Effective Date: April 19, 2022

Last Updated: November 1, 2024

Coaction Global, Inc. and its subsidiaries, and affiliates (collectively, “Coaction”, “we” “our”, and “us”), believe the protection of the information we collect about you is important. This privacy policy (“Privacy Policy”) applies to any Personal Information we collect through websites that we own and control, such as https://www.coactionspecialty.com/, the Coaction Customer Portal, the Coaction Partner Portal, and products and services we may offer to you, including any website, mobile application, email, online advertisement, feature, widget, or other digital service, that posts a link to this Privacy Policy(collectively, the “Website”). This Privacy Policy also applies to other online and offline interactions we may have with you.

Scope: This Privacy Policy covers how Coaction collects, uses, shares, and otherwise processes Personal Information as explained above. “Personal Information” is information that reasonably relates to a person.

This Privacy Policy does not apply to the following Personal Information:

1. Personal Information we collect in connection with providing consumers a financial product or service, such as when we review insurance claims. This Privacy Policy does not apply to that we collect that is subject to the Gramm-Leach-Bliley Act, the Fair Credit Reporting Act, and other financial and insurance privacy laws. This information is subject instead to our Insurance Consumer Privacy Notice.
2. Information about our employees, contractors, and agents.

Whenever you provide us with Personal Information about another individual or entity, you must obtain their consent (or have the legal authority without consent) to share their Personal Information with us. Coaction disclaims any liability associated with any Personal Information you improperly or inadvertently share with us or for which you did not have permission to share with us.

Changes: We reserve the right to change this Privacy Policy at any time, and we will post a notice or inform you of any such changes on our Website.

1. COACTION INFORMATION COLLECTION.

Depending on how you interact with us, we may process Personal Information about you in the following ways:

• Direct Identifiers, such as your first and last name, e-mail address, mailing and billing addresses, and telephone number, and your Internet Protocol (“IP”) address and unique device identifier or other unique identifier (“Device Identifier”).
• Demographic information, such as age (via date of birth) and marital status.
• Customer records, such as payment information including financial account numbers; information about the harm suffered and the circumstances, causes, reasons, and events that led you to file an insurance claim.
• Commercial information, including information about purchases, inquiries, and claims.
• Professional or employment-related information, if you interact with us in that capacity. The Personal Information we collect may include employment Information, your job title, and employer.
• Non-precise geolocation data, such as information about your general location derived from your IP address.
• Internet and other electronic activity information such as your Device Identifiers; information about your device (like your operating system, browser type, hardware, and mobile network information); referring uniform resource locators (URLs); areas within our Website that you visit and your activities there; device characteristics; and other device data (collectively, “Usage Information”). For more 1 Coaction Global, Inc. Privacy Policy information about our use of cookies and other Tracking Technologies, please see the “Cookies and Other Tracking Technologies” section.

We may collect your Personal Information in different ways, including:

• When you provide it directly to us, such as when you choose to share information with us by entering it through our Website or when you complete transactions, such as your payment of bills and submission of claims.
• When we collect it automatically when you use our websites and apps, including through cookies and other data collection technologies. We and our third-party partners may use a variety of technologies that automatically (or passively) store or collect Usage
  Information whenever you visit or interact with our Website. For more information about cookies and other device data, please see the “Cookies and Other Tracking Technologies” section below.
• When we collect it from or through other third parties, such as vendors, suppliers, and other Coaction business partners or affiliates, or individuals you direct to share information with us or that choose to share information with us.

2. HOW COACTION USES COLLECTED INFORMATION.

We may use the information we collect about you in a variety of ways. For example:

• To provide you with products and services, such as to process transactions and provide products, services, and information to you; to process your applications and payments; to adjust claims; to provide loss control services; to inform underwriting; to provide you with information that may be of interest to you; to process your account registration; to provide customer support; to enable you to use certain Website features and to customize your experience on the Website.
• For our internal business purposes, such as when we collect information to better tailor our product offerings, to improve the Website and the content provided on and through the Website, and for other day-to-day operational purposes.
• For marketing purposes, such as to provide you with content or advertisements that may be of interest to you.
• In connection with a corporate transaction, such as if we acquire assets of another business, or sell or transfer all or a portion of our business or assets, including through a sale in connection with bankruptcy and other forms of corporate change.
• For legal, safety, or security reasons, such as to meet our legal obligations or to inform a legal proceeding; to exercise of defend legal claims; to enforce our Terms of Use and other agreements; to detect and respond to security incidents and health and safety issues; and to protect the safety, property, or rights of us, you, and other third parties.

