The following disclosures are in addition to the Upside Insurance Services LLC and are made pursuant to the California Consumer Privacy Act, as amended by the California Privacy Rights Act and its implementing regulations (“Act”).
Definitions
| Term | Definition |
|---|---|
| Personal Information | Information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, to you or your household. |
| Sensitive personal information | Personal information that reveals your social security number, driver›s license number, state identification card, passport number, account log-in and password, financial account and password, debit or credit card number and access code, precise geolocation information, race, ethnic origin, citizenship or immigration status, religious or philosophical beliefs, union membership, the content of your mail, email or texts other than those communications with us, genetic data, neural data, biometric information, health information, and information that concerns your sex life or sexual orientation. |
| Sell, sale, or sold | Selling, renting, releasing, disclosing, disseminating, making available, transferring, or otherwise communicating orally, in writing, or by other means, your personal information to a third party for monetary or other valuable consideration. |
| Share, shared, or sharing | Sharing, renting, releasing, disclosing, disseminating, making available, transferring, or otherwise communicating orally, in writing, or by electronic or other means, your personal information to a third party for cross-context behavioral advertising, whether or not for monetary or other valuable consideration, including transactions between us and a third party for cross-context behavioral advertising for our benefit in which no money is exchanged. |
Summary of Categories of Personal Information Collected and Disclosed
Below is a summary of the categories of personal information we have collected from and about you in the twelve months preceding the date this Notice was last updated. Also included in this description is personal information about: (1) why the personal information is collected and used; (2) whether the information is “sold” or “shared” to third parties; (3) whether the information is disclosed for a business purpose to third parties; (4) whether the information includes “sensitive personal information”; and (5) a description of how long we may keep your information.
Categories of Personal Information
- Identifiers (Includes Sensitive Personal Information): Includes personal information such as your name, alias, postal address, telephone number, unique online identifier, social media handle, IP address, username and password, email address, account name and/or account number, social security number, driver›s license number, passport number, or state identification number.
- Physical Characteristics (Includes Sensitive Personal Information): Includes personal information such as your race, sex, age, and ethnicity.
- Financial Information (Includes Sensitive Information): Includes personal information such as bank account number, credit card number, debit card number, insurance policy number, or other financial information.
- Internet or other Electronic Network Activity Information: Includes personal information such as browser type and version, browser settings, operating systems and platform, device type, operating information, mobile carrier, page response time and download errors.
- Commercial Information: Includes personal information such as records of products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.
- Biometric Information (Includes Sensitive Personal Information): Includes personal information such as fingerprints and voice recordings.
- Professional and Educational Information: Includes your work history, salary history, and education history.
- Audio, Electronic, Visual, and Related Information: Includes personal information such as photographs, video recordings, or recorded messages.
- Geolocation: Such as zip code and time zone.
- Inferences: Such as profiles created about you that reflect on your preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and/or aptitude.
Category Disclosure Information
| Disclosure | Categories | Description |
|---|---|---|
| How do we collect this information? | Identifiers* | We collect this personal information directly from you or automatically from your device(s). We also may collect this personal information from third parties such as service providers and government agencies. |
| Physical Characteristics* | We collect this personal information directly from you. We also may collect this personal information from other parties, such as service providers. | |
| Financial Information* | ||
| Internet or other Electronic Activity Information | We collect this personal information directly from you or automatically from your device(s). We also may collect this personal information from other parties such as service providers. | |
| Commercial Information | ||
| Biometric Information* | ||
| Professional and Educational Information* | We collect this personal information directly from you. We also may collect this personal information from other parties such as service providers and government agencies. | |
| Audio, Electronic, Visual, and Related Information | We collect this personal information directly from you or automatically from your device(s). We also may collect this personal information from other parties such as service providers. | |
| Inferences | ||
| Does this include sensitive personal information? | The categories of sensitive personal information we collect include social security number, driver’s license number, passport number, racial or ethnic origin, health information, and bank account number, credit card number, debit card number, or any other financial information with a required access or security code, password, or credentials. *Denotes which categories may include sensitive personal information. We do not process your sensitive personal information other than for the purposes permitted under the Act, such as providing the Sites to you, providing the Services you requested, fulfilling a transaction you requested or servicing your policy. | |
| Is the information “sold” or “shared”? | Identifiers* | We may sell or share this personal information. |
| Physical Characteristics* | ||
| Financial Information* | We do not sell or share this personal information. | |
| Internet or other Electronic Activity Information | We may sell or share this personal information. | |
| Commercial Information | ||
| Biometric Information* | We do not sell or share this personal information. | |
| Professional and Educational Information | ||
| Audio, Electronic, Visual, and Related Information | ||
| Inferences | ||
| What is our business purpose for collecting your information? | See How Do We Use Your Personal Information above. | |
| Who do we disclose this information to? | See How Do We Share Your Personal Information above. | |
| How long do we keep the information? | We keep your personal information for so long as is reasonably necessary and proportionate to the original purpose for which we collected the personal information. We base our criteria in determining appropriate retention periods on regulatory and legal requirements, contractual requirements, business needs, and the expectations of you. | |
Notice of Disclosure for a Business Purpose
To learn more about the categories of personal information we have disclosed for a business purpose over the last twelve months, including the categories of parties with whom we have disclosed that personal information, please contact us at (_____) _____-_______ or _________@______.com.
