Privacy Policy

California Privacy Policy

Additional Privacy Notice

California Privacy Policy

Notice To California Consumers

We provide the following Privacy Notice (“Notice”) in accordance with the California Consumer Privacy Act of 2018, as amended, (“CCPA”) to give California consumers information about how we collect, use and disclose their personal information, and about the rights and choices we offer California consumers regarding our processing of their personal information.

Bold terms throughout this Notice are used as defined in the CCPA.

WHO WE ARE

Cross Current Insurance Group LLC and its subsidiary companies (“we”, “us” or “CCIG”) provide insurance brokerage and consulting products and services, as well as other financial services and products, to corporate and individual clients.

This Notice describes how CCIG collects, handles and otherwise processes personal information in relation to your use of any of the services, websites and apps we offer (collectively, the “Services”). The Notice is a statement of our practices and of rights regarding your personal information and is not a contractual document, and does not create any rights or obligations on either party, beyond those which already exist under data protection laws. This Notice is intended to meet the requirements of the CCPA as amended. Bolded terms not otherwise defined in this Notice have the same meaning as set forth under the CCPA.

This Notice covers those applicable Services offered by CCIG in California to consumers and their households, however this Notice does not apply, and excludes Services of our companies, as follows:

For our offices and operations conducted outside of California
For our offices and operations with separate privacy policies or that do not incorporate this Notice
When we act as a business associate to covered entities in connection with receiving Protected Health Information as defined under the Health Information Portability and Accountability Act (“HIPAA”)
When we collect personal information subject to the Gramm Leach Bliley Act (“GLBA”), such as when you apply for, or obtain, a financial product or service from us
When we act as service provider since we are processing personal information only on behalf of our clients, often pursuant to a written engagement or formal broker of record engagement, and then only to provide our service pursuant to such engagement
To personal information that was collected from a consumer in connection with being a job applicant, employee or independent contractor

PERSONAL INFORMATION WE COLLECT, USE AND DISCLOSE

We collect personal information about California consumers as summarized in the table below. Where we disclose personal information, such as to our service providers, we do so for the same business purposes described below and where appropriate, require that such parties maintain its confidentiality and maintain appropriate systems and processes to ensure its security and protection. These examples may vary depending on the nature of your interactions with us.

Category	Examples	Sources	Business Purposes	Recipients
Identifiers	Name, postal address, IP address, email address, account name, social security number, driver’s license number, passport number	Consumer Business partners Clients	Providing Services Security Compliance & operations Research & development Quality control & audit	Business partners Our companies* Government entities Service Providers Operating systems and platforms Business/asset purchasers **
Customer/Individual Records	Name, address, telephone number, email address, signature, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, medical information, health insurance information	Consumer Business partners Clients	Providing Services Security Compliance & operations Research & development Quality control & audit	Business partners Our companies* Government entities Service Providers Operating systems and platforms Business/asset purchasers **
Protected Characteristics	Marital/familial status, race, religion, disabilities	Consumer Business partners Clients	Providing Services Security Compliance & operations Quality control & audit	Business partners Our companies* Government entities Service Providers Operating systems and platforms Business/asset purchasers **
Commercial Information / Purchase Details	Purchase history or tendencies	Consumer Business partners	Providing Services Compliance & operations Research & development	Business partners Service Providers Our companies* Business/asset purchasers **
Internet Usage Information	Browsing history, search history, information regarding interactions with our website or advertisements	Consumer	Security Compliance & operations Research & development Quality control & audit	Business partners Service Providers Our companies* Operating systems and platforms
Geolocation Data	Approximate location inferred from your device IP Address	Consumer	Providing Services Compliance & operations Research & development	Business partners Service Providers Our companies* Operating systems and platforms
Sensory Data	Audio recordings of customer service calls, CCTV footage	Consumer	Providing Services Security Compliance & operations Quality control & audit	Business partners Service Providers Our companies* Operating systems and platforms<br< td=”” style=”box-sizing: border-box; color: rgb(0, 0, 0);”></br<>
Professional or Employment Information	Professional, educational, or employment-related information	Consumer	Providing Services Security Compliance & operations Quality control & audit	Business partners Service Providers Our companies* Government entities
Inferences from PI Collected	Customer profiles reflecting preferences and predispositions	Consumer Business partners	Providing Services Research & development	Business partners Service Providers Our companies* Operating systems and platforms
Sensitive Personal Information	Social Security, driver’s license, state identification card, or passport number; Account log-in, financial account, geolocation; racial or ethnic origin, contents of a consumer’s mail, email, and text messages (unless the business is the intended recipient; genetic data); health information; sexual orientation.	Consumer Business partners Clients	Providing Services Security Compliance & operations Research & development Quality control & audit	Business partners Our companies* Government entities Service Providers Operating systems and platforms Business/asset purchasers **