We may anonymize or aggregate your information for any purpose permitted by law. We may also use the information we collect from you for additional purposes with your consent where required.

3. HOW COACTION SHARES COLLECTED INFORMATION.

We may share Personal Information we collect from you with third parties for a variety of purposes. For example, we may share information with:

• Affiliates and subsidiaries, including corporate affiliates, subsidiaries, and other companies that share common ownership in order to provide marketing services and for other business purposes.
• Service providers and vendors, that work on our behalf to provide the products and services you request or support our relationship with you, and who assist us with our business operations.
• Business partners, that may use the information for their own purposes, such as:
• • Advertisers and ad platforms and networks;
  • Third parties whose Tracking Technologies we use as described in the “Cookies and Other Tracking Technologies” section below; and
  • Partners who work with us on promotional opportunities, included co-branded services.
• Law enforcement, government agencies and other recipients for legal, security, or safety purposes, including where required by law or to satisfy any applicable law, regulation, subpoena, government request, or other legal process; to protect this Website
  and to enforce our Terms of Use and other agreements; and to defend or enforce our rights and the rights of others.
• Other entities in connection with a corporate transaction, such as with any subsequent owner in the event of a merger, consolidation, sale of our assets, or other change in our business, including during the course of any due diligence process.
• The public, such as when you make public comments or posts regarding us or our products or services. Any Personal Information in comments, reviews, or other content that you share in public areas of our Website may be read, collected, or used by other users or the public.
• Entities to which you have consented to the disclosure. .

4. COOKIES AND OTHER TRACKING TECHNOLOGIES.

We may use various methods and technologies to store or collect Usage Information (“Tracking Technologies”). The Tracking Technologies we use may include, without limitation, the following:

• Cookies. A cookie is a data file placed on a device when it is used to visit the Website. A flash cookie (or locally shared object) is a data file placed on a Device via the Adobe Flash plug-in that may be built-in to or downloaded by you to your Device. HTML5 cookies can be programmed through HTML5 local storage.
• Web Beacons. Small graphic images or other web programming code called web beacons (also known as “1×1 GIFs” or “clear GIFs”) may be included in our Website’s pages and messages. Web beacons may be invisible to you, but any electronic image or other web
  programming code inserted into a page or e-mail can act as a web beacon. Web beacons or similar technologies may be used for a number of purposes, including, without limitation, to count visitors to the Website, to monitor how users navigate the Website, to count how many e-mails that were sent were actually opened or to count how many particular articles or links were actually viewed.
• Embedded Scripts. An embedded script is programming code that is designed to collect information about your interactions with the Website, 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 Website and is deactivated or deleted thereafter.
• Browser Fingerprinting. Browser fingerprinting is the collection and analysis of information from your device, such as, without limitation, your operating system, plug-ins, system fonts and other data for purposes of identification
• ETag, or Entity Tag. ETag is a feature of the cache in browsers. It is an opaque identifier assigned by a web server to a specific version of a resource found at a URL. If the resource content at that URL ever changes, a new and different ETag is assigned. Used in this manner ETags are a form of Device Identifier. ETag tracking may generate unique tracking values even where the consumer blocks HTTP, Flash, and/or HTML5 cookies.
• Recognition Technologies. Technologies, including application of statistical probability to data sets, which attempt to recognize or make assumptions about users and devices (e.g., that a user of multiple devices in the same user).

Tracking Technologies Usage. We may use Tracking Technologies for a variety
of purposes, including:

• Strictly Necessary. We may use cookies or other Tracking Technologies that we consider strictly necessary to allow you to use and access our Website, including cookies required to prevent fraudulent activity and improve security.
• Analytics Related. We may use cookies or other Tracking Technologies that are useful in order to assess the performance of the Website, including as part of our analytic practices or otherwise to improve the content, products or services offered through the Website. For example, we may use Google Analytics to help us understand how the Website is used. To learn how Google collects and uses data, please visit www.google.com/policies/privacy/partners
• Functionality Related. We may use cookies or other Tracking Technologies to offer you enhanced functionality when accessing the Website, including identifying you when you sign in to our Website or keeping track of our specified preferences, including in terms of the presentation of content on our Website.
• Targeting Related. We may use Tracking Technologies to deliver content relevant to your interests on our Website and third-party sites based on how you interact with our and other content (‘interest-based advertising”). These Tracking Technologies may collect information about your online activities over time and across websites. This includes using Tracking Technologies to understand the usefulness to you of the content that has been delivered to you.

