NOTICE OF INFORMATION AND PRIVACY PRACTICES
Last Updated: May 7, 2018
This Notice of Information and Privacy Practices (this “Notice”) describes the information collection and processing practices of our website, https://www.tbgwest.com/ (together with all of its pages and subdomains, collectively, the “Site”) and how we process Personal Information (defined below) that we receive from you and from insurance carriers. This notice applies only to information collected by TBG West (“we,” “us,” or “our”).
This Notice outlines our privacy practices, including: what information we collect and how we use that information; to whom we disclose that information; how we safeguard that information; how you can have access to that information, and if appropriate, correct that information; and how you can contact us concerning our privacy practices. This Notice applies to former, current, and future customers.
What is Personal Information?
“Personal Information” is information that, either alone or in combination with other information, identifies you. When we combine other information (i.e., information that does not, on its own, identify you) with Personal Information, we treat the combined information as Personal Information.
In this Notice, we also refer to a category of information called “Nonpublic Personal Information” or “NPI”. NPI consists of any information we obtain from you or about you and that we do not believe has been made publicly available. For practical purposes, NPI is information we obtain through our interactions with you; we assume all such information is nonpublic.
The Information We Collect and Use
Information We Collect from Insurance Carriers
We only collect and disclose Personal Information, including NPI, to the insurance carriers from whom we provide services. Accordingly, we operate under the view that it is generally those insurance carriers’ obligation to provide you a notice about how we and they collect and use information. We provide this privacy notice simply to inform you of our information collection and use policies and practices. We are not responsible for the privacy practices of any insurance carriers from whom we provide services. The insurance carriers from whom we provide services have their own privacy policies and practices that are described in their own notices. We encourage you to read the privacy notices of any such third parties.
Information that You Provide Us
As an insurance agent, we collect Personal Information about you that you provide to us. We treat all such Personal Information as NPI
Such NPI may include your name, home telephone number, business telephone number, home address, Social Security number, business address, e-mail address, date of birth, occupation, date of hire, earnings information, and health information. We also collect NPI about you from so-called census data provided to us by your employer, partnership, corporation and/or other affiliated entities. This census data may include your name, telephone numbers, home address, Social Security number, business address, e-mail address, date of birth, occupation, date of hire, and earnings information.
To the extent that we collect health NPI about you, we only do so from your insurance application to the extent you provide it and upon exception at time of claims from a medical provider to assist you at time of claim, if needed, and specifically approved by you, with valid authorizations executed by you.
The NPI that we collect is obtained from any applications and forms submitted to us by you (including the contact form on the Site) or your employer, partnership, corporation or any related entities as well as any other communications you and/or your employer, partnership, corporation, and/or other affiliated entity may have with us – whether those communications are in writing, over the phone, by e-mail or in any other medium.
Information We Receive from Your Use of the Site
We collect the following types of information through your use of the Site:
Cookies, Device Identifiers, and Similar technologies
We use Google Analytics to help us analyze the traffic on our Site. For more information on Google Analytics’ processing of Personal Information, please see http://www.google.com/policies/privacy/partners/.” By using a browser plugin http://www.google.com/ads/preferences/plugin/ provided by Google, you can opt out of Google Analytics.
Most browsers provide you with the ability to block, delete, or disable cookies, and your mobile device may allow you to disable transmission of device identifiers. If you choose to reject cookies or block device identifiers, some features of the Site may not be available or some functionality may be limited or unavailable. If you disable cookies or device identifiers, you may be unable to use some of the features and content on our Site. Please review your help pages of your browser or mobile device for assistance with changing your settings.
Without an industry or legal standard of interpreting Do Not Track Signals (“DNT”) sent to us by your browser, we do not respond to DNT signals at this time. To learn more about how DNT works, please visit http://allaboutdnt.com/.
Log File Information:
When you use our Site, our servers automatically record information, including your Internet Protocol address (“IP Address”), browser type, referring URLs (e.g., the site you visited before coming to our Site), number of clicks, and how you interact with links on the Site, domain names associated with your internet service provider, pages viewed, and other such information (collectively, “Log File Information”). We may also collect similar information from emails sent to you which then help us track which emails are opened and which links are clicked by recipients. We use Log File Information collected from our implementation of the Site to further our legitimate interests in securing the Site by identifying potential threats and vulnerabilities, and in analyzing the effectiveness of our Site to improve the Site’s function and content.
The Purposes for Which We Use Personal Information
If you submit or we collect Personal Information, then such Personal Information may be used in the following ways: (i) to provide our services as an insurance agent; (ii) to contact you in connection with providing our services; (iii) to protect our rights and/or our property; (iv) as required by law or regulation; or (v) in connection with mergers and acquisitions transactions to which we are a party.
