Effective Date: June 30, 2020

This Privacy Policy for California Residents (“CCPA Privacy Policy”) applies to eFinancial, LLC or one of its affiliates or subsidiaries (“eFinancial,” “we,” “us,” or “our”) processing of personal information of California residents to the extent the information is subject to the California Consumer Privacy Act of 2018 (“CCPA”). This CCPA Privacy Policy does not apply to personal information collected pursuant to: (i) the Gramm-Leach-Bliley Act and its implementing regulations or the California Financial Information Privacy Act; or (ii) certain medical and health information covered by HIPAA. This CCPA Privacy Policy supplements and does not replace our website Privacy Policy and Terms of Use.

Categories of Personal Information We Collect, Use, or Disclose

eFinancial collects information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household (“Personal Information”).

In general, within the last twelve (12) months eFinancial has collected consumers’ Personal Information so we can provide you with products and services and satisfy our legal obligations. Further, we share consumers’ Personal Information with other businesses who provide services to us, and with government agencies and regulators so that we can provide our products and services to consumers. We may also share a consumer’s Personal Information with our affiliates or in the event of a business transfer. Additional detail on how eFinancial processes Personal Information of consumers is set forth below.

Category of Personal Information

Identifiers

• Examples: Real name, postal address, email address, Social Security number, driver’s license number, or other similar identifiers. In addition, through online facilities or services, (e.g., our website) we collect the following identifiers: Internet Protocol address.
• Categories of Sources of Personal Information: Directly from you, for example when you request a quote, fill out an application or file a claim, from your transactions with us, and from third parties that interact with us in connection with the products and/or services we provide as permitted by law, as well as our service providers.

As a result of your use of our website or other online services, and from third parties such as website analytics providers.

• Business or Commercial Purpose(s) for which Used: We use this Personal Information for performance of our services and for our business operations as required or permitted by law. For example:
  • Providing you with the services that you request, such as by completing transactions, processing registration, processing claims or providing your quote or processing your application for one of our products, or
  • Communicating with you, for example to respond to inquiries, or
  • To respond to law enforcement requests and as required by applicable law, court order, or local, state, or federal government regulations.

We use this information to provide services to you and to maintain our website or other online services, such as:

• To help maintain the safety, security, and integrity of our website, information systems, databases and other technology assets, or
• To personalize the website experience and to deliver content and product and service offerings relevant to your interests, or
• To respond to law enforcement requests and as required by applicable law, court order, or local, state, or federal government regulations.

• Categories of Third Parties with Whom Personal Information is Shared, if any: We share Personal Information as permitted or required by law in connection with performance of our services and for our business operations, including:
  • Administrative service providers, or
  • Our affiliates, pursuant to a business transfer, or
  • Government agencies if required by law, or
  • Advertising or social media networks, to direct content to consumers.

We may share this information as described above as well as with third parties providing:

• Application and security services,
• Website or other online hosting services, or
• Information technology services.

Our website may provide links to content or services controlled or owned by third parties. When website visitors interact with such third-party content or services, they may be sharing their Personal Information with such third parties.

Categories of Personal Information Identified in the California Customer Records Statute (Note: Some Personal Information included in this category may overlap with other categories)

• Examples: A person’s name, signature, social security number, address, telephone number, passport number, driver’s license or state identification card number, insurance policy number, employment, bank account number, credit card number, or debit card number.
• Categories of Sources of Personal Information: We collect this information from the categories of sources of Personal Information listed next to “Identifiers” above.
• Business or Commercial Purpose(s) for which Used: We use this Personal Information for performance of our services and for our business operations as required or permitted by law. For example:
  • Providing you with the services that you request, such as by completing transactions, providing quotes, processing claims or processing your application for one of our products, or
  • Communicating with you, for example to respond to inquiries, or
  • To respond to law enforcement requests and as required by applicable law, court order, or local, state, or federal government regulations.
• Categories of Third Parties with Whom Personal Information is Shared, if any: We may share Personal Information as permitted or required by law in connection with performance of our services, and for our business operations, such as:
  • Administrative service providers, or
  • Our affiliates, pursuant to a business transfer, or
  • Government agencies if required by law, or
  • Advertising or social media networks, to direct content to consumers.

Characteristics of protected classifications under California or federal law

• Examples: Age, citizenship, marital status, medical condition, physical or mental disability, sex (including pregnancy).
• Categories of Sources of Personal Information: Directly from you, for example when you request a quote, fill out an application or file a claim, from your transactions with us, and from third parties that interact with us in connection with the products and/or services we provide as permitted by law, as well as our service providers.
• Business or Commercial Purpose(s) for which Used: We use this Personal Information for performance of our services and for our business operations as required or permitted by law. For example:
  • Providing you with the services that you request, such as by completing transactions, processing registration, processing claims, or processing your application for one of our products, or
  • To respond to law enforcement requests and as required by applicable law, court order, or local, state, or federal government regulations.
• Categories of Third Parties with Whom Personal Information is Shared, if any: We may share Personal Information as permitted or required by law in connection with performance of our services and for our business operations, including:
  • Administrative service providers, or
  • Our affiliates, pursuant to a business transfer, or
  • Government agencies if required by law, or
  • Advertising or social media networks, to direct content to consumers.