* We work closely with other businesses and companies that fall under CCIG and its affiliates and subsidiaries, which may or may not be CCIG branded

** We will not disclose your personal information to others except to the extent reasonably necessary to proceed with the consideration, negotiation, or completion of a merger, reorganization, or acquisition of our companies’ business, or a sale, liquidation, or transfer of some or all of our companies’ assets. In these situations, we will use reasonable efforts to ensure any such purchaser uses personal information transferred in accordance with this Notice.

We do not sell personal information or share personal information for cross-context behavioral advertising, and have not done so in the past twelve (12) months.

Disclosure of Personal Information

We may disclose each of the categories of personal information identified above to the respectively identified categories of recipients for operational or business purposes consistent with the purposes for collection or use designated, as is reasonably necessary and proportionate to achieve those purposes, or for another purpose that is compatible with the context in which the personal information was collected, including:

Auditing our ads;
Helping to ensure security and integrity of your personal information;
Debugging, repairing, and improving functionality;
Short-term, transient use;
Performing services on our behalf;
Internal research for technological development; and
Verifying the quality and/or safety of our Services and infrastructure.

In addition to the other purposes for collection, use, and disclosure of personal information described in this Notice, we may collect, use and disclose personal information as required by law, regulation or court order; to respond to governmental and/or law enforcement requests; to identify, contact or bring legal action against someone who may be causing injury to or interfering with our or others’ rights or property; to support any actual or threatened claim, defense or declaration in a case or before any jurisdictional and/or administrative authority, arbitration or mediation panel; or in connection with disciplinary actions or investigations. Likewise, we may use and disclose personal information to other parties in connection with the sale, assignment, merger, reorganization, or other transfer.

Children’s Information

We do not knowingly collect or sell personal information of children under the age of 16. Our Services are marketed towards corporate entities and adults. If we are notified that we have collected personal information of a child under the age of 16, we will delete the information as quickly as possible.

CALIFORNIA CONSUMER PRIVACY RIGHTS

California consumers have the following rights regarding their own personal information. Please note that the CCPA limits these rights by, for example, prohibiting us from providing certain sensitive personal information in response to an access request and limiting the circumstances in which we must comply with a deletion request. If we deny your request, we will communicate our decision to you. To exercise any of these rights, please submit a request through our webform found on our website or call us at 860-598-8810. Please note that, if you submit a request to know, request to delete, or request to correct, you will be asked to verify your identity in accordance with the law. You may designate an authorized agent to make a request on your behalf; however, you may need to verify your identity directly with us before your request can be processed. An authorized agent may submit a request on your behalf using the webform or toll-free number listed above. We will never discriminate against you for choosing to exercise any of your privacy rights.

Right to Know. You have the right to know what personal information we have collected about you, which means you may ask for:

1. 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 and disclosing personal information;
  - the categories of recipients to which we disclose personal information; and/or
  - 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.
2. The specific pieces of personal information we have collected about you.

Right to Delete. You can request personal information be deleted.
Right to Correct. If you believe that personal information we have about you is inaccurate, you have the right to request that we correct that information.
Right to Opt Out of Sales and Sharing of Personal Information. We do not sell your personal information or share your personal information for cross-context behavioral advertising.
Right to Limit Use and Disclosure of Sensitive Personal Information. We do not use or disclose sensitive personal information for purposes to which the right to limit use and disclosure applies under the CCPA.

