Last updated: April 14, 2020
This Coalition Privacy & Security Policy ("Policy") outlines the general policy and practices for the types of information that Coalition, Inc. ("Coalition", "we", "us", or "our") collects from you when you access or use our applications (online or mobile) and websites (the “Platform”) on which this Policy appears, including all products and services provided therein (together with the Platform, the "Services"), how we use and disclose that information, and the options that our users ("you" or "your") have regarding our collection, use, and disclosure of, and your ability to access and correct, such information. As an insurance agency, Coalition is regulated by federal and state/provincial/territorial laws that protect your information and our use and disclosure of it. Your access to and use of our Services is subject to the Terms of Service located at www.coalitioninc.com/en-ca/legal/terms. If you do not agree to our Terms of Service or this Policy, please do not access or otherwise use our Services or any information contained herein.
For the purposes of this Policy, “personal information” means personally identifiable information, which is information about an identifiable individual.
It is our overriding privacy principle that any personal information provided to us by you is just that: personal and private. As such, we will never sell, rent, share, or otherwise disclose your personal information to anyone except to provide our Services or as otherwise described in this Policy, without providing explicit notice of such to you, obtaining your consent, and providing you with the ability to opt-out. Please note that our Services may require us to share and disclose your personal information for the purposes of underwriting (re)insurance.
If you have any privacy or data use concerns, please contact us as set out below under the heading “Contact Information”. If you have an unresolved privacy or data use concern that we have not addressed satisfactorily, please contact our U.S.-based 3rd party dispute resolution provider (free of charge) at https://www.jamsadr.com/about/submit-a-case.
This Policy applies to information provided to us by: (i) visitors to our Platform and (ii) users of our Services (i.e., policyholders, insurance agents and brokers, and subscribers to any of our Services). This Policy does not apply to our users' websites, applications, or other platforms or those to which we provide links, which may have their own privacy policies. Because of this, we strongly encourage awareness and understanding of such platform’s separate privacy policies.
Coalition's Platform and Services are not intended for, nor designed to attract, individuals under the age of majority in their jurisdiction of residence. Coalition does not knowingly collect personal information from any person who is under the age of majority in their jurisdiction of residence. If it comes to our attention through reliable means that a registered user is under the age of majority in their jurisdiction of residence, we will cancel that user's account and/or access to our Services.
Coalition collects a variety of information that will aid us in quoting and servicing your insurance policy and providing our Services to you. This information includes "nonpublic personal information", which is all information that identifies you and is not available to the general public or information that is not publicly available information as prescribed by applicable law.
We collect this information through your insurance policy application information, your communications with us, your transactions, and your use of our Services.
Here are some examples of the information we get:
Application and Communications:
Through our Platform and provided Services, we gather information such as your name, address, corporate information, phone number, occupational information, former insurance information, domain name(s), and claims history, as well as other information that you may provide through other communication features of our Services.
Through your transactions with us, we gather information such as insurance coverage, payments and claims history, and payment instrument information, such as credit card or banking information. However, we do not store full credit card numbers or personal account numbers (“PANs”).
Like most online services, when you use our Services, we may automatically collect certain information about your visit and store it in log files, such as the app or website and/or search criteria that led you to our Services, your Internet Protocol address ("IP Address"), UDID, or other device address or ID, device type, operating system, browser information, and what pages you visit when using our Services, and the web pages or sites that you visit just before or just after using the Services. We do not link this automatically-collected data to other personal information we collect about you.
Coalition and our partners (such as our marketing partners), affiliates, or analytics or service providers (such as our live chat feature provider), use technologies such as cookies, beacons, tags, and scripts, to analyze trends, administer the Platform, track users' movements around the Platform, and to gather demographic information about our user base as a whole. We may receive reports based on the use of these technologies by these companies on an individual and aggregated basis.
3rd Party Technology:
We and 3rd parties with whom we partner to provide certain features on our Platform or to display advertising based upon your web browsing activity, use locally shared objects (“LSOs”) or flash cookies to collect and store information. Various browsers may offer their own management tools for removing HTML5 LSOs. If you wish to opt-out of targeted advertising, see “Online Advertising” below.
Information From Referrals:
If you choose to use our referral service to tell someone about our Services, we will ask you for their name and email address. We will automatically send them a one-time invitation email to visit the Platform and provide your name as the person who made the referral, and a one-time reminder if permitted by applicable law. Coalition stores this information for the sole purpose of sending the invitation and reminder email (if applicable), and for tracking the success of our referral program. Any recipient of an invitation may contact us at [email protected] to request that we remove this information from our database.
