California Consumer Privacy Act
Privacy Notice
Effective Date: January 1, 2023
This notice (“CCPA Noticeâ€) describes how Â鶹Çø and our brands, affiliates, and subsidiaries (“Â鶹Çø", “‘weâ€, “usâ€, or “ourâ€) collect, use, and disclose Personal Information of California residents who interact with us as consumers, job applicants or employees (“Consumersâ€) or in the course of their work for another company (“B2B Contactsâ€). We provide this CCPA Notice pursuant to the California Consumer Privacy Act, as amended by the California Privacy Rights Act (the “CCPAâ€) and as a supplement to Â鶹Çø’s other privacy policies or notices, including our Privacy Policy (/privacy-policy). In the event of a conflict between this CCPA Notice and the Privacy Policy, or other Â鶹Çø privacy policies, this CCPA Notice shall govern as to the rights of California Consumers and B2B Contacts under the CCPA. Capitalized terms that are used in this CCPA Notice shall have the meaning given to them in the Privacy Policy unless otherwise noted.
PI Not Covered by this CCPA Notice.
This CCPA Notice does not cover information that is outside of the scope of the CCPA, including:
- Data governed by other laws such as the Health Insurance Portability and Accountability Act of 1996, the California Medical Information Act, the Gramm-Leach-Bliley Act of 1999, the California Financial Information Privacy Act, the Fair Credit Reporting Act, or the Driver’s Privacy Protection Act of 1994.
- Publicly available information that is lawfully made available from federal, state, or local government records, or information that we have a reasonable basis to believe is lawfully made available to the general public by you, by widely distributed media, or by a person to whom you have disclosed the information if you have not restricted the information to a specific audience.
- Deidentified, aggregated, or publicly available information.
PI We Collect and Why We Collect It
“Personal Information†or “PI†means information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with you. Within the past 12 months, we have collected and may collect the following categories of PI about California Consumers and B2B Contacts:
Category of Personal Information | Categories of Sources from which Information was Collected | Purposes for Collection |
Identifiers, including real name, alias, postal address, unique personal identifier, online identifier, IP address, email address, account name, social security number, driver’s license number, passport number, or other similar identifiers | Directly from you Automatically when you use our websites or mobile apps Service Providers that help us to run our business Affiliates, Agents, and Insurance Brokers Data Analytics Providers Ad Networks, Social Media Platforms, and other marketing or advertising partners Data Brokers | To provide our products and services To communicate with you To facilitate services you provide as a B2B Contact To support our websites and mobile apps, including customizing your user experience For marketing purposes To show you relevant ads while you browse the internet or use social media For analytics, research and development, or to otherwise improve our business To comply with applicable laws and regulations To detect and protect against malicious, deceptive, fraudulent or illegal activity To consider you for employment at our company In connection with your employment with us |
Personal records described in Cal. Civ. Code § 1798.80(e), including 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 other financial information, medical information, or health insurance information | Directly from you Service Providers that help us to run our business Affiliates, Agents, and Insurance Brokers Data Analytics Providers Ad Networks, Social Media Platforms, and other marketing or advertising partners Data Brokers | To provide our products and services To communicate with you To facilitate services you provide as a B2B Contact To support our websites and mobile apps, including customizing your user experience For marketing purposes To show you relevant ads while you browse the internet or use social media For analytics, research and development, or to otherwise improve our business To comply with applicable laws and regulations To detect and protect against malicious, deceptive, fraudulent or illegal activity To consider you for employment at our company In connection with your employment with us |
Characteristics of protected classifications under California or federal law, including age and date of birth, race, ancestry, ethnic origin, sex, gender, sexual orientation, gender identity, religion or creed, military or veteran status, medical condition, genetic information, disability, marital status | Directly from you Data Brokers | To provide our products and services For marketing purposes For analytics, research and development, or to otherwise improve our business To comply with applicable laws and regulations To detect and protect against malicious, deceptive, fraudulent or illegal activity To consider you for employment at our company In connection with your employment with us |
Commercial information, including records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies | Directly from you Service Providers that help us to run our business Affiliates, Agents, and Insurance Brokers Data Analytics Providers Ad Networks, Social Media Platforms, and other marketing or advertising partners Data Brokers | To provide our products and services To support our websites and mobile apps, including customizing your user experience For marketing purposes To show you relevant ads while you browse the internet or use social media For analytics, research and development, or to otherwise improve our business To comply with applicable laws and regulations To detect and protect against malicious, deceptive, fraudulent or illegal activity In connection with your employment with us |
