California Consumer Privacy Act (CCPA) Privacy Policy

California Residents: Your privacy rights under the California Consumer Privacy Act (CCPA)



Effective Date: 10/01/2024


This California Consumer Privacy Act Disclosure explains how Everly collects, uses, and discloses personal information relating to California residents that is subject to the California Consumer Privacy Act of 2018 ("CCPA"). 



What is personal information under the CCPA?


Under the CCPA, “personal information” is information that identifies, relates to, describes, references, or is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular California resident or device. Personal information does not include deidentified or aggregate consumer information (such as demographic-level data or data that can no longer be tied to a single identifiable individual), or information that is publicly available (such as information from public records).


Overview of your rights under California's privacy law

The CCPA gives California residents certain privacy rights with respect to some of the personal information we collect. These rights are: 

  • The right to notice of the personal information we collect;
  • The right to know the categories, sources and specific pieces of personal information we have collected about you in the past 12 months, including our purpose for collecting the information and the categories of third parties with whom we share that personal information, subject to certain exceptions;
  • The right to limit the use of your sensitive personal information;
  • The right to correct certain personal information we collect;
  • The right to delete some or all of the personal information we collect, subject to certain exceptions; and/or 
  • The right to opt-out of our sale of your personal information, if we sell your personal information. 


This section describes the steps you must take to exercise these rights, how we will verify your identity, and how we will respond to your requests.

Your rights under the CCPA are limited. In some cases, federal law protects certain classes of personal information that we collect, such as all the information we collect in order to provide you with financial and insurance products and services. Such personal information is excluded from the CCPA. Personal Information does not include: 

  • Publicly available information from government records 
  • De-identified data (where personally identifiable information has been removed) or aggregated consumer information (information provided in a summary format) 
  • Information excluded from the CCPA’s scope, like health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 and the California Confidentiality of Medical Information Act or clinical trial data; personal information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act, the Gramm-Leach-Bliley Act or California Financial Information Privacy Act, and the Driver’s Privacy Protection Act of 1994. 



Notice of collection 


We collect personal information about California residents from a variety of sources and use it for purposes related to our business. We may disclose personal information to our service providers in order to manage consumer accounts, provide goods and services to our consumers, market our products, improve our business, including our marketing services, and respond to legal and regulatory requirements. A fuller description of the purposes for which we collect the personal information of our consumers is provided below.

The personal information we collect includes not only clear personal identifiers, but also any information that directly or indirectly can be associated with, or linked to, our consumers or their households. Below are the categories of personal information we collect about our consumers, the sources of that information, the purposes for which we use personal information and the types of third parties with whom we have shared personal information in the past 12 months.

For more information on the purposes for which we use personal information, see the section below on “Purposes for which we use your data.”



Personal information we collect, use and share

Categories of the Personal Information we collected 

Personal Identifiers: address, social security number, driver’s license number, passport number, or other similar identifiers your name, alias, phone number, postal address, email address, unique personal identifier, online identifier, account name, Internet Protocol.  
 
We may collect similar information about your spouse, children and beneficiaries. 

Sources of Personal Information

  • directly from you or from others on your behalf 
  • insurance producer/agent 
  • consumer reporting agencies 
  • our service providers 
  • our affiliates 
  • government agencies 
  • public records 
  • consumer data resellers 
  • social platforms 

Purposes of which we use your data 

We may use this data for a number of our operational functions, including underwriting and issuing insurance policies; providing services under your insurance contract; meeting our legal and compliance obligations; detecting security incidents; performing data analytics and engaging our customers; improving our technology and systems, and marketing our products to you directly and through our joint marketing partners. 

Disclosed for a business purpose in the last 12 months? 

