Privacy Policy

     

    Last Updated: 8/16/21

    We are committed to maintaining the confidentiality, integrity and security of personal information entrusted to us by current and prospective customers. We want you to know how we protect your information and how we use it to service your account. We hope you will take a moment to review our Privacy Policy.

     

    YOUR RIGHTS

    You have a right to know what we do with the personal and confidential information we collect about you in the normal course of business of offering, processing, administering and maintaining the insurance products and other products and services you purchase from us. Because we value the integrity of our customer relationships, we want to assure you that we are properly safeguarding this important information.

    You can request that we disclose to you certain information about the personal information we have collected about you. For us to provide this information, you must provide us with a verifiable customer/consumer request. Once we receive this request, we will provide certain information about the personal information we have collected about you to you, free of charge. 

    You may have certain rights to request that we delete any of your personal information we have collected from you. If we receive a verifiable request to delete your personal information and it is not necessary for us to maintain your personal information, then we will delete your personal information we have collected. 

    You have the additional right under certain state laws to opt out of the disclosure of your nonpublic personal information to non-affiliated third parties.

    In order to provide a verifiable request to us, you may either call 800.345.6040 or send a message through our website https://www.treloaronline.com/contact-us and provide your request in that manner.

     

    PERSONAL INFORMATION WE COLLECT

    We need accurate, current insurance, health, and financial information about you so that we can determine your insurability and provide products to meet your specific needs at a fair price. We collect personal information that you provide to us on applications, other forms, and in interviews. In addition, we maintain information about your transactions with us, such as policy coverage, premiums, and payment history. We may obtain additional information from third parties which may include agents, employers, other insurers, consumer reporting agencies or health care providers in the course of processing, underwriting or administering your life insurance policies.

    We collect this information primarily to appropriately advise you and recommend certain financial services we offer and to obtain the financial services that you desire to purchase through us.



    OTHER INFORMATION WE COLLECT

    Our web server places a ‘cookie’ on your computer for use in tracking visitors to our website. This information is used only to create traffic reports and analyze your activity on our website. The IP address of your computer, the type of computer and browser you are using, and other similar information is also logged each time you visit our site, and used for the same purpose. We also collect information related to your activity on our website, such as forms that you submit and other actions that you take on our website.

     

    INFORMATION WE MAY DISCLOSE

    We may share your personal financial and health information and other personal information on a confidential basis only with authorized employees, representatives and third parties whose services are required to help try to ensure a high level of service to you. We will disclose only financial personal information that is necessary to such individuals or companies who perform marketing services on our behalf, or to other financial institutions with whom we have agreements, or to our service providers. This includes information about medical visits, examinations, or diagnoses, financial or bank account information, financial account information, insurance coverage We may share your personal information with third parties that assist us in accomplishing our business purposes, including agents, insurance companies, credit bureaus and/or consumer reporting agencies, medical providers, and companies that provide standard business assistance for us. These assisting companies may process transactions, host or operate our systems, advertise for us, or provide technical support or products, including customer relationship management and similar products or services. By providing us with your personal information, you consent to these uses and sharing, unless you specifically indicate otherwise. 

    We only disclose your personal information to third parties to assist you in obtaining or implementing the financial services you have purchased through us. We will not sell your personal information to a third party. The personal information that is disclosed to a third party generally consists of any personal information stated on an application or similar form that will be submitted to a third-party company, including providing financial information to determine insurability.

    We will not disclose any non-public personal information about you or about any other customers or former customers except as authorized by law, as described in this Privacy Notice or as otherwise communicated to you. Because we respect and share your concern for privacy, we will not provide your health information to anyone outside of our Companies except as described above. We will notify you if we make any material change in this Privacy Notice. We may share selected financial information about you with our affiliated companies in order to better serve you and to offer you worthwhile products and services. 

     

    PROTECTION OF YOUR INFORMATION

    Reasonable care will be taken to keep pertinent records current, complete and accurate. If you see any inaccuracy in your statements, or in any other communication from us, we would appreciate your assistance in making corrections by contacting us.

    We will protect all information collected about you, and we will restrict access to your non-public personal information by maintaining physical, electronic and procedural safeguards. We will restrict access to protected data only to individuals who must use it in the performance of their job-related duties. Employees who violate our Privacy Policy will be subject to disciplinary action, which may include termination.

