Supplemental Privacy Notice
for California Residents

INTRODUCTION

This Supplemental Privacy Notice for California Residents (“Notice”) supplements the information contained in the TruChoice Financial Group, LLC (“TruChoice,” “we,” “our,” or “us”) Privacy Notice available here and applies solely to website visitors, users and to individuals who reside in the State of California (“consumer,” “you,” or “your”). We adopt this Notice to comply with the California Consumer Privacy Act of 2018 (“CCPA”) and any terms defined in the CCPA have the same meaning when used in this Notice.

This Notice describes the following:

SCOPE

This Notice applies to personal information collected, used and shared by TruChoice.

This Notice does not apply to employment-related personal information collected from California-based employees, job applicants, contractors, or similar individuals (“employment-related personal information”).

Where noted in this Notice, the CCPA temporarily exempts personal information reflecting a written or verbal business-to-business communication or transaction (“B2B personal information”) from some of its requirements.

TYPES OF PERSONAL INFORMATION WE COLLECT

We collect information that identifies, relates to, describes, references, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer, household, or device ("personal information"). Personal information does not include:

  • Publicly available information from government records.
  • Deidentified or aggregated consumer information.
  • Information excluded from the CCPA's scope, such as:
    • Health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and the California Confidentiality of Medical Information Act (CMIA) or clinical trial data;
    • Personal information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FCRA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver's Privacy Protection Act of 1994.

Most of the personal information we collect about you is covered by sector-specific privacy laws or is temporarily exempted from the CCPA. This means the CCPA does not apply to that information. Even though we have an exemption for most of the personal information we collect, we want to be transparent about our information collection practices. We collect the following categories of personal information from consumers:

  • Unique personal identifiers such as real name, alias, postal address, online identifier (e.g., an internet protocol (IP) address), email, account name, Social Security number, driver’s license number, or other similar identifiers;
  • Financial information including bank account numbers, credit or debit card numbers, or other financial information;
  • Medical information including any information in possession of or derived from a healthcare provider, healthcare service plan, pharmaceutical company, or contractor regarding medical history, mental or physical condition, or treatment;
  • Protected characteristics such as race, gender, physical or mental disability, and religion;
  • Commercial information such as products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies;
  • Network activity that includes internet or other electronic network activity information, such as browsing history, search history and information regarding your interaction with our internet website, application, or advertisement;
  • Electronic and sensory information such as audio, electronic, or similar information (e.g., a recording of a service call);
  • Signature, such as a consumer’s signature on an application or form; and
  • Inferences drawn from any of the information listed above to create a profile about a consumer reflecting the consumer’s preferences, characteristics, and abilities (e.g., predications about a consumer’s preferences or tendencies).

We obtain the categories of personal information listed above from the following sources:

  • Directly from you. For example, from your insurance application, or other forms you complete when applying to purchase products or services from the insurance carriers we are contracted with. For insurance producers, we collect information about you from your insurance carrier appointment paperwork and other forms you complete before and during your appointment with an insurance carrier.
  • Indirectly from you. For example, from your insurance agent or the insurance carriers you have purchased a product or service from, or from your actions on our website. For insurance agents, we may obtain information about you from the insurance carriers you are appointed with (e.g., compensation and transaction information, etc.).

TYPES OF PERSONAL INFORMATION WE USE

We use the personal information we collect for one or more of the following purposes:

  • To fulfill or meet the reason you provided the information. For example, if you provide your personal information for the purpose of purchasing an insurance product, we will use your personal information to facilitate your request;
  • If you are an insurance producer, to appoint you with insurance carriers, to assist you in placing business, and to offer you rewards for the business you place through our company. We process the personal information you provide through our marketplace for the purpose of processing your request(s) for rewards;
  • To provide, support, personalize and develop our products, services, and website;
  • If you are an insurance producer with us, to create, maintain, customize, and secure your account with us;
  • To provide you with support and to respond to your inquiries, including to investigate and address your concerns and monitor and improve our responses;
  • To personalize your experience on our website and to deliver content and product and service offerings relevant to your interests;
  • To help maintain the safety, security and integrity of our website, products and services, databases, and other technology assets and business;
  • To help monitor and address financial fraud;
  • For testing, research, analysis and product development, including to develop and improve our website, products, and services;
  • To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations; and
  • As described to you when collecting your personal information or as otherwise defined in the CCPA.

We will not collect additional categories of information or use the personal information we collect for materially different, unrelated, or incompatible purposes without providing you notice.

TYPES OF PERSONAL INFORMATION WE DISCLOSE TO OTHER PARTIES

We disclose your personal information to other parties (e.g., service providers, insurance producers, insurance carriers, third-party administrators, producer rewards marketplace vendors, etc.) for business purposes. The personal information we disclose and who we disclose it to is based on the insurance product or service for which you applied. For our insurance producers, we disclose your personal information to the insurance carriers you request appointments with and with service providers to process your requests for marketplace rewards. When we disclose personal information for a business purpose, we enter into a contract describing that purpose and requiring the recipient to safeguard the personal information and not to use it for any purpose other than performing the contract. We do not sell your personal information to third parties.

YOUR RIGHTS UNDER THE LAW

To the extent the CCPA applies to your interactions with us, the law provides you with specific rights regarding your personal information. This section describes your CCPA rights and explains how to exercise those rights.

Access to Specific Information and Data Portability Rights

To the extent the CCPA applies, you have the right to request we disclose certain information to you about our collection and use of your personal information over the past 12 months. TruChoice must verify your identity before responding to your request.

TruChoice does not provide access and data portability rights for B2B personal information.

Deletion Request Rights

To the extent the CCPA applies to your interactions with us, you have the right to request we delete personal information we collected from you and retained, subject to certain exceptions. Once we receive your request and verify your identity, we will delete (and direct our service providers to delete) your personal information from our information systems and paper documents, unless an exception applies.

TruChoice does not provide deletion rights for B2B personal information.

Exercising Access, Data Portability and Deletion Rights

To exercise the access, data portability, and deletion rights described above, please submit a verifiable consumer request to us using one of the contact methods described in the How to Contact Us section.

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

Under the CCPA, you may only make a verifiable consumer request for access or data portability of your personal information twice within a 12-month period. The verifiable request must:

  • Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative.
  • Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

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 you seek relates to you.

When making a verifiable consumer request, you do not need to create an account with us. If you have an online account with us, we may consider requests made through your password-protected account sufficiently verified when the request relates to personal information associated with that specific account.

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

Response Timing and Format

If the CCPA applies to your interactions with us, we endeavor to respond to a verifiable request within forty-five (45) days of its receipt. If we require more time (up to 90 days), we will inform you of the reason and extension period in writing.

If you have an online account with us, we may deliver our written response to that account. If you do not have an account with us, we will deliver our written response by mail or electronically, at your option.

Any disclosures we provide to you will only cover the 12-month period preceding receipt of a verifiable consumer request. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your personal information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance.

We do not charge a fee to process or respond to your verifiable 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.

Non-Discrimination

We will not discriminate against you for exercising any of your CCPA rights.

HOW TO CONTACT US

You may contact TruChoice by telephone, email, or web inquiry.

Telephone: 800-237-0263
Email: tccompliance@truchoicefinancial.com

Web inquiry: On our Contact Us page, please select “Other” on the drop-down menu and reference CCPA in the subject line before submitting your message.

PRIVACY NOTICE REVISIONS

This Notice is effective January 1, 2020. We reserve the right, at our discretion, to change, modify, add, or remove portions of this Notice at any time. Your continued use of this website and our services constitutes your acceptance of any changes to this Notice.

(Revised 1/10/2020)