California Privacy Policy - PFA Transportation Insurance & Surety Services

Updated October 7th, 2020

California Consumer Privacy Act Statement

Consumers residing in California have some additional rights with respect to their personal information under the California Consumer Privacy Act (“CCPA”). If you are a California resident, this California Privacy Act Statement (“Statement”) section applies to you and supplements PFA’s main Privacy Policy. It describes our collection and use of Personal Information that is subject to the CCPA, and your rights under that law.

This Statement has been adopted to comply with the CCPA and any terms defined in the CCPA have the same meaning when used in this Statement. This Statement does not apply to personal information publicly available nor to de-identified or aggregated consumer information. This Statement also does not apply to information excluded from or otherwise unregulated by the CCPA. It also does not apply to employees, contractors, or job applicants.

Categories of Personal Information We Collect

We collect 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 (“personal information”). We may collect the following categories of your personal information:

Category of Personal Information	Examples
Identifiers (“Identifiers”)	Name, alias, postal address, social security number, personal identifier, online identifier, email address, account name, driver’s license number, passport number, or other similar identifiers.
Personal Information as defined in the California Customer Records statue (Cal. Civ. Code 1798.80(e)) (“Other PI”)	Name, signature, social security number, address, telephone number, passport number, driver’s license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit or debit card number, or any other financial information. Some personal information included in this category may overlap with other categories.
Characteristics of protected classifications under California or federal law (“Characteristics”)	Age, citizenship, marital status, medical condition, physical or mental disability, sex, and veteran or military status.
Commercial Information (“Commercial”)	Records of personal property, products or services purchased, obtained or considered.
Biometric Information (“Biometric”)	Physiological, biological, or behavioral characteristics such as fingerprints, voice recordings or other data that contain indentifying information.
Internet or similar network activity (“Internet Activity”)	Website information, browsing history, search history, and information regarding a consumer’s interaction with an Internet Web site, application, or advertisement.
Geolocation data (“Geolocation”)	Physical location and/or movements.
Sensory data (“Sensory”)	Audio, electronic, visual, or similar information including recorded phone calls and other audio recordings.
Professional or employment-related information (“Professional”)	Current and/or past employment history, professional licenses or affiliations.
Inferences drawn from other personal information (“Inferences”)	Information used to create a profile about a consumer reflecting the consumer’s preferences and characteristics.

Sources of Personal Information

We collect the personal information described above directly from you such as through your transactions with PFA, including through our account representatives, claims representatives, insurance producers, business partners, and your interactions with us on our websites and social media pages. We also collect this personal information from other categories of sources such as publicly available databases, consumer reporting agencies, commercially available sources, third parties authorized by you such as financial service providers, and prior and current employers, when they share the information with us.

Uses and Disclosures of Personal Information

We may use all of the categories of personal information for the following commercial or business purposes:

Category of Personal Information	Purposes
All Categories	To fulfill or meet the reason you provided the information. For example, if you share your name and contact information to ask a question about our products or services, we will use that personal information to respond to your inquiry. To provide you with information, products, or services that you request from us. To provide support, personalize, and develop our website, products, and services. To create, maintain, customize, and secure your account with us. To process requests for services, purchases, transactions, and payments, and to prevent transaction fraud. For example, if you share your name and contact information to request a quote or to obtain a product or service, we will use that information to process your request or to facilitate a payment. We also may save your personal information to facilitate new requests for products or services or to make payments. To provide you with support and to respond to your inquiries, including to investigate and address your concerns, claims handling, and to monitor and improve our response(s). To provide you with alerts or other notices, including via electronic mail and/or text messages, concerning our products, services, payments, events, or news that may be of interest to you. To help maintain the safety, security, and integrity of our website, products and services, databases and other technology assets, and business. For testing, research, analysis, and product development, including to develop and improve our website, products and services. To respond to law enforcement, regulatory, or other legal requests, to prevent and detect fraud, defend legal claims and to comply with laws or regulations. For security purposes, such as to maintain our facilities and infrastructure, protect against malicious, deceptive, or fraudulent activity, and conduct internal investigations. As necessary or appropriate to protect the rights, property, or safety of us, our clients, or others. To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of the Company’s assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by us is among the assets transferred. To process insurability with any of our products or services, including verifying your information is accurate and valid. To contact you with regard to, in our discretion, changes to any of our services and/or any of our services’ policies. For internal business purposes.

