Rev. March 2022
CALIFORNIA CONSUMER PRIVACY ACT PRIVACY POLICY
Your privacy is important to us. This California Consumer Privacy Act
Privacy Policy explains how Covered Care, LLC (collectively “we,” “us” and
“our”) collect, use, and disclose personal information relating
to California residents covered by the
California Consumer Privacy Act of 2018 (“CCPA”). This notice is provided
pursuant to the CCPA.
Introduction
Under the CCPA, ‘Personal Information’ is information that identifies,
relates to, or could reasonably be linked directly or indirectly with a
particular California resident. The CCPA, however, does not apply to certain
information, such as information subject to the Gramm-Leach-Bliley Act
(“GLBA”).
The specific Personal Information that we collect, use, and disclose
relating to a California resident covered by the CCPA will vary based on our
relationship or interaction with that individual. For example, this
Disclosure does not apply with respect to information that we collect about
California residents who apply for or obtain our financial products and
services for personal, family, or household purposes. For more information
about how we collect, disclose, and secure information relating to these
customers, please refer to our
Privacy Notice.
Keeping Personal Information secure is one of our most important priorities.
Consistent with our obligations under applicable laws and regulations, we
maintain physical, technical, electronic, procedural and organizational
safeguards and security measures that are designed to protect personal data
against accidental, unlawful, or unauthorized destruction, loss, alteration,
disclosure, or access, whether it is processed by us or elsewhere.
Collection and Disclosure of Personal Information
In the past 12 months, we have collected, and may have disclosed to third
parties for our business purposes, the following categories of Personal
Information relating to California residents covered by this privacy policy:
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Category A. Identifiers, such as name and government-issued
identifier (e.g., Social Security number);
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Category B. Personal information, as defined in the California
safeguards law (Cal. Civ. Code § 1798.80(e)), such as contact
information and financial information;
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Category F. Internet or network activity information, such as
browsing history and interactions with our website;
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Category G. Geolocation data, such as device location and Internet
Protocol (IP) location;
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Category H. Audio, electronic, visual and similar information,
such as call and video recordings;
Sources from which Personal Information is Collected
The categories of sources from whom we collected this Personal Information
are:
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Directly from a California resident or the individual’s representatives
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Service providers, consumer data resellers and other third parties
- Information from our affiliates
- Website, mobile app and social media activity
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Information from client directed third parties or institutions
representing a client or prospective client
Third Parties with whom Personal Information is Shared
In the past 12 months, we have disclosed the following categories of
personal information of California consumers for a business purpose:
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Category A. Identifiers, such as name and government-issued
identifier (e.g., Social Security number);
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Category B. Personal information, as defined in the California
safeguards law (Cal. Civ. Code § 1798.80(e)), such as contact
information and financial information;
-
Category F. Internet or network activity information, such as
browsing history and interactions with our website;
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Category G. Geolocation data, such as device location and Internet
Protocol (IP) location;
-
Category H. Audio, electronic, visual and similar information,
such as call and video recordings;
The categories of third parties to whom we disclosed Personal Information
for our business purposes and the categories of personal information
shared with such third parties are:
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Vendors and service providers who provide services such as website
hosting, data analysis, payment processing, order fulfillment,
information technology and related infrastructure, customer service,
email delivery, auditing, marketing and marketing research activities
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Third parties who provide services such as payment, banking and
communication infrastructure, storage, legal expertise, tax expertise,
notaries and auditors, who promote the financial services and products
that we offer to customers and applicants
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Other third parties who enable customers to conduct transactions online
and via mobile devices, support mortgage and fulfillment services,
vehicle loan processes and aggregators (at the direction of the
customer)
- Government agencies as required by laws and regulations
Use of Personal Information
In the past 12 months, we have used Personal Information relating to
California residents to operate, manage, and maintain our business, to
provide our products and services, and to accomplish our business purposes
and objectives, including the following:
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Performing services, including maintaining or servicing accounts,
providing customer service, processing or fulfilling transactions,
verifying customer information, processing payments, providing
financing, providing analytic services, providing marketing services, or
providing similar services.
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Detecting security incidents, protecting against malicious, deceptive,
fraudulent, or illegal activity, and prosecuting those responsible for
that activity.
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Short-term, transient use where the information is not disclosed to a
third party and is not used to build a profile or otherwise alter an
individual consumer’s experience outside the current interaction,
including, but not limited to, the contextual customization of ads shown
as part of the same interaction.