Yes

Types of third parties with whom we have shared Personal Information in the past 12 months 

  • affiliates 
  • group policy sponsors, such as employers and affinity groups 
  • insurance producer/agents 
  • service providers 
  • reinsurers and other insurance companies 
  • joint marketing partners 
    consumer reporting agencies 
  • government, judicial and law enforcement agencies and their agents 
  • industry self-regulatory bodies 
  • attorneys, accountants and auditors 
  • your fiduciary or legal representatives 
  • persons holding a legal or beneficial interest relating to you 
  • data analytics providers 
  • social networks 
  • consumer data resellers 

Categories of the Personal Information we collected 

Additional personal identifiers: your signature, physical characteristics or description, insurance policy number, bank account, credit card and debit card number, or any other financial information, medical information, and health, life or other insurance information, including your claims history. 

Sources of Personal Information

  • directly from you or from others on your behalf 
  • insurance producer/agent 
  • consumer reporting agencies 
  • our service providers 
  • our affiliates 
  • government agencies 
  • public records 
  • consumer data resellers 
  • social platforms 

Purposes of which we use your data 

We may use this data for a number of our operational functions, including underwriting and issuing insurance policies; providing services under your insurance contract; meeting our legal and compliance obligations; detecting security incidents; performing data analytics and engaging our customers; improving our technology and systems, and marketing our products to you directly and through our affiliate and non-affiliate marketing partners. 

Disclosed for a business purpose in the last 12 months? 

Yes

Types of third parties with whom we have shared Personal Information in the past 12 months 

  • group policy sponsors, such as employers and affinity groups 
  • insurance producer/agents 
  • service providers 
  • reinsurers and other insurance companies 
  • joint marketing partners 
  • consumer reporting agencies 
  • government, judicial and law enforcement agencies and their agents 
  • industry self-regulatory bodies 
  • attorneys, accountants and auditors 
  • your fiduciary or legal representatives 
  • persons holding a legal or beneficial interest relating to you 
  • data analytics providers 
  • social networks 
  • consumer data resellers 

Categories of the Personal Information we collected 

Sensitive information protected by federal or state law: your age, gender, familial status, disability, sex, national origin, marital status, veteran status, medical condition, ancestry, source of income, and genetic information. 

Sources of Personal Information

  • directly from you or from others on your behalf 
  • insurance producer/agent 
  • consumer reporting agencies 
  • our service providers 
  • our affiliates 
  • government agencies 
  • public records 
  • consumer data resellers 
  • social platforms 

Purposes of which we use your data 

We may use this data for a number of our operational functions, including underwriting and issuing insurance policies; providing services under your insurance contract; meeting our legal and compliance obligations; detecting security incidents; performing data analytics and engaging our customers; improving our technology and systems, and marketing our products to you directly and through our affiliate and non-affiliate marketing partners. 

Disclosed for a business purpose in the last 12 months? 

Yes

Types of third parties with whom we have shared Personal Information in the past 12 months 

  • group policy sponsors, such as employers and affinity groups 
  • insurance producer/agents 
  • service providers 
  • reinsurers and other insurance companies 
  • joint marketing partners 
  • consumer reporting agencies 
    government, judicial and law enforcement agencies and their agents 
  • industry self-regulatory bodies 
  • attorneys, accountants and auditors 
  • your fiduciary or legal representatives 
  • persons holding a legal or beneficial interest relating to you 
  • data analytics providers 
  • social networks 
  • consumer data resellers 

Categories of the Personal Information we collected 

Commercial information: records of your personal property, products or services you have purchased or considered, and other histories or tendencies to purchase or consume particular products and services. 

Sources of Personal Information

  • directly from you or from others on your behalf 
  • insurance producer/agent 
  • consumer reporting agencies 
  • our service providers 
  • our affiliates 
  • government agencies 
  • public records 
  • consumer data resellers 
  • social platforms 

Purposes of which we use your data 

We may use this data for a number of our operational functions, including underwriting and issuing insurance policies; providing services under your insurance contract; meeting our legal and compliance obligations; detecting security incidents; performing data analytics and engaging our customers; improving our technology and systems, and marketing our products to you directly and through our affiliate and non-affiliate marketing partners. 

Disclosed for a business purpose in the last 12 months? 

