Effective Date: November 01, 2021
Table of Contents
- What Information Do We Collect?
- How Do We Use Your Information?
- Who Do We Share Information With?
- Protection of Information
- Links to Third Party Sites
- Notice to International Users
- Children's Privacy
- California Residents Privacy Rights
- Nevada Resident Privacy Rights
- Your Choices
- Your Rights
- Contact Us
1. What Information Do We Collect?
Information You Provide Directly to Us
We collect information you provide directly to us in order to provide the best service possible. For example, we collect information when you: interact with Cover-More in person, by phone or through mail or email, request or purchase a plan, register for an account, participate in any interactive features of the Sites, subscribe to a newsletter or email list, participate in a survey, contest, promotion or event, request customer support or otherwise communicate with us. Categories of information we may collect from you include:
- Account Information. When you register or contract for an account on the Sites or other channels to become a partner, you will need to provide us with certain personal information to complete the registration, including information that can be used to contact or identify you, which may include your name, email address, mailing address, username, and phone number. We also collect other information you provide as part of registration process and the administration and personalization of your user experience. We may combine this information with the personal information we collect from you.
- Transaction Information. If you choose to order products or services from us you will have to provide us with certain information, including personal information such as: your name, mailing and/or e-mail address, credit or debit card information, Driver's License and/or other photographic identification.
- Content You Submit. We collect the content you submit to the Sites. This includes all comments, feedback or materials submitted by you to us, for example, feedback, testimonials, images, reviews, questions, comments, suggestions or ideas (“Feedback”). Cover-More will be free to use, display, perform, distribute, copy, adapt, and promote, without compensation to you, the Feedback for any purpose whatsoever.
- Verification Information. We may collect information to verify and confirm your identity. This information may include your name, address, date of birth and any other information required by us to complete the verification process.
- Surveys and Promotions. We may request information from you via surveys or promotions. Participation in these surveys or promotions, which might include contests or sweepstakes, is voluntary. Examples of requested information may include contact and demographic information.
1(a). Information We Collect Automatically
We and our third-party service providers or affiliates may use a variety of online tracking technologies, such as cookies, embedded scripts and web beacons, that automatically (or passively) collect certain information whenever you visit or interact with our Sites.
- Usage Information. We collect information about your usage of, and interaction with the Sites. For example, we may track the number of people who view each page and all of the areas within our Sites you visit. We may also collect and store statistics and other information about the online activities of our users on an aggregated (collective) basis.
- Location Information. With your permission, we may also collect information about the precise location of your device using methods that may include GPS, wireless networks, cell towers, and Wi-Fi access points. For more information about how you can control the collection of location information and/or our access to other applications on your device, please see "Your Choices" below.
- Log Information. When you access or use the Sites, our servers automatically record certain log file information, such as your Internet Protocol ("IP") address, operating system, browser type and language, referring URLs, access times, pages viewed, links clicked and other information about your activities on the Site.
- Information Collected by Cookies, Web Beacons and Embedded Scripts. We and our service providers use various tracking technologies, including cookies, web beacons and embedded scripts, to collect information about you when you interact with our Sites, including information about your browsing and purchasing behavior. Cookies are small data files stored on your hard drive or in device memory that help us improve the Sites and your experience, see which areas and features of the Sites are popular, and count visits. Most web browsers are set to accept cookies by default. If you prefer, you can usually choose to set your browser to remove or reject browser cookies. Please note that if you choose to remove or reject cookies, this could affect the availability and functionality of the Sites. Web beacons are small pieces of data that are embedded in images on the pages of web sites. Web beacons may involve the transmission of information directly to us, to another party on our behalf, or to another party in accordance with its privacy practices. We may use web beacons to bring together information we collect about you and to help us optimize and tailor our Sites for you and other future visitors to our Sites. An embedded script is programming code that is designed to collect information about your interactions with our Sites, such as the links you click on. The code is temporarily downloaded onto your device from our web server or a third party service provider, is active only while you are connected to the Sites, and is deactivated or deleted thereafter.
1(b). Information We Collect From Third Parties
2. How Do We Use Your Information?
We may use your information for various purposes related to our operations and your use of the Sites. For example, we may use your information:
- To personalize the user content and experience.
- To provide, maintain and improve our Sites and provide you with relevant information and content.
