PRIVACY NOTICE
This Notice describes the types of information collected from visitors to Our Websites, applicants for, purchasers of, or claimants under Our insurance policies, and other users of Our Services. It also describes how that information may be used, your rights to access or update your information, and how you can limit its use or disclosure.
Summary
We use Personal Information to conduct Our business. By way of example, We may require Personal Information to underwrite an insurance policy or adjust a claim, or use it to evaluate the impact of Our marketing efforts. We understand and appreciate the trust Our customers and others place in Us to protect that information from unauthorized access and use it as described in this Notice, in a lawful manner, and consistent with reasonable expectations.
We take Our privacy obligations seriously. Among other steps We have taken:
Our Chief Compliance Officer is responsible for privacy.
Our employees, insureds, and distribution partners participate in training, testing, and awareness programs concerning privacy and information security.
We regularly evaluate Our data security practices, so We can take appropriate measures to help safeguard and protect Personal Information in Our control from unauthorized access. We provide timely and appropriate notices, as required by law, in the event of unauthorized access to that information.
We work with Our service providers and suppliers who have access to Personal Information to include appropriate data security measures in Our contracts.
We assess new vendors’ information security practices and periodically review security assessment and risk mitigation initiatives for third-party hosted applications.
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Information We Collect
Personal Information
To conduct Our business, including by operating Our Websites, We or Our service providers collect certain Personal Information from or about you.
We may collect this information using technology or from third parties. You also may choose to provide Personal Information to Us – for example, by sending an e-mail, registering for online account management, participating in a survey, responding to a feedback or “contact us” form, or signing up for or using Our Services. We may use your Personal Information to evaluate your service needs and contact you regarding additional services you may find helpful. Please notify Us at privacy@Commencemint.com if you do not wish to receive such contact.
Website Browsing Information
We, along with third parties and service providers, use automated technologies such as Cookies, Pixels, and Similar Technologies to collect information about your internet-connected devices and use of Our Websites. This information may include your IP address, Browser characteristics, operating system, domain name, the site from which you enter Our Websites, dates and times of your visits, the language your system uses, and the country and time zone in which your device is located. These automated technologies also permit the collection of “clickstream data,” which may include information about the content you access while browsing Our Websites (such as the pages you visit and how much time you spend on each page).
Insurance Applicants, Policyholders, and Claimants
Our Notice of Information Practices describes other types of Personal Information we may collect from or about you if you are an insurance applicant, policyholder, or claimant.
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What We Do With Information Collected
We may use information, including Personal Information, as described in this Notice. Some of the ways we may use your information are:
Interest-Based Advertising
We use Advertising Providers to provide advertisements to you on third-party websites. These advertisements may be personalized, meaning that they are intended to be relevant to you based on information that these Advertising Providers collect from Our Website and other websites over time. We and Our Advertising Providers use Cookies, Pixels, and Similar Technologies to inform, optimize and serve advertisements to you.
Transactions
We may store your information as part of a transaction history. We also may share your information with service providers that We use to complete your requests, operate Our Services and respond to your inquiries to Us.
Service and Support
We may use your information to provide service, product updates, other notices and distribute related feedback or satisfaction surveys to help Us improve Our service and product offerings.
Matching
We may use your information to match it with other public and private data to enhance Our records. We also may work with service providers who also possess information about you to improve Our marketing.
Selecting Content
We may use your information to help create relevant and user-friendly content and assist navigation on Our Websites.
Account Information
We may store your information to maintain your account or profile. You may request to update your information at any time by sending an e-mail to privacy@Commencemint.com.
Payment
You can enroll in online bill payment for certain products and services and make payments online, including through Our mobile application. We will use and provide to Our payment processors information about you to facilitate those payments.
Inquiries and Requests for Information, Services, or Quotes
If you have submitted an inquiry, requested information, services, or a price quote, We will provide your information to employees or independent agents to assist with your request. We may also use information for general marketing and advertising purposes, including sending advertising to you.