Category of Personal Information

Purposes

All Categories

To fulfill or meet the reason you provided the information. For example, if you share your name and contact information to ask a question about our products or services, we will use that personal information to respond to your inquiry.
To provide you with information, products, or services that you request from us.
To provide support, personalize, and develop our website, products, and services.
To create, maintain, customize, and secure your account with us.
To process requests for services, purchases, transactions, and payments, and to prevent transaction fraud. For example, if you share your name and contact information to request a quote or to obtain a product or service, we will use that information to process your request or to facilitate a payment. We also may save your personal information to facilitate new requests for products or services or to make payments.
To provide you with support and to respond to your inquiries, including to investigate and address your concerns, claims handling, and to monitor and improve our response(s).
To provide you with alerts or other notices, including via electronic mail and/or text messages, concerning our products, services, payments, events, or news that may be of interest to you.
To help maintain the safety, security, and integrity of our website, products and services, databases and other technology assets, and business.
For testing, research, analysis, and product development, including to develop and improve our website, products and services.
To respond to law enforcement, regulatory, or other legal requests, to prevent and detect fraud, defend legal claims and to comply with laws or regulations.
For security purposes, such as to maintain our facilities and infrastructure, protect against malicious, deceptive, or fraudulent activity, and conduct internal investigations.
As necessary or appropriate to protect the rights, property, or safety of us, our clients, or others.
To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of the Company’s assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by us is among the assets transferred.
To process insurability with any of our products or services, including verifying your information is accurate and valid.
To contact you with regard to, in our discretion, changes to any of our services and/or any of our services’ policies.
For internal business purposes.

Third Parties with Whom Personal Information is Disclosed

We may disclose the following consumers’ personal information to the following categories of third parties:

Category of Personal Information	Third Parties
All Categories	Service providers. Providers of Internet-connected devises and associated software. Data aggregators. To our affiliates or pursuant to a business transfer. Government agencies or to protect the rights of our Company or others. Our business partners or other third parties as may be required.
Identifiers and Internet Activity	When you interact with third-party content on our website.

We do not sell your information. If in the future, we anticipate selling your personal information to any party for marketing purposes, we will provide notice so that you may exercise your opt-in and opt-out rights required by federal and state laws and regulations including the California Consumer Privacy Act (CCPA) if you have not done so already.

Your Privacy Rights

The CCPA provides California residents, or a person registered with the California Secretary of State that a California resident authorizes to act on their behalf, with specific rights regarding their personal information. This section describes your CCPA rights and explains how to exercise those rights and how to make a verifiable request.

Right to Know and Access or Request Deletion of Your Information

You have the right to request that we disclose to you the following information covering the 12 months preceding your request:

the categories of personal information we have collected about you;
the categories of sources from which we collect your personal information;
the business or commercial purposes for collecting or disclosing your personal information;
the categories of third parties with whom we share your personal information;
the categories of personal information we have disclosed about you for a business purpose; and
the specific pieces of personal information we have collected about you.

To the extent provided by law, you may also request that we delete Personal Information that we collected about or from you. To exercise the rights described above, please contact us at privacy@PFAprotects.com or by telephone at 800-595-2615. You may also write to us at the following address:

PFA Transportation Insurance & Surety Services
ATTN: Compliance Officer
22601 N. 19th Avenue, Suite 202
Phoenix, AZ 85027

If you want us to disclose specific pieces of Personal Information that we collected about or from you, you also must provide us with a copy of the front and back of your driver's license or other government-issued identification card.
If the request is made by a designated agent on your behalf, the agent must mail the form to our Compliance officer at the above address along with proof of a power of attorney from you or your signed permission authorizing the agent to make the request for you. If the agent requests disclosure of specific pieces of personal information or deletion of personal information, the agent also must send us a copy of the front and back of your driver's license or other government-issued ID card. If the agent does not provide us with proof of power of attorney, we may contact you to directly verify with you your identity and that you gave the agent permission to submit the request.
We cannot respond to your request or provide you with personal information, however, if we cannot (i) verify your identity or authority to make the request, and (ii) confirm the personal information relates to you. To make a verifiable request, you must provide sufficient information to allow us to reasonably verify you are the person about whom we collected personal information or that you are the person authorized to make the request. Additionally, you must describe your request with sufficient detail that allows us to properly understand, evaluate, and respond.
We will only use personal information you provide to verify your identity or authority to make the request. Making a verifiable request does not require you to create on account with us.
You may make up to two (2) requests in any twelve (12) month period.
You should be aware, however, that California law allows us to retain your personal information under certain conditions, even if you have asked us to delete it. We, therefore, may deny your deletion request if, for example, retaining the information is necessary for us or our service provider(s), including, but not limited to, for any of the following reasons:

to complete the transaction for which we collected the personal information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you;
to detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities;
to comply with a legal obligation; or
otherwise use personal information, internally, in a manner compatible with the context in which you provided the information.

We will promptly consider all deletion requests. In addition, we will notify you of any denial of your deletion request and the reason for such denial. 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 reason and extension period in writing. Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request's receipt. 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.

Right to Non-discrimination for the Exercise of Consumer Privacy Rights

We will not discriminate against you because you have chosen to exercise any of your privacy rights described above.
If you have questions about this notice, please contact us at privacy@PFAprotects.com or by telephone at 800-595-2615. You may also write to us at the following address:

PFA Transportation Insurance & Surety Services
ATTN: Compliance Officer
22601 N. 19th Avenue, Suite 202
Phoenix, AZ 85027

Changes to this Privacy Disclosure

This Privacy Disclosure may be changed from time to time. We will post any changes on our website. The date noted on the Privacy Disclosure indicates when it was last revised.