Yes

Types of third parties with whom we have shared Personal Information in the past 12 months 

  • group policy sponsors, such as employers and affinity groups 
  • insurance producer/agents 
  • service providers 
  • reinsurers and other insurance companies 
  • joint marketing partners 
  • consumer reporting agencies 
  • government, judicial and law enforcement agencies and their agents 
  • industry self-regulatory bodies 
  • attorneys, accountants and auditors 
  • your fiduciary or legal representatives 
  • persons holding a legal or beneficial interest relating to you 
  • data analytics providers 
  • social networks 
  • consumer data resellers 

Categories of the Personal Information we collected 

Biometric information: physiological, biological or behavioral characteristics that can be used to identify you, such as fingerprints, retina scans, photos used for facial recognition and genetic information. 

Sources of Personal Information

  • directly from you or from others on your behalf 
  • insurance producer/agent 
    our affiliates 

Purposes of which we use your data 

We may use this data for a number of our operational functions, including underwriting and issuing insurance policies; providing services under your insurance contract; meeting our legal and compliance obligations; detecting security incidents; performing data analytics and engaging our customers; improving our technology and systems, and marketing our products to you directly and through our affiliate and non-affiliate marketing partners. 

Disclosed for a business purpose in the last 12 months? 

No

Types of third parties with whom we have shared Personal Information in the past 12 months 

Categories of the Personal Information we collected 

Internet or other electronic network activity information: browsing history, search history, and information about your interaction with a Web site, online application and advertisements. 

Sources of Personal Information

  • directly from you or from others on your behalf 
  • insurance producer/agent 
  • consumer reporting agencies 
  • our service providers 
  • our affiliates 
  • government agencies 
  • public records 
  • consumer data resellers 
  • social platforms 

Purposes of which we use your data 

We may use this data for a number of our operational functions, including underwriting and issuing insurance policies; providing services under your insurance contract; meeting our legal and compliance obligations; detecting security incidents; performing data analytics and engaging our customers; improving our technology and systems, and marketing our products to you directly and through our affiliate and non-affiliate marketing partners. 

Disclosed for a business purpose in the last 12 months? 

Yes

Types of third parties with whom we have shared Personal Information in the past 12 months 

  • group policy sponsors, such as employers and affinity groups 
  • insurance producer/agents 
  • service providers 
  • reinsurers and other insurance companies 
  • joint marketing partners 
  • consumer reporting agencies 
  • government, judicial and law enforcement agencies and their agents 
  • industry self-regulatory bodies 
  • attorneys, accountants and auditors 
  • your fiduciary or legal representatives 
  • persons holding a legal or beneficial interest relating to you 
  • data analytics providers 
  • social networks 
  • consumer data resellers 

Categories of the Personal Information we collected 

Geolocation data 

Sources of Personal Information

  • directly from you or from others on your behalf 
  • insurance producer/agent 
    consumer reporting agencies 
  • our service providers 
  • our affiliates 
  • government agencies 
  • public records 
  • consumer data resellers 
  • social platforms 

Purposes of which we use your data 

We may use this data for a number of our operational functions, including underwriting and issuing insurance policies; providing services under your insurance contract; meeting our legal and compliance obligations; detecting security incidents; performing data analytics and engaging our customers; improving our technology and systems, and marketing our products to you directly and through our affiliate and non-affiliate marketing partners. 

Disclosed for a business purpose in the last 12 months? 

Yes

Types of third parties with whom we have shared Personal Information in the past 12 months 

  • group policy sponsors, such as employers and affinity groups 
  • insurance producer/agents 
  • service providers 
  • reinsurers and other insurance companies 
  • joint marketing partners 
  • consumer reporting agencies 
  • government, judicial and law enforcement agencies and their agents 
  • industry self-regulatory bodies 
  • attorneys, accountants and auditors 
  • your fiduciary or legal representatives 
  • persons holding a legal or beneficial interest relating to you 
  • data analytics providers 
  • social networks 
  • consumer data resellers 

Categories of the Personal Information we collected 

Sensory information: Audio, electronic, visual, thermal, olfactory or similar information, including voice signatures and recorded calls. 