Legal Compliance
We may be required to disclose information We collect to comply with legal or regulatory requirements or to protect the safety of Our customers, employees, or property.
Corporate Sale, Merger, Acquisition, or Other Transfer of Assets
We may share your information as part of a corporate sale, merger, acquisition, or other transfer of some or all of Our assets, including as part of a bankruptcy proceeding.
Fraud Prevention
We may use your information to help protect against fraud and other unlawful activities.
Applicants, Policyholders, and Claimants
If you are an insurance applicant, policyholder, or claimant, We may use your Personal Information as described in Our Notice of Information Practices.
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Other Ways We Use Your Information
If you are an insurance applicant, policyholder or claimant, We may also use your Personal Information as detailed in Our Notice of Information Practices.
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Your Choices
Cookies
Our Websites use cookies.
You can change the settings on your Browser to notify you each time a Cookie is sent to you or to reject all or certain kinds of Cookies; some of these Browsers may block Cookies by default. For information on how to change your Browser settings, please click on the appropriate link below.
Internet Explorer
Edge
Chrome
Safari
Firefox
Opera
If you choose to reject Cookies, Our Websites may not function properly for you.
Website Analytics
For information about Google Analytics please click on this link: https://www.google.com/policies/privacy/partners/. To opt-out of Google Analytics, please copy and paste “tools.google.com/dlpage/gaoptout” into your Browser and download the Google Analytics opt-out browser add-on.
Interest-Based Advertising
You may choose to opt-out of Our interest-based advertising efforts. The Digital Advertising Alliance and the Network Advertising Initiative maintain websites where people can opt-out of interest-based advertising from their members. To opt-out on these pages, visit http://optout.aboutads.info or http://optout.networkadvertising.org. Note that electing to opt-out will not stop advertising from appearing in your Browser or applications. It may make the advertisements you see less relevant to your interests. We comply with the Self-Regulatory Principles for Online Behavioral Advertising set forth by the Digital Advertising Alliance.
By clicking on the following, you can also modify your advertising preferences directly with Google, Facebook, LinkedIn, LiveRamp, and Taboola.
Do Not Track
Your Browser settings may allow you to transmit a Do Not Track signal to Our Websites automatically. We do not respond to Do Not Track signals or other mechanisms. For more information on Do Not Track, please click on this link: http://www.allaboutdnt.com.
Insurance Applicants, Policyholders, and Claimants
Our Notice of Information Practices describes other rights available to insurance applicants, policyholders, or claimants.
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Links To Third Party Websites
Our Websites may include links to other sites that We do not control. In some cases, these sites may have a look and feel that is similar to Our Websites. If you submit any information to any of those sites, their privacy policies will apply to that information. We encourage you to carefully read the privacy policy for each linked site before sending any Personal Information. Any link or mention of another site should not be considered Our endorsement of that particular site. We are not responsible for the content, privacy policies, or practices employed by any other site.
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Our Other Services
Smart SecureSM
In addition to insurance, through one or more contracted suppliers, We offer alarm and smart home services– called Smart SecureSM – as a risk reduction tool. When you sign-up for or use Smart Secure, you may provide certain information, including Personal Information, to Our supplier(s) or to Us, or We and Our supplier(s) may otherwise receive it from your Smart Secure devices, your computer, or your other electronic devices that you use to access, browse, download, receive or otherwise use the Smart Secure services (each a “Personal Device”).
The information you provide or which Our supplier(s) and We may otherwise receive is used to coordinate installation and personalize, administer, and deliver your Smart Secure services. It may include, without limitation, home size; system configuration; login or access credentials; sensor names; device types, settings, and performance; account information; schedule; mode; automation settings; electrical usage or consumption; heating and cooling information; light or other fixture settings; and usage and alert logs (collectively “Smart Secure Services Information”).
In addition, as described below, the Smart Secure services may include video or audio recording capability or capture location-based information.
