Who We Are
Information We Collect from Website Visits
Information we obtain from your visits to our Website can be broadly described as the personal information that visitors provide us and technical information that we collect through the use of technology concerning those visits.
Visitors to our Website have the opportunity to review information concerning available insurance products and premium quotes and, in some instances, apply for insurance. From our Website, we will collect any information that you voluntarily provide us such as your name, email address, telephone number or fax number, your company or firm name, and other business contact information. We will also collect other types of information you might provide such as preferences as to the types of insurance products and services you would like to receive, as well as responses to surveys or questionnaires.
If you are a resident of the State of California
, please see our “Privacy Notice for California Residents” below for additional information concerning personal information under the California Consumer Privacy Act.
Consent and Withdrawing Your Consent
We collect certain types of technical information provided by the browser of the computer, tablet or mobile device used when visiting our Website, such as:
Usage Details, IP Addresses, and Browser Information.
When you visit our Website, we collect technical information such as the identity of your Internet Protocol (IP) address, your computer’s or device's operating system and browser type, geo-location data, and the pages of our Website that you visit. Most browsers transmit this type of information to Websites automatically. We will anonymize your IP address. We collect this information to administer and manage our Website, to ensure that it functions properly and to review aggregate information.
How We Use or Process Your Information
We may process the information you provide and that we collect via our Website to:
Fulfill or meet the reasons you provided us the information, including to process your requests, transactions or payments and to prevent transaction fraud.
Provide invitations to seminars, conferences and other Telivy-sponsored programs, to register you for events or to sponsor events, or to provide newsletters, publications, blogs, social media feeds, and marketing information.
To respond to your inquiries, process your requests concerning your personal information in our possession, to investigate and address your concerns and to monitor and improve our responses.
To help maintain the safety, security, and integrity of our Website, products, services, databases, networks, and other technical assets and business.
Deliver any requested products or services, or to provide you with customer support.Improve, develop, modify or support our Website, products and services, to update and maintain client, subscription or email lists, and for other internal purposes.
Respond to requests for information, to respond to requests for proposals ("RFPs"), or to provide information about insurance services that you request.
Respond to lawful requests for information through court orders, subpoenas, warrants and other legal process, obligations or governmental regulations.
Enforce our Website's Terms of Service (www.telivy.com/terms
) or for the establishment, exercise or defense of legal claims.
Protect the operations of Telivy or the safety, security and privacy of Telivy, our officers, directors, employees, staff and other insurance producers (agents/brokers) with whom we conduct business, our clients or third parties. This potentially includes sharing information with others for purposes of fraud protection, information security, and related matters.
We do not sell the personal information you provide us.We will not share your personal information with third parties for marketing purposes.We will not use your personal data for making any automated decisions affecting you or your legal rights or for creating profiles other than as described above.
With Whom We Will Share Your Information
We may share the information you provide us on a confidential basis with the following categories of third parties such as contractors, vendors, or service providers that support Telivy’s operations and our Website, but only for those purposes. This may include, for instance, tracking applications for insurance, confirming policy issuance or premium payments by you, and providing information you provide to us to insurance companies and insurance agents/brokers who partner with us. When we disclose any personal information for these purposes, we require that the recipient keep the information confidential and not to use it for any other purpose.We may also share your personal information with courts, law enforcement authorities, regulators, attorneys or other parties (a) when it is reasonably necessary to comply with a subpoena or court order, legal process, or other legal requirement, (b) when we believe in good faith that such disclosure is necessary to comply with the law or prevent imminent physical harm or material financial loss, (c) to investigate, prevent or take action concerning illegal activities, suspected fraud, threats to Telivy or any of our officers, directors, employees and/or staff or to our property, or (d) as necessary in connection with an investigation of fraud, intellectual property infringement, piracy or other unlawful activity.
