Privacy Policy


Last Update: October 2015

Our Commitment to Privacy

This website located at www.cfpnet.com (the “Website”) is maintained by the California FAIR Plan Association (“CFP” or “we” or “us”). We respect the privacy of your information. By using our Website, you consent to the collection and use of your information in accordance with this Policy. The Privacy Policy covers people who visit the Website (“Visitors”), as well as individuals who are eligible to use CFP’s Adjuster/Broker portal on behalf of themselves or Applicants. (“Applicants/Policyholders”).

The Effective Date of the Privacy Policy is November 8, 2015.

What information do we collect?

CFP does not collect any unsolicited identifying information. The only personally identifying information that is collected from Visitors (“Visitors” or “you”) utilizing the Website is that which you have chosen to share with us. This information may include information that you voluntarily submit to CFP via email and payment information such as bank routing numbers and bank account numbers used for electronic payments. CFP does collect non-identifying information for customer service, feedback, and diagnostic purposes.

Non-identifying information

Visitors may browse the Website to access information about CFP products and services, without telling us who you are or revealing any personal information. The only data we collect and store as a result of Visitor use during normal website usage is typical web server log data. Examples of this type of data are the name of your Internet service provider, the site that referred you to us, any pages you request, and the time and date of those requests.

We use this information to generate statistics and measure site activity to benefit Website users. This same information may be shared with third parties in order to provide these services or to analyze, store, or aggregate the information. It may also be shared with other third parties that work with us to improve the services of CFP or the Website. Any statistical information derived from the information submitted via the CFP Website that may be shared with third parties is always anonymized and is not associated with any individual in a personally identifiable manner.

Personally Identifiable Information (“PII”)

CFP only collects personal information (that is, information from which an individual may be identified) from visitors to the Website that is submitted voluntarily through direct email or through our ACH payment system.

If you choose to utilize our payment system, we will temporarily collect and store ACH payment information, including financial institution routing numbers and individual bank account numbers, in order to process your payments. Any payments made through the Website are subject to the Terms & Conditions.

CFP will not use any personally identifiable information submitted via email or the payment system for marketing purposes, nor will CFP share it with any third party for marketing purposes.

PII you provide may be used to improve the products and services offered by CFP. CFP values your privacy and the security of your information and it is never provided or sold to any other company for that company’s independent use.

Cookies and Other Tracking Devices

As part of our services, we use cookies to store and sometimes track information about you. A cookie is a small amount of data that is sent to your browser from a web server and stored on your computer’s hard drive. Generally, we use cookies to remind us who you are and to enable us to access your account information so you do not have to re-enter it, gather statistical information about usage by registered or unregistered users, research visiting patterns, and help target information based on user interests. Preference and options configurations in your browser determine if and how a cookie will be accepted. You can change those configurations on your computer if you desire. By changing your preferences, you can accept all cookies, you can be notified when a cookie is set, or you can reject all cookies. If you do so and cookies are disabled, you may be required to re-enter your information more often and certain features of our site may be unavailable.

Please note that when you click on any third-party website from this Website – regardless of whether CFP has included the link on the Website, the operator of such third-party website (whether CFP or a third party) may collect information about you, including through cookies or other technologies. Links on the Website to other websites are provided only as a convenience, and the inclusion of such links does not imply endorsement of the linked site. CFP does not maintain control of third-party websites and is not responsible for their content or tracking technology. You should review the privacy policies of any other website that you visit to understand how your information is collected and used.

In addition, your Internet or other service provider(s) may collect information about or submitted by you while you use the Website, or any other website. You acknowledge that information collection or privacy practices of any other party are not monitored or controlled by CFP and CFP is not responsible for such websites.

Notwithstanding the policies stated above, CFP reserves the right to store information in accordance with our document retention policies. CFP may disclose information to third parties under certain circumstances, such as in order to comply with law enforcement or regulatory inquiry; to legal advisors; and to protect the rights, property, safety or security of CFP, Website visitors or the public.

This Privacy Policy applies solely to online information collection and use practices in connection with this Website; it does not apply to any practices conducted offline or in connection with any other websites owned or operated by CFP.

Information Security

CFP recognizes the importance of safeguarding consumer personal information in CFP’s possession from theft, inappropriate use, or improper distribution. It should, however, be recognized that no company can perfectly protect personal information.

Additional Terms Applicable to Brokers

We accept applications for insurance and endorsements from California licensed insurance agents and brokers (“Brokers” or “you” “your”) on behalf of potential insureds (“Applicants”) or insureds (“Policyholders”) through the Website. Brokers using the Website on behalf of Applicants or Policyholders are subject to these additional terms under the Privacy Policy.

Applications submitted by Brokers on behalf of Applicants may include personally identifiable information such as names and residences. In transacting insurance with us, it is important to realize that each Broker acts as the legal agent of the Applicant or Policyholder. The Broker therefore must have the authorization of the Applicant or Policyholder to conduct business with CFP over the Internet. It is the Broker’s responsibility to obtain that authorization after the Applicant or Policyholder has had an opportunity to review the Privacy Policy. As soon as an application is submitted, each Broker’s or Applicant/Policyholder’s information is governed by these additional terms.

It is the Broker’s responsibility ensure the Applicant or Policyholder has had an opportunity to review the Privacy Policy prior to conducting business on the Website.

