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EU–US Privacy Shield Framework Statement

Coalition, Inc. ("Coalition", "we", "us", or "our") complies with the EU-U.S. Privacy Shield framework ("Privacy Shield") regarding the collection, use, and retention of personal information transferred from the European Union and the United Kingdom to the United States. For more information on the EU-U.S. Privacy Shield and to view our certification, please visit the U.S. Department of Commerce's Privacy Shield website here .
We commit to periodically review and verify the accuracy of our policies and our compliance with the EU-U.S. Privacy Shield Framework. If there is any conflict between our Policy (including this Framework Statement), the principles of the EU-U.S. Privacy Shield shall govern where applicable.

Scope

We adhere to the principles of the EU-U.S. Privacy Shield framework with respect to personal data provided by: (i) visitors to our website and (ii) users of our services (i.e., insurance policyholders and users of our applications). We use this data, where applicable, to: (i) communicate directly with website visitors; (ii) administer insurance policies and process claims on behalf of our policyholders, including the transfer of information to 3rd parties who may do the same on our behalf; (iii) 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; (iv) 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; (v) provide customized 3rd party advertisements, content, and information; (vi) monitor and analyze the effectiveness of our services and 3rd party marketing activities; (vii) monitor aggregate site usage metrics such as total number of visitors and pages viewed; and (viii) comply with legal and contractual requirements.

Choice

We will offer you the opportunity to choose (opt out) whether your personal data is (i) to be disclosed to 3rd parties, except when disclosure is made to a 3rd party that is acting as an agent to perform task(s) on our behalf and under our instructions or (ii) to be used for a purpose that is materially different from the purpose for which it was originally collected or subsequently authorized by you. We will provide you with clear, conspicuous, and readily available mechanisms to exercise your choices should applicable circumstances arise. To request that Coalition not use your personal data or opt out of marketing messages from Coalition, you should contact Coalition at  [email protected] .

Disclosure and Accountability of Onward Transfer

We may use 3rd party service providers to assist us in providing services to our customers or as required for our internal business needs. These providers may provide services such as billing systems, contract and account management, customer support, relationship management, claims support, and other technical operations. These 3rd parties may access, process, or store personal data in the course of providing their services. We maintain contracts with these 3rd parties to restrict their access, use, and disclosure of personal data in compliance with our Privacy Shield obligations.

Pursuant to the Privacy Shield Principles, Coalition remains accountable for personal data that we receive under the Privacy Shield and subsequently transfer to a 3rd party. In particular, we remain responsible and liable under the Privacy Shield Principles if 3rd parties we engage to process personal data on our behalf do so in a manner inconsistent with the Privacy Shield Principles, unless we prove we are not responsible for the event giving rise to the damage.

Security

We are committed to securing all personal data provided to us. We have deployed and maintain reasonable and appropriate process and technology measures to provide reasonable assurance that your personal data is secured against loss, misuse and unauthorized access, disclosure, alteration, and/or destruction.

Data Integrity and Purpose Limitation

Consistent with the Privacy Shield Principles, we limit collection of personal data to the information that is relevant for the purposes of processing and will not process such personal data in a way that is incompatible with the purposes for which it has been collected or subsequently authorized by you. We also take reasonable steps to ensure that personal data is reliable for its intended use, accurate, complete, and current. To accomplish this, we also rely on you exercising your access rights to keep us apprised of any changes in your personal data.

Rights to Access

Upon request, we will grant individuals reasonable access to personal data that we hold about them. In addition, we will take reasonable steps to permit individuals to correct, amend, or delete information where it is inaccurate, or has been processed in violation of the Privacy Shield Principles.

We will process all reasonable requests for access within a reasonable time period, but reserve the right to restrict access in cases where the legitimate rights of persons other than the individual would be violated or where the burden or cost of providing access would be disproportionate to the risks to the individual's privacy.

Enforcement and Required Disclosure

Our commitments under the Privacy Shield framework are subject to the investigatory and enforcement powers of the U.S. Federal Trade Commission. We may be required to disclose personal data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements. Under such circumstances, we may be prohibited by law, court order, or other legal process from providing notice of disclosure.

Contact Information, Inquiries, and Complaints

If you believe that we maintain copies of your personal data within the scope of the EU-U.S. Privacy Shield framework, you may direct any inquiries below:

Attention: Trust and Compliance
Coalition, Inc. 
1160 Battery St., Ste 350
San Francisco, CA 94111
[email protected]

We will respond to your inquiry within 45 days of receipt and verification of your identity. If we fail to respond during that time, or if you have an unresolved privacy or data use concern that we have not addressed satisfactorily, please contact our 3rd party dispute resolution provider (free of charge) at https://www.jamsadr.com/about/submit-a-case . If neither we nor our 3rd party dispute resolution provider are able to resolve your complaint, as a last resort you may engage in binding arbitration through the Privacy Shield Panel.

Effective Date:

This Policy was last updated on September 4, 2019.

Coalition’s products are offered with the financial security of Swiss Re Corporate Solutions* (A.M. Best A+ rating), Lloyd’s of London** (A.M. Best A+ rating), and Argo Pro US*** (A.M. Best A rating).
WHAT WE DO
© 2019 Coalition, Inc. | Licensed in all 50 states and D.C. | CA License # 0L76155
*Insurance products may be underwritten by North American Capacity Insurance Company, North American Specialty Insurance Company, or an affiliated company, which are members of Swiss Re Corporate Solutions. **Insurance products may be underwritten by Certain Underwriters at Lloyd's of London. ***Insurance products may be underwritten by Peleus Insurance Company, Colony Specialty Insurance Company, or an affiliated company, which are members of Argo Group US, Inc.