Sources of Personal Information

  • directly from you or from others on your behalf 
  • insurance producer/agent 
  • consumer reporting agencies 
  • our service providers 
  • our affiliates 
  • government agencies 
  • public records 
  • consumer data resellers 
  • social platforms 

Purposes of which we use your data 

We may use this data for a number of our operational functions, including underwriting and issuing insurance policies; providing services under your insurance contract; meeting our legal and compliance obligations; detecting security incidents; performing data analytics and engaging our customers; improving our technology and systems, and marketing our products to you directly and through our affiliate and non-affiliate marketing partners. 

Disclosed for a business purpose in the last 12 months? 

Yes

Types of third parties with whom we have shared Personal Information in the past 12 months 

  • group policy sponsors, such as employers and affinity groups 
  • insurance producer/agents 
  • service providers 
  • reinsurers and other insurance companies 
  • joint marketing partners 
  • consumer reporting agencies 
  • government, judicial and law
  • enforcement agencies and their agents 
  • industry self-regulatory bodies 
  • attorneys, accountants and auditors 
  • your fiduciary or legal representatives 
  • persons holding a legal or beneficial interest relating to you 
  • data analytics providers 
  • social networks 
  • consumer data resellers 

Categories of the Personal Information we collected 

Professional or employment-related information such as your job title, job history, income. 

Sources of Personal Information

  • directly from you or from others on your behalf 
  • insurance producer/agent 
  • consumer reporting agencies 
  • our service providers 
  • our affiliates 
  • government agencies 
  • public records 
  • consumer data resellers 
  • social platforms 

Purposes of which we use your data 

We may use this data for a number of our operational functions, including underwriting and issuing insurance policies; providing services under your insurance contract; meeting our legal and compliance obligations; detecting security incidents; performing data analytics and engaging our customers; improving our technology and systems, and marketing our products to you directly and through our affiliate and non-affiliate marketing partners. 

Disclosed for a business purpose in the last 12 months? 

Yes

Types of third parties with whom we have shared Personal Information in the past 12 months 

  • group policy sponsors, such as employers and affinity groups 
  • insurance producer/agents 
  • service providers 
  • reinsurers and other insurance companies 
  • joint marketing partners 
  • consumer reporting agencies 
  • government, judicial and law enforcement agencies and their agents 
  • industry self-regulatory bodies 
  • attorneys, accountants and auditors 
  • your fiduciary or legal representatives 
  • persons holding a legal or beneficial interest relating to you 
  • data analytics providers 
  • social networks 
  • consumer data resellers 

Categories of the Personal Information we collected 

Educational information not publicly available: your level of education, schools attended, your degrees. 

Sources of Personal Information

  • directly from you or from others on your behalf 
  • insurance producer/agent 
  • consumer reporting agencies 
  • our service providers 
  • our affiliates 
  • government agencies 
  • public records 
  • consumer data resellers 
  • social platforms 

Purposes of which we use your data 

We may use this data for a number of our operational functions, including underwriting and issuing insurance policies; providing services under your insurance contract; meeting our legal and compliance obligations; detecting security incidents; performing data analytics and engaging our customers; improving our technology and systems, and marketing our products to you directly and through our affiliate and non-affiliate marketing partners. 

Disclosed for a business purpose in the last 12 months? 

Yes

Types of third parties with whom we have shared Personal Information in the past 12 months 

  • group policy sponsors, such as employers and affinity groups 
  • insurance producer/agents 
  • service providers 
  • reinsurers and other insurance companies 
  • joint marketing partners 
  • consumer reporting agencies 
    government, judicial and law enforcement agencies and their agents 
  • industry self-regulatory bodies 
  • attorneys, accountants and auditors 
  • your fiduciary or legal representatives 
  • persons holding a legal or beneficial interest relating to you 
  • data analytics providers 
  • social networks 
  • consumer data resellers 
     

Categories of the Personal Information we collected 

Inferences drawn from any of the above categories of information to create a profile about you: Information about your preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes. 