Third-Party Tracking Technologies

Trusted third parties may use Tracking Technologies in connection with our Website. These third parties may use the data collected through these Tracking Technologies for their own purposes. This Privacy Policy does not apply to these third parties’ privacy practices, and we are not responsible for them.

Your choices

Some of the third parties we work with may participate with the Digital Advertising Alliance (“DAA”) and Network Advertising Initiative (“NAI”). The DAA and NAI provide mechanisms to opt out of interest-based advertising performed by participating members at http://www.aboutads.info/choices/ and https://optout.networkadvertising.org/. Opting out of interest-based advertising will not opt you out of all advertising, but rather only interest-based advertising from participating members. You may also be able to refuse or delete Tracking Technologies using your browser settings. If you refuse or delete Tracking Technologies, some of our Website’s functionality may be impaired. Please refer to your browser’s Help instructions to learn more about how to manage Tracking Technologies. If you change computers, devices, or browsers; use multiple computers, devices, or browsers; or delete cookies or other Tracking Technologies, you may need to repeat this process for each computer, device, or browser. Some browsers have incorporated Do Not Track (“DNT”) preferences. While we try to honor your privacy preferences, we do not respond to DNT signals at this time due to the lack of an established industry standard.

You may also be able to refuse or delete Tracking Technologies using your browser settings. If you refuse or delete Tracking Technologies, some of our Website’s functionality may be impaired. Please refer to your browser’s Help instructions to learn more about how to manage Tracking Technologies. If you change computers, devices, or browsers; use multiple computers, devices, or browsers; or delete cookies or other Tracking Technologies, you may need to repeat this process for each computer, device, or browser.

Some browsers have incorporated Do Not Track (“DNT”) preferences. While we try to honor your privacy preferences, we do not respond to DNT signals at this time due to the lack of an established industry standard.

5. LINKS TO THIRD-PARTY WEBSITES AND CO-BRANDED AREAS.

Our Website may include links to third-party websites or other online services. We are not responsible for these other sites and services, which may collect and use information about you for their own purposes. You should review the privacy policies for such third parties before using their sites or services to understand how they collect and use information.

6. INFORMATION SECURITY AND PROTECTION AND INFORMATION RETENTION.

We use commercially reasonable security technologies and safeguards to protect the information that we collect and use. However, no data transmission over the Internet, mobile networks, wireless transmission or electronic storage of information can be guaranteed 100% secure. Please note that we cannot guarantee the security of any information you transmit to us.

Your Personal Information will be retained as long as necessary to fulfill the purposes we have outlined above unless we are required to do otherwise by applicable law. This includes retaining your Personal Information to provide you with the products or services you have requested and interact with you; maintain our business relationship with you; improve our business over time; ensure the ongoing legality, safety and security of our services and relationships; or otherwise in accordance with our internal retention procedures.

7. YOUR CHOICES: CHANGING INFORMATION AND COMMUNICATION PREFERENCES.

Updating Your Information: You are responsible for maintaining the accuracy of the information you submit to us, such as your contact information provided as part of any registration on a Website.

Marketing Options: We may provide marketing communications, such as by email. You can opt out of receiving our marketing emails by clicking the unsubscribe link in the email you receive. Please note that we reserve the right to send you certain non-marketing communications relating to your account or use of our Website, such as administrative and service announcements, and these messages may be unaffected if you choose to opt-out from receiving our marketing communications.

8. ADDITIONAL INFORMATION FOR CALIFORNIA RESIDENTS.

This section applies to California residents and supplements the information above; however, this section does not apply to the following information:

1. Personal Information we collect in connection with providing consumers a financial product or service, such as when we review insurance claims.
2. Information about our employees, contractors, and agents.