Video and Audio Recordings
If you purchase video monitoring or video monitoring services such as Visual Verification, a connected doorbell, camera, image sensor, or other connected device or wearable or subscribe to two-way voice, you may enable Our supplier(s), including your central monitoring station, to record, store, view and process video and/or audio recordings from this equipment (collectively, “Monitoring”). This Monitoring may include capturing and sending to you portions of this data as part of a notification or analyzing the data to identify motion or other events. This information from your Monitoring equipment may be processed to send alerts to you. In addition, if you have recording features enabled on these video products or services, video and audio data recordings from your device will be captured, processed, and stored by the applicable supplier(s). You may be able to access those recordings.
Data protection and privacy laws may impose specific responsibilities on you and your use of security cameras, connected doorbells, and other devices with recording capabilities. You alone are responsible for ensuring that you comply with any applicable laws. For example, you may need to display a notice alerting visitors to your home or business that they may be recorded using security cameras and other devices with recording capabilities. We take no responsibility for your compliance with these laws.
Location-based Information
Some features of the Smart Secure services use location-based information to enable geofencing capabilities (e.g., to send arming reminders or adjust the thermostat when you are a designated distance from home). When you opt-in to activate these geofencing services, location information will automatically be collected and stored by Our supplier(s) from your Personal Device or vehicle you designate which is capable of producing location data (e.g., mobile or GPS device). This location information may include your current location or places you recently visited and may be used by Our supplier(s) in aggregated form only for internal purposes, such as to improve the quality of service provided. Do not enable geofencing features if you do not want location-based information collected by Our supplier(s).
Our Smart Secure supplier(s) may provide some or all of this information to Us for legally permissible purposes in connection with providing the Smart Secure services or as needed to provide insurance discounts or otherwise administer your policy(ies) with Us.
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We Do Not Sell Your Personal Information
We do not sell Personal Information or Smart Secure Services Information as a stand-alone product or service. If We pursue the sale, merger, liquidation, dissolution, or transfer of all or part of Our business, trade, or assets, We may share information about you with prospective buyers under non-disclosure agreements. We may sell, assign or transfer any or all Personal Information collected through Our Websites or through conducting the business of insurance – but not through Smart Secure – to an acquiring party. Your use of Our Websites and provision of Personal Information to Us demonstrates your consent to the sale and transfer of your information under such circumstances.
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Security
We Are Serious About Security
We work hard to prevent unauthorized access to your information. We have appointed a Chief Compliance Officer who is responsible for privacy, and We educate Our employees, insureds, and distribution partners about the importance of privacy and information security. We also use appropriate security measures in Our efforts to safeguard and protect the confidentiality of your information, prohibit the unlawful disclosure of it, and limit access to it. We sign contracts with Our service providers and suppliers who have access to your Personal Information that require them to use appropriate security measures.
Our information security program focuses on six key areas:
Proactive cybersecurity, including cyber threat hunting, ethical hacking campaigns, and periodic cybersecurity program assessments;
Reactive cybersecurity processes that we regularly test using incident response and disaster recovery exercises, based on realistic scenarios;
Endpoint controls that provide data encryption, threat detection, malicious software defense, and data backups;
Identity and access management controls that include multifactor authentication and additional safeguards for staff with elevated privileges;
Employee cyber risk awareness programs that leverage general education, role-based training, and simulated phishing attacks; and
Third-party risk management and security standards that include due diligence, continuous monitoring, and cyber risk scoring.
We Do Not Request Sensitive Information By E-mail
We do not request sensitive information such as social security number, account number or password, via e-mail. Please notify Us immediately at privacy@Commencemint.com if you receive an e-mail identified as coming from Us requesting sensitive information. Do not provide sensitive information in response to that e-mail.
How We Treat Social Security Numbers
In some instances, We may need to collect, other than through e-mail, and use Social Security Numbers (“SSNs”). We safeguard and protect the confidentiality of SSNs, prohibit the unlawful disclosure of SSNs, and limit access to SSNs to those employees or service providers who require access to that information
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Children
We do not knowingly seek information from or about children under the age of 13 online, and We do not knowingly market any of Our products or services to children under the age of 13 online. If We become aware that a child under the age of 13 is attempting to or has submitted information to Us via Our Websites, We will delete the submitted information.