    In accordance with our routine record keeping, we may delete certain records that contain personal information you have submitted to us. We are under no obligation to store your personal information indefinitely and disclaim any liability arising out of, or related to, the destruction of your personal information. It may not always be possible to completely remove or delete your information from our databases without some residual data because of backups and other reasons.

    Above all, we value your trust and your confidence in our ability to manage and protect your important personal information.

    If you have any questions or concerns about our Privacy Policy, please contact us at the addresses listed below or in the manner described above.

    Thank you for choosing our Companies. We value you as a customer and appreciate the opportunity to serve you.

    Treloar and Heisel, LLC
    134 East Washington Street
    New Castle, Pennsylvania 16101
    Telephone: 800-345-6040
    Fax: 724-654-9029

     

    ADDITIONAL RIGHTS FOR CALIFORNIA RESIDENTS

    The California Consumer Privacy Act of 2018 (CCPA) provides California residents with certain additional privacy rights related to the personal information Treloar & Heisel, LLC. and its divisions (“we”, “us”, or “our”) collect about you. The CCPA provides California residents with rights to know about your personal information we collect and rights to have certain personal information deleted. 

    This California Privacy Notice supplements the information contained in Treloar & Heisel, LLC.’s Privacy Policy and applies solely to consumers and all visitors, users and others who reside in the State of California. Terms defined in the CCPA have the same meaning when used in this California Privacy Notice.

     

    Categories of Personal Information Collected

    We may collect personal information that identifies, relates to, references, is reasonably capable of being associated with or could reasonably be linked, directly or indirectly, with particular consumers, households or devices, including you and persons other than the individual(s) proposed for coverage. Such personal information does not include publicly available information from government records, de-identified or aggregated consumer information, and certain information protected by other specific federal or state statutes including, but not limited to, the Gramm-Leach-Bliley Act (GLBA) or California's Insurance Information and Privacy Protection Act (IIPPA).

    We may share your personal information by disclosing it to a third party for permitted business purposes. In particular, the following table lists the categories of personal information about consumers which we may collect, along with the business purpose(s) for which each category of personal information may be used. This information may be shared with service providers for business purposes.

    Category 

    Examples

    Collected

    Business Purposes

    Personal 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, date(s) of birth, or other similar identifiers.

    YES

    Application and underwriting purposes, claims administration, marketing, policy administration, for communicating with you, to provide services to you, and otherwise in furtherance of our business relationship with you

    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.

    YES

    Application and underwriting purposes, claims administration, marketing, policy administration, for communicating with you, to provide services to you, and otherwise in furtherance of our business relationship with you

    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).

    YES

    Application and underwriting purposes, claims administration, marketing, policy administration, for communicating with you, to provide services to you, and otherwise in furtherance of our business relationship with you

    Commercial information

    Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.

    YES

    Application and underwriting purposes, claims administration, marketing, policy administration, for communicating with you, to provide services to you, and otherwise in furtherance of our business relationship with you

    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.

    YES

    Application and underwriting purposes, claims administration, policy administration, for communicating with you, to provide services to you, and otherwise in furtherance of our business relationship with you.

    Internet or other similar network activity

    Browsing history, search history, information on a consumer’s interaction with a website, application, or advertisement.

    YES

    Traffic reports and analysis of your activity on our website to improve performance of the website or the services we offer to you

    Geolocation data

    Physical location or movements.

    NO

     

    Sensory data

    Audio, electronic, visual, thermal, olfactory, or similar information.

    YES

    Application and underwriting purposes, claims administration, marketing, policy administration, for communicating with you, to provide services to you, and otherwise in furtherance of our business relationship with you

    Professional or employment-related information

    Current or past job history or performance evaluations.

    YES

    Application and underwriting purposes, claims administration, marketing, policy administration, for communicating with you, to provide services to you, and otherwise in furtherance of our business relationship with you

    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.

    YES

    Actuarial and underwriting purposes, claims administration, marketing, policy administration, for communicating with you, to provide services to you, and otherwise in furtherance of our business relationship with you

    Inferences drawn from other personal information

    Profile reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.