- To facilitate and administer the provision of the products and services you purchase or request from us, including the verification of your identity, processing payment or to administer a survey, promotion, sweepstakes or contest you participate in.
- To contact you in connection with a particular activity, purchase, or product or service, in person or by recorded message, by e-mail, telephone and/or mobile telephone number, text (SMS) message, or any other means of available communication.
- To notify you in connection with a survey, promotion, sweepstakes or contest.
- To provide you with information and offers on our products and services, that we believe may be of interest to you.
- To send you technical notices, updates, security alerts and support and administrative messages.
- To respond to your comments, questions and requests and provide customer service.
- To monitor and analyze trends, usage and activities in connection with our Sites.
- To detect, investigate and prevent fraudulent transactions and other illegal activities.
- To protect our rights and property and the rights and properties of others.
- To maintain appropriate records for internal administrative purposes.
- To perform operational functions in connection with our business, including data analysis, audits, developing and improving products and services, enhancing the Sites and identifying usage trends.
- To link or combine with information we get from others to help understand your needs and provide you with a better experience.
- To carry out any other purpose described to you at the time the information was collected.
- To comply with legal and regulatory requirements (including fraud prevention and anti-money laundering), required disclosures and choices and controls that may be available.
- To comply with our obligations to third parties in accordance with the terms and conditions of their services being provided on our behalf or directly to you.
- Automated Decision Making. 'Automated Decision Making' refers to a decision which is taken solely on the basis of automated processing of your personal data. This means processing using, for example, software code or an algorithm, which does not require human intervention. If you are a prospective plan holder or holder of an insurance plan, we may use automated decision making using your personal information to calculate insurance premiums (which are often based on age, state of resident, and/or trip cost).
Record Retention. We will maintain your information as long as reasonably necessary to fulfil the purpose for which it was collected, and as long as legally necessary. In some circumstances we may retain your personal data for longer periods of time, for instance where we are required to do so in accordance with legal, regulator, tax or accounting requirements. For example, some insurance related insurance information must be retained for seven (7) years. Some contracts require a longer retention period.
In specific circumstances we may also retain your personal data for longer periods of time so that we have an accurate record of your dealings with us in the event of any complaints or challenges, or if we reasonably believe there is a prospect of litigation relating to your personal data or dealings.
We maintain a data retention policy which we apply to records in our care. Where your personal data is no longer required we will undertake reasonable efforts ensure it is either securely deleted or stored in a way which means it will no longer be used by the business. We may also use your information in connection with promotional or marketing efforts, for example:
- Electronic Promotional Messages. We may send you promotional emails regarding special offers about our or our affiliates' products and services or products and services on behalf of third party marketing partners who we think can offer products, services or content of interest to you. If you do not wish to receive information from us regarding special promotions or offers you can opt out of receipt of such promotional mailings (please see "Your Choices" below). Even if you opt out of receiving promotional emails we may continue to send you transactional notifications that are related to your account, orders, or other products or services you have requested.
- Direct Mail Promotional Offers. We may use your name and mailing address which we obtain from you for us, our affiliates or third party marketing partners to provide marketing offers to you through direct mail. If you prefer not to have your name and mailing address shared with a third party in connection with direct mail promotional messages please see "Your Choices" below. Please note that even if you opt out of receiving promotional mail we may continue to send you transactional notifications in the mail that are related to your account, orders, or other products or services you have requested.
3. Who Do We Share Information With?
- With vendors, consultants or service providers to help us operate our business and the Sites and to administer activities on our behalf
- With strategic partners who provide additional features on the Sites. These strategic relationships may include business partners, sponsors and co-branded Site features. The use of your information by these third parties is subject to their own privacy practices and you should check their website for information regarding their privacy policies.
- By participating in any survey, promotion, sweepstakes or contest, you agree to the official rules that govern that survey, promotion, sweepstakes or contest, including disclosure of your information to third parties or the public in connection with the administration of such survey, promotion, sweepstakes or contest, or as required by law.
- In response to a request for information if we believe disclosure is in accordance with, or required by, any applicable law, rule, regulation or legal process.
- As determined necessary to protect the physical safety of any person or property or as otherwise appropriate when we believe your conduct on the Sites is inappropriate, is detrimental to us, or is inconsistent with generally accepted norms of behavior.