Internet or other electronic network activity information, including browsing history, search history, and information regarding your interactions with our websites, applications, or advertisements | Automatically when you use our websites or mobile apps Service Providers that help us to run our business Data Analytics Providers Ad Networks, Social Media Platforms, and other marketing or advertising partners | To support our websites and mobile apps, including customizing your user experience For marketing purposes To show you relevant ads while you browse the internet or use social media For analytics, research and development, or to otherwise improve our business To detect and protect against malicious, deceptive, fraudulent or illegal activity To consider you for employment at our company In connection with your employment with us |
Geolocation data | Automatically when you use our websites or mobile apps Ad Networks, Social Media Platforms, and other marketing or advertising partners Directly from you. If you are enrolled in our voluntary Â鶹Çø Auto telematics program and use the Â鶹Çø Co-Pilot App or if you are enrolled in the Â鶹Çø Auto Commercial telematics program and use the Telematics-Â鶹Çø Commercial App, we will collect information about your driving style and habits, such as your location, speed, acceleration, braking, cornering, device ID, device model and carrier information.
| To provide our products and services To support our websites and mobile apps, including customizing your user experience For marketing purposes To show you relevant ads while you browse the internet or use social media For analytics, research and development, or to otherwise improve our business To detect and protect against malicious, deceptive, fraudulent or illegal activity To consider you for employment at our company In connection with your employment with us |
Audio, electronic, visual, thermal, olfactory, or similar information, including photographs, audio, and video recordings | Directly from you (e.g., when you speak with us on a recorded phone line or engage with us via teleconferencing) | To provide our products and services To communicate with you For analytics, research and development, or to otherwise improve our business To detect and protect against malicious, deceptive, fraudulent or illegal activity To consider you for employment at our company In connection with your employment with us |
Professional or employment-related information Recruitment information (such as skills, qualifications, references, recommendations, and other information included in a CV, application form, or cover letter); Information relating to professional licenses, training, disciplinary actions, and membership in professional organizations; Onboarding and human resources records (including engagement documents, employment contracts, start date, job positions/titles, department, usernames and passwords used to access our systems, work history, working hours/time sheets, training records, and professional memberships); Details of salary, bonus, benefits, payroll records; retirement plan information (including details of your retirement accounts); Medical, parental, family, vacation, and other leave and associated records, including details of the types of and reasons for leave being taken, duration of leave, and leave-related correspondence; Performance and appraisal information, including performance improvement plans, targets, and objectives; Training records; Disciplinary and grievance information; Any termination of employment documentation, including resignation letters, dismissal letters, minutes of meetings, settlement agreements and related correspondence.
| Directly from you | To provide our products and services To communicate with you To facilitate services you provide as a B2B Contact For marketing purposes To show you relevant ads while you browse the internet or use social media For analytics, research and development, or to otherwise improve our business To comply with applicable laws and regulations To detect and protect against malicious, deceptive, fraudulent or illegal activity To consider you for employment at our company In connection with your employment with us |
Inferences used to create a profile reflecting someone’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes | Drawn from the other categories of Personal Information we collect Data Analytics Providers Ad Networks, Social Media Platforms, and other marketing or advertising partners Data Brokers | To support our websites and mobile apps, including customizing your user experience For marketing purposes To show you relevant ads while you browse the internet or use social media For analytics, research and development, or to otherwise improve our business To detect and protect against malicious, deceptive, fraudulent or illegal activity To consider you for employment at our company In connection with your employment with us |
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​The categories of PI we may collect include the following categories of Sensitive PI:
Category of Sensitive Personal Information | Categories of Sources from which Information was Collected | Purposes for Collection |
Personal Information that reveals a person’s Social Security, driver’s license, state identification card, or passport number | Directly from you
| To provide our products and services To comply with applicable laws and regulations To detect and protect against malicious, deceptive, fraudulent or illegal activity To consider you for employment at our company In connection with your employment with us |
Personal Information that reveals an account log-in, financial account, debit card, or credit card number in combination with any required security or access code, password, or credentials allowing access to an account | Directly from you
| To provide our products and services To detect and protect against malicious, deceptive, fraudulent or illegal activity To consider you for employment at our company In connection with your employment with us |