Links to Social Media and Third-Party Websites
Updating, Correcting or Withdrawing Your Personal Information
It is important that the personal information we have about you is accurate. If any of the personal information you provide us should ever change, for instance if you change your email address or phone number, or should you wish to change your preferences, to stop receiving announcements from us, to correct any inaccurate personal information about you, or to delete any personal information that you provided through your visits to our Website, please let us know by either following [this link] or by sending an email to [Telivy email contact]. We are not responsible for any losses that could arise from any inaccurate, deficient or incomplete personal information that you provide to Telivy.For security reasons, we may need to request specific information from you to help us confirm your identity before we correct, update or delete any personal information you provide us.
We have implemented appropriate physical, administrative, technical and organizational security measures, including encryption, to protect your personal information from inadvertent or unauthorized access, use, disclosure, alteration or destruction. No method of data storage or data transmission over the Internet, however, is guaranteed to be completely secure. Your use of our Website, and any personal information that you transmit over the Internet to our Website, is at your own risk.
Notice to Minors
Our Website is not directed at and is not intended to be visited by minors.
No visitor to our Website who is a minor or under the age of 18 should provide any personal information to Telivy. If you are a minor, do not visit our Website, including any Telivy blogs or social media site(s), and do not send any type of personal information about yourself to Telivy or our Website.
Privacy Notice for California Residents
Information We Collect
The CCPA defines personal information as 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 under the CCPA, however, does not include:
De-identified or aggregated consumer information.
Publicly available information from federal, state or local government records.
Other information is excluded from the scope of the CCPA:
Medical or health information covered by the Health Insurance and Portability and Accountability Act of 1966 (“HIPAA”) and the California Confidentiality of Medical Information Act (“CIMIA”).
Personal information covered by the Gramm-Leach-Bliley Act (“GLBA”), the California Financial Information Privacy Act (“FIPA”).
Personal information Driver’s Privacy Protection Act of 1994.
Personal information collected, processed, disclosed or sold for use in a report or by the user of a report under the Fair Credit Reporting Act (“FCRA”).
The information immediately below identifies categories or examples of personal information covered by the CCPA, and identifies categories of information that Telivy may collect from visitors to our Website in the next twelve (12) months:A. Identifiers:A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, Social Security number, driver’s license number, passport number, or other similar identifiers. B. 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. Some personal information included in this category may overlap with other categories. C. 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). D. Commercial information:Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies. E. Biometric information:Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as, fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data. F. Internet or other similar network activity:Browsing history, search history, information on a consumer’s interaction with a website, application, or advertisement. G. Geolocation data:Physical location or movements.H. Sensory data:Audio, electronic, visual, thermal, olfactory, or similar information I. Professional or employment-related information: J. Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 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. K. Inferences drawn from other personal information:Profile reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities and aptitudes.
Our Use and Sharing of Personal Information
personal information we receive from visitors to our website.
Your CCPA Privacy Rights
The CCPA provides California residents with the right to request that Telivy disclose the following:Categories of any personal information we collected about you.Specific pieces of personal information we collected about you.Categories of sources for any personal information we collected about you.Our business or commercial purpose for collecting that personal information.Categories of any third parties with whom we shared your personal information.Categories of any personal information we disclosed about you for a business purpose.Your right to request that we delete any personal information about you that we collected from you, subject to certain exceptions outlined below.Your right not to receive discriminatory treatment for the exercise of your privacy rights conferred by CCPA.By availing yourself to any of the rights afforded in this Privacy Notice, you are declaring that you are a California resident.
Requests to Delete Personal Information
You have the right to request that we delete any of your personal information collected from you. Once we receive and confirm your request, we will delete the information from our records unless an exception applies. The CCPA provides that we are not required to comply with a request to delete personal information if the information is necessary for Telivy to:Comply with a legal obligation.Complete the transaction for which the information was collected, provide a good or service you requested, perform a contract with you, to fulfill the terms of a written warranty or product recall conducted in accordance with federal law, or take actions reasonably anticipated in the context of our ongoing business relationship with you.Detect security incidents, protect against deceptive, malicious, fraudulent or illegal activity, or to prosecute those responsible for that activity.Debug products, services or applications to identify and repair errors that impair existing functionality.Exercise free speech, to ensure the rights of others to exercise their free speech rights, or to exercise another right provided by law.Comply with the California Electronic Communications Privacy Act (Cal. Penal Code §1546 et. seq
.).Enable solely internal uses that are reasonably aligned with consumer expectations based upon your relationship with Telivy.Make other internal and lawful uses of the information that are compatible with the context in which you provided the information.