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Definitions
Advertising Providers means entities that provide interest-based advertising services to Us.
Browser means an internet website browser such as Internet Explorer, Edge, Chrome, Safari, Firefox, or Opera.
Cookies, Pixels and Similiar Technologies Include:
Cookies are small data files sent from a website’s server and stored on your device’s hard drive either for the duration only of your visit – session cookies – or for a fixed period – persistent cookies. Cookies contain information that a web server can later read.
Pixels or Web Beacons are small, generally transparent images embedded in web pages, applications, and emails. They also may be called “clear gifs,” “single-pixel gifs”, “page tags” or “web bugs.” We may use pixels to track the web pages you visit, test the effectiveness of Our marketing, and find out if an email has been opened and acted on.
Java Scripts are snippets of code embedded in parts of Websites and applications. They help facilitate a variety of operations, including monitoring usage of various online components.
Personal Information means any information that could reasonably be used to identify you, including your first and last name, your home address, email address, telephone number, social security number, IP address, or geolocation data. For purposes of the California Residents section of this Notice, Personal Information takes the meaning assigned in the California Consumer Privacy Act of 2018.
Services means the services we provide, including Smart SecureSM.
Websites means www.Commencemint.com, www.music-ins.com, thinkbig.Commencemint.com, roadshow.Commencemint.com, social.Commencemint.com, diamondcouncil.Commencemint.com, smart-secure.com, drive.Commencemint.com, Our limited access websites or portals, and Our mobile applications. Some of Our websites are hosted, maintained, or operated on Our behalf by third parties. If you would like information about the third parties We use, please contact Us at privacy@Commencemint.com.
We, Our or Us refers to Commencemint Insurance Group, Inc. and its member insurers.
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Contacting Us
Regarding How We Use Your Information
If you have questions about this Notice, please direct your concern or questions to privacy@Commencemint.com.
To Correct Your Information
If you are not a resident of California, and you would like to receive a copy of the Personal Information We have about you, please send a request to privacy@Commencemint.com. We will make reasonable efforts to comply with your request. If you believe this information is incorrect or incomplete, please notify Us. We will work to make any appropriate corrections or updates as promptly as possible and in accordance with applicable laws. You also may request that We limit Our use of your Personal Information. If you do, We will make reasonable efforts to do so.
Unsubscribe from E-mails
Some emails have a built-in unsubscribe link that you can use to opt-out of emails from Us. You will still receive emails related to correspondence or transactions with Us.
Written Inquiries
Please address any written inquiries to Commencemint Insurance Company of America, Attn: Chief Compliance Officer, 40 Wantage Avenue, Branchville, NJ 07890 or to privacy@Commencemint.com.
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California Residents
California Privacy Rights
The California Consumer Privacy Act of 2018 (“CCPA”) affords certain rights to the residents of the State of California. The following disclosures apply only to the Personal Information of California residents that is subject to the CCPA.
Personal Information We Collect and Disclose for a Business Purpose
In the past 12 months, We collected and disclosed for a business purpose the following categories of Personal Information about California consumers. As further set forth in the chart below, in the past 12 months, We have disclosed California consumers’ Personal Information to third parties for business or commercial purposes. We do not sell Personal Information, as “sell” is defined under the CCPA.
