Effective Date: August 5, 2020
Last Reviewed: September 21, 2021
- on our Website;
- through our Services; and
- by email, telephone and other electronic messages between you and us.
- us through any other means, including on any other website operated by EFG or any third-party;
- any third party, including through any application or content (including advertising) that may link to the Website.
2. Children Under the Age of 13
3. Information We Collect About You and How We Collect It
GenerallyWe collect several types of information from and about users of our Website (“Personal Data”):
- by which you may be personally identified, such as first and/or last name, postal address, e-mail address, telephone number, driver’s license number, government issued identification details, passport number, insurance policy number, financial information, loan number, and bank account number or credit card information (for payment information only);
- that is about you but individually does not identify you, such as date of birth, gender, information related to auto, home warranty or other claims, information about your vehicle, health information, other information we receive from you on forms (e.g., occupation, current employer, insurance coverage, purchase and claims history, and premiums), and other information about your use of our Website; and/or
- about your internet connection, the equipment you use to access our Website and usage details.
- directly from you when you provide it to us, such as when you request a quote, submit a claim or apply for a product through our Services;
- automatically as you navigate through the Website. Information collected automatically may include usage details, IP addresses, device information, and information collected through cookies, and other tracking technologies and online browsing data (like date and time of access to our website, referring website address, pages viewed, features used, links clicked, and other actions you take in connection with the website, sometimes referred to as “clickstream data”); and
- from our affiliates and third parties, for example, that help determine eligibility and process requests for Services and process your payment information.
Information You Provide to UsThe information we collect are:
- information that you provide by filling in forms on our Website or through our third parties. This includes information provided when requesting a quote, purchasing a product, submitting a claim, or requesting further information from us;
- information that you provide when requesting a quote or purchasing a product through one of our representatives;
- records and copies of your correspondence (including telephone and email addresses and any transcript of a call), if you contact us;
- your responses to surveys that we might ask you to complete for research purposes; and
- when you report a problem with our Website.
Information We Collect Through Automatic Data Collection TechnologiesAs you navigate through and interact with our Website, we may use automatic data collection technologies to collect certain information about your equipment, browsing actions, and patterns:
- details of your visits to our Website. We collect traffic data, location data, logs, referring/exit pages, date and time of your visit to our Website, error information, clickstream data, and other communication data and the resources that you access and use on the Website; and
- Information about your computer and internet connection, i.e. your IP address, operating system, and browser type.
- estimate our guest size and usage patterns;
- recognize you when you return to our Website.
4. How We Use Your Information
- to present our Website and its contents to you;
- to provide you with information, products or services that you request from us, including to customize our communications with you and provide personalized content, offers, and advertising;
- to administer offers, promotions and surveys;
- to fulfill any other purpose for which you provide it;
- to provide you with notices about your account or product, including notices about your purchase or repair status;
- to carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collection;
- to notify you about changes to our Website, account, or any products or services we offer or provide though them;
- to protect against, and identify, fraud and other criminal activity or to exercise our rights or defend legal claims;
- to perform data analyses and other processing (including market and consumer research, trend analysis, and financial analysis);
- to comply with applicable legal or regulatory obligations, including but not limited to, use in connection with legal claims, compliance, and regulatory or investigative purposes;
- in any other way we may describe when you provide the information; and
- for any other purpose with your consent.
5. Disclosure of Your Information
- to our subsidiaries and affiliates;
- to contractors, service providers, and other third parties that support our business, including those that help us to provide customer service, manage claims, detect and prevent fraud, manage our website, send out communications on our behalf, and process orders for our products;
- to evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of EFG’s assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which Personal Data held by EFG about our customers are among the assets transferred;
- to fulfill the purpose for which you provide it;
- for any other purpose disclosed by us when you provide the information; and
- with your consent.
- to comply with any court order, law, or legal process, including to respond to any government or regulatory request;
- if we believe disclosure is necessary or appropriate to protect the rights, property, or safety of EFG, our staff, or others. This includes exchanging information with other companies and organizations for the purposes of deterring crime, fraud protection, and credit risk reduction.
6. Choices About How We Use and Disclose Your Information
- Promotional Offers from EFG. We may also use your information to contact you about our goods and services that may be of interest to you. If we have sent you a promotional email, you may send us a return email asking to be omitted from future email distributions. This opt out does not apply to information provided to EFG as a result of a request for a quote or to order a product or to a claim request.
7. Accessing and Correcting Your Information
8. State-Specific Privacy Rights
9. Do Not Track Signals
10. Data Security
11. Changes to Our Privacy Notice
12. Contact Information
122 West Carpenter Frwy. Sixth Floor Irving, TX 75039 1-800-527-1984 firstname.lastname@example.orgEFG Privacy Addendum for California Residents Effective Date: January 1, 2020 Last Reviewed on: August 5, 2020 This Privacy Addendum for California Residents (“Privacy Addendum”) supplements the information contained in the EFG Privacy Notice that this is attached to 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 notice. Personal Information that is regulated under the CCPA may represent a limited portion of Personal Data as described in the EFG Privacy Notice; therefore, this Privacy Addendum applies solely to the Personal Information as defined below. We may update this Privacy Addendum for California Residents as necessary and in the event of changes in the CCPA. Note that this notice does not apply to our personnel. Please contact your supervisor if you are personnel and would like additional information about how we process your personal information.
