Privacy Policy

We collect information that identifies, relates to, describes, references, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer, household, pet, or device (“personal information”). Personal information does not include:

• Publicly available information from government records.
• Deidentified or aggregated consumer information.
• Information excluded from the CCPA’s scope, like:
  • health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and the California Confidentiality of Medical Information Act (CMIA) or clinical trial data; and
  • personal information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FCRA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA) and the Driver’s Privacy Protection Act of 1994.

Categories of Sources of Personal Information

We obtain your personal information listed above from the following categories of sources:

Directly from you – for example, from insurance applications or in connection with your other communications with us.

From third parties – for example, from insurance carriers and other industry service providers, and other third parties with which you maintain a relationship, such as an employer, financial service or medical or health providers, or any industry provider from which we purchase or acquire industry assets or operations. This may occasionally include referral sources and service providers.

Indirectly from you – for example, from observing your actions on our Website, including through the use of “cookies” as described on our Website, or as may otherwise be developed over time based on your interactions with us.

Use of personal information
We may use or disclose the personal information we collect for one or more of the following purposes:

• To fulfill or meet the reason you provided the information and for our everyday business purposes – for example, to obtain quotations for insurance or other insurance or financial industry services (including those procured proactively and/or in connection with the movement of a book of business from one provider to another) on your behalf; to obtain insurance (or similar products) on your behalf or to facilitate the performance of related services by other industry service providers; to maintain or service your account or insurance, including by reporting claims of loss to other industry service providers, such as insurance carriers and adjusters; to evaluate our performance or offerings; and to make reports to credit bureaus. We may also save your information to facilitate new quotations or placements.
• To comply with, or exercise rights under, applicable law – for example to make required or advisable reports to insurance regulatory, law enforcement or other similarly situated authorities; to respond to and comply with court orders, applicable law and other legal requirements; and to defend ourselves against claims and to enforce our rights or protect our employees or property.
• To market to you products and services, including through the use of targeted or similar advertising on the internet.
• auditing related to a current interaction with you and concurrent transactions, including, but not limited to, counting ad impressions to unique visitors, verifying positioning and quality of ad impressions, and auditing compliance (“Auditing”).
• short-term, transient use, including, but not limited to, the contextual customization of ads shown as part of the same interaction (“Short-term Use”).
• detecting security incidents, protecting against malicious, deceptive, fraudulent, or illegal activity, and prosecuting those responsible for that activity (“Data Security & Fraud Prevention”).
• undertaking internal research for technological development and demonstration (“Research and Development”).
• undertaking activities to verify or maintain the quality or safety of a service or device that is owned, manufactured, manufactured for, or controlled by us, and to improve, upgrade, or enhance the service or device that is owned, manufactured, manufactured for, or controlled by us (“Quality and Safety”).
• To provide or receive shared organizational services.
• As described to you when collecting your personal information or as otherwise set forth in the CCPA.
• To evaluate or effect a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, in which personal information held by us about our consumers is among the assets evaluated or transferred.

Retention of Data

We intend to retain each category of personal information described above only for as long as necessary to fulfill the purpose for which it was collected, or a related and compatible purpose consistent with the average person’s expectation, and to comply with applicable laws and regulations. We consider the following criteria when determining how long to retain personal information: why we collected the personal information; the nature of the personal information; the sensitivity of the personal information; our legal obligations related to the personal information, and risks associated with retaining the personal information.

Sharing of personal information

We generally share your personal information to perform services on your behalf and provide you with the insurance products and services you expect from us. We may disclose your personal information to a third party, including for any purpose identified within this Notice (see also “Use of Personal Information”). We share your personal information with the following categories of third parties:

• Service providers.
• Insurance carriers and other industry service providers.
  Other third parties with which you or we maintain a relationship regarding your insurance.
• Affiliates.

