Effective Date: April 12, 2021
This Privacy Notice explains how we collect, use, disclose, and otherwise process personal information in connection with our services, including Arbella.com and MyArbella.com (the “Sites”). This Privacy Notice is not a contract and does not create any legal rights or obligations.
Who We Are: Arbella Insurance Group provides car insurance, home insurance, and business insurance you need to meet the demands of driving, living, and running a business. When we use the terms, “Arbella”, “we”, “us”, or “our” in this Privacy Notice, we are referring to the following insurance company members of the Arbella Insurance Group:
- Arbella Mutual Insurance Company
- Arbella Protection Insurance Company, Inc.
- Arbella Indemnity Insurance Company, Inc.
- Covenant Insurance Company
- Bearingstar Insurance, Inc.
Our Services: When we use the term, “services”, we are referring to our U.S.-facing Internet websites that link to this Privacy Notice, including the Sites.
If you are a policyholder under an Arbella policy, please see the privacy notice, which has been provided to you, and gives more information about our practices and your rights in respect of the information we collect through insurance transactions.
1. WHAT IS PERSONAL INFORMATION?
When we use the term “personal information” in this Privacy Notice, we mean information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, to you. It does not include aggregated or de-identified information that is maintained in a form that is not capable of being associated with or reasonably linked to you.
2. OUR PRIVACY PLEDGE
- We maintain physical, electronic and procedural safeguards to guard your nonpublic personal information.
- We restrict access to your nonpublic personal information to those employees who need to know it in order to provide products and services to you, and we train our employees on how to handle and protect that information.
- We do not disclose any nonpublic personal information about you to any affiliate or non-affiliated third party other than those permitted by law.
3. INFORMATION WE COLLECT AND HOW WE USE IT
The personal information we collect, the way we collect it and how we use it will depend on how you are interacting with us and the type of services you use.
Website and Online Services
Collection of Personal Information:
As is true of most digital platforms, we and our third-party providers and partners collect certain personal information automatically when you visit or interact with our websites and other online services:
- Log Data: Including your internet protocol (IP) address, operating system, browser type, browser ID, the URL you entered and the referring page/campaign, date/time of your visit, the time you spent on our services and any errors that may occur during your visit to our services.
- Analytics Data: Including the electronic path you take to our services, through our services and when exiting our services, as well as your usage and activity on our services, such as the links, objects, products and benefits you view, click or otherwise interact with (also known as “Clickstream Data”).
- Location Data: Including your general geographic location based on the Log Data we collect or more precise location when permitted by law.
In addition to the personal information we collect automatically, we also collect personal information directly from you through our websites and online services:
- Newsletters and Email Communication: Many of our websites and online services provide you an opportunity to sign up for our newsletters and email communications by providing your email address.
- Contact Us: Our websites and online services provide individuals and representatives of prospective business customers and partners the ability to connect with us through an online web form that collects contact information (such as first and last name, email address, and phone number), area(s) of interest or concern, and a custom message from you. We use this information to communicate with you in connection with your request, including corresponding with you about Arbella’s services, offerings, customer service, business partnership opportunities or media inquiries.
Although we often collect the personal information described above directly from you, we also collect this information through service providers and other third parties that collect it on our behalf, such as communications providers, analytics providers, website hosting providers and marketing providers. Please note that our systems may record personal information that you type into our websites and other online services even if you do not choose to submit.
Use of Personal Information:
We use the personal information we collect through our websites and other online services to:
- Help to optimize your experience with our Sites and other online services;
- Administer and improve our Sites and other online services;
- Test different configurations of our Sites and other online services;
- Diagnose errors and problems with our Sites and other online services;
- Conduct research and analytics on visitor usage and activity trends relating to our Sites and other online services;
- Remember you and the choices you have made in relation to our services;
- Connect you to the requests and transactions you make on our Sites and other online services;
- Identify how you use our Sites and other online services, determine products/services that may be of interest to you and customize our personalized offerings and marketing efforts accordingly;
- Provide you with news about products and services we offer;
- Deliver marketing communications and advertisements based on your interests and interactions with us;
- Assess the performance of marketing campaigns and facilitate remarketing efforts; and
- Respond to your comments and questions and provide customer service
Please note that we link the personal information we collect through our Sites and online services with the other personal information that we collect about you and may use it for the purposes we describe in more detail in the other sections of this Privacy Notice.