INFORMATION WE COLLECTOur Website and your participation in Services collects information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or device (“Personal Information”). In particular, EFG collects and has collected Personal Information through its Website and through Services from its consumers, as provided below. Categories of Personal Information EFG has collected in the preceding 12 months:
- Identifiers (e.g., name, title, mailing address, email address, driver’s license number, unique personal or contract identifier, online identifier, health information or health insurance information or other similar identifiers)
- Personal Information categories listed in the California Customer Records statute (e.g., name, signature, address (home and correspondence address, if different), home and mobile telephone number, driver’s license, insurance policy number, employment, employment history, bank account number, credit card or debit card number, loan number, or any other financial information. Note, some of this information may overlap with other categories)
- Commercial information (e.g., records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies)
- Internet or other similar network activity (e.g., information on a consumer’s interaction with a website, application, or advertisement)
- Professional or employment related information (e.g., current or past job history)
- Directly from you. For example, from forms you complete when requesting a quote, purchasing a product, or submitting a claim
- Indirectly from you. For example, from our operating systems and platforms
- Affiliates, parents and subsidiary organizations of EFG
- Service providers
- Businesses whom we work with to offer our products and services
- Advertising networks
USE OF PERSONAL INFORMATIONWe may use or disclose the Personal Information we collect for one or more of the following business purposes:
- To fulfill or meet the reason you provided the information. For example: if you share your name and contact information to 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 for a quote (whether through our Website or by telephone with one of our representatives), we will use that information to process your request or payment and facilitate fulfilling your order. We may also save your information to process claims related to our products.
- To provide, support, develop and improve our Website, products and services.
- To process your requests, purchases, transactions, and payments and prevent transactional fraud.
- To provide you with support and to respond to your inquiries, including to investigate and address your concerns and to monitor and improve our responses.
- To help maintain the safety, security, and integrity of our Website, products and services, databases and other technology assets, and business, including to detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, and prosecute those responsible for that activity, and to debug to identify and repair errors that impair existing intended functionality.
- To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.
- Undertaking internal research for technological development and demonstration.
- As described to you when collecting your Personal Information or as otherwise set forth in the CCPA.
- To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of EFG assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which Personal Information held by EFG about our customers are among the assets transferred.
SHARING PERSONAL INFORMATIONWe do not sell, rent, release, disclose, disseminate, make available, transfer, or otherwise communicate your Personal Information to another organization for monetary or other valuable consideration. However, EFG may disclose your Personal Information to a third party for one or more business purposes. When we disclose Personal Information for a business purpose, we enter a contract that describes the purpose and requires the recipient to both keep that Personal Information confidential and not use it for any purpose except performing the contract. We share your Personal Information with the following categories of third parties:
- Service providers
- Affiliates, parents and subsidiary organizations of EFG
- California Customer Records Personal Information categories
- Commercial information
- Service providers.
YOUR RIGHTS AND CHOICESThe 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. Access request rights You have the right to request that EFG 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 (see Exercising Access and Deletion 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 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 sold or disclosed your Personal Information for a business purpose, two separate lists disclosing:
- sales, identifying the Personal Information categories that each category of recipient purchased; and
- disclosures for a business purpose, identifying the Personal Information categories that each category of recipient obtained.
- 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, or otherwise perform our contract 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.
- Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et. seq.).
- Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
- Comply with a legal obligation.
- Make other internal and lawful uses of that information that are compatible with the context in which you provided it.
Exercising Access and Deletion RightsTo exercise the access and deletion rights described above, please submit a verifiable consumer request to us by either:
- Calling us at 1-800-527-1984
- Emailing us at email@example.com
- Provide sufficient information that allows us to reasonably verify you are the person about whom we collected Personal Information or an Authorized Representative; and
- Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.
Personal Information Sales Opt-Out and Opt-In RightsWe do not sell the Personal Information of consumers and therefore do not provide any opt-in or opt-out capabilities on our website or otherwise.
NON-DISCRIMINATIONWe 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 granting discounts or other benefits, or imposing penalties. However, we will continue to offer you discounts and other benefits if you choose to participate in EFG Rewards.
- 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.
CHANGES TO OUR CALIFORNIA ADDENDUMWe reserve the right to amend this California Privacy Addendum as described in our Privacy Notice. When we make changes to this California Privacy Addendum, we will inform you of such updates as described in our Privacy Notice.
OTHER CALIFORNIA PRIVACY RIGHTSCalifornia Civil Code Section 1798.83 (California’s “Shine the Light” law) permits users of our Website that are California residents and who provide Personal Information in obtaining products and services for personal, family, or household use to request certain information regarding our disclosure of Personal Information to third parties for their own direct marketing purposes. If applicable, this information would include the categories of Personal Information and the names and addresses of those businesses with which we shared your Personal Information with for the immediately prior calendar year (e.g. requests made in 2019 will receive information regarding such activities in 2018). You may request this information once per calendar year. To make such a request, please send an email to firstname.lastname@example.org or write us at the mailing address shown in the Privacy Notice that this addendum is attached to.
EFG Privacy Addendum for Nevada ResidentsEffective Date: January 1, 2020 Last Reviewed on: August 5, 20202 Enterprise Financial Group Inc. and its affiliates (“EFG”, “we”, “us”, “our”) respect your privacy and is committed to protecting it through our compliance with this policy. EFG does not sell your personal information to any outside companies. You are entitled, nevertheless, under Nevada law to formally request that we not sell any of your personal information. Please email us at email@example.com to submit your request and we will confirm your request.