Precise geolocation (location within a radius of 1,850 feet). | Automatically when you use our website and mobile apps Directly from you. If you are enrolled in our voluntary Â鶹Çø Auto telematics program and use the Â鶹Çø Co-Pilot App or if you are enrolled in the Â鶹Çø Auto Commercial telematics program and use the Telematics-Â鶹Çø Commercial App, we will collect information about your driving style and habits, such as your location, speed, acceleration, braking, cornering, device ID, device model and carrier information. | To provide our products and services To detect and protect against malicious, deceptive, fraudulent or illegal activity
|
Personal Information collected and analyzed concerning a person’s health | Directly from you | To provide our products and services In connection with your employment with us |
How Long We Keep Your Personal Information
We keep the categories of Personal Information described above for as long as necessary or permitted for the purposes described in this Notice or otherwise authorized by law. This generally means holding PI for as long as one of the following apply:
- Your PI is reasonably necessary to manage our operations, to manage your relationship with us, or to satisfy another purpose for which we collected the information;
Your PI is reasonably necessary to carry out a disclosed purpose that is reasonably compatible with the context in which the PI was collected;
The PI is reasonably necessary to protect or defend our rights or property (which will generally relate to applicable laws that limit actions in a particular case); or
We are otherwise required or permitted to keep your information by applicable laws or regulations.
Where PI is used for more than one purpose, we will retain it until the purpose with the latest period expires. For more information about our retention policies, please contact us using the contact details below.
How We Disclose, Share, and Sell Personal Information
We may disclose Personal Information as indicated below. The first chart shows the categories of Personal Information we disclose to our service providers and contractors for a business or commercial purpose. Although we do not sell Personal Information in exchange for money, some of our advertising practices or other disclosures of PI to third parties under circumstances where the third parties may use the information for their own purposes may be classified as “sales†or “sharing†under California law. The second chart shows the categories of Personal Information we may share for purposes of cross-context behavioral advertising or otherwise “sell,†as that term is defined under California law. We do not have actual knowledge that we sell or share the PI of California residents under 16 years of age.
Disclosures for a Business or Commercial Purpose
Category of Personal Information | Categories of Recipients to which Information was Disclosed | Purposes for Disclosure | |
Personal Information | |||
| Identifiers | Service Providers that help us to run our business (e.g., financial institutions and payment processors, technical support, analytics, communications and marketing services, promotions, call centers, web hosting and monitoring services, and event-related services, among other) Government entities Affiliates, Agents, and Insurance Brokers | Providing our products and services Processing payments Communicating with you Supporting our websites and mobile apps, including debugging and repair of errors Registration for events, memberships, accounts, etc. Marketing and advertising (except for cross-context behavioral advertising) Short-term, transient use, including, but not limited to, non-personalized advertising For analytics, research and development, or to otherwise improve our business Ensuring security and integrity, and to detect and protect against malicious, deceptive, fraudulent or illegal activity To comply with applicable laws and regulations Relating to hiring and employment |
Personal records | Service Providers that help us to run our business (e.g., financial institutions and payment processors, technical support, analytics, communications and marketing services, promotions, call centers, web hosting and monitoring services, and event-related services, among other) Government entities Affiliates, Agents, and Insurance Brokers | Providing our products and services Processing payments Communicating with you Supporting our websites and mobile apps, including debugging and repair of errors Registration for events, memberships, accounts, etc. Marketing and advertising (except for cross-context behavioral advertising) Short-term, transient use, including, but not limited to, non-personalized advertising For analytics, research and development, or to otherwise improve our business Ensuring security and integrity, and to detect and protect against malicious, deceptive, fraudulent or illegal activity To comply with applicable laws and regulations Relating to hiring and employment | |
Characteristics of protected classifications | Government entities Affiliates, Agents, and Insurance Brokers | Providing our products and services To comply with applicable laws and regulations Relating to hiring and employment | |
Commercial information | Service Providers that help us to run our business (e.g., financial institutions and payment processors, analytics, communications and marketing services, promotions, call centers, and event-related services, among other) Government entities Affiliates, Agents, and Insurance Brokers | Providing our products and services Processing payments Communicating with you Registration for events, memberships, accounts, etc. Marketing and advertising (except for cross-context behavioral advertising) Short-term, transient use, including, but not limited to, non-personalized advertising For analytics, research and development, or to otherwise improve our business Ensuring security and integrity, and to detect and protect against malicious, deceptive, fraudulent or illegal activity To comply with applicable laws and regulations Relating to hiring and employment | |