- In the event that we, or any of our businesses, are sold or disposed of as a going concern, whether by merger, sale of assets or otherwise, or in the event of an insolvency, bankruptcy or receivership.
- In connection with a commercial transaction where we or any one of our businesses are seeking financing, investment, support or funding.
- To enforce any agreement we may have with you.
- Between and among us and any current or future parent, subsidiary and/or affiliated company.
- With your consent or at your direction.
Affiliated and non-affiliated third parties that may receive or have access to the personal information in our care are not authorized to use such information for any marketing purposes except as permitted by law or with your consent. They may not copy or disclose personal information to any other party and may use it only for the purpose of performing their responsibilities to us, one of our policyholders and as otherwise permitted or required by law.
Consent. Depending on the nature and sensitivity of your personal information, your consent to the collection, use and disclosure of personal information may be required. This consent can be express (oral or written) or implied. Your consent may be withdrawn, subject to legal or contractual restrictions. By providing your personal information to us as part of a request that we provide a plan, product, or services, or as a request for employment and employment related benefits, you are implied to have consented to the transfer of your personal information to affiliated and unaffiliated third parties as may be necessary to provide the plan, service, or employment and benefits that you have requested.
4. Protection of Information
We maintain reasonable physical, operational and electronic security measures to protect your information. However, the transmission of information via the Internet, the Sites or email is not completely secure and we cannot guarantee the security of information transmitted to or from us. Your use of the Sites and provision of information to us indicates that you are willing to assume this risk. Access to personal information is limited to those with a specific “need to know” in order to provide products and services to policyholders and to others as permitted or required by law. We maintain contractual, physical, electronic and procedural safeguards to protect against the misuse of personal information under our control.
5. Links to Third Party Sites
Our Sites may link to other websites whose privacy practices may differ from ours. If you submit information to any of those websites, your information is governed by their privacy statements. We do not exercise control over third-party websites and are not responsible for the privacy practices or the content of any such third-party websites. We encourage you to carefully read their privacy statement. The fact that we may link to a third-party website or present a banner ad or other type of advertisement from a third party is not an endorsement, authorization, or representation of any affiliation by us with that third party, nor is it an endorsement of their privacy or information security policies or practices.
6. Notice to International Users
The Sites are hosted in the United States and are subject to U.S. law. If you are accessing the Sites from outside the United States, please be advised that U.S. law may not offer the same privacy protections as the laws of your jurisdiction. By accessing and using the Sites, you consent to the transfer to and processing of your personal information in the U.S.
7. Children's Privacy
9. California Resident Privacy Rights
If you are a California resident, California law may provide you with additional rights regarding our use of your personal information; subject to exclusions from the rights granted under California law with respect to certain information governed by certain sector-specific privacy laws.
California Resident Rights
Subject to certain exceptions under California law, California residents may have the following rights with respect to their personal information collected by Cover-More:
- The right to know and access. California residents have the right to request we disclose (i) a copy of the personal information that we collect about you; (ii) the categories of personal information that we collected about you in the preceding 12 months; (iii) the categories of purposes for which such personal information was disclosed in the preceding 12 months; (iv) the categories of sources such personal information was collected for; and (v) the categories of third parties such personal information may have been shared with.
- The right to deletion. California residents have the right to request that we delete the personal information that we or our vendors collected about you. There may be circumstances under which we will be unable to delete your personal information, such as if we need to comply with our legal obligations or complete a transaction for which your personal information was collected. If we are unable to comply with your request for deletion, we will let you know the reason why.
- The right to equal service. If a California resident chooses to exercise any of these rights, we will not discriminate against the California resident in anyway. However, if a California resident exercises certain rights, such California resident may be unable to use or access certain features of the Sites.
9(a). Exercising California Resident Rights
To exercise any of these rights, contact us at [email protected], 888-744-6564. In connection with submitting a request, you must provide the following information: name, email, phone number, state of residence, and policy number and you must state what type of request you are making.
Only a California resident, or someone legally authorized to act on such California resident's behalf, may make a verifiable consumer request related to his or her personal information. In general, we have the right to require you to provide written permission granting authority to your representative and for your agent to verify its identity directly with us, and we may deny a request from your representative who does not submit proof of authorization as we request.