Sources of Personal Information

  • directly from you or from others on your behalf 
  • insurance producer/agent 
  • consumer reporting agencies 
  • our service providers 
  • our affiliates 
  • government agencies 
  • public records 
  • consumer data resellers 
  • social platforms 

Purposes of which we use your data 

We may use this data for a number of our operational functions, including underwriting and issuing insurance policies; providing services under your insurance contract; meeting our legal and compliance obligations; detecting security incidents; performing data analytics and engaging our customers; improving our technology and systems, and marketing our products to you directly and through our affiliate and non-affiliate marketing partners. 

Disclosed for a business purpose in the last 12 months? 

Yes

Types of third parties with whom we have shared Personal Information in the past 12 months 

  • group policy sponsors, such as employers and affinity groups 
  • insurance producer/agents 
  • service providers 
  • reinsurers and other insurance companies 
  • joint marketing partners 
  • consumer reporting agencies 
  • government, judicial and law enforcement agencies and their agents 
  • industry self-regulatory bodies 
  • attorneys, accountants and auditors 
  • your fiduciary or legal representatives 
  • persons holding a legal or beneficial interest relating to you 
  • data analytics providers 
  • social networks 
  • consumer data resellers 

Purposes for which we use your data 


We may use your data for the following business purposes: 

  • To consider your application for insurance, assess and evaluate institutional risk and provide you with an insurance product and services, where applicable; 
  • To administer your insurance product and maintain your account, including processing premium payment, processing claims, administering benefits and paying out withdrawals, surrenders and claims settlements, and encouraging customer engagement; 
  • To provide account statements and other required documents; 
  • To respond to court orders and legal investigations or as otherwise required or permitted by federal and state law; 
  • To comply with legal requirements; 
  • To report to consumer reporting agencies; 
  • To authorize, settle and clear the collection of amounts charged, debited or otherwise used to pay premium or receive payments and the audit of such information; 
  • To prevent and detect security incidents, fraud, money laundering, unauthorized access, data destruction and other crimes; 
  • To obtain reinsurance, or stop loss or excess loss insurance on our operations; 
  • To improve our products and technology, carry out market research, perform data analytics, risk modeling and statistical analysis and for mergers and reorganizations; 
  • For marketing and analytic purposes. 



Children under the age of 16


Our website does not target consumers under 16 years of age. We do not knowingly collect, sell or disclose the personal information of consumers under 16 years of age.  



Exercising your rights under California’s privacy law

Right to know and access 


You have a right to ask us to disclose certain personal information that we have collected about you over the 12 months before we received your request. You, or your authorized agent, may ask us to disclose, subject to certain exceptions:

  • the categories of personal information we have collected;
  • the categories of sources for the personal information we collected about you; 
  • the purposes for which we collected the personal information; 
  • the categories of third parties with whom we have shared the personal information; and 
  • the specific pieces of personal information that we have collected.


Before we respond to your request to know, we must verify the identity of the requestor. Our process for verifying the identity of the requestor is described below.  



Right to correct


You have the right to correct certain personal information. There are many types of correction requests and our service areas are ready to assist you with your request.

Before we respond to your request to know and access, we must verify the identity of the requestor. Our process for verifying the identity of the requestor is described below.  



Right to delete


You have the right to ask us to delete some or all of the personal information we have collected or maintained about you, subject to certain exceptions.

Before we respond to your request to delete personal information, we must verify the identity of the requestor. Our process for verifying the identity of the requestor is described below. 



Right to non-discrimination if you exercise your consumer rights


We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by law, we will not do any of the following to you if you exercise your CCPA rights:

  • 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 you a different level or quality of goods or services 
  • Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services 



How to submit a request to exercise your rights

Authorized agent 


You may designate an authorized agent to submit a request to know or a request to delete on your behalf.

If that agent is not already authorized to access your account in your profile, please submit a notice in writing that provides the authorized agent with permission to make a request to know or a request to delete on your behalf. We may also ask you to verify your identity directly with us.

