This PRIVACY STATEMENT supplements the information contained in the Personal Lines Privacy Notice of IPFS Corporation and its affiliates (collectively “IPFS”, “we,” “us,” or “our”) and governs our privacy practices on our website, the products and services offered by us through our website, and any mobile application or product that incorporates this Privacy Statement. In a typical transaction, IPFS may collect information such as name, company name, address, email address, phone number, insurance policy information, bank account information, financial information, credit history, and information about an entity’s officers, directors and other control persons. While we do not sell any of the information we collect, we may make the information available to affiliates and third parties in connection with fulfilling your request, servicing your account, and to market our products and services, as allowed by law and subject to the more specific privacy notices covered below in “Personal Line Notice” and “Date Use Notice” or that you may receive as part of a particular product or service.
Effective Date: January 15, 2021
Last Update Date: January 1, 2023
Information We Collect
When you interact with us, including as part of a product or service or applying for employment, we may collect information that identifies, relates to, describes, references, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with you or your device (“personal information”). In particular, we may have collected the following categories of personal information within the last twelve (12) months:
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.
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 state 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 our 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.
Current or past job history or performance evaluations.
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.
Personal information does not include:
- Publicly available information from government records.
- Deidentified or aggregated data that can no longer be used to identify a specific person.
- Business information, such as employer’s name and contact information.
- Because each state’s privacy laws may vary, your home state’s privacy laws may not apply to all personal information we collect. Please review your home state’s privacy laws as they relate to:
- Certain personal information covered by or collected under industry-specific privacy laws including, but not limited to, the Health Insurance Portability and Accountability Act of 1996, the California Confidentiality of Medical Information Act, the Fair Credit Reporting Act, the Gramm-Leach-Bliley Act, the California Financial Information Privacy Act, and the Driver's Privacy Protection Act of 1994.
- Personal information that we collect about you when you are acting as our job applicant, employee, owner, director, officer, medical staff member, or contractor to the extent that we collect and use your personal information solely within the context of that role. This also includes your emergency contact information and personal information that is necessary for us to retain to administer benefits for you. However, you will still receive a notice at the time of collection, which outlines the categories of personal information we collect and the purposes for which we collect the categories of personal information.
- Personal information we receive from you reflecting a communication or transaction between us and another business when you are acting as an employee, owner, director, officer, or contractor of such company, partnership, sole proprietorship, nonprofit, or government agency and you are seeking a product or service from us for the company, partnership, sole proprietorship, nonprofit, or government agency.
We obtain the categories of personal information listed above from the following categories of sources:
- Directly from you or your agent. For example, from documents that our clients or their agents provide to us related to the services for which they engage us.
- Indirectly from you or your agent. For example, through information we collect from a client in the course of providing services to them.
- Directly and indirectly from activity on our website (www.ipfs.com). For example, from submissions through our website portal or website usage details collected automatically.
- From third-parties that interact with us in connection with the services we perform.
Information Collected Automatically Online
In addition to collecting information directly from you as described in the previous section, we also automatically gather information when you browse or view our website. This information may include Internet Protocol (IP) address, browser type and language, Internet service provider (ISP), referring and exit websites and applications, operating system, date/time stamp, clickstream data, whether you are a first-time or a returning user, links you clicked on while on our website, and your flow and navigation path through our website. We use this information to make sure that our website, and its associated parts, are functioning properly, that our website is displayed properly for your equipment and software, and that we can provide you with information useful to you.
There are “do not track” or similar browser choices available to internet users with respect to online web activity but given the present lack of consensus of what constitutes an informed election, appropriate trigger or breadth of scope of such choice, our website will not operate any differently when a “do not track” signal is received.
In some of our email messages, you will find a “click-through URL” linked to content on our website. We track this click-through data to help us determine interest in specific topics and measure the effectiveness of our customer communications. If you prefer not to be tracked in this way, you should not click such links in our email messages.
We use technologies such as “cookies” so we can remember certain information about you, remember your preferences or recognize you when you return. They also help us compile aggregate data about our website traffic and website interaction so that we can improve our website and protect our website from fraud.