A California resident may only make a verifiable consumer request for access or data portability twice within a 12-month period. The verifiable consumer request must provide sufficient information that allows us to reasonably verify the requestor is the person about whom we collected personal information or an authorized representative and describe the request with sufficient detail that allows us to properly understand, evaluate, and respond to it. We cannot respond to a request or provide personal information if we cannot verify the identity or authority to make the request.
We will endeavor to confirm receipt of a request within 10 days following submission and provide information about how we will process the request. We will endeavor to respond to a verifiable consumer request within 45 days of its receipt. If we require more time (up to an additional 45 days), we will provide notice in writing explaining the reason for the extended time period.
Making a verifiable consumer request does not require a California resident to create an account with us. We may deliver our written response by mail or electronically, at your option.
Any disclosures we provide will only cover the 12-month period preceding the request receipt date. If we deny a request, we will provide a response explaining the reasons we cannot comply with a request, if applicable.
9(b). Sharing of California Resident Personal Information
We may have collected and disclosed the following categories of personal information from a California resident for a business purpose in the preceding 12 months:
- Various identifiers, including, name, address, online identifier, Internet Protocol (IP) address, email address, account name, or other similar identifiers.
- Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)), including, telephone number or financial information.
- Commercial information, including, records of products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.
- Biometric information, including, behavioural characteristics, or activity patterns used to extract a template or other identifier or identifying information.
- Internet or other similar network activity, including, browsing history, search history, information on a consumer's interaction with a website, application, or advertisement, including internet protocol (IP) addresses, browser type, internet service provider (ISP), referring/exit pages, the files viewed on our Site (e.g., HTML pages, graphics, etc.), operating system, date/time stamp, and/or clickstream data in order to analyze trends in the aggregate and administer our Site.
- Geolocation data, including, physical location or movements.
- Sensory data, including, audio, electronic, visual, or similar information.
- Professional or employment-related information, including, current or past job history or performance evaluations.
- Educational information, including, transcript, student records, grades and performance, activities, school name or school ID.
- Inferences drawn from other personal information, including, profile reflecting a person's preferences, characteristics, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.
- Protected classification characteristics, including, race, color, national origin, marital status, sex, veteran or military status.
- Personal records, such as, power of attorney, family history or power of attorney.
- Information received from a government entity or other third party.
We may collect the above categories of personal information directly from you, indirectly as you interact with our Sites, from or through other third party sources, including our customers, or through email or other electronic messages between you and our Sites.
9(c). Sale of California Resident Personal Information
In the prior 12 months, we have not sold personal information of a California resident.
Refer to the Section above entitled "Third Party Analytics Services" to review how to opt-out of receiving behavioral or targeted advertising.
9(d). "Shine the Light" Law
California's "Shine the Light" law, Civil Code section 1798.83, requires certain businesses to respond to requests from California consumers asking about the business' practices related to disclosing personal information to third parties for the third parties' direct marketing purposes. To make such a request, please send an email to [email protected].
How We Respond to "Do Not Track" Signals
Our Sites do not respond to DO NOT Track signals. Third parties cannot collect any other personally identifiable information from our Sites unless you provide it to them directly.
10. Nevada Resident Privacy Rights
Nevada residents may have certain rights to opt-out of sales of their personal information under Nevada Revised Statutes Chapter 603A. However, please know Cover-More does not currently sell data triggering this Nevada statute's opt-out requirements. If you have questions with respect to this right, please contact [email protected].
11. Your Choices
- Location Information. With your consent, we may collect information about your actual location when you use our mobile applications and when you request or purchase products or services. You may stop the collection of this information at any time by changing the settings on your mobile device, but note that some features of our mobile applications may no longer function if you do so.
- Native Applications on Mobile Device. Some features of our mobile applications may require access to certain native applications on your mobile device, such as the camera, photo album and the address book applications. If you decide to use these features, we will ask you for your consent prior to accessing the applications and collecting associated information. Note that you can revoke your consent at any time by changing the settings on your device.
- Cookies. Most web browsers are set to accept cookies by default. If you prefer, you can usually choose to set your browser to remove or reject browser cookies. Please note that if you choose to remove or reject cookies, this could affect the availability and functionality of the Sites.
- Push Notifications. With your consent, we may send promotional and non-promotional push notifications or alerts to your mobile device. You can deactivate these messages at any time by changing the notification settings on your mobile device or within our mobile applications.