We disclose your personal information for a business purpose to the following categories of third parties:

• Service providers.
• Insurance carriers and other industry service providers.
• Other third parties with which you or we maintain a relationship regarding your insurance.

In the preceding twelve (12) months, we have not sold personal information.

Your Rights and Choices

The CCPA provides California residents with specific rights regarding their personal information. This section describes your CCPA rights and explains how to exercise those rights.

Access to specific information and data portability rights

You have the right to request that we disclose certain information to you about our collection and use of your personal information over the past twelve (12) months. Once we receive and confirm your verifiable consumer request, we will disclose to you:

• The categories of personal information we collected about you.
• The categories of sources for the personal information we collected about you.
• Our business or commercial purpose for collecting or selling that personal information.
• The categories of third parties with whom we share that personal information.
• The specific pieces of personal information we collected about you (also called a data portability request).
• If we sold or disclosed your personal information for a business purpose, two separate lists disclosing:
  • sales, identifying the personal information categories that each category of recipient purchased; and
  • disclosures for a business purpose, identifying the personal information categories that each category of recipient obtained.

We do not provide these access and data portability rights for B2B personal information.

The right to opt-out of the sale or sharing of your personal information. 

You have the right to opt out of the sale or sharing of your personal information. California law broadly defines sale such that it may include allowing third parties to receive certain information, such as cookies IP address and/or browsing behavior, to deliver targeted advertising.    If you would like to opt out, you may do so by sending a request to support@truffleinsurance.com. 

Right to Limit the Use of Your Sensitive Personal Information.

You have the right to instruct us to limit the use and disclosure of your Social security, driver’s license, state identification card, or passport number; account log-in, financial account number, debit card number, or credit card number in combination with any required security or access code, password, or credentials allowing access to the individual’s account; Precise geolocation; Racial or ethnic origin; Religious beliefs; and contents of email or text messages, unless we are the intended recipient (collectively, “Sensitive Personal Information”). Sensitive Personal Information to only that which is necessary to perform the services or provide the goods reasonably expected by average consumers, or for specific business purposes defined by applicable law. However, we do not use Sensitive Personal Information for purposes beyond those authorized by the CCPA.

Deletion request rights 

You have the right to request that we delete any of your personal information that we collected from you and retained. Once we receive and confirm your verifiable consumer request (see “Exercising Access, Data Portability and Deletion”), we will delete your personal information from our records, unless an exception applies. We may deny your deletion request for other reasons described in the CCPA. We do not provide these deletion rights for B2B personal information.

Exercising access, data portability and deletion rights

To exercise the access, data portability and deletion rights described above, please click here or submit a verifiable consumer request to us by:
Calling us at 1-877-788-8833; or
Emailing us at support@truffleinsurance.com.

Only you, or someone legally authorized to act on your behalf, may make a verifiable consumer request related to your personal information. You may also make a verifiable consumer request on behalf of your minor child. To designate an authorized agent, please contact us by email at the email address shown above.

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 as we may request that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative of such person, which may include personal and/or commercial identifiers, such as an insurance policy number. Depending on the sensitivity of the information you are requesting, we may ask for additional information to verify your identity.
• 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. We will only use personal information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.

Response timing and format

We endeavor to respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time, we will inform you of the extension period.

Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request’s receipt. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your personal information that is readily useable and should allow you to transmit the information from one entity to another entity without significant 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.

Non-discrimination

We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not:

• 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.

To learn more about your California privacy rights, visit https://oag.ca.gov/privacy/ccpa.

Other California privacy rights

California’s “Shine the Light” law (Civil Code Section § 1798.83) permits users of our Website that are 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 support@truffleinsurance.com with the subject “Shine the Light Request.”.

Changes to this notice

We reserve the right to amend this Notice at our discretion and at any time. When we make changes to this Notice, we will post the updated notice on the Website and update the Notice’s effective date. Your continued use of our Website following the posting of changes constitutes your acceptance of such changes with respect to your use of the Website.