HOW WE STORE AND KEEP YOUR PERSONAL INFORMATION SECURE

We implement industry-standard technical, organizational, administrative and physical measures to help ensure a level of security appropriate to the risk to the personal information we collect, use, disclose and otherwise process. These measures are aimed at ensuring the on-going integrity and confidentiality of personal information. We evaluate these measures on a regular basis to help ensure the security of the processing. Please be aware that, despite our ongoing efforts, no security measures are perfect or impenetrable. We restrict access to your personal information to those who require access to such information for legitimate, relevant business purposes. We seek commitments of confidentiality, security and proper use from service providers we engage to process personal information.

We will keep your personal information for as long as we have a relationship with you. Once our relationship with you has come to an end, we will retain your personal information for a period that enables us to:

maintain business records for analysis and/or audit purposes;
comply with our record retention requirements under the law and our corporate policies;
defend against or bring any existing or potential legal claims; and/or
deal with any complaints regarding the Services.

We will delete your personal information when it is no longer required for these purposes. If there is any information that we are unable, for technical reasons, to delete entirely from our systems, we will put in place appropriate measures to prevent any further processing or use of the personal information.

CALIFORNIA’S SHINE THE LIGHT LAW

California law (referred to as the “Shine the Light” law) permits customers in California to request certain details about how their “personal information” (as defined by California Civil Code Section 1798.83/84) is disclosed to other parties for direct marketing purposes.

We do not disclose personal information to other parties for those parties’ own direct marketing purposes. Californians may request information about our compliance with this law and our personal information handling practices by contacting as set forth in the How to Contact Us section below.

Your inquiry must specify “California Privacy Rights Request – California Civil Code 1798.83/84 Request” in the subject line of the email or the first line of the letter, and include your name, street address, city, state and ZIP code.

Additional Privacy Notice

Facts	WHAT DOES CCIG DO WITH YOUR PERSONAL INFORMATION?
Why?	Financial companies choose how they share your personal information. Federal law gives consumers the right to limit some, but not all sharing. Federal law also requires us to tell you how we collect, share, and protect your personal information. Please read this notice carefully to understand what we do.
What?	The types of personal information we collect and share depend on the product or service you have with us. This information may include: Social Security Number Income Credit Based Insurance Scores Insurance Claim History Medical Information Employment Information When you are no longer our customer, we continue to share your information as described in this notice.
How?	All financial companies need to share customers’ personal information to run their everyday business. In the section below, we list the reasons financial companies can share their customers’ personal information; the reasons CCIG chooses to share; and whether you can limit this sharing.
Reasons we can share your personal information	Does CCIG share?	Can you limit this sharing?
For our everyday business purposes – such as to process your transactions, maintain your account(s), respond to court orders and legal investigations, or report to credit bureaus Yes No	Yes	No
For our marketing purposes – to offer our products and services to you	Yes	No
For joint marketing with other financial companies – Pursuant to a written contract pursuant to which CCIG and one or more financial institutions jointly offer, endorse or sponsor a financial product or service, to include insurance policies.	Yes	No
For our affiliates’ everyday business purposes – information about your transactions and experiences	Yes	No
For our affiliates’ everyday business purposes – information about your creditworthiness	No	We Don’t Share
For our affiliates to market to you	No	We Don’t Share
For non-affiliates to market to you	No	We Don’t Share

Questions? Call your broker or contact Cross Current Insurance Group LLC with our website contact form: https://crosscurrentinsurance.com/contact-cross-current/

Who we are

Who is providing this notice? CCIG on behalf of itself and the subsidiary that provide insurance brokerage and consulting services to clients.

What we do

How does CCIG protect my personal information?	To protect your personal information from unauthorized access and use, we use administrative, technical and physical safeguards as well as security measures that comply with applicable law. These measures include computer safeguards and secured files and buildings.
How does CCIG collect my personal information?	We collect your personal information, for example, when you apply for insurance pay insurance premiums file an insurance claim provide employment information give us your contact information We also collect your personal information from others, such as credit bureaus, affiliates, or other companies.
Why can’t I limit all sharing?	Federal law gives you the right to limit only sharing for affiliates’ everyday business purposes – information about your creditworthiness affiliates from using your information to market to you sharing for non-affiliates to market to you State laws and individual companies may give you additional rights to limit sharing. See below for more information on your rights under state law.