Coalition uses the information you provide or that we collect to develop, operate, maintain, enhance, and provide all of our features and Services now and in the future, and to service your account with us, including the following:
We will use your email address to contact you for administrative purposes, for customer service purposes, or regarding your use of our services.
We use the information that you provide or that we collect to understand and analyze the usage trends and preferences of our users, to improve the way our services work and look, and to create new features and functionality.
We may use information to: (a) personalize our Services, such as remembering your information so that you will not have to re-enter it during your visit or the next time you use our Services; (b) provide customized 3rd party advertisements, content, and information in accordance with applicable law; (c) monitor and analyze the effectiveness of our Services and 3rd party marketing activities; and (d) monitor aggregate Platform usage metrics such as total number of visitors and pages viewed.
Coalition is the responsible party for the personal information collected on this Platform and through any Coalition Service. In order for us to provide some of our Services we may also provide personal information that you supply to us to our affiliates, vendors and service providers, which we use for billing systems, contract and account management, customer support, claims support, relationship management, and other service and technical operations. Such disclosures include:
Disclosures In Connection with Claims:
We may disclose your personal information to insurers, their agents and representatives, claims representatives, insurance agents, law enforcement agencies, courts, and government agencies. These parties may disclose personal information to other parties as permitted by law in order to process and/or investigate your insurance claims.
Coalition collects and maintains certain personal information from our users for the purposes of billing. We may share this information with 3rd party processors for the limited purpose of receiving payment. Your payment information is collected and stored by your broker or a 3rd party payment provider (as applicable) and is subject to their respective privacy policies and practices. Your payment information is not disclosed to, or shared with, Coalition.
3rd Party Service Providers:
Coalition works with other 3rd party service providers in the U.S. and other jurisdictions to provide website development, hosting, maintenance, transcription, marketing, and support as well as other business services for us. To the extent it is necessary for these service providers to complete their work, these 3rd parties may have access to or process your personal information. Such users are required to agree to limit their use of the information for the purpose for which it was provided or to seek your consent for any additional purposes.
Coalition may aggregate data we acquire about our users. For example, we may aggregate data to determine if particular software used by our users is susceptible to exploitation. If we aggregate this sort of data and provide it to external parties, our users' personal information will not be attached to or included in such aggregated data. Please note, data that our users provide to us, including data collected in our underwriting process, may be included in the aggregate data, reports, and statistics.
In such cases, we will try to ensure that such entities are bound by appropriate confidentiality restrictions to protect the personal information covered by this Policy.
We do not sell, rent, or share personal information with 3rd parties for their direct marketing purposes, including as defined under California Civil Code Sec. 1798.83.
California Civil Code section 1798.83 also permits Coalition users who are California residents to request certain information regarding Coalition's disclosure within the immediately preceding calendar year of that California resident's personal information to 3rd parties and in some cases affiliates for their direct marketing purposes. To make such a request, use the information provided in the "Contact Information" section at the bottom of this Policy. Any such inquiry must include "California Privacy Rights Request" in the first line of the inquiry.
From time-to-time, Coalition may notify you about an offer from one of our promotional partners (e.g., Apps Marketplace partners) via our Platform or email. While we may target particular types of users for these offers, we do all of the targeting within our systems and not externally. Our partners will not have any access to the targeting information, including the names of the people who may be interested in a particular product or service. Until you affirmatively respond to a promotional offer, we will not share any identifying information about you with any of these partners. If you do affirmatively respond to a promotional offer, we will share your personal information (such as your name, company name, business email address, etc.) with the applicable partner to allow them to respond to the affirmative response.
If you install an app from one of our 3rd party partners, Coalition may provide your email address to that partner for account creation and communication with that partner.
Coalition may, now or in the future, allow you to link your account on the Platform to your account(s) on 3rd party services, such as social networking sites ("Linked Accounts"). If you link your account on the Platform to a Linked Account, you are authorizing Coalition to store and use your access credentials to access your Linked Account on your behalf as your agent to integrate your experience with the Platform with content, information, and features available through such Linked Account. This may include importing the contacts, preferences, interests or "likes" of the Linked Account, and/or pushing updates regarding your use of the Services out to your Linked Accounts. Linking, accessing, or using a 3rd party service through the Platform in this manner may be subject to additional terms and privacy policies established by the applicable 3rd party, and it is your sole responsibility to comply with such 3rd party terms and familiarize yourself with such privacy policies.
