Privacy Policy and Notice at Collection for California Residents

Personal Information We Collect, Use, Disclose, Share, or Sell

Categories of Personal Information We Collect, Categories of Sources of Personal Information, Business or Commercial Purposes for Which Personal Information Will Be Used, and Third Parties with Whom Personal Information is Sold, Shared, or Disclosed.

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”). The chart below includes information collected for various types of individuals, such as our customers, employees, and others including independent contractors. As a result, not all of the categories of collected personal information described below may be applicable to you. Within the last twelve (12) months and on an ongoing basis, we have collected and disclosed, and may collect and disclose, the following categories of personal information as further described below.

 

Category of Personal Information Collected
Identifiers A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, Social Security number, or other similar identifiers.
Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)) A name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver's license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information. Personal Information does not include publicly available information that is lawfully made available to the general public from federal, state, or local government records. Note: Some personal information included in this category may overlap with other categories.
Protected classification characteristics under California or federal law Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information).
Commercial information Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.
Biometric information Physiological, biological, or behavioral, characteristics (including DNA) that can be used to establish individual identity, or imagery of the iris, retina, fingerprint, face, hand, palm, vein patterns, and voice recordings, from which an identifier template such as a faceprint, a minutiae template, or a voiceprint, can be extracted and keystroke  patterns or rhythms, gait patterns, or rhythms, and sleep, health or exercise data that contain identifying information.
Internet or other electronic network activity Browsing history, search history, information on a consumer's interaction with an internet website, application, or advertisement.
Geolocation data Physical location or movements.
Sensory data Audio, electronic, visual, thermal, olfactory, or similar information.
Professional or employment-related information Current or past job history or performance evaluations.
Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Sec. 1232g, 34 C.F.R. Part 99)) Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records.
Inferences drawn from other personal information to create a profile about a consumer Profile reflecting a consumer's preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.
Sensitive Personal Information Social Security number, driver’s license, state identification card, or passport number; Account log-in; Precise geolocation; Racial or ethnic origin, religious or philosophical beliefs, or union membership; Contents of mail, email or text messages unless Cinch is intended recipient of the communication; or genetic information.

Information about our Personal Information Processing Activities

We use personal information for the performance of our services, and for our business operations or human resource functions. For example, we use personal information to support and improve our website, products and services; manage human resources and benefits for our employees; evaluate job applicants’ suitability for a job opening; make decisions about promotion and determinations about seniority of employees; and evaluate employees and their performance.

We collect personal information from the following sources: from you and from others including financial services companies that we work with; third party claims handlers who are involved in a claim or assist us in investigating or processing claims, third party marketing service providers we have contracted with for cross-context behavioral advertising; and individuals that you may be associated with (e.g., employees or directors, family members, etc.).

We disclose all categories of personal information to our service providers; other third parties with which you or we maintain a relationship regarding your service or products; government agencies, including to support legal and regulatory requirements; and our affiliates.

Personal information is retained based on internal retention policies, which typically requires retention for a period of up to ten years. Information is segregated by legal retention requirements and maintained in accordance with various local, state, federal, and other legal requirements. Personal information will not be retained beyond the reasonably foreseen need to retain the information for legal or business purposes.

We may sell consumers’ personal information for marketing purposes.

We share personal information for purposes of cross-context behavioral advertising. We may disclose personal information collected via online website tracking technologies for advertising purposes as described in our online Privacy Policy. You have the ability to restrict this sharing through your browser preferences. Please review our website privacy policy for more information.

We do not sell or share (for purposes of cross-context behavioral advertising) the personal information of minors under 16 years of age.

We do not use or disclose Sensitive Personal Information for purposes other than the following:

(1) To perform the services or provide the goods reasonably expected by an average consumer who requests those goods or services.

(2) To prevent, detect, and investigate security incidents that compromise the availability, authenticity, integrity, or confidentiality of stored or transmitted personal information,

(3) To resist malicious, deceptive, fraudulent, or illegal actions directed at the business and to prosecute those responsible for those actions.

(4) To ensure the physical safety of natural persons.