    NO

     



    We may receive the categories of personal information listed above about you and other individuals proposed for coverage from the following sources:

    • Directly from you, including, but not limited to: when you request a quote and/or insurance product or service; through applications or other forms and records received by us (for example, we may ask you to provide personal information to us when you enroll for insurance coverage and when you purchase an insurance policy through us); through insurance transactions you conduct with us or our affiliates (for example, we may ask you to provide personal information to us when you conduct insurance business with us or our affiliates through postal mail, telephonically, electronically or by other means); through claims information you provide in the event of a claim; through consumer reporting agencies; and when you interact with us on social media platforms such as Facebook and Twitter.

    • Indirectly from you and other consumers through your use of our website, such as from observing your actions on our website. This information may include the type of device you are using, your IP address, the pages you visit while navigating the website, and how long you visit certain pages. This information is collected for a variety of purposes, including enhancing or improving the website or the services we offer to you.

     

    Use of Personal Information

    We may use the personal information collected about you for one or more of the following purposes:

    • Fulfill the reason you provided the personal information.

    • Underwrite, sell, solicit, and negotiate insurance products and services.

    • Provide you with support and respond to inquiries.

    • Contact you regarding your account, your orders, upcoming and/or failed payments, renewals and endorsements, or for any other important reason.

    • Provide you with a requested quote or offer goods and services of a third party vendor.

    • Determine eligibility and process applications for products and services.

    • Inform you with products and services we may offer and for other marketing purposes.

    • Communicate, create, service, secure and bill accounts or clients.

    • Obtain and update insurance or credit information with appropriate third parties, such as credit reporting agencies.

    • Monitor and administer accounts and the services thereto.

    • Process requests, purchases, transactions and payments and prevent transactional fraud.

    • Fulfill contractual obligations.

    • Comply with or satisfy a legal or regulatory requirement.

    • Fulfill or meet any other reasons you provided the information.

    • Fulfill any additional commercial purposes, with your consent as required by law.

    • Provide, support, personalize and develop our website, products and services.

    • Enhance or improve the website or the services we offer to you.

    • Help maintain the safety, security and integrity of our website, products and services, databases and other technology assets, and business.

    We do not sell personal information to any third parties and have not done so in the preceding twelve (12) months.

     

    De-Identified Patient Information

    We may use or disclose de-identified patient information exempt from the CPPA to third parties for commercially legitimate business purposes.

    Right to Know:

    You have the right to know certain information about our collection, use, and disclosure of your personal information for the 12 months preceding your request. You may also right to request that we provide you with specific pieces of your personal information. These rights have certain exceptions. Once we receive your request and confirm your identity, we will disclose to you the following:

    • The categories of personal information we collected from you.

    • The categories of personal information sources we collected about you.

    • Our business or commercial purpose for the information.

    • The categories of third parties with whom we shared that personal information.

    • If we sold or disclosed your personal information for a business purpose, a list identifying disclosures for a business purpose, identifying the personal information categories that each category of recipient obtained.

    • The specific pieces of personal information.

    If responding to all or part of your request would conflict with federal or state law, or your personal information is subject to an exemption under the CCPA, we will inform you of that fact. We will respond to the portion of your request that does not conflict with applicable laws and is not exempt under the CCPA.

     

    What are My Rights to Have my Personal Information Deleted?

    You have the right to have us delete certain personal information we have collected from you, with certain exceptions and exemptions. Upon your request and our verification of your identity, we will review your request to see if an exception allowing us to retain the information applies. We may deny your deletion request if retaining the information is necessary for us or our service provider(s) 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, fulfill the terms of a written warranty or recall conducted in accordance with federal law, 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 their free speech rights, or exercise another right provided for by law.

    • Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et. 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.

    We will delete or de-identify personal information not subject to one of these exceptions from our records and will direct our service providers to take similar action.

     

    Making Verifiable Requests:

    You may request that we delete personal information we have collected from you. Subject to exemptions, such as a need to retain the information to service products you have purchased from us, we will delete the personal information we have collected from you.