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Auditing related to a current interaction and concurrent transactions,
including, but not limited to, counting ad impressions to unique
visitors, verifying positioning and quality of ad impressions, and
auditing compliance with this specification and other standards.
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Undertaking activities to verify or maintain the quality or safety of a
service controlled by us, and to improve, upgrade, or enhance the
service controlled by the business.
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Debugging to identify and repair errors that impair existing intended
functionality.
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Undertaking internal research for technological development and
demonstration.
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Complying with laws and regulations and to comply with other legal
process and law enforcement requirements (including any internal policy
based on or reflecting legal or regulatory guidance, codes or opinions).
Sale of Personal Information
In the past 12 months, we have not “sold” Personal Information subject to
the CCPA, including Personal Information of minors under the age of 16.
For purposes of this privacy policy, “sold” means the disclosure of
Personal Information to a third-party for monetary or other valuable
consideration.
Rights under the CCPA
Right to Request Disclosure of Collected, Used or Disclosed Personal
Information. You have the right to request that we disclose to you your Personal
Information that is collected, used, and disclosed to third
parties.
If you make a Right to Access request, you will receive the following
information about you:
- Categories of personal information collected
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Categories of sources from which personal information are collected
- Specific pieces of personal information collected about you
- Business purpose for collecting or selling
- Categories of third parties with whom sold
This information will be provided free of charge, unless we determine that
your request is manifestly unfounded or excessive. You may request this
information twice in a 12-month period. This Right to Access is subject to
certain restrictions and is not available to our employees and employees
of our business partners and service providers also do not have a Right to
Access under the CCPA.
Right to Request Deletion. You have the right to request that
we and our service providers delete any Personal Information about you
that we have collected from you upon receipt of a verifiable request. This
right is subject to the same exceptions as for Right to Access
requests.
Submitting Requests. You can submit your request by calling
us at 888-589-5444 or visiting our request website at
www.coveredcare.com/contact
We will acknowledge receipt of your request and advise you how long
we expect it will take to respond if we are able to verify your
identity.We will work to process all verified requests within 45 days
pursuant to the CCPA. If we need an extension for up to an additional 45
days in order to process your request, we will provide you with an
explanation for the delay.
Verifying Requests. To verify a California Consumer’s
identity, we may request up to three pieces of Personal Information about
you when you make a request to compare against our records. We cannot
respond to your request or provide you with Personal Information if we
cannot verify your identity. An authorized agent may submit a
request on your behalf.If an authorized agent submits a request on your
behalf, we may require proof of authorization and verification of identity
directly from you. Making a verifiable consumer request does not require
you to create an account with us. We will only use Personal Information
provided in your request to verify your identity. We reserve the right to
take additional steps as necessary to verify the identity of California
Consumers where we have reason to believe a request is fraudulent.
In some instances, we may not be able to honor your request. For example,
we will not honor your request if we cannot verify your identity or if we
cannot verify that you have the authority to make a request on behalf of
another individual. Additionally, we will not honor your request where an
exception applies, such as where the disclosure of Personal Information
would adversely affect the rights and freedoms of another consumer or
where the Personal Information that we maintain about you is not subject
to the CCPA’s access or deletion rights.
We will advise you in our response if we are not able to honor your
request. We will not provide social security numbers, driver’s license
numbers or government issued identification numbers, financial account
numbers, health care or medical identification numbers, account passwords
or security questions and answers, or any specific pieces of information
if the disclosure presents the possibility of unauthorized access that
could result in identity theft or fraud or unreasonable risk to data or
systems and network security.
Right to Non-Discrimination. We will not discriminate against
you because you exercised any of your rights, including, but not limited
to, by:
- Denying products or services to you.
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Charging different prices or rates for products or services, including
through the use of discounts or other benefits or imposing penalties.
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Providing a different level or quality of products or services to you.
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Suggesting that you will receive a different price or rate for products
or services or a different level or quality of products or services.
Questions or Concerns
You may contact us with questions or concerns about this Disclosure and
our practices by:
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Emailing us at support@coveredcare.com
Changes to This California Consumer Privacy Act Privacy Policy
We may change or update this Privacy Policy from time to time. When we do,
we will post the revised Privacy Policy on this page with a new “Last
Updated” date.