How To Exercise Your Privacy Rights
You can exercise these rights in several ways. You can make a request by calling [Telivy telephone number, preferably toll free] or by submitting a request via email to [Telivy email address]. You can also send a written request by mailing it to Telivy Insurance Solutions, [Address], to the attention of [Telivy Contact Name]. Here is a link to a form to use when submitting a request via email or regular mail.You may make the request on your own behalf or on behalf of your minor child. Another person who is legally authorized to act on your behalf may also submit a request for you. Please describe your request in sufficient detail to allow us to understand the nature of the request, evaluate and respond to it. Please provide sufficient information with your request to allow us to verify that you are the person about whom we collected personal information, or an authorized representative of that person.We will promptly acknowledge receipt of your request and begin our verification process.
How We Will Verify and Respond
Before we respond to any request involving personal information, the CCPA requires that we confirm the identity of the person making the request, and if the request is made on behalf of another person, his or her authority to make the request on the other person’s behalf. We are not obligated to provide or to delete any information pursuant to your request if we are unable to adequately verify your identity or the identity of the person making the request on your behalf.Accordingly, we reserve the right to deny any request where we are unable to satisfactorily confirm your identity. If you have authorized someone to make a request on your behalf, we reserve the right to deny the request if we are unable to adequately verify the identity of that person or if we are unable to verify that the individual making the request is authorized to act on your behalf.We will attempt to verify your identity by matching any information provided in your request against the personal information already in our possession. If you have authorized someone to make a request on your behalf, we will attempt to verify the identity of that person. We will also seek to confirm that you have authorized that person to submit a request on your behalf, which may include requesting a copy of any written authorization or power of attorney for the request. This process does not require that you establish any type of account with Telivy or sign up to receive any of our publications or services.The amount of information we may require in our verification process will depend on a variety of factors including the nature of your request, the type, sensitivity and value of the personal information in our possession, the potential risk of harm that could result from any unauthorized access to or deletion of your personal information, the likelihood that fraudulent or malicious actors would seek your information and whether the information provided to us in your request is sufficient to protect against fraudulent requests or being fabricated or spoofed. For instance we will require more points of confirmation if you request that we disclose specific pieces of information rather than categories of information in our possession. Concerning a request to delete information, once we confirm your identity we will separately confirm that you want the information deleted.During our verification process, we may request additional information from you. Any information provided to Telivy during our verification process will only be used for purposes of verifying your identity or the identity and/or authority of the person making the request.We will endeavor to respond within forty-five (45) days of receipt of your request. If, however, we are unable to respond within that time, we will notify you of the reason and the additional time needed to make our response. The CCPA permits us to extend the time of our response by up to an additional 45 days.If we deny a request in whole or in part, we will endeavor to explain the reasons for our denial.
CCPA’s Limitations on Disclosures
Telivy is not obligated under the CCPA to respond to any request where compliance or disclosure would violate an evidentiary privilege under California law, or conflict with federal or state law. The CCPA, does not require that we provide personal information to a consumer more than twice in a twelve month period. Any disclosures we make will only cover the twelve (12) month period preceding the request. We will not charge a fee to process or respond to your request and will provide information free of charge. Where a person’s requests are repetitive, manifestly unfounded or excessive, the CCPA authorizes us to either charge a reasonable fee that takes into account our administrative costs, or refuse to act on the request and notify the person making the request our reason for refusing the request. If we determine that a request warrants a fee, we will explain our decision and will endeavor to provide you with a cost estimate.Regulations proposed by the California Attorney General prohibit us from disclosing specific pieces of personal information if the disclosure creates a substantial, articulable, and unreasonable risk to the security of that information or the security of our systems or networks. These proposed regulations further prohibit us from disclosing in response to a consumer’s request a Social Security number, driver’s license number, other government issued identification number, financial account number, any health insurance or medical identification number, an account password or security questions and answers.