The Information We Disclose to Others
We only share Personal Information, including NPI, with third party insurance carriers with whom we act as an agent in order to determine your eligibility for an insurance coverage, benefit, or payment, and/or to service your insurance application and/or policy. This allows us to obtain price quotes, negotiate for prices and services, enroll you in the policies you select, negotiate coverage subject to medical underwriting, and service your disability and long-term care insurance needs. We routinely limit our disclosure of this information to that which is necessary for the insurance company to offer a product or service to you. In connection with this, we may request that you provide us with a written authorization to share health NPI with the insurance carrier in order to facilitate your insurance transaction.
We may also share Personal Information with a court, governmental or regulatory agency when there is a lawful request; law enforcement to protect against fraud or unauthorized transactions; and a group policyholder (such as your employer) for purposes of reporting experience. We also may share Personal Information as otherwise allowed or required by law.
We may transfer or assign this Notice and any Personal Information to a third party entity that acquires or is merged with as part of a merger, acquisition, sale, or other change of control.
We do not provide NPI, including health NPI, to any affiliates or nonaffiliated third party for the purpose of marketing any products or services.
How We Safeguard Your Information
We employ physical, electronic and procedural safeguards, including firewalls and monitoring, in order to protect the confidentiality and security of Personal Information, including NPI. We regularly review our policies and practices in this regard. In addition, our employees are permitted access to Personal Information only on a “need-to-know” basis, that is to say, only if necessary to our providing services to you.
Despite these efforts to store Personal Information in a secure operating environment that is not available to the public, we cannot guarantee the security of Personal Information during its transmission or its storage on our systems. Further, while we attempt to ensure the integrity and security of Personal Information, we cannot guarantee that our security measures will prevent third parties such as so-called hackers from illegally obtaining access to Personal Information. We do not represent or warrant that Personal Information about you will be protected against, loss, misuse, or alteration by third parties.
How You May Access Nonpublic Personal Information
You have the right to inspect the Personal Information that we collect from you for purposes of obtaining quotations and providing services. You may visit our facility to do so, or you may request that we send you a copy of NPI about you. In order to do either, you must send a written request to the address listed below. The request should include your full name, address, telephone number and policy number if a policy has been issued. If you so request, we will send the information to you by U.S. Mail and we may charge a reasonable fee for copying and sending the information to you (unless such fee is prohibited by applicable law). If you so request, we also will disclose to you the insurance carrier(s) to whom such NPI was disclosed, or if that information was not recorded, the names of the persons to whom such NPI normally is disclosed. If the NPI you request includes health information, we may provide that information to you through a health care provider you designate. Your right to access NPI about you may be limited by applicable law under certain circumstances.
Correction of Nonpublic Personal Information
If you believe the NPI we have about you is incorrect, you may request that we correct that NPI by writing to us. Your letter should include your full name, address, telephone number and policy number if a policy has been issued. Your letter should explain why you believe the NPI is inaccurate. If we agree that the NPI is inaccurate, we will correct the NPI and notify you in writing of the correction. We also will notify any insurance carrier who may have received the incorrect NPI from us in the past two years. If we disagree with you, we will so inform you and explain our decision. We will also tell you that you may submit a statement to us. Your statement should include the corrected NPI and explain why you disagree with our decision. We will file your statement with the disputed NPI. We will include your statement anytime we disclose the disputed NPI. We also will give the statement to any person you designate if we may have disclosed the disputed NPI to that person in the past two years.
Your Other Rights Concerning Personal Information
Depending on where you live, you may have certain rights under applicable law, including the rights to access, amend, export, erase, or object to the processing of Personal Information about you. If you would like to exercise such rights, please contact us at email@example.com. We will promptly review all such requests in accordance with applicable laws.
You also may have a right to lodge a complaint with a supervisory authority or other regulatory agency if you believe that we have violated any of the rights concerning Personal Information about you. We encourage you to contact us first, so we have an opportunity to address your concerns directly before you do so.
Transfers of Personal Information to the U.S.
Retention of Personal Information
We will retain Personal Information for at least as long as necessary to fulfill the purposes for which such Personal Information has been collected as outlined in this Notice or for a longer retention period if required by law (typically, a minimum of seven years in compliance with U.S. federal and state insurance regulations).
Changes to this Notice
We reserve the right to modify this notice. If we modify this notice we will post it to our website www. tbgwest.com. UNLESS OTHERWISE INDICATED, ANY CHANGES TO THIS NOTICE WILL APPLY IMMEDIATELY UPON POSTING TO THE SITE.
How to Contact Us
For additional information about TBG West’s commitment to privacy, please visit www.tbgwest.com, email firstname.lastname@example.org or write to: TBG West, Chief Administrative Officer, 6077 Bristol Parkway, Culver City, CA 90230. To request access to NPI about you or to correct NPI, you must write to: TBG West, Chief Administrative Officer, 6077 Bristol Parkway, Culver City, CA 90230.