Privacy Notice for California Residents

Last Updated:  June 1, 2020

This Privacy Notice for California Residents supplements the information contained in our general Privacy Policy and applies solely to individuals who are California residents ("consumers" or "you"). We adopt this Notice to provide information about collection, use, and sharing of personal information and provide notice to consumers of their privacy rights under the California Consumer Privacy Act of 2018 (the “CCPA”). Any terms defined in the CCPA have the same meaning when used in this Notice. In the event that this Privacy Notice conflicts with our general Privacy Policy, the terms of this Notice shall prevail.

This Notice does not apply to employment-related personal information collected from employees, job applicants, contractors, or similar individuals. 

Among other exceptions, the CCPA also currently exempts personal information reflecting a written or verbal business-to-business communication or transaction ("B2B personal information") from certain of its requirements.

Information We Collect

We collect information that identifies, relates to, describes, references, is reasonably capable of being associated with, or could reasonably be linked with a particular consumer ("personal information"). Personal information does not include deidentified or aggregated consumer information or information otherwise excluded from the CCPA's scope. 

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

 Identifiers.  For example, a real name, postal address, driver's license number, or other similar identifiers.

Protected classification characteristics under California or federal law. For example, age, citizenship, marital status, medical condition, or veteran or military status. 

Commercial information. For example, products or services purchased, obtained, or considered. 

Financial account information. 

Internet activity or history or other electronic network activity information.

 Professional, educational, or employment-related information. For example, current or past job history. 

 Inferences drawn from other personal information. For example, information reflecting a person's preferences, characteristics, or attitudes. 

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

• Directly from you or from the entity with which you have a direct relationship
• Directly or indirectly through our website
• Consumer reporting agencies
• Other insurance companies 

Use of Personal Information 

We may use or disclose the personal information that 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 facilitate the provision of our products or services.
• To provide, support, personalize, and develop our website, products, and services.
• To create, maintain, customize, and secure your account with us.
• To process your requests, purchases, transactions, and payments and prevent fraud.
• For testing, research, analysis, and product development, including to develop and improve our website, products, and services.
• To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.
• To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets. 

Sharing Personal Information 

We share your personal information with the following categories recipients:

• Analytics providers
• Website hosting providers
• Marketers
• Payment processors
• Affiliated companies within the Gen Re Group
• Other insurance companies
• Persons who perform a business or professional service for us, such as a consultant 

In the preceding twelve months, we have disclosed all of the categories of personal information that we collect for a business purpose. 

Sales of Personal Information

In the preceding twelve months, we have not sold personal information, and, furthermore, do not have actual knowledge that we sell the personal information of consumers under 16 years old. 

Your Rights and Choices

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

You may request certain information from or certain action by us, such as exercising the access and deletion rights described below, or you may authorize an agent to make such a request on your behalf.  We will seek to verify your identity and your agent’s authority when we receive an individual rights request from you or on your behalf to ensure the security of your personal information, and may need to collect additional personal information to do so. 

Please direct any such rights requests (as further described below) or additional questions that you may have regarding this Notice to the addresses found in the Contact Information section below. 

California residents have the right to request the deletion of personal information, but we may not delete some or all personal information, as required or permitted by applicable law, such as if the requested information is necessary to: 

• Complete your transaction;
• Provide you a good or service;
• Perform a contract between us and you;
• Protect your security and prosecute those responsible for breaching it;
• Protect the free speech rights of you or other users;
• 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;
• Comply with a legal obligation; or
• Make other internal and lawful uses of the information that are compatible with the context in which you provided it. 

If you are a California resident, you may also request to receive details about how we collect, use, and share your personal information.  You may also request to receive the specific pieces of personal information that we have collected about you. 

If a business sells personal information, you have a right to opt-out of that sale. We do not, and do not intend to, sell the personal information of California residents and, furthermore, do not have actual knowledge that we sell the personal information of consumers under 16 years old. 

Businesses may not, and we do not, discriminate against you for exercising any CCPA rights, such as the access and deletion rights described above.

Changes to Our Privacy Notice

We reserve the right to amend this Notice at our discretion and at any time. When we make changes to this Notice, we will post the updated notice on the website and update the Notice's effective date. 

Contact Information

If you have any questions or comments about this Notice or wish to exercise your rights under California law, please contact us at:
Email: andrew.gifford@genre.com
Postal Address: 400 Atlantic Street, 9th Floor, Stamford, CT 06901