Effective Date: September 1, 2020
1. COLLECTION OF PERSONAL INFORMATION
1.1 Personal information You may provide to us through the Website or otherwise includes:
- Corporate Information
- Phone Number
- Internet or Network Activity
- Website Usage Data
- Registration Information
- Prior Insurance Information
- Broker Information
- Application Information
1.2 Sources of Personal Information. We obtain personal information from the following categories of sources:
- Personal Information You Provide. CPI collects personal information when You voluntarily submit it to us.
- Personal Information that is Automatically Collected. In addition to personal information that we may receive directly from You, CPI indirectly collects other information from You automatically log information about You, Your computer or mobile device, and Your activity over time on our Website, and other sites and online services.
- Personal Information Obtained from Third Parties. CPI may receive personal information about You from other third party sources, including from business partners or data providers. We may merge or combine such personal information with the personal information we collect from You directly or automatically.
- Personal Information from Public Sources. CPI collects personal information from public sources that is freely available without restriction or in the public domain and can freely be given to anyone.
2. USE OF PERSONAL INFORMATION
CPI’s primary purpose in collecting personal information is to provide the Services and Content that You request on the Website. CPI may also use personal information for various purposes, including without limitation:
- Fulfilling Your requests for selecting and purchasing insurance offers.
- Establish and maintain Your Account on the Website.
- Understanding and analyzing the usage trends and preferences of our Users to make our Website better, diagnose technical issues, prevent fraud, and develop new features and functionality.
- To personalize Your experience on the Website and to deliver information about insurance offers relevant to Your interests.
- To verify Your identity or determine Your eligibility for insurance offers and promotions.
- To communicate with You, including responding to any of Your requests or questions.
- To provide Users with maintenance and support including responding requests for customer support or responding to Your Feedback.
- To send You materials, updates, information, special offers, and promotional material from us and from other Users and our business partners using direct marketing or behavioral-based advertising.
- To respond to requests from law enforcement and as required by applicable law, court order, or government investigation.
3. SHARING OF PERSONAL INFORMATION
3.1 Related Companies and M&A Transactions. We may share Your personal information with companies that are affiliated with us (that is, that control, are controlled by, or are under common control with us). In addition, if we sell all or part of its business or make a sale or transfer of assets or is otherwise involved in a merger or business transfer, we may transfer Your personal information to a third party as part of that transaction, including at the negotiation stage.
3.3 Legal Compliance. We may disclose personal information in response to subpoenas, warrants, or court orders, in connection with any legal process, or to comply with relevant laws. We may also share Your personal information in order to establish or exercise our rights; to defend against a legal claim; to investigate, prevent, or take action regarding possible illegal activities or fraud; to protect the safety and security of other Users; or to prevent a violation of our Terms of Service.
3.5 Behavioral-Based Advertising Partners. We participate in behavioral-based advertising. This means that a third party advertising company may use technology (e.g., a cookie) to collect information about Your use of our Website so that we can provide advertising about products and services tailored to Your interest. That advertising may appear either on our Website, or on other websites.
3.6 Chat. The Website may provide You with the opportunity to chat. If You decide to submit personal information through chat, such personal information may be made available to other Users.
3.7 Referrals. Users may recommend other Users to join the Website by providing their contact information or selecting friends from a social networking site. Users may also provide personal information about other Users of the Website such as reviews of the services or products that he or she received, or reference information.
3.8 Brokers. Appointed Brokers may have access to Your information in order to assist in the submitting and completion of Your Applications, or jointly offer content, promotions, and other service offerings with us.
3.9 Risk Mitigation Services. Your contact information and certain details from Your application will be shared with our risk mitigation service providers (e.g. HR Counterpart) upon the purchase of certain insurance policies. These partners may contact You about their services in an effort to reduce the exposures of Your business.
3.10 Promotional Partners and 3rd Party Apps. From time-to-time, Counterpart may notify You about an offer from one of our promotional partners via our Services or email. While we may target particular types of users for these offers, we do all of the targeting within our systems and not externally. Our partners will not have any access to the targeting information, including the names of the people who may be interested in a particular product or service. Until You affirmatively respond to a promotional offer, we will not share any identifying information about You with any of these partners. If You do affirmatively respond to a promotional offer, we will share Your personal information (such as Your name, company name, business email address, etc.) with the applicable partner to allow them to respond to the affirmative response. If You install an app from one of our 3rd party partners, Counterpart may provide Your email address to that partner for account creation and communication with that partner.