We will not discriminate against you for exercising any of your CCPA rights. This means, for instance, that we will not deny you services, charge you a different price, including a discount or other benefit or impose a penalty for the exercise of your CCPA rights.
Other California Privacy Rights
The California Civil Code permits California residents with whom we have an established business relationship to request that we provide you with a list of certain categories of personal information that we have disclosed to third-parties for their direct marketing purposes during the preceding calendar year. To make such a request, please send an email to [Telivy Contact Name] at [Contact Email Address] or write him/her at [Telivy Mailing Address]. Please mention that you are making a "California Shine the Light" inquiry.
Visitors from Outside the United States
If you are visiting our website from outside the United States ("U.S."), any information you voluntarily provide via our Website and any technical information from the browser of your computer, tablet or mobile device will be transferred out of your country and into the U.S. where Telivy is located. The laws and protections available to the privacy of your personal information in the U.S. may significantly differ from the protections available in your country. Personal data transferred to the U.S. may be subject to lawful access requests by state and federal authorities in the U.S. If you do not want any personal information to be transferred to the U.S., please do not provide that information to Telivy via our Website.
Visitors from the European Union
On May 25, 2018, the General Data Protection Regulation ("GDPR") went into effect in the European Union ("EU"). The GDPR extends certain rights to natural persons involving the privacy of their personal information. Telivy is the data controller for any personal information provided via our Website. Telivy does not have a data protection officer in the EU. Any information that you provide to us will be stored in the United States; we do not intend to transfer your personal data to another country or international organization. We will retain any personal information that you provide via our Website for seven (7) years from the date you provided or last updated that information, unless you request that information be deleted at an earlier date. If that information is subject to a litigation hold, or is required to assert or defend a legal claim, then we will hold that information until the claim or action is finally resolved. Under the GDPR individuals are granted the following rights:
Right of Access
You have the right to ask what personal information we have about you in our possession. You have the right to obtain a copy of your personal data free of charge so long as it does not adversely affect the rights of others. We may charge a reasonable fee based on administrative costs for additional copies. The right of access includes the right to request that we update, correct or complete your personal information in our possession.
Right of Erasure
You have a right to request that data be deleted or erased when it is no longer needed for the purposes for which it was collected or processed, when you withdraw your consent, when data is unlawfully processed, to comply with a legal obligation of the EU or a Member State, or when you object to the processing and we are unable to demonstrate compelling, legitimate grounds for the processing which overrides your rights, freedoms or interests. Personal data does not have to be erased when and to the extent it is necessary "for the establishment, exercise, or defense of legal claims."
Right to Restrict Processing
You have a right to restrict the processing of your personal data when you contest the accuracy of the personal data in our possession until we are able to verify its accuracy, if the processing is unlawful and you oppose its erasure and request restriction instead.
Right to Data Portability
The right to data portability is triggered when processing activity was based on your consent, or was necessary for the performance of a contract, and the processing was carried out by automated means. This right, however, shall not adversely affect the rights of others.
Automated Decision Making
You have the right not to be subjected to decision-making based solely
on automated processing or profiling that either significantly affects you or results in some sort of legal effect. This right does not apply to decisions that are necessary for entering into or performing a contract with you or are based on your explicit consent.
Right to Object to Processing
You have the right to object to processing when it is based on a "legitimate interest" of the controller or a third party, or to processing that occurs for direct marketing purposes.
Withdrawing Your Consent
Right to Complain
You also have the right to lodge a complaint with the supervisory authority about our data privacy practices where you reside.
How to Exercise These Rights
You can exercise these rights by sending an email to info [at] telivy [dot] com. We will review any requests we receive and will endeavor to respond in a timely manner. For security reasons, we may request specific information from you to help us confirm your identity before taking action on any request, and to ensure your right of access and the exercise any of GDPR right does not adversely affect the rights of others.We reserve the right to refuse to act on a request, or to charge a reasonable administrative fee when a request is either manifestly unfounded or excessive because of its repetitive character.
How to Contact Us