personal Information we collected from you, or opt-out of the sale of your Personal Information, by contacting us at:
When you make a request, depending on the type of request, we may take steps to verify your identity, such as asking you to verify certain pieces of Personal Information or with challenge questions.
Requests by Authorized Agents
A California resident may authorize an agent to make a CCPA rights request on behalf of the California resident. A California resident’s authorized agent may make a request on behalf of the California resident by contacting us at the toll-free telephone number or website listed above.
In general, if an authorized agent makes a request on behalf of a California resident, we may:
- require that the authorized agent provide proof of its registration with the California Secretary of State to conduct business in California;
- require that the California resident provide the authorized agent with written permission signed by the California resident authorizing the agent to make the request on the individual’s behalf (“Signed” means that the permission has either been physically signed or provided electronically in accordance with the Uniform Electronic Transactions Act, Civil Code 1633.7 et seq.);
- verify the identity of the California resident as we would if the California resident were making the request directly; and
- obtain verification from the California resident that the individual gave the authorized agent permission to make the request.
You may also opt-out of the sale of your Personal Information by clicking the “Do Not Sell My Info” link located on each webpage through which we collect Personal Information.
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Changes to This California Consumer Privacy Act Disclosure
We may change or update this Disclosure from time to time. When we do, we will post the revised Disclosure on this page with a new “Last Updated” date.