A cookie is a text file that is stored on your computer. As text files, cookies cannot read information on your hard drive, run programs or deliver viruses to your computer.
Most browsers are set to accept cookies automatically. You can set your browser to decline all cookies automatically or to prompt you for a response each time a cookie is offered. If you decline cookies, you may find that some of our website’s features may not fully function.
We also use log files when you visit our website. Log files track IP addresses, browser type, Internet Service Provider (ISP) identity, referring/exit pages, platform type, date/time stamp, and number of clicks. We utilize this information in our legitimate interest in administering our website, preventing fraud, tracking website navigation in the aggregate, and gathering broad demographic information for aggregate use.
Pixel tags enable us to send email messages in a format that customers can read, and they tell us whether mail has been opened. We may use this information to reduce or eliminate messages sent to customers.
We may allow third-party companies to collect information about your visit to our website such as, date/time stamp, operating system, referring and exit websites and applications, whether you are a first-time or a returning user, links you clicked on while on our website, etc. These third-party companies typically use a cookie or third-party web beacon to collect this information. To opt-out of this type of tracking you may refuse to accept cookies while on our website. You may also be able to adjust your browser setting to refuse third-party cookies
Website Analytics Tools and Service Providers
We may use web analytics tools or service providers (e.g., Google Analytics and Lucky Orange) to perform the tasks identified above or to gather other data such as Browser, Operating System, County, City and Network (ISP) to provide advertising targeted to suit your interests and preferences.
Use of Personal Information
We may use or disclose the personal information we collect for one or more of the following business or commercial purposes:
- To fulfill or meet the reason for which the information is provided. For example, to finance or pay for an insurance policy.
- Performing services such as maintaining or servicing accounts, providing customer service, processing or fulfilling orders and transactions, verifying customer information, processing payments, providing financing, providing advertising or marketing services, providing analytic services, or providing similar services on behalf of the business or service provider.
- To provide you with information, products or services that you request from us.
- To provide you with email alerts, event registrations and other notices concerning our products or services, or events or news, that may be of interest to you.
- To carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collections.
- To improve our website and present its contents to you.
- As part of our hiring and employment practices.
- For testing, research, analysis and product development.
- As necessary or appropriate to protect the rights, property or safety of us, our clients or others.
- To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.
- To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our 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.
- Detecting security incidents, protecting against malicious, deceptive, fraudulent, or illegal activity, and prosecuting those responsible for that activity.
- Debugging to identify and repair errors that impair existing intended functionality.
- Short-term, transient use.
- Verification, maintenance, or improvement of the quality of our services and devices.
- Undertaking internal research for technological development and demonstration.
- Auditing related to a current interaction with the consumer and concurrent transactions, including, but not limited to, counting ad impressions to unique visitors, verifying positioning and quality of ad impressions, and auditing compliance with this specification and other standards.
- To advance the business’s commercial or economic interest not otherwise identified above.
We will not collect additional categories of personal information or use the personal information we collected for materially different, unrelated, or incompatible purposes without providing you notice.
Sharing Personal Information
We may disclose your personal information to a third party for a business or commercial purpose. When we disclose personal information for a business purpose, we enter a contract that describes the purpose and requires the recipient to both keep that personal information confidential and not use it for any purpose except performing the contract.
In the preceding twelve (12) months, we may have disclosed the following categories of personal information for a business or commercial purpose:
Category A: Identifiers.
Category B: Customer Records personal information categories.
Category C: Protected classification characteristics under state or federal law.
Category D: Commercial Information
Category E: Biometric Information
Category F: Internet or other similar network activity
Category G: Geolocation data
Category I: Professional or employment-related information.
Category J: Non-public education information
Category K: Inferences drawn from other personal information
We disclose your personal information for a business or commercial purpose to our service providers and the following categories of third parties:
- Our affiliates.
- Third parties to whom you or your agents authorize us to disclose your personal information in connection with products or services we provide to you.
In the preceding twelve (12) months, we have not sold any personal information. We do not and will not sell your personal information. In addition, we do not sell the personal information of minors under 16 years of age.