Notice of Sale or Sharing
To learn more about the categories of personal information we may have “sold” or “shared” for cross-context behavioral advertising over the last twelve months, and may do so on an ongoing basis, see Is the personal information “sold” or “shared” for targeted advertising? above. We may have “sold” or “shared” your personal information to third party advertising, marketing, and cookie providers for targeted and other advertising purposes. We have no actual knowledge of selling or sharing for targeted advertising the personal information of minors under the age of 16.
Your Rights
Under Act and its implementing regulations, you have a Right to Know, Right to Correct, Right to Delete, Right to Opt-Out of the Sale of Personal Information or Sharing of Personal Information for Cross-Context Behavioral Advertising, and Right to Non-Discrimination. We do not offer a right to opt out of sale or sharing or limit the use and disclosure of sensitive personal information because we do not sell or share your personal information or use your sensitive personal information other than for permitted purposes under the Act. We provide you the ability to exercise certain controls and choices regarding our collection, use, storage, and disclosure of your personal information. Please note that for some of these rights, such as the Right to Know, Right to Correct, and Right to Delete, we will verify your identity before we respond to your request. To verify your identity, we will generally match the identifying personal information provided in your request with the information we have on file about you. Depending on the sensitivity of the personal information related to your rights request, we may also utilize more stringent verification methods to verify your identity, including but not limited to requesting additional information from you and/or requiring you to sign a declaration under penalty of perjury.
- Right to Know. You have a right to confirm whether we are processing your personal information and ask that we disclose to you the categories and specific pieces of personal information we have collected about you including a description of the categories of sources from which we have collected that personal information, the business or commercial purpose for collecting, selling or sharing that information, and the categories of third parties to whom we have disclosed that personal information. You have the right to receive this information in a format, to the extent technically feasible, that is portable, usable, and allows you to transmit the personal information to a person without impediment. You may submit this request by (_____) _____-_______ or _________@______.com. You may also designate an authorized agent to submit a request on your behalf.
- Right to Correct. You have a right to ask that we correct your personal information, subject to appropriate legal exceptions. You may submit this request by (_____) _____-_______ or _________@______.com. You may also designate an authorized agent to submit a request on your behalf.
- Right to Delete. You have a right to ask that we delete your personal information, subject to appropriate legal exceptions. You may submit this request by (_____) _____-_______ or _________@______.com. You may also designate an authorized agent to submit a request on your behalf.
- Right to Opt-Out of the Sale of Personal Information and Sharing for Targeted Advertising. You have a right to opt-out of the “sale” of your personal information and “sharing” of your personal information for cross-context behavioral advertising. Although we do not “sell” your information in the traditional sense, the definition of “sale” is broad under applicable state laws that some disclosures of your information to third parties may be considered a “sale” or “sharing” for targeted advertising. To exercise this right, you may access our “Do Not Sell or Share My Personal Information” link at the bottom of our website.
- Right of Non-Discrimination. You have a right to exercise your rights under this section free of discrimination. Upside Insurance Services, LLC will not discriminate against you in any way if you choose to exercise your rights under this section.
Authorized Agents
If permitted or required by applicable law, you may exercise your privacy rights through an authorized agent. If we receive your request from an authorized agent, we may ask for evidence that you have provided such agent with a power of attorney or that the agent otherwise has valid written authority to submit requests to exercise rights on your behalf. If you are an authorized agent seeking to make a request, please contact us for an authorized agent form at (_____) _____-_______ or _________@______.com.
Shine the Light
If you are a California resident, you are permitted to request information regarding the disclosure of your information to Third Parties for their direct marketing purposes. To make such a request, please contact us at (_____) _____-_______ or _________@______.com.
California Minors
If you are a California resident under the age of 18, California Business and Professions Code § 22581 permits you to request and obtain removal of content or information you have publicly posted on any of our Sites. To make such a request, please send an email with a detailed description of the specific content or information to _________@______.com. Please be aware that such a request does not ensure complete or comprehensive removal of the content or information you have posted and there may be circumstances in which the law does not require or allow removal even if requested.