Internet or Other Electronic Network Activity Information

• Examples: Browsing history, search history, and information regarding a consumer’s interaction with a website, application, or advertisement.
• Categories of Sources of Personal Information: As the result of your use of our online services, such as our website, consumer portals or mobile applications (if any), including through the use of cookies, Web beacons, embedded scripts, and other recognition and/or tracking technologies.
• Business or Commercial Purpose(s) for which Used: We use this Personal Information for performance of our services and for our business operations as required or permitted by law. For example:
  • To provide access to our website and the information about our products and services contained therein, or
  • For the security of our website and information systems, or
  • Providing you with information, including communications about products that may be of interest to you, or
  • To support, personalize, improve our website, products or services, or
  • To respond to law enforcement requests and as required by applicable law, court order, or local, state, or federal government regulations.
• Categories of Third Parties with Whom Personal Information is Shared, if any: We may share Personal Information as permitted or required by law in connection with performance of our services, and for our business operations, such as:
  • Administrative service providers, or
  • Our affiliates, pursuant to a business transfer, or
  • Government agencies if required by law, or
  • Advertising or social media networks, to direct content to consumers.

Professional or Employment-Related Information

• Examples: Current employment-related information.
• Categories of Sources of Personal Information: Directly from you, for example when you request a quote, fill out an application or file a claim, from your transactions with us, and from third parties that interact with us in connection with the products and/or services we provide as permitted by law, as well as our service providers.
• Business or Commercial Purpose(s) for which Used: We use this Personal Information for performance of our services and for our business operations as required or permitted by law. For example:
  • Providing you with the services that you request, such as by completing transactions, processing registration, processing claims, or processing your application for one of our products, or
  • To respond to law enforcement requests and as required by applicable law, court order, or local, state, or federal government regulations.
• Categories of Third Parties with Whom Personal Information is Shared, if any: We may share Personal Information as permitted or required by law in connection with performance of our services, and for our business operations, such as:
  • Administrative service providers, or
  • Our affiliates, pursuant to a business transfer, or
  • Government agencies if required by law, or
  • Advertising or social media networks, to direct content to consumers.

Disclosure of Personal Information for a Business or Commercial Purpose

Our disclosures of Personal Information for business or commercial purposes in the preceding twelve (12) months are disclosed above.

Do Not Sell My Personal Information

You have the right to request that we do not sell your Personal Information. You can visit our privacy portal or call 888-305-7832 so we can process your opt out request.

Your Privacy Rights

Right to Know

You have the right to request that we disclose to you the Personal Information we collect, use, or disclose about you.

You can visit our privacy portal or call 888-305-7832 to make a disclosure request. You may make up to two requests in any 12-month period.

Only you or a person we can validate as being authorized by you may make a verifiable consumer request related to your Personal Information. If you are requesting information as an authorized agent, additional documentation will be required, and we will contact you about your request.

When you use our online form, it will ask you for certain information. When information is designated as being mandatory, that means we will be unable to verify your identity (or the identity of your authorized agent) without it. We cannot respond to your request or provide you with Personal Information if we cannot both verify your identity or authority to make the request and confirm that Personal Information we have relates to you.

Making a verifiable consumer request does not require you to create an account with us. We will only use Personal Information provided in a Request to Know or Request to Delete to verify the requestor’s identity or authority to make the request and to confirm Personal Information we have relates to the person who is the subject of the request.

Right to Request Deletion

You have the right to request that we delete your Personal Information. You may make such a request by visiting our privacy portal or call 888-305-7832.

You should be aware, however, that California law allows us to retain your Personal Information under certain conditions, even if you have asked us to delete it, such as when retaining your Personal Information is necessary for us to complete a transaction with you or provide you with a good or service you have requested. We will notify you of any denial of your deletion request and the reason for such denial.

Non-Discrimination

We will not discriminate against you for exercising your rights under the CCPA. Unless otherwise 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,
• Provide a different level or quality of goods or services, or
• Suggest that you will receive a different price or rate for goods or services or a different level or quality of goods or services.

Using an Authorized Agent

You may use an authorized agent to submit a “request to know” or “request to delete.” To use an authorized agent, you will need to (i) provide written instruction to your agent, and verify your identity to us, or (ii) provide a power of attorney pursuant to California Probate Code Sections 4000 to 4465.

Contact Us

Phone: 888-305-7832

Email: CCPArequests@efinancial.com