Your Rights and Choices
State privacy laws may provide individuals with specific rights regarding their personal information. This section generally describes these rights and explains how to exercise those rights. The availability of these rights is dependent on your home state’s privacy laws. Please review your home state’s privacy laws to determine which rights are available to you.
Access to Personal Information Rights
You (or the household) have the right to request that we disclose certain information to you about our collection and use of your personal information over the past 12 months. Once we receive and confirm your verifiable consumer request, we will disclose to you:
- The categories of personal information we collected about you.
- The categories of sources for the personal information we collected about you.
- Our business or commercial purpose for collecting that personal information.
- Our business or commercial purpose for disclosing the category of personal information about you.
- The specific pieces of personal information we collected about you.
- If we disclosed your personal information for a business or commercial purpose:
- The categories of personal information that we disclosed about you for a business or commercial purpose; and
- The categories of third parties to whom your personal information was disclosed for a business or commercial purpose, and which category of personal information was disclosed to that category of third party.
However, there is certain information that we will not disclose to you. This information includes but is not limited to your Social Security number, driver’s license number or other government-issued identification number, financial account number, any health insurance or medical identification number, an account password, or security questions and answer. Also, we will not provide you with specific pieces of personal information if the disclosure creates a substantial, articulable, and unreasonable risk to the security of that personal information, your account with us, or the security of our systems or networks.
Deletion Request Rights
You (or the household) have the right to request that we delete any of your personal information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request, we will delete (and direct our service providers to delete) your personal information from our records, unless an exception applies.
We may deny your deletion request if retaining the information is necessary for us or our service providers 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.
- Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
- Debug products to identify and repair errors that impair existing intended functionality.
- Exercise free speech, ensure the right of another consumer to exercise that consumer’s free speech rights, or exercise another right provided for by law.
- Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 seq.).
- Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information's deletion may likely render impossible or seriously impair the research's achievement, if you previously provided informed consent.
- Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
- Comply with a legal obligation.
- Make other internal and lawful uses of that information that are compatible with the context in which you provided it.
Exercising Access, and Deletion Rights
To exercise the access and deletion rights described above, please submit a verifiable request to us by either:
- Calling us at 844-722-4092.
- Email us at email@example.com
Only you or a person registered with the appropriate Secretary of State that you authorize to act on your behalf, may make a verifiable request related to your personal information. You may designate an authorized agent to make a request on your behalf. If you would like to use an authorized agent, which is an individual or business registered with the Secretary of State that you have authorized to act on your behalf, to submit a request to opt-out, you must provide the authorized agent with written permission to do so and verify your own identity directly with us. We may deny a request from an agent that does not submit proof that they are authorized to act on your behalf.
Please note that we are only required to respond to your request for access to your personal information twice within a 12-month period.
The verifiable request must:
- Provide sufficient information such as an account number and policy number 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 relates to you. Making a verifiable request does not require you to create an account with us. We will only use personal information provided in a verifiable request to verify the requestor's identity or authority to make the request.
Response Timing and Format
We endeavor to respond to a verifiable request within 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 account with us, we will 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 will only cover the 12-month period preceding the verifiable request's receipt. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For requests of specific information, 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.
We will not discriminate against you for exercising any of your rights. Unless permitted, we will not:
- Deny you goods or services.
- Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.
- Provide you a different level or quality of goods or services.
- Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.
Our Security Practices
We utilize administrative, technical, and physical controls to protect your information during transmission and once we receive it. These controls include physical security, encrypting electronic submissions (e.g., using secure socket layer technology), password management policies, and other measures to restrict access to your information. However, no method of transmission or storage is 100% secure. Thus, we cannot guarantee your information’s absolute security.
Changes to Our Privacy Statement
We reserve the right to amend this Privacy Statement at our discretion and at any time. If we make a material change to this Privacy Statement, we will notify you by using one of the following methods at least thirty (30) days prior to the effective date of such change: (a) email; or (b) through a notice on our website homepage.
If you have any questions or comments about this notice, our Privacy Statement, the ways in which we collect and use your personal information, your choices and rights regarding such use, or wish to exercise your right, please do not hesitate to contact us via email at: firstname.lastname@example.org or by phone at 844-722-4092.