Internet or other electronic network activity information | Service Providers that help us to run our business (e.g., technical support, analytics, communications and marketing services, promotions, and web hosting and monitoring services) Operating systems, internet service providers, and platforms Affiliates, Agents, and Insurance Brokers | Supporting our websites and mobile apps, including debugging and repair of errors Marketing and advertising (except for cross-context behavioral advertising) Short-term, transient use, including, but not limited to, non-personalized advertising For analytics, research and development, or to otherwise improve our business Ensuring security and integrity, and to detect and protect against malicious, deceptive, fraudulent or illegal activity Relating to hiring and employment | |
| Geolocation | Service Providers that help us to run our business (e.g., technical support, analytics, communications and marketing services, and web hosting and monitoring services, among other) Government entities Affiliates, Agents, and Insurance Brokers | Supporting our websites and mobile apps, including debugging and repair of errors Marketing and advertising (except for cross-context behavioral advertising) Short-term, transient use, including, but not limited to, non-personalized advertising For analytics, research and development, or to otherwise improve our business Ensuring security and integrity, and to detect and protect against malicious, deceptive, fraudulent or illegal activity Relating to hiring and employment |
| Audio, electronic, visual, thermal, olfactory, or similar information | Service Providers that help us to run our business (e.g., technical support, analytics, communications and marketing services, promotions, call centers, and event-related services, among other) Government entities Affiliates, Agents, and Insurance Brokers | Providing our products and services Communicating with you Registration for events, memberships, accounts, etc. Marketing and advertising (except for cross-context behavioral advertising) Short-term, transient use, including, but not limited to, non-personalized advertising For analytics, research and development, or to otherwise improve our business Ensuring security and integrity, and to detect and protect against malicious, deceptive, fraudulent or illegal activity To comply with applicable laws and regulations Relating to hiring and employment |
| Professional or employment-related information | Service Providers that help us to run our business (e.g., financial institutions and payment processors, technical support, analytics, communications and marketing services, promotions, call centers, and event-related services, among other) Government entities Affiliates, Agents, and Insurance Brokers | Providing our products and services Communicating with you Registration for events, memberships, accounts, etc. Marketing and advertising (except for cross-context behavioral advertising) Short-term, transient use, including, but not limited to, non-personalized advertising For analytics, research and development, or to otherwise improve our business Ensuring security and integrity, and to detect and protect against malicious, deceptive, fraudulent or illegal activity To comply with applicable laws and regulations Relating to hiring and employment |
Sensitive Personal Information | |||
| Social security, driver’s license, state identification card, or passport number | Service Providers that help us to run our business (e.g., financial institutions and payment processors) Government entities Affiliates, Agents, and Insurance Brokers
| Providing our products and services Ensuring security and integrity, and to detect and protect against malicious, deceptive, fraudulent or illegal activity To comply with applicable laws and regulations Relating to hiring and employment |
Account log-in, financial account, debit card, or credit card number in combination with any required security or access code, password, or credentials allowing access to an account | Service Providers that help us to run our business (e.g., technical support, and web hosting and monitoring services) | Supporting our websites and mobile apps, including debugging and repair of errors Ensuring security and integrity, and to detect and protect against malicious, deceptive, fraudulent or illegal activity Relating to hiring and employment | |
Precise geolocation | Service Providers that help us to run our business (e.g., technical support, analytics, and web hosting and monitoring services) | Providing our products and services Supporting our websites and mobile apps, including debugging and repair of errors Ensuring security and integrity, and to detect and protect against malicious, deceptive, fraudulent or illegal activity Relating to hiring and employment | |
| Personal Information collected and analyzed concerning a person’s health | Service Providers that help us to run our business Affiliates, Agents, and Insurance Brokers | Providing our products and services Ensuring security and integrity, and to detect and protect against malicious, deceptive, fraudulent or illegal activity |
Sale and Sharing of Personal Information
Category of Personal Information | Categories of Third Parties to which Information was Sold or Shared | Purposes for Selling / Sharing |
Identifiers | Ad networks, search and social media platforms, and other online advertising partners | Cross-context behavioral advertising |
Commercial information | ||
Internet or other electronic network activity information | ||
Geolocation data |
Rights Relating to Your Personal Information
If you are a California Consumer, a Â鶹Çø Job Applicant, employee or B2B Contact, you have the right to submit requests related to your PI as described below.