4. SECURITY OF PERSONAL INFORMATION
No method of transmission over the Internet, or method of electronic storage, is fully secure. While we use reasonable efforts to protect Your personal information from the risks presented by unauthorized access or acquisition, we cannot guarantee the security of Your personal information. In the event that we are required by law to inform You of any unauthorized access or acquisition of Your personal information we may notify You electronically, in writing, or by telephone, if permitted to do so by law.
5. YOUR CHOICES
You can make the following choices regarding Your personal information:
5.1 Modifications to Your Personal Information. We rely on You to update and correct the personal information contained in Your Account. Note that we may keep historical information in our backup files as permitted by law. If our Website does not permit You to update or correct certain personal information, please contact us as described below.
5.2 Promotional E-mails. You may choose to provide us with Your e-mail address for the purpose of allowing us to send newsletters, surveys, offers, and other promotional materials related to our Website, as well as targeted offers from third parties. You can stop receiving promotional e-mails by clicking the “unsubscribe” links in the e-mails or by contacting us as described below. If You decide not to receive promotional e-mails, we may still send You service-related communications, such as those about Your Account, to fulfill orders for insurance offers You have requested, or deliver notifications directly to You through the Website.
5.3 Behavioral-Based Advertising. We participate in behavioral-based advertising. This means that a third party may use technology (e.g., a cookie) to collect information about Your use of our Website so that we can provide advertising about products and services tailored to Your interest. That advertising may appear either on our Website, or on other websites. If You wish to limit third parties’ collection of information about Your use of our Website, You can opt-out of receiving behavioral-based advertising from participating NAI and DAA members at http://www.networkadvertising.org/managing/opt_out.asp or optout.aboutads.info. Please note that we also may work with companies that offer their own opt-out mechanisms and may not participate in the opt-out mechanisms that we linked above. ADDITIONALLY, PLEASE NOTE THAT OPTING-OUT OF BEHAVIORAL ADVERTISING DOES NOT MEAN THAT YOU WILL NOT RECEIVE ADVERTISING WHILE USING THE WEBSITE. IT WILL, HOWEVER, EXCLUDE YOU FROM BEHAVIORAL -BASED ADVERTISING CONDUCTED THROUGH PARTICIPATING NETWORKS, AS PROVIDED BY THEIR POLICIES AND CHOICE MECHANISMS.
5.4 Do-Not-Track. Some web browsers and devices permit You to broadcast a preference that You not be “tracked” online. We currently do not respond to “Do Not Track” or similar signals. To find out more about “Do Not Track,” please visit http://www.allaboutdnt.com.
6. NOTICE TO CALIFORNIA RESIDENTS
Under California Civil Code sections 1798.83-1798.84, California residents who have an established business relationship with CPI are entitled to ask us for a notice describing what categories of personal information we share with third parties for their direct marketing purposes. This notice will identify the categories of information shared with and will include a list of the third parties with which it is shared, along with their names and addresses. If You are a California resident and would like a copy of this notice, please submit Your request to the address listed in the section titled “CONTACTING US” below.
We display testimonials, which may include personal information, of satisfied customers on our Services in addition to other endorsements. We may post Your testimonial along with Your name and employer name. If You wish to update or delete Your testimonial, You can contact us at [email protected].
8. OTHER SITES AND SERVICES
The Website may contain links to other websites and online services operated by third parties. These links are not an endorsement of, or representation that we are affiliated with, any third party. In addition, our content may be included on web pages or online services that are not associated with us. We do not control third party websites or online services, and we are not responsible for their actions. Other websites and services follow different rules regarding the collection, use, and sharing of Your personal information. We encourage You to read the privacy policies of the other websites and online services You use.
9. INTERNATIONAL TRANSFERS OF PERSONAL INFORMATION
CPI is based in the United States of America. If You are from a country outside of the United States of America with laws governing data collection, use, and disclosure that may differ from U.S. law and You provide personal information to us, please note that any personal information that You provide to us may be transferred to the United States of America. By providing Your personal information, where applicable law permits, You hereby specifically and expressly consent to such transfer and processing and the collection, use, and disclosure set forth herein or in the Terms of Service.
10. CONTACTING US
Attn: Trust and Compliance
440 N Barranca Ave #7008
Covina, CA 91723