California FAIR Plan Association
Effective Date: [03/25/2021]
California FAIR Plan Association (“CFP”, “us”, “we”, or “our”) operates the cfpnet.com website (“Website”), and provides various services to clients, aimed at ensuring the availability of basic property insurance to people who own insurable property in the State of California and who have been unable to obtain insurance in the voluntary insurance market. CFP wants you to know, and assures you, that CFP does not sell your information to anyone.
or provided on behalf of, CFP.
Information We Collect
CFP may collect certain Personal Information about you in order to provide and improve our Services to you.
“Personal Information” means data about a particular individual or household that identifies, relates to, describes, could be reasonably linked with, or could be used to identify that person or household (or from those and other information either in our possession or likely to come into our possession). It may also include other information that may be associated with your Personal Information, such as Generic Information (defined below), location, preferences or interests, if that information can be used to identify you, your household, or your device.
Personal Information: CFP may collect the following Personal Information about you when you apply for and/or use our services: your name, mailing address, phone number, email address, age, loan number, prior insurance carriers, prior insurance claims, reason for termination, prior denials of coverage, prior existing property damage, and prior unrepaired damage. Social Security numbers will be collected for insurance brokers only. Additionally, driver’s license numbers may be collected for the purpose of verifying claimant identification.
Generic Information: This includes information that does not, by itself, identify you. Generic information may include Usage Data and other aggregate usage metrics such as total number of Website visitors, pages viewed, and usage patterns within the Website, etc. This may also include information about your device, your browser or operating system information, or other information that relates to your interaction with our Website. We may automatically gather some Generic Information from our members, customers, and Website visitors.
At times, Generic Information and Usage Data may qualify as Personal Information, either by itself or when combined with other information that may identify you. In those situations, such information will be treated like Personal Information.
Cookies & Tracking Data: The Website may use third party products and services to gather anonymous traffic statistics using cookies and web beacons. A cookie is a small piece of information stored on your device that helps websites and multiple servers recognize you. CFP and its third party service providers may also use other tracking technologies such as pixels, or transparent GIF files, for web site management and user tracking.
Some of the cookies we use are “strictly necessary” for the functionality of our Website. Others improve the functionality of our Website but are not strictly necessary. These cookies help improve the performance of our Website (such as by gathering analytic data).
Examples of cookies we use include:
- Session Cookies: These are cookies that enable our Website to keep track of movement from page to page so you are not asked for information that you have already provided to the Website.
Your Cookie Choices
How We Collect Your Information
CFP collects your information in different ways: there is information that you give us, information we obtain through your use of our Services, and information we obtain from third parties, such as insurance brokers.
A. Information You Provide Us
We collect information that you share with us. At times, in order to access our Services, we may require you to provide certain information that may include Personal Information. For instance, we may seek your name, address, date of birth and phone number when you submit an application to us. If you are an insurance broker, we may require you to upload your Social Security number as a part of the agency licensing process. Further, we may collect a claimant’s driver’s license number or other state identification number for the purpose of verifying that claimant’s identity.
Additionally, we will collect any information that you choose to provide to us. For instance, when you complete the 24/7 Claims Report on our Website or email us with a question, we will collect and retain the information you choose to give us – including any Personal Information – to fulfill your request.
B. Information We Obtain When You Use Our Services
We collect certain information from you through your use of our Services, such as Website usage data and other Generic Information. Further, in using our Website, we may collect information about the device you use to log into, access, and use the Website. We may collect other Generic Information in relation to how you use our Website or other Services (for example, aggregate metrics on how often certain pages on our Website are accessed and viewed).
C. Information We Obtain from Other Sources
We may obtain information about you from third parties who help us provide our Services to you. For example, we may obtain information about prior insurance claims you have made, prior denials of coverage, and prior insurance carriers.
We may receive your Personal Information from insurance brokers and underwriters in reference to your application for coverage and claims filed.
D. Personal Information Collected Over the Last 12 Months
Other than those listed above, CFP has not collected any types of Personal Information from our members and visitors over the last 12 months.
How We Use Your Information
A. Business & Other Purposes for Collection
CFP collects, processes, and uses your information to provide the Services that CFP makes available to you. We therefore collect your information for a variety of reasons, including:
- To process and fulfill your requests for coverage with CFP-affiliated insurance providers, and CFP clearinghouse participating insurers.
- You have otherwise given us permission to do so – for example, when you sign up for coverage with CFP, we will collect and process your information to evaluate your application.
- To facilitate our business purposes in relation to the Services that we provide to you. These operational purposes may include but are not limited to:
- Undertaking tasks related to the operations of our Website.
- Maintenance and improvement of our Services, including the Website;
- Detecting security incidents; and
- Debugging our Services.
- For a purpose otherwise related to the provision of our Services to you. For example, we may collect your information:
- To gather analytics or valuable information so that we can improve our Services.
- To monitor usage of our Services.
- To detect, prevent, and address technical issues.
How We Disclose or Share Your Information
A. Why We Disclose Your Information
CFP may share your Personal Information, as provided to CFP, with third parties who provide services to CFP and our clients. Examples of ways in which your information may be used by third parties include, but are not limited to, the following:
- To review and process your application for coverage.
- To confirm your identity to insurance providers.
- To clean, maintain, and analyze the CFP database.
- To investigate, protect against and help prosecute individuals responsible for malicious, deceptive, fraudulent, or illegal activity involving or affecting CFP, our Services, and/or our members. This may include disclosures to law enforcement, prosecutors, and other entities to investigation potential criminal activity and other civil violations. To comply with applicable laws, in response to a lawful and enforceable request by a law enforcement, judicial, or other public authority, or in connection with