We will deny a request from an authorized agent that does not submit proof that they have been authorized by you to act on your behalf.


Request to know

You or your authorized agent may submit a request to know by calling this toll-free number – (855) 290-0529 – to speak to a customer service representative.

If we deny your request in whole or in part, we will provide you with an explanation or direct you to our general business practices for collecting personal data. Under no circumstances will we provide the requestor with a consumer’s Social Security number, driver’s license number or other government-issued identification number, financial account numbers, any health insurance or medical identification numbers, any account passwords, or any security questions and answers. If you maintain a password-protected account with us, we may comply with your request to know by using a secure self-service portal for you to use to access, view and receive a portable copy of your personal information. We will use reasonable security measures when transmitting information to a consumer.


Request to delete

You or your authorized agent may submit a request to delete all or some of your personal information by calling this toll-free number – (855) 290-0529– to speak to a customer service representative.

Submitting a request to delete is a two-step process. After you submit a request to delete, we will ask you separately to confirm that you want all or some of your personal information deleted.

Once we receive your verified request to delete and confirm your identity, we will delete (and direct our service providers to delete) your personal information from our records, unless the information is subject to other laws or we need the information to:

  • Complete the transaction for which we collected the Personal Information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you 
  • Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities 
  • Debug products to identify and repair errors that impair existing intended functionality 
  • Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 seq.) 
  • Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us 
  • Comply with a legal obligation 
  • Make other internal and lawful uses of that information that are compatible with the context in which you provided 



How we will verify your identity 


Only you, or an authorized agent, may submit a request to know or to delete your personal information.  You may also make a request on behalf of your minor child.

You 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 you are the person about whom we collected Personal Information or an authorized representative
  • Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.


We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you. Making a verifiable consumer request does not require you to create an account with us. We will use the personal information you provide to us when submitting a consumer request only to verify the requestor’s identity or authority to make the request.

We will require the following information to verify your identity:

  • Policy/Contract owners who have a web-access account: if you have a web-based account with us that has a password, we will verify your identity using our existing authentication process. We may require you to correctly match at least two data points we have previously collected about you. We will match this information against information we have previously collected about you to verify your identity and your request. If we are unable to verify your identity as part of your request, we will not honor your request. 
  • Policy/Contract owner who do not have a web-access account: If you do not have a web-access account with us, we will require the following information to verify your identity: 
  • For requests to know categories of personal information: We will require you to correctly match at least two data points we have previously collected about you.  
  • For requests to know specific pieces of personal information we have collected in the past 12 months: We will require you to correctly match at least three data points we have previously collected about you. We may also require you to sign a declaration under penalty of perjury that the requestor is the consumer whose personal information is being requested. 
  • For requests to delete: We will require you to correctly match at least two or three data points we have previously collected about you, depending on the sensitivity of the personal information you are requesting. We may also require you to sign a declaration under penalty of perjury that the requestor is the consumer whose personal information is being requested.


Data we may request to verify your identity: When we request additional information from you to verify your identity, we may request other account information, answers to security questions, your name, government identification number, date of birth, contact information, or other personal identifying information.



How we will respond to your request


We intend to confirm receipt of your request within 10 business days and to respond to a verified request within 45 calendar days of its receipt. If we require more time (up to 90 days), we will inform you of the reason and extension period in writing. If you have an account with us, we will provide a written response to you via your account portal. If you do not have an account with us, we will deliver our written response by mail or electronically, at your option. Any disclosures we provide will only cover the 12-month period preceding our receipt of a verified request from you. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For requests to know the specific pieces of information we have collected, we will select a format to provide your Personal Information that is readily usable and should allow you to transmit the information from one entity to another entity without hindrance.

We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.  



Contact us

For more information, please:



Changes to this California Consumer Privacy Act (CCPA) Privacy Policy


We may change or update this Disclosure from time to time. When we do, we will post the revised Disclosure on this page with a new effective date. 

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