Effective Date: [4/28/2021]
Our Privacy Policies and Practices
- The types of information we collect through our Sites and Services
- How we use and protect that information
- The types of information we may share with others and under what circumstances
- The choices you have regarding our collection, use, and sharing practices
We also include specific disclosures for residents of California and Nevada.
Information We Collect
We collect, use, and retain personal information that you provide when using our Sites and Services. We collect the following information from you:
- Information, such as your name, contact information, social security number, and driver’s license number, that you provide on applications, registration forms, and other forms;
Some of this information may be collected by external parties on our behalf. For example, we use payment processors when you engage in transactions related to our Sites and Services. We also collect the following information about you from other sources:
- Information about your transactions with us from the insurance companies we contact to underwrite your insurance;
Information We Collect Automatically
When you interact with our Sites and Services, certain information about your use is collected automatically. This includes:
- Details of your visits to and information generated in the course of your use of the Sites (including the timing, frequency, and pattern of service use) including, but not limited to, traffic data, location data, weblogs and other communication data, the resources that you access, and how you reached our Sites;
- Details regarding the device you use to access our Services, including but not limited to your IP address, operating system, and browser type;
- Information about how you interact with our ads and newsletters, including whether you open or click links in any correspondence; and
- Information that you make available to us on social media platforms, such as by clicking on a social media icon linked from our Sites or Services, including your account ID or username and other information included in your posts.
- [Advertising: Allowing us to provide you with targeted advertisements or marketing communications that we believe may be of interest to you.]
- Analytics: Allowing us to understand how our services are being used, track site performance and make improvements.
- Site Operations: Enabling features that are necessary for providing you the services on our Sites, such as identifying you as being signed in, tracking content views, and remembering your preferences.
- Social Media: Enabling the sharing of content from our Services through social networking and other Sites.
[Most web browsers automatically accept cookies but, if you prefer, you can usually modify your browser setting to disable or reject cookies. If you delete your cookies or if you set your browser to decline cookies, some features of the Sites or Services may not be available, work, or work as designed. You may also be able to opt out of or block tracking by interacting directly with the other companies who conduct tracking through our Sites and Services.
[Information collected about you from a particular browser or device may be linked to information collected from another computer or device that we believe relates to you.]
Your browser or device may include “Do Not Track” functionality. At this time, we do not alter our Sites’ data collection and use practices in response to Do Not Track signals.
How We Use Your Information
We use the personal information we collect for the following purposes:
- To provide you with our products and services, including to process your requests, transactions, and payments; obtain quotations for insurance or other insurance or financial industry services; maintain or service your account or insurance, including by reporting claims of loss to outside entities, such as insurance carriers and adjusters; and to make reports to credit bureaus;
- To understand how our Sites and Services are being used, track site performance, and make improvements;
- To provide you with the best service and improve and grow our business, including improving and optimizing our Sites and Services, understanding our customer base, and understanding the effectiveness of our marketing;
- To detect, investigate, and prevent activities that may violate our policies or be fraudulent or illegal, including to screen orders for potential risk or fraud, and to comply with legal requirements regarding the provision of products and services; and
- To provide you with information or advertising related to our products and Services, including targeted advertisements and marketing communications.
How We Share Your Information
- Group Policyholders: We share information with group policyholders for the purpose of reporting claims experiences or conducting audits of our operations or services.
- Insurance Institutions, Agents, or Credit Reporting Agencies: We share information with other insurance institutions, agents, and credit reporting agencies in order to provide a function in connection with an insurance transaction involving you or to detect or prevent criminal activity, fraud, or misrepresentation in connection with an insurance transaction.
- Medical Care Institutions or Medical Professionals: We share information with medical care institutions and medical care professionals in order to verify coverage or benefits, inform you of a medical problem of which you may not be aware, or conduct an audit that would enable us to verify treatment.
- Insurance Regulatory Authorities: We share information with insurance regulatory authorities, law enforcement, or other governmental authorities in order to protect our interests in preventing or prosecuting fraud, or if we believe that you have conducted illegal activities.
- Outside Vendors: We engage the following types of vendors to perform functions on our behalf: payment processing firms; billing and collection providers; auditing and accounting firms; professional services consultants; analytics services providers; customer survey vendors; software providers; IT vendors, including security and email vendors; and website hosting services, data storage services, and accessibility services.
- [Marketing Partners. We share information with our marketing and advertising partners in order to provide advertisements to you.]
- Social Media Platforms: Where you choose to interact with us through social media, your interaction with these programs typically allows the social media company to collect some information about you through cookies they place on your device and other tracking mechanisms. In some cases, the social media company may recognize you through its digital cookies even when you do not interact with their application. Please visit the social media companies’ respective privacy policies to better understand their data collection practices and controls they make available to you.
- Law Enforcement, Legal Process, and Emergency Situations: We also use or disclose your personal information if required to do so by law or on the good-faith belief that such action is necessary to conform to applicable law or comply with legal process served on us or our sites; protect and defend our rights or property, the websites or our users; or act to protect the personal safety of us, users of our websites, or the public.
- Change of Ownership or Corporate Organization: We may transfer to another entity or its affiliates or service providers some or all information about you in connection with, or during negotiations of, any merger, acquisition, sale of assets or any line of business, change in ownership control, or financing transaction. We cannot promise that an acquiring party or the merged entity will have the same privacy practices or treat your information the same as described in this Policy.