Right to Know. You have the right to know what Personal Information we have collected about you, which includes:
- The categories of Personal Information we have collected about you, including
The categories of sources from which the Personal Information was collected
Our business or commercial purposes for collecting, selling, or sharing Personal Information
The categories of recipients to which we disclose Personal Information
The categories of Personal Information that we sold, and for each category identified, the categories of third parties to which we sold that particular category of Personal Information
The categories of Personal Information that we disclosed for a business purpose, and for each category identified, the categories of recipients to which we disclosed that particular category of Personal Information
A copy of the specific pieces of Personal Information we have collected about you
How to Request Deletion. You have the right, subject to certain conditions and exceptions, to request that we delete your PI that we have collected directly from you and are maintaining. If you prefer to exercise more limited control of your PI, you may cancel or modify the email marketing communications you receive from us by following the instructions contained within our promotional emails.
How to Request Correction of Inaccurate Information. If you believe that Personal Information we maintain about you is inaccurate, you have the right, subject to certain restrictions, to request that we correct that information.
Right to Opt Out of Sales and Sharing of Personal Information. The CCPA gives you the right to opt out of the sale of your PI and to request that we do not share your PI for cross-context behavioral advertising purposes. To opt-out, please click on the following link /?otgeo=us,ca. If you choose to use the Global Privacy Control (GPC) browser signal, you will be opted out of cookie-based sales or sharing of Personal Information, and will need to turn it on for each browser you use. To submit a request to opt out of offline sales and sharing, please use our webform: /form/privacyrights-form
Right to Limit Use and Disclosure of Sensitive Personal Information. You may direct us to limit the use and disclosure of your Sensitive Personal Information to uses/disclosures that are reasonably necessary to provide our products and services, or as needed: to ensure security and integrity; to prevent fraud or illegal activity; for physical safety; for short-term, transient use, including for non-personalized advertising; to perform services on behalf of the business; and to verify or maintain the quality or safety of a service or device owned, manufactured, manufactured for, or controlled by us, and to improve, upgrade, or enhance such services or devices. To limit our use of your Sensitive Personal Information, please click here /form/privacyrights-form
Right to Non-Discrimination for the Exercise of Your Privacy Rights. If you choose to exercise any of your privacy rights under the CCPA, you will not receive discriminatory treatment by us.
How to Exercise Your Rights
Directly. To exercise any of the rights outlined in the preceding section, please use:
our webform /form/privacyrights-form, or
call our toll-free number, 800-790-3340
Through An Authorized Agent. An authorized agent may submit a request on your behalf using the webform or toll-free number listed above. We may require the authorized agent to provide proof that you gave the agent signed permission to submit the request. Depending on the type of request, we may also require that you either verify your identity directly with us or directly confirm with us that you provided the authorized agent permission to submit the request.
Verification Process. Whether you submit your request to us directly or through an authorized agent, we must first verify your identity. The information we need to verify your identity will differ depending on the type of request and our relationship with you. Please note that, if you submit a request to know, request to delete, or request to correct, you may be asked to log into your account if you already have an account with us, or to provide PI that we will match against our records to verify your identity. In some cases, we may also use third-party identity verification services to verify your identity.
How to Contact Us
If you have questions regarding this Policy or the CCPA Notice, you can contact us by email at privacy@kemper.com. If you prefer to write, our address is Â鶹Çø Privacy Team, 200 East Randolph Street, Suite 3300, Chicago, IL 60601.