Service Enrollment and Account Management
Collection of Personal Information:
When you enroll in our services or create/maintain a MyArbella account with us, we collect certain personal information from you, which may include:
- Contact Information: Including your full name, email address, mailing address and telephone number.
- Joint Account Holder and Family Information: Including the names of the joint account holders and/or your family members, when needed for the service, as well as the household indicator used to connect you to your family members in our systems.
- Account Identifiers: Including a username and password and/or member number, as well as artificial internal identifiers we assign to your account to allow our systems to connect account information stored in different databases and tables.
- Security/Authentication Information: Including additional biographical information and security answers that will help us identify you.
- Payment Information: Including payment status, billing address, billing phone number, credit/debit card name, number, expiration date and security code (CVV), check number, bank account number, transit routing number, payment dates, renewals and renewal period, billing history, card number history, and third-party payment identifiers and confirmations.
- Account History: Including the services of interest/purchase, the date and type of enrollment and/or account creation, account status, log in activity, account transactions and benefits, the services we provide to you, the alert messages you receive in connection with the services, enrollment and account errors, and the cancellation date and associated cancellation confirmation code if you choose to cancel your services.
- Customer Service and Communication History: Including your name, address, email, proof of purchase, Account Identifiers, Account History and the contents of your requests and your correspondence with us.
- Communication Preferences: Including your preferences for the ways in which we contact you (e.g., physical mail, email, text messages) and the frequency at which we reach out.
Although we often collect the personal information described above directly from you, we may also collect certain information through our business partners when you enroll through a partner that you already have a relationship with. In addition, we may also collect this information through service providers and other third parties that collect it on our behalf, such as communications providers, payment processors, payment system providers, and information technology providers.
Use of Personal Information:
We use the personal information we collect in connection with your enrollment and/or account to:
- Determine your eligibility for and/or proof of enrollment in our services;
- Create an account for MyArbella and/or any other services you choose to enroll in or interact with;
- Authenticate your identity when you choose to log in or interact with us or our services;
- Process payment for the services you enrolled in and/or signed up for;
- Provide our services to you, including allowing you to place orders and make service requests;
- Coordinate with business partners and other relevant third parties to provide you our services and the day-to-day operations relating to your enrollment and/or account;
- Communicate with you, including to provide you with customer service, answer your questions, share news about Arbella with you, market our products and services to you, and notify you about your account; and;
- Prevent fraudulent or other harmful activity, which may result in certain individuals being unable to re-enroll in our services.
Please note that we link the personal information we collect in connection with your enrollment and/or account with the other personal information that we collect about you and may use it for the purposes we describe in more detail in the other sections of this Privacy Notice.
Other Collection of Personal Information
In addition to the personal information collected above, we may also collect your personal information as follows:
- Directly from you (on insurance applications or other forms you fill out, or through telephone or in-person interviews): such as your name, address, telephone number, and social security number.
- From your transactions with us, our affiliates or others: such as your premium payment history.
- From other third parties: such as other companies or government agencies, such as your driving record or claims history.
- From medical professionals or medical records: such as information necessary to adjust claims.
- From inspections or photos taken of your property: such as information about the value or condition of property proposed for coverage.
- From consumer reporting agencies: such as your credit history. Upon request, we will tell you how to get a copy of this report. The agency that prepares the report for us may retain the report and disclose it to others as permitted by law.
- Service Providers: Our service providers, such as payment processors and marketing providers, collect personal information and often share some or all of this information with us. For example, we receive personal information from payment processors to confirm that your payment for the services was accepted.
- Information Providers: We may from time to time obtain information from third-party information providers to correct or supplement personal information we collect. For example, we may obtain updated contact information from third-party information providers to reconnect with you.