Our Sites and Services are intended for users age 13 and over. We do not knowingly collect information from children. If we discover that we have inadvertently collected information from anyone younger than the age of 13, we will delete that information.
How We Secure Your Information
We use a combination of physical, technical, and administrative safeguards to protect the information we collect through our Sites and Services. While we use precautions to safeguard your information, we cannot guarantee the security of the networks, systems, servers, devices, and databases we operate or that are operated on our behalf.
Your California Privacy Rights
Residents of California have the right to request information from Shepherd Insurance regarding other companies to which we have disclosed certain categories of personal information during the preceding year for those companies’ direct marketing purposes. At this time, we do not provide your information to outside companies for those companies’ direct marketing purposes.
The California Consumer Privacy Act (CCPA) provides California residents with rights to receive certain disclosures regarding the collection, use, and sharing of “personal information,” as well as rights to know or access, request deletion, and limit sharing of personal information. The CCPA defines “personal information’ as “information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household.” Certain information we collect may be exempt from the CCPA because it is public information (i.e., it is made available by a government entity) or covered by a specific federal privacy law, such as the Gramm-Leach-Bliley Act, the Health Insurance Portability and Accountability Act, or the Fair Credit Reporting Act. To the extent that we collect personal information that is subject to the CCPA, that information, our practices, and your rights are described below.
Right to Information Regarding Categories of Personal Information Collected, Sold, and Disclosed
The following is a description of our data collection practices, including the personal information we collect, the sources of that information, the purposes for which we collect information, and whether we disclose that information to external parties. We may use any and all of the information for any of the purposes described in this Policy, unless limitations are listed. The categories we use to describe the information are those enumerated in the CCPA.
- Personal Identifiers:
- We collect your name, postal address, email address, and telephone when we provide services to you.
- We collect your payment information when you complete a transaction.
- We collect your Social Security number, Driver’s License number, or passport number when necessary to provide services to you.
- We collect your IP address and device identifier automatically when you use our Services.
- Protected Classifications: We collect [protected classifications collected by Shepherd Insurance].
- Commercial Information: When you engage in transactions with us, we create records of goods or services purchased or considered, as well as your purchasing or consuming histories or tendencies.
- Biometric Information: We collect health information when necessary to provide insurance to you. We do not otherwise collect information about your physiological, biological, and behavioral characteristics.
- Internet or Other Electronic Network Activity Information: We collect information about your browsing history, search history, information regarding your interaction with websites, and applications or advertisements automatically when you use our Sites and Services.
- Geolocation Data: As described above, we collect your IP address automatically when you use our Services. We may be able to determine your general location based on your IP address.
- Audio, electronic, visual, thermal, olfactory, or similar information: If you contact us via phone, we may record the call. We will notify you if a call is being recorded at the beginning of the call.
- Professional or employment-related information: We collect professional or employment-related information when necessary to provide insurance to you.
- Education information: We collect education information when necessary to provide insurance to you.
- Inferences drawn to create a profile about a consumer reflecting the consumer’s preferences or characteristics: We do not draw inferences in order to create a profile about you.
We may share any of the above-listed information with service providers, which are external parties that we engage for business purposes and are restricted from using personal information for any purpose that is not related to our engagement. The categories of service providers with whom we share information and the services they provide are described in this Policy.
On certain occasions, we also sell information to third parties. An external party may be considered a third party either because the purpose of sharing is not an enumerated business purpose under California law, or because our contract does not restrict them from using personal information for other purposes. To “sell” information means to disclose it to an external party for monetary or other benefit. We sell the following information:
- Personal Identifiers: We provide your IP address and device identifier to our online advertising partners.
We also may disclose information to other external parties when required by law or to protect our company or other persons, as described in this policy.
Right to Access
You have the right to request access to personal information collected about you and information regarding the source of that information, the purposes for which we collect it, and the categories of third parties and service providers with whom we share it. To protect our customers’ personal information, we will verify your identity before we act on your request.
Right to Request Deletion of Information
You have the right to request in certain circumstances that we delete personal information we have collected directly from you. To protect your personal information, we will verify your identity before we act on your request. We may have a reason under the law why we do not have to comply with your request, or why we may comply with it in a more limited way than you anticipated. If we do, we will explain that to you in our response.
Right to Information Regarding Participation in Data Sharing for Financial Incentives
We run promotions from time to time and offer online resources whereby we incentive you to share certain pieces of information with us. Participation in these incentives is voluntary and you may opt out of the data sharing at any time.
Right to Opt Out of Sale of Personal Information to Third Parties
You have the right to opt out of any sale of your personal information to third parties. To exercise this right, please visit our “Do Not Sell My Personal Information” webpage here. Please note that your right to opt out does not apply to our sharing of personal information with service providers, who are parties we engage to perform a function on our behalf and are contractually obligated to use the personal information only for that function.
Special Information for Nevada Residents
Residents of the State of Nevada have the right to opt out of the sale of certain pieces of their information to other companies who will sell or license their information to others. We do not sell your information at this time.
Users Outside the United States
If you use our Sites and Services outside the United States, you understand that we collect, process, and store your information in the United States. The laws in the United States regarding personal information may be different from the laws of your jurisdiction. Any such transfers will comply with safeguards as required by relevant law. By using the Sites and Services, you consent to the collection, international transfer, storage, and processing of your data, where permitted by law.