Effective Date: April 19, 2022
1. Information Collection.
We collect information from you in several ways, including when you choose to share information with us by entering it through our Website and by using automated processes. We also collect information about your transactions with us, such as your payment of bills and submission of claims.
(a) Information You Provide.
We may ask you and you may choose to provide certain “Personal Information” to us, which is information that identifies you personally, such as your first and last name, e-mail address, payment information including financial account numbers, mailing and billing addresses, government identification numbers, policy number, date of birth, social security number, job title, marital status, employment information, and telephone number. If you submit a claim online, you may also provide a description of the claim that may include health and medical information, and other personal information included in your description. Please note that we use a third-party payment processor and so we do not store information about your payment card when you submit an online payment. If you choose to submit a claim online, we may require you to provide additional information, such as information about your insurance policy, including the policy number, and information about the harm suffered and the circumstances, causes, reasons, and events that led you to make an insurance claim. This information you submit may also include posts, comments, photos, messages, feedback, and other content you generate. We may collect this information in a variety of places, including claim submission forms, through our Website in its various forms including any applications, and through our bill payment platform.
(b) Information About Third Parties.
If you submit a claim online, you may choose to provide us with information about third parties who were witness to or otherwise involved in the circumstances and events that led you to make an insurance claim. By submitting Personal Information about any third party, you represent and warrant to Coaction that you have the consent of the third party to do so, and that the information you submit is factually accurate.
(c) Automated Information Collection.
In addition to any information that you choose to submit to us via the Website, we and our third-party service providers may use a variety of technologies that automatically (or passively) store or collect certain information whenever you visit or interact with the Website (“Usage Information”). This Usage Information may be stored or accessed using a variety of technologies that may be downloaded to your Device whenever you visit or interact with our Website. To the extent we associate Usage Information with your Personal Information we collect directly from you on the Website, we will treat it as Personal Information.
This Usage Information may include:
- your IP address, UDID or other unique identifier (“Device Identifier”). A Device Identifier is a number that is automatically assigned to your Device used to access the Website, and our computers identify your Device by its Device Identifier;
- your Device functionality (including browser, operating system, hardware, mobile network information);
- the URL that referred you to our Website;
- the areas within our Website that you visit and your activities there, including remembering you and your preferences;
- your Device location;
- your Device characteristics; and
- certain other Device data, including the time of day, among other information.
Tracking Technologies. We may use various methods and technologies to store or collect Usage Information (“Tracking Technologies”). Tracking Technologies may set, change, alter or modify settings or configurations on your Device. A few of the Tracking Technologies include, without limitation, the following (and subsequent technology and methods later developed):
- 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. 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. 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:
- 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 content. This includes using Tracking Technologies to understand the usefulness to you of the content that has been delivered to you.
2. Use of Collected Information.
3. Information Sharing.
(a) Co-Branded Areas.
We may provide certain parts of our Website in association with third parties, such as promotional partners or affiliates. These “co-branded areas” will identify the third party. If you choose to use these co-branded areas, we may share your information with the identified third party, and that third party may also collect information from you, in addition to the information that we collect, as described above. You should review the privacy policies of those identified third parties to understand how they collect and use information.
(b) Links to Third-Party Websites.
Our Website may include links to third-party websites or other online services. We are not responsible for these other sites and services, and they may collect and use information about you. You should review the privacy policies for such third parties before using their sites or services to understand how they collect and use information.
(c) Third-Party Tracking and Do Not Track.
(d) Analytic Services and Targeted Ads.
We use third-party analytics services, like Google Analytics, to collect, monitor and analyze data we collect through the Website to better understand how our Website is used and to improve its functionality. These services may track details about your online activities over time and across different websites. These services may also allow us and others to provide you with targeted advertisements or other content that you may be interested in based on your online activities.
The Google Analytics service tracks and reports website traffic and provides us insight into behavior information relating to visitor age, gender and interests. Google Analytics Demographics and Interest Reporting give us insight into behavior to help us understand browsing behavior and give you a better experience when you visit our website. You can opt-out of Google Analytics for Display Advertising and customize Google Display Network ads using the Ads Settings.
These third-party services have their own privacy policies addressing how they use such information. We recommend you review their privacy policies. If you want to prevent your data from being used by Google Analytics, you may wish to take advantage of Google Analytics’ currently available opt-outs for the web.
If you would like to learn more about targeted ads that may be based on your online activities, and the choices that you may exercise for certain sites and advertisers, you may wish to visit the Network Advertising Initiative or the Digital Advertising Alliance.
4. Information Protection.
We use commercially reasonable and industry standard security technologies and safeguards to protect the information that we collect and use. For example, we use Secure Sockets Layer (SSL) for our registration and ordering functions, and we utilize a PCI-certified service provider to process payment card payments. We also expect our service providers to protect information in the same manner. 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.
5. Changing Information and Communication Preferences.
You can always contact us in order to request that we (i) remove the personal information that you have provided to us from our systems, (ii) update the personal information that you have provided to us, and (iii) change your preferences with respect to our use of your personal information by e-mailing us at email@example.com. If so, we will make good faith efforts to make requested changes in our then active databases as soon as reasonably practicable (but we may retain prior information as business records). Please note that it is not always possible to completely remove or delete all of your information from our databases and that residual data may remain on backup media or for other reasons.
6. 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, and that by using our Website, you consent to such transfers and processing.
7. 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.
8. 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 the Child Online Privacy Protection Act, 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 firstname.lastname@example.org.
9. Contact Us.
Coaction Specialty Insurance Group, Inc.
412 Mt Kemble Avenue, Suite 300C
Morristown, NJ 07960
Attn: General Counsel