- Inquiry Information: If you choose to contact us, we will collect personal information in connection with your inquiry and correspondence with us. We may need additional information to fulfill your request or respond to your inquiry. We may provide additional privacy disclosures where the scope of the inquiry/request and/or personal information we require fall outside the scope of this Privacy Notice. In that case, the additional privacy disclosures will govern how we may process the information you provide at that time.
- Publicly Available Information: We may collect personal information from publicly available sources, such as government records or public review websites, to supplement the personal information identified above.
Other Uses of Personal Information
In addition to the uses identified above, we use the personal information we collect to:
- Facilitate our day-to-day business operations, such as maintaining accounts and processing transactions;
- Develop new products and services, and improve existing products and services;
- Aggregate information we receive from you and third parties to help understand your needs, customize our services and offerings to you, and provide you better service;
- Conduct research and analytics designed to understand our customer base and improve our products, services and customer experience;
- Prevent, investigate or provide notice of fraud or unlawful or criminal activity;
- Enforce and carry out contracts and agreements; and
- Comply with legal obligations.
4. INFORMATION WE DISCLOSE
We may disclose information to:
- Arbella entities. We are able to offer you the products and services we make available because of the hard work of the entire Arbella team. Arbella entities disclose personal information to other Arbella entities for purposes and uses that are consistent with this Privacy Notice and applicable law
- Third parties who perform professional, insurance, or business functions for us.
- Insurance institutions, agents or consumer reporting agencies in connection with any application, policy or claim involving you or your policy.
- Claims adjusters, appraisers and others to defend or settle claims involving your policy.
- Medical professionals or medical institutions to verify coverage or conduct an audit of services.
- A group policyholder to provide information regarding the status of a claim, to report claims experience or to conduct an audit of our operations or services.
- An insurance regulatory authority in connection with the regulation of our business, or to a law enforcement agency, governmental authority or other authorized person or institution to protect our legal interests, detect or prevent insurance fraud or criminal activity, or as otherwise permitted or required by law.
- Businesses that conduct scientific or actuarial research.
- Lienholders, mortgagees, lessors or other persons having a legal or beneficial interest in your property.
- Third parties in relation to a business transaction and reorganization. We may take part in or be involved with a corporate business transaction, such as a merger, acquisition, joint venture, or financing or sale of company assets. We may disclose personal information to a third party during negotiation of, in connection with or as an asset in such a corporate business transaction. Personal information may also be disclosed in the event of insolvency, bankruptcy, or receivership.
- Third parties in relation to legal obligations and rights. We may disclose personal information to third parties, such as legal advisors and law enforcement:
- In connection with the establishment, exercise, or defense of legal claims;
- To comply with laws and regulations or to respond to lawful requests and legal process;
- To detect, suppress, or prevent fraud;
- To reduce credit risk and collect debts owed to us;
- To protect the health and safety of us, our customers, or any person; or
- As otherwise required by applicable law.
- Third parties with your consent.
5. COOKIES AND RELATED DATA COLLECTION TECHNOLOGIES
Cookies are small data files that are stored on your computer that allow us and our third-party providers and partners to collect certain information about your interactions with our email communications, websites and other online services. We and our third-party providers and partners may also use other, related technologies to collect this information, such as web beacons, pixels, embedded scripts, location-identifying technologies and logging technologies (collectively, “cookies”).
What We Collect When Using Cookies
Our third-party providers and partners may also directly collect personal information about your online activities over time and across different websites when you use our websites and online services.
How We Use That Information
We may use the data collected through cookies to: (a) remember information so that you will not have to re-enter it during your visit or the next time you visit our websites and other online services; (b) provide and monitor the effectiveness of our websites and other online services; (c) monitor online usage and activities of our websites and other online services; (d) diagnose errors and problems with our websites and other online services; (e) otherwise plan for and enhance our websites and other online services; and (f) facilitate the other purposes identified in the “Website and Online Services” section of this Privacy Notice. We and our advertising partners also use the information we collect through cookies to understand your browsing activities, including across unaffiliated third-party sites, so that we can deliver information and advertisements about our services that may be of interest to you.