Non-identifying information

We automatically gather general statistical information about our Website and Visitors, such as IP addresses, browsers, pages viewed, number of visitors, etc., but in doing so we do not reference you by individual name, e-mail address, or telephone number. We use this data in the aggregate to determine how much our customers use parts of our site so we can improve our site. We may provide this statistical information to third parties, but when we do so we do not provide personally identifiable information without your permission, unless required by law or as part of our investigation of possible use of our System in violation of our Terms and Conditions.

Personally Identifiable Information

When a Broker applies for a policy of insurance on behalf of an Applicant, or endorsements on behalf of a Policyholder, all of the information contained in that application becomes subject to the Privacy Policy Additional Terms. The Applicant information we collect is categorized as follows:

Application and Endorsement Information – Information that you as the Broker provide to us through our Website and through other means. Examples include Applicants’ physical address, zip code and phone number, as well as personally identifiable information about the individuals or businesses for whom insurance is sought. This may include the names, residences, or other information that we ask be provided to us on application forms.

Transaction and Experience Information – Information about your or an Applicant’s transactions with us and others, as well as information about our communications with you. Examples include account history, loss history, requests for information and our responses.

Information from Outside Sources – Information from outside sources is needed to provide and manage the insurance products and services that you request on behalf of an Applicant/ Policyholder and to let you or an Applicant/Policyholder know of additional goods and services of interest.
We may also share some or all of the information we collect about you and Applicant/Policyholders with third parties from one or more of the following categories.

• An Applicant/Policyholder’s insurance agent or broker
• Other insurance carriers
• Independent insurance adjusters
• Investigators
• Property inspectors
• An Applicant/Policyholder’s neighbors (only to the extent necessary for our purposes)
• Government Agencies

The Way We Use Personally Identifiable Information

We use information that you as a Broker provide to us in deciding whether to issue an insurance policy, how much premium to charge for that policy, and for investigations of the validity and extent of loss claims, and whether other persons or organizations (including, as one example, other insurance companies) have any responsibility for losses. In doing that we may combine the information you provide us with information from other sources, and in doing so we share that information with those other sources. These include, for example, credit reporting agencies, investigators, insurance adjusters, and attorneys who are involved in the functions described above.

Customer Service – We may use your or an Applicant/Policyholder’s personally identifiable information to statistically analyze site usage, to improve our content and product offerings and to customize our site’s content, layout, and services.

Personalized Customer Service – We may use and Applicant/Policyholder’s information to deliver information to you that, in some cases, is targeted to his or her interests. We may ask you as Broker, or the Applicant/Policyholder, to provide us voluntarily with additional information regarding personal or business interests, experience or requests, which we may use to improve our service to you and Applicant/Policyholders.

Communication – We use your e-mail address, your mailing address, and phone number, as well as those belonging to Applicant/Policyholders for contact regarding administrative notices and communications relevant to use of the Website.

Order Processing – If you place a request for insurance products or services on behalf of an Applicant/Policyholder, we use information to fulfill that order. If you as Broker use our payment system, we sometimes temporarily collect additional information, including billing information, ACH processing information, and tracking information from checks or money orders.

Legal – We may also use or disclose information to resolve disputes, investigate problems, or enforce our Agreement. At times, we may review the status or activity of multiple users to do so. We may disclose or access information whenever we believe in good faith that the law so requires or if we otherwise consider it necessary to do so to maintain service and improve our products and services.

Technology – We use your IP address to help diagnose problems with our server, to manage our Website and to enhance our site based on the usage pattern data we receive.

Security

We employ reasonable security methods to prevent unauthorized access, maintain data accuracy, and ensure correct use of information, as more fully described in the Agreement, of which the Privacy Policy is a part.

Your account information and profile are password-protected. We recommend that you not divulge your password to anyone. Our personnel will never ask for a password in an unsolicited phone call or in an unsolicited e-mail.

No data transmission over the Internet or any wireless network can be guaranteed to be perfectly secure. As a result, while we try to protect your and Applicant/Policyholders’ personal information, we cannot ensure or guarantee the security of any information transmit to us, and all information is transmitted at your own risk.

How You Can Update, Correct or Delete Your Information

You can access the information that we collect online and maintain through normal updating methods. To update, correct or delete this information, you can contact websupport@cfpnet.com. Your account will be deactivated upon your written request, the sale of your book of business, or the closure of your business. Upon deactivation, your profile will remain on our internal system but will be inaccessible through the Website.

During the normal course of doing business, we will continue to share your or an Applicant/Policyholder’s information among our business units, our affiliates and unaffiliated third parties as necessary in order to service your or their accounts with us.

Transfer of Your Information To Successor Organization

CFP reserves the right to transfer all personally identifiable information in its possession to a successor organization in the event of a reorganization of CFP, statutory or otherwise. Other than to the extent provided by law, the use and disclosure of all transferred personally identifiable information will be subject to the Privacy Policy, or to a new privacy policy if you are given notice of that new privacy policy and are given an opportunity to affirmatively opt-out of it. Personally identifiable information submitted or collected after a transfer, however, may be subject to a new privacy policy adopted by a successor organization.

California Do Not Track Disclosures

CFP does not respond to Do Not Track (DNT) signals over time and across third party websites to provide any form of targeted advertising. However, some third party sites that may be accessed via the Website may keep track of browsing activities through their sites. When a user visits such third party sites, web browsers allow users to enable DNT so that third parties (such as advertisers) know that the user does not want to be tracked. CFP does not endorse or have control of a third party’s use or intention of collecting personally identifiable information and information about a user’s online activities regardless of the third party’s Privacy Policy and DNT disclosures.
For more information on how CFP uses user information, see CFP’s Privacy Policy.