(5) For short-term, transient use, including, but not limited to, nonpersonalized advertising shown as part of a consumer’s current interaction with the business, provided that the personal information is not disclosed to another third party and is not used to build a profile about the consumer or otherwise alter the consumer’s experience outside the current interaction with the business.

(6) To perform services on behalf of the business.

(7) To verify or maintain the quality or safety of a product, service, or device that is owned, manufactured, manufactured for, or controlled by the business, and to improve, upgrade, or enhance the service or device that is owned, manufactured by, manufactured for, or controlled by the business.

(8) To collect or process Sensitive Personal Information where such collection or processing is not for the purpose of inferring characteristics about a consumer.

Your Privacy Rights

Submitting Consumer Requests

You may submit a consumer request to us through our contact us section below to make a consumer request. You may make up to two disclosure requests in any 12 month period.

Only you, or someone legally authorized to act on your behalf, may make a verifiable consumer request related to your personal information. You may also make a verifiable consumer request on behalf of your minor child.

Making a verifiable consumer request does not require you to create an account with us.

When you submit a verifiable consumer request, we will take steps to verify your request by email or telephone call. In some cases, we may request additional information in order to verify your request or where necessary to process your request. If we are unable to adequately verify a request, we will notify the requestor. Authorized agents will be required to provide proof of their authorization and we may also require that the relevant consumer directly verify their identity and the authority of the authorized agent.

We will only use personal information provided in a verifiable consumer request to verify the requestor's identity or authority to make the request.

We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you.

Right to Know and Access Your Information

You have the right to request that we disclose to you certain descriptions and categories of the personal information we collect, use, disclose, share, or sell about you. For example, you may request the following through a consumer request:

(1) The categories of personal information we have collected about you.

(2) The categories of sources from which the personal information is collected.

(3) The business or commercial purpose for collecting, selling, or sharing personal information.

(4) The categories of third parties to whom we disclose the personal information.

(5) The specific pieces of personal information we have collected about you.

You may make up to two disclosure requests in any 12 month period. See above for additional details on making a consumer request.

Right to Opt-Out of the Sharing or Sale of Personal Information

We may share personal information we collect about you with third parties for purposes of cross-context behavioral advertising. We may sell personal information we collect about you, as the term “Sale” is defined by the CCPA. You may opt out of the sale or sharing (for purposes of cross-context behavioral advertising) of your personal information by signaling an opt-out preference by making an opt-out request.

To submit a request under the Right to Opt-Out, please provide the information necessary to identify the consumer to whom the request should be applied and reasonable identifying information that you are authorized to make the request and submit an email requesting your “Right to Opt-Out” to our contact point below.

Once you make an opt-out request, we will wait at least twelve (12) months before asking you to reauthorize personal information sales. However, you may change your mind and opt back in to personal information sharing or sale at any time by contacting us at privacy@cinchhs.com.

Authorized agents will be required to provide proof of their authorization to submit opt-out requests and we may also require that the relevant consumer directly verify their identity and the authority of the authorized agent in limited circumstances.

Right to Request Deletion

You have the right to request that we delete your personal information. See above for additional details about how to submit a consumer request.

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, such as when retaining your personal information is necessary for us to complete a transaction with you or provide you with a good or service you have requested. We will notify you of any denial of your deletion request and the reason for such denial.

Right to Request Correction

You have the right to request that we correct your personal information. See above for additional details about how to submit a consumer request.

Right to Non-Retaliation for Exercise of Consumer Privacy Rights

We will not retaliate against you because you have chosen to exercise any of your privacy rights provided by the CCPA.

Using an Authorized Agent

You may use an authorized agent to submit a consumer request. To use an authorized agent, you will need to (i) provide written instruction to your agent, and verify your identity to us, or (ii) provide a power of attorney pursuant to California Probate Code Sections 4000 to 4465.

Contact Us

Please read this Policy carefully to understand our practices regarding how we process CCPA personal information. If you have any questions or comments about this notice, the ways in which we collect and use your information described here and in the website Privacy Policy, your choices and rights regarding such use, or wish to exercise your rights under California law, please do not hesitate to contact us at:

Toll Free Phone Number: (844) 324-5688

Email: privacy@cinchhs.com