Categories of Personal Information Disclosed for business purposes to the following categories of third parties: Sold to the following categories of third parties:
Personal and online identifiers (such as first and last name, email address, or unique online identifiers) All categories listed below. N/A
Categories of information described in Section 1798.80(e) of the California Civil Code (such as physical characteristics or description, insurance policy number, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information) All categories listed below. N/A
Characteristics of protected classifications under California or federal law (such as race or gender) All categories listed below. N/A
Commercial or transactions information (such as records of personal property or products or services purchased, obtained or considered) All categories listed below. N/A
Internet or other electronic network activity information (such as browsing history, search history, interactions with a website, email, application, or advertisement) All categories listed below. N/A
Biometric information (such as call recordings) All categories listed below. N/A
Geolocation information All categories listed below. N/A
Sensory information (such as audio, electronic, visual, thermal, olfactory, or similar information) All categories listed below. N/A
Professional or employment-related information All categories listed below. N/A
Education information All categories listed below. N/A
Inferences drawn from the above information about your predicted characteristics and preferences All categories listed below. N/A
Other information about you that is linked to the Personal Information above All categories listed below. N/A
Categories of Sources
We collect Personal Information from the following categories of sources:
Consumers;
Service providers;
Consumer data resellers; and
Government entities
Why We Collect, Use, and Share California Information
We use and disclose the Personal Information We collect for Our commercial and business purposes, as further described in this Privacy Notice. These commercial and business purposes include, without limitation:
Our commercial purposes, including marketing, advertising, authentication, identity resolution, fraud prevention, fulfillment services, and facilitating transactions.
Our business purposes as identified in the CCPA, which include:
Auditing related to Our interactions with you;
Legal compliance;
Detecting and protecting against security incidents, fraud, and illegal activity;
Debugging;
Performing services (for Us or Our service provider) such as account servicing, processing orders and payments, and analytics;
Internal research for technological improvement;
Internal operations;
Activities to maintain and improve Our services; and other one-time uses.
Recipients of California Personal Information
Commencemint does not sell Personal Information, as “sell” is defined under the CCPA. We disclose the categories of Personal Information designated above to the categories of third parties listed below for business purposes:
Service providers;
Government entities;
Advertising networks;
Data analytics providers;
Operating systems and platforms; and
Social networks.
Your Rights Regarding Personal Information
California residents have certain rights with respect to the Personal Information collected by businesses. If you are a California resident, you may exercise the following rights regarding your Personal Information, subject to certain exceptions and limitations:
The right to know the categories and specific pieces of Personal Information We collect, use, and disclose about you, the categories of sources from which We collected Personal Information about you, Our purposes for collecting Personal Information about you, the categories of Personal Information about you that We have disclosed for a business purpose, and the categories of third parties with which We have shared Personal Information.
The right to request that We delete the Personal Information We have collected from you.
The right not to receive discriminatory treatment for the exercise of the privacy rights conferred by the CCPA.
To exercise any of the above rights, please contact Us using the following information and submit the required verifying information, as further described below:
By phone at 866-455-9969
Online at https://www.Commencemint.com/site-services/ccpa-requests.
If you have Flood Insurance with us, please click here.
Verification Process and Required Information
We may need to request additional information from you to verify your identity or understand the scope of your request, although you will not be required to create an account with Us to submit a request or have it fulfilled. We will require policyholders and claimants to provide, at a minimum, their name, address, email address, and claim or policy number.
Authorized Agent
You may designate an authorized agent to make a CCPA request on your behalf. If so, you must provide the authorized agent written permission to do so, We may require that you verify your identity directly with Us and We may require other proof of the agent’s authority to act on your behalf.
Contact for More Information
For questions or concerns about Commencemint’s privacy policy or practices, please contact Us by using the information below.
By phone at 866-455-9969
Online at https://www.Commencemint.com/site-services/ccpa-requests.
If you have Flood Insurance with us, please click here.
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Changes To This Notice
We may change this Notice and User Agreement from time to time and We encourage you to review them regularly.
At least thirty (30) days before any material changes to this Notice take effect, We will put a link on Our Website describing those changes. If the changes concern how We treat your Personal Information already in Our care, custody or control, We will email you about the changes. Your continued use of the Websites after Our new notice becomes effective tells Us that you have accepted the changes We made.
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United States Audience
We only are licensed to sell our insurance products in the United States. Our Websites are designed for use in the United States. They are neither directed to nor intended to be used by any person or entity in any other jurisdiction or country.