Please note that we link some of the personal information we collect through cookies with the other personal information that we collect about you and for the purposes described in the “Information We Collect and How We Use It” section of this Privacy Notice.
Your Choices About Cookies
If you would prefer not to accept cookies, most browsers will allow you to: (i) change your browser settings to notify you when you receive a cookie, which lets you choose whether or not to accept it; (ii) disable existing cookies; or (iii) set your browser to automatically reject cookies. Please note that doing so may negatively impact your experience using our websites and other online services, as some features and offerings may not work properly. Depending on your device and operating system, you may not be able to delete or block all cookies. In addition, if you want to reject cookies across all your browsers and devices, you will need to do so on each browser on each device you actively use. You may also set your email options to prevent the automatic downloading of images that may contain technologies that would allow us to know whether you have accessed our email and performed certain functions with it.
Your Choices About Online Ads
We support the self-regulatory principles for online advertising (Principles) published by the Digital Advertising Alliance (DAA). This means that we allow you to exercise choice regarding the collection of information about your online activities over time and across third-party websites for online interest-based advertising purposes. More information about these Principles can be found at www.aboutads.info. If you want to opt out of receiving online interest-based advertisements on your internet browser from advertisers and third parties that participate in the DAA program and perform advertising-related services for us and our advertising partners, please follow the instructions at www.aboutads.info/choices, or http://www.networkadvertising.org/choices/ to place an opt-out cookie on your device indicating that you do not want to receive interest-based advertisements. Opt-out cookies only work on the internet browser and device they are downloaded onto. If you want to opt out of interest-based advertisements across all your browsers and devices, you will need to opt out on each browser on each device you actively use. If you delete cookies on your device generally, you will need to opt out again.
If you want to opt out of receiving online interest-based advertisements on mobile apps, please follow the instructions at http://www.aboutads.info/appchoices.
6. YOUR COMMUNICATION PREFERENCES
In connection with our services, we may send you email messages, direct mail offers, SMS messages, push notifications or other communications, including telephone calls, regarding our services. You may ask us not to send you marketing communications or request a change to the method or frequency of communication by:
Please allow up to 10 days for your request to be processed. If you request to opt out of marketing communications, please note that we may continue to send you non-marketing communications, such as those directly related to the fulfillment of a specific transaction you requested, maintenance of your account or status of our ongoing business relations.
7. CHILDREN’S PERSONAL INFORMATION
Our websites and online services are not directed to, and we do not intend to, or knowingly, collect or solicit personal information from children under the age of 13. If you are under the age of 13, please do not use our websites or online services or otherwise provide us with any personal information either directly or by other means. If a child under the age of 13 has provided personal information to us, we encourage the child’s parent or guardian to contact us to request that we remove the personal information from our systems. If we learn that any personal information we collect has been provided by a child under the age of 13, we will promptly delete that personal information.
8. THIRD-PARTY WEBSITES
Our websites and online services may include links to or redirect you to third-party websites, plug-ins and applications, including social media services where you may connect with us. Third-party websites may also reference or link to our websites and online services. Except where we post, link to or expressly adopt or refer to this Privacy Notice, this Privacy Notice does not apply to, and we are not responsible for, any personal information practices of third-party websites and online services or the practices of other third parties. To learn about the personal information practices of third parties, please visit their respective privacy notices or policies.
9. UPDATES TO THIS PRIVACY NOTICE
We will update this Privacy Notice from time to time. When we make changes to this Privacy Notice, we will change the “Effective Date” at the beginning of this Privacy Notice. If we make material changes to this Privacy Notice, we will notify you by prominent posting on our Site.
10. CONTACT US
If you have any questions or requests in connection with this Privacy Notice or other privacy-related matters, please send an email to privacy.officer@Arbella.com.
Alternatively, inquiries may be addressed to:
Arbella Insurance Group
1100 Crown Colony Drive
P.O. Box 699103
Quincy, MA 02269-9103