How does CCIG protect my personal information?

To protect your personal information from unauthorized access and use, we use administrative, technical and physical safeguards as well as security measures that comply with applicable law. These measures include computer safeguards and secured files and buildings.

How does CCIG collect my personal information?

We collect your personal information, for example, when you

apply for insurance
pay insurance premiums
file an insurance claim
provide employment information
give us your contact information

We also collect your personal information from others, such as credit bureaus, affiliates, or other companies.

Why can’t I limit all sharing?

Federal law gives you the right to limit only

sharing for affiliates’ everyday business purposes – information about your creditworthiness
affiliates from using your information to market to you
sharing for non-affiliates to market to you

State laws and individual companies may give you additional rights to limit sharing. See below for more information on your rights under state law.

Definitions

Affiliates	Companies related by common ownership or control. They can be financial and nonfinancial companies.
Non-affiliates	Companies not related by common ownership or control. They can be financial and nonfinancial companies. CCIG does not share with nonaffiliates so they can market to you.
Joint Marketing	A formal agreement between nonaffiliated financial companies that together market financial products or services to you. Our joint marketing partners include to insurance carriers, markets, intermediaries, wholesalers, brokers and other similar entities.

Affiliates

Companies related by common ownership or control. They can be financial and nonfinancial companies.

Non-affiliates

Companies not related by common ownership or control. They can be financial and nonfinancial companies.

CCIG does not share with nonaffiliates so they can market to you.

Joint Marketing

A formal agreement between nonaffiliated financial companies that together market financial products or services to you.

Our joint marketing partners include to insurance carriers, markets, intermediaries, wholesalers, brokers and other similar entities.

Other Important Information

For Insurance Customers in AZ, CA, CT, GA, IL, ME, MA, MN, MT, NV, NJ, NC, OH, OR and VA only: The term “Information” in this part means customer information obtained in an insurance transaction. We may give your Information to state insurance officials, law enforcement, group policy holders about claims experience or auditors as the law allows or requires. We may give your Information to insurance support companies that may keep it or give it to others. We may share medical Information so we can learn if you qualify for coverage, process claims or prevent fraud or if you say we can. To see your Information, contact Privacy Office, 1250 Capital of Texas Highway, Austin, TX 78746 Attn: Data Subject Request. You must state your full name, address, the insurance company, policy number (if relevant) and the Information you want. We will tell you what Information we have. You may see and copy the Information (unless privileged) at our office or ask that we mail you a copy for a fee. If you think any Information is wrong, you must write us. We will let you know what actions we take. If you do not agree with our actions, you may send us a statement.

For MA Insurance Customers only: You may ask in writing, for the specific reasons for an adverse underwriting decision. An adverse underwriting decision is where we decline your application for insurance, offer to insure you at a higher than standard rate or terminate your coverage.

Your Choices

If you no longer want to receive emails or marketing-related materials from us, you may opt out of receiving these materials by following the unsubscribe instructions in such messages or by contacting us as indicated in the “Contact Us” section below. Please note that even if you opt out of receiving promotional emails from us, we may continue to send you transactional or informational email communications.

Changes

We may modify or supplement this Privacy Policy from time to time, in which case we will post the updated Privacy Policy here and change the “last updated” date at the top of this page. You should check this page regularly to review changes to this Privacy Policy.

Your continued use of this Site after we have posted changes to this Privacy Policy will indicate that you agree with our changes. If any change to this Privacy Policy is unacceptable to you, please discontinue your use of the Site.

Contact Us

If you have questions regarding this Privacy Policy or our personal information handling practices, please contact the Cross Current Insurance Group LLC as follows:

Contact Form Page: https://crosscurrentinsurance.com/contact-cross-current/

Postal Address:
Cross Current Insurance Group LLC
PO Box 270060
West Hartford, CT 06127

Phone: 860-932-8082

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