- Direct Mail Marketing. To request to opt out of receiving unsolicited commercial direct mail please contact [email protected].
- Email Marketing. You can choose to opt out of receiving promotional emails from Cover-More at any time. Emails will include an unsubscribe link that will remove you from future emails. You may also submit a request to [email protected].
12. Your Rights
To the extent that the General Data Protection Regulation of the EU (GDPR), or some other privacy related law that includes similar rights applies to our processing of your personal data not otherwise addressed herein - you have several rights, of which we would like to inform you; the right to access your data, the right of data rectification (if your data is inaccurate), the right of erasure (if the retention of your data is no longer necessary in relation to the envisaged purpose of the processing), the right to restrict the data processing (e.g. if you contest the accuracy of your data that we process), the right to data portability and the right to lodge a complaint with the competent supervisory authority. At any time during which your data is processed by us, you can withdraw your consent to the processing by reaching out to Zurich and request the data deletion.
You may request access to your data, correction of any mistakes in our files, erasure of records where no longer required, restriction on the processing of your data, objection to the processing of your data, data portability and various information in relation to any Automated Decision Making or the basis for international transfers. You may also exercise a right to complain to your Supervisory Authority. More information about each of these rights can be found by referring to the table set out further below.
To exercise your rights you may contact us as set out in Section 14. Please note the following if you do wish to exercise these rights:
|Right||What this means|
You can ask us to:
|Rectification||You can ask us to rectify inaccurate personal data.|
We may seek to verify the accuracy of the data before rectifying it.
You can ask us to erase your personal data, but only where:
We are not required to comply with your request to erase your personal data if the processing of your personal data is necessary:
There are certain other circumstances in which we are not required to comply with your erasure request, although these two are the most likely circumstances in which we would deny that request
You can ask us to restrict (i.e. keep but not use) your personal data, but only where:
We can continue to use your personal data following a request for restriction, where:
You can ask us to provide your personal data to you in a structured, commonly used, machine-readable format, or you can ask to have it 'ported' directly to another Data Controller, but in each case only where:
|Objection||You can object to any processing of your personal data which has our 'legitimate interests' as its legal basis, if you believe your fundamental rights and freedoms outweigh our legitimate interests.|
Once you have objected, we have an opportunity to demonstrate that we have compelling legitimate interests which override your rights and freedoms.
|Automated Decision Making|
You can ask not to be subject to a decision which is based solely on automated processing (see Section 2), but only where that decision:
In such situations, you can also obtain human intervention in the decision making, and we will ensure measures are in place to allow you to express your point of view, and/or contest the automated decision.
However, in these situations you can still obtain human intervention in the decision making, and we will ensure measures are in place to allow you to express your point of view, and/or contest the automated decision.
|International Transfers||You can ask to obtain a copy of, or reference to, the safeguards under which your personal data is transferred to third parties in other countries.|
We may redact data transfer agreements or related documents (i.e. obscure certain information contained within these documents) for reasons of commercial sensitivity.
|Supervisory Authority||You have a right to lodge a complaint with your local supervisory authority about our processing of your personal data. In the UK, the supervisory authority for data protection is the ICO (https://ico.org.uk/).|
We ask that you please attempt to resolve any issues with us first although you have a right to contact your supervisory authority at any time.
|Identity||We take the confidentiality of all records containing personal data seriously, and reserve the right to ask you for proof of your identity if you make a request in respect of such records.|
|Fees||We will not ask for a fee to exercise any of your rights in relation to your personal data, unless your request for access to information is unfounded, respective or excessive, in which case we will charge a reasonable amount in the circumstances. We will let you know of any charges before completing your request.|
|Timescales||We aim to respond to any valid requests within one month unless it is particularly complicated, or you have made several requests in which case we aim to respond within three months. We will let you know if we are going to take longer than one month. We might ask you if you can tell us what exactly you want to receive or are concerned about. This will help us to action your request more quickly.|
|Third Party Rights||We do not have to comply with a request where it would adversely affect the rights and freedoms of other data subjects.|
14. Contact Us
810 N. 96th Street, Suite 300
Omaha, NE 68114
If you have a complaint or concern about how we use your personal data, please contact us in the first instance and we will attempt to resolve the issue as soon as possible. You also have a right to lodge a complaint with your national data protection supervisory authority at any time.