California Privacy Rights

If you live in California, you may have certain rights regarding Personal Information:

• Right to Know. You may have the right to request information about the categories of Personal Information we have collected about you, the categories of sources from which we collected the Personal Information, the purposes for collecting, selling, or sharing the Personal Information, and to whom we have disclosed your Personal Information and why. You may also request the specific pieces of Personal Information we have collected about you.
• Right to Delete. You may have the right to request that we delete Personal Information that we have collected from you.
• Right to Correct. You may have the right to request that we correct inaccurate Personal Information that we maintain about you.
• Right to Opt Out of Sales and Sharing for Targeted Advertising. You may have the right to opt out of the sale of your Personal Information or the sharing of your Personal Information for targeted advertising.

You may exercise the rights available to you by emailing us at privacy@coactionspecialty.com or by calling us toll-free at 1-800-774-2755.

We will not discriminate against you for exercising your privacy rights.

Verification: In order to process rights requests, we may need to obtain information to locate you in our records or verify your identity depending on the nature of the request. In most cases we will collect some or all of the following data elements: first and last name, email address, and telephone number. In some cases, we may request different or additional information, including a signed declaration that you are who you say you are. We will inform you if we need such information.

Authorized Agents: Authorized agents may exercise rights on behalf of an individual by submitting a request via email to <ahref=”mailto:privacy@coactionspecialty.com”>privacy@coactionspecialty.com and indicating that they are submitting the request as an agent. We may require the agent to demonstrate authority to act on behalf of the individual by providing signed permission from the individual. We may also require the individual to verify their own identity directly with us or to directly confirm with us that they provided the authorized agent permission to submit the request.

Disclosure of Personal information

Below please find a chart detailing the categories of Personal Information collected and how it may be shared for a business purpose in the past 12 months.

Sensitive Personal Information: We only use and disclose sensitive Personal Information for the following purposes: (i) performing services or providing goods reasonably expected by an average person; (ii) detecting security incidents; (iii) resisting malicious, deceptive, or illegal actions; (iv) ensuring the physical safety of individuals; (v) for short-term, transient use, including non-personalized advertising; (vi) performing or providing internal business services; (vii) verifying or maintaining the quality or safety of a service or device; or (viii) for purposes that do not infer characteristics about you. For purposes of this Privacy Policy, Sensitive Personal Information (SPI) is Personal Information that reveals:

• a consumer’s Social Security, driver’s license, state identification card, or passport number.
• a consumer’s account login, financial account, debit card, or credit card number in combination with any required security or access code, password, or credentials allowing access to an account.
• a consumer’s precise geolocation.
• a consumer’s racial or ethnic origin, religious or philosophical beliefs, or union membership.
• the contents of a consumer’s mail, email, and text messages, unless the business is the intended recipient of the communication.
• a consumer’s genetic data.

SPI also includes:

• the processing of biometric information for the purpose of uniquely identifying a consumer.
• personal information collected and analyzed concerning a consumer’s health.
• personal information collected and analyzed concerning a consumer’s sex life or sexual orientation.

SPI that is publicly available shall not be considered sensitive personal information or personal information.

California Shine the Light: California law permits California residents to request certain information regarding our disclosure of Personal Information to third parties for their direct marketing purposes. To make such a request, please send an email to privacy@coactionspecialty.com

9. USERS OUTSIDE OF THE UNITED STATES.

Our Website is operated in the United States and intended for users located in the United States. The privacy and data protection laws in the United States differ from those of other countries. If you are located outside of the United States, please be aware that the information that we collect will be transferred to and processed, stored, and used in the United States.

10. SOCIAL SECURITY PROTECTION POLICY STATEMENT.

Coaction seeks to protect the confidentiality of social security numbers (SSNs) by maintaining physical, electronic, and procedural safeguards. We limit access to SSNs to help protect against their loss, misuse or unlawful disclosure. We do not disclose SSNs to third parties except where required or permitted by law.

11. CHILDREN’S PRIVACY.

Our sites and applications are intended for general audiences, and we do not knowingly seek or collect Personal Information from children under the age of eighteen (18). In accordance with applicable law, in the event that we learn that we have collected Personal Information from a child under age thirteen (13) without verification of parental consent, we will delete that information as quickly as possible. If you believe that we might have any Personal Information from or about a minor, please contact us at privacy@coactionspecialty.com

12. CONTACT US.

If you have any questions about our privacy policy or comments on the Website or become aware of misuse of the Website by any person, please contact us at:

Coaction Specialty Insurance Group, Inc.
412 Mt Kemble Avenue, Suite 300C
Morristown, NJ 07960
Attn: General Counsel
privacy@coactionspecialty.com