Our Platform offers publicly accessible blogs. You should be aware that any information you provide in these areas may be read, collected, and used by others who access them so care should be taken when posting any personal information. To request removal of your personal information from our blog, contact us at [email protected]. In some cases, we may not be able to remove your personal information, in which case we will let you know if we are unable to do so and why.
We display personal testimonials of satisfied customers on our Platform in addition to other endorsements. We may post your testimonial along with your name and employer name. If you wish to update or delete your testimonial, you can contact us at [email protected].
In the event that all or a portion of Coalition or its assets are acquired by or merged with a 3rd party entity, we reserve the right, in any of these circumstances, to share, transfer, or assign the information that we have collected from users, including personal information and user data in connection with such prospective or completed merger, acquisition, sale, or other change of control, in accordance with applicable law.
We reserve the right to disclose your information that we believe is reasonable, appropriate, or necessary to take precautions against liability; to protect Coalition and others from fraudulent, abusive, predatory, or unlawful uses or activity; to investigate and defend ourselves against any 3rd party claims or allegations; to assist government enforcement agencies; to protect the security or integrity of our Services; or to protect or vindicate the rights, property, or personal safety of Coalition, our users, or others. In addition, we may be required by law, court order, or other legal process to provide information about our customers to outside parties. It is our policy to ensure adherence to the due process of law in all such instances, and if we are required to provide information under these circumstances, we will, whenever possible, attempt to inform users whose information we are compelled to produce, unless prohibited by law.
We may also retain copies of personal information to comply with our legal obligations, pursuant to our data retention policies, or for such reasonable period as is required to address potential disputes.
We take commercially reasonable steps to protect information we receive from our users from loss, misuse or unauthorized access, disclosure, alteration, and/or destruction. We have put in place physical, technological, and administrative procedures designed to safeguard and secure such information; however, no Internet or email transmission is ever fully secure or error free. Therefore, you should take special care in deciding what information you send to us in connection with our Services.
We allow our users access to their own personal information, and allow them to correct, amend, or delete inaccurate personal information. There may be exceptions to such access in accordance with applicable law, including: (a) where the burden or expense of providing such access is disproportionate to the individual privacy risk or such information is prohibitively costly to provide; (b) where the rights of persons other than the requesting individual risk being violated; (c) where the information cannot be disclosed for legal, security, or commercial proprietary reasons; or (d) where the information is subject to solicitor-client or litigation privilege.
If you are a Coalition policyholder, we may contact you regarding your policy, such as billing notices and confirmations of changes, by mail or through email. We will also use your email address to provide you with updates about our products and services in accordance with applicable law. We may also contact you by phone regarding timely matters such as late payment or other factors that might affect your policy.
When you register for an account, we will use your name and email address to send periodic emails to you of both promotional and transactional nature in accordance with applicable law. You may choose to stop receiving promotional emails by following the unsubscribe instructions included in these emails or you can contact us at [email protected].
If you are visiting our Platform from outside the United States, please be aware that your information may be transferred to, stored, and processed in the United States where our servers are located and our central database is operated. As a result, your personal information may be subject to the laws of the United States and may be accessible without notice to you by the courts, law enforcement, and national security authorities of the United States.
ACCESSING OR USING OUR SITES OR SERVICES, OR OTHERWISE PROVIDING INFORMATION TO US, CONSTITUTES CONSENTING TO OUR POTENTIAL TRANSFER, PROCESSING, AND STORAGE OF SUCH INFORMATION IN THE UNITED STATES.
We take the trust and privacy of our customers extremely seriously, and do not believe that we will need to change the core principles set forth in this Policy going forward. However, if we are required to modify this Policy, we will promptly provide notice of any material changes and post the modified Policy on this Platform along with the effective date of any necessary edits, as indicated by the “Last updated” date at the top of this Policy.
We make information about our privacy policies and practices available. If you have any concerns, complaints, or if you would like further information regarding our privacy policies or practices, including with respect to our use of service providers outside of the United States and Canada, please contact our Privacy Officer as set out below.
Attention: Trust and Compliance
1160 Battery St., Ste 350
San Francisco, CA 94111