    Beginning January 1st 2020, if you are a California resident and would like to submit a CCPA request, you may:

    This CCPA Privacy Policy for California Residents supplements the information contained in our above standard privacy policy. This notice is intended to comply with the California Consumer Privacy Act of 2018 (“CCPA”). Terms in this policy, such as personal information, consumers, and service providers, have the same meaning as defined in the CCPA.

    Only you, or a person you authorize to act on your behalf may make a verifiable request related to your personal information. You may also make a verifiable request for your minor child. To authorize another person to make a verifiable request for you, you must provide that person with written permission clearly describing their authority to make a request for you. Your agent under a valid Power of Attorney may also make a request for you. You may only submit a request to know twice within a 12-month period.

    We will endeavor to confirm receipt of your request within ten (10) business days. Please contact us if you do not receive confirmation within the 10-day timeframe. We endeavor to substantively respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time, 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 our receipt of your 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 consumer 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.

     

    How Will you Verify My Identity If I Make a CCPA Request?

    In order to verify your identity, we will collect certain identifying information from you. We will use this information to verify your identity using reasonable methods in order to process your rights request. These methods may include matching information you provided to us with information already maintained by us, through the use of a third party identity verification service, or by personally contacting you.

    We will use the information you provide to verify your identity and to respond to your rights request and for no other purpose.

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

    You are not required to have an account or policy with us to make a verifiable request.

     

    Personal Information Sales Opt-Out and Opt-In Rights

    If you are age 16 or older, you have the right to direct a business that sells your personal information to third parties not to sell your personal information. Because we do not sell your personal information, we do not provide any mechanism for you to exercise the right to opt out.

     

    What Are My CCPA Non-Discrimination Rights?

    We will not discriminate against you for exercising your CCPA rights, which means we will not:

    • Deny you products or services.

    • Charge you different prices or rates for products or services, including through granting discounts or other benefits, or imposing penalties.

    • Provide you a different level or quality of products or services.

    • Suggest that you may receive a different price or rate for products or services or a different level or quality of products or services.

     

    Minors

    We do not knowingly collect online information from children under the age of 13. If we are notified that we have collected personal information of a child under the age of 13 as defined by the Children’s Online Privacy Protection Act (“COPPA”), we will delete the information as quickly as possible. We never sell the personal information of minors under 16 years of age and would not do so in the future without affirmative authorization of the consumer if between 13 to 16 years of age, or the parent or guardian of a consumer less than 13 years of age.

     

    Summary of CCPA Privacy Policy

    Please read this entire policy carefully to understand our practices regarding your personal information. The following points summarize some of the important details discussed below:

    • Under the CCPA, a California consumer has the right to request that we disclose what personal information we collect, use, disclose, and sell. However, we do not sell personal information.

    • Under the CCPA, a California consumer has the right to request that we delete the personal information we have collected.

    • Not all of your personal information is subject to the CCPA. Notably, if you are our customer, your personal information may be subject to other privacy laws and your personal information that we maintain may be exempt from the CCPA. Your rights under other applicable privacy laws are described in our online privacy notice and customer privacy notices, which can be found above.

    • California consumers have the right not to receive discriminatory treatment from us for the exercise of their CCPA privacy rights.

     

    What Personal Information Does Treloar & Heisel Collect, for What Purpose, from Whom, and Do We Disclose it to Service Providers?

    Because of the nature of our business, we need to collect personal information to provide our products and services, and we work hard to maintain the trust and confidence of our clients. You can make a verifiable request as described above to receive information about the categories of personal information we collect, the purpose of our collection, the source of the personal information, and whether we disclose the personal information:

     

    Do We Sell Personal Information?

    We do not sell personal information and we have not done so for the 12-month period preceding the last revision date of this policy.

     

    Changes to This Privacy Notice

    We reserve the right to amend or change this Notice at our discretion and at any time. When we amend or make changes to this Notice, we will post the updated notice on our website and update the notice’s effective date. Any changes will be effective immediately upon the posting of the revised Notice unless otherwise specified. Your continued use of the website after the posting of amendments or changes constitutes your consent to and acceptance of those changes.

     

    Contact Us

    If you have any questions about this Notice, the ways in which we collect and use your personal information described here, our privacy practices, your choices and rights regarding such use, or wish to exercise your rights under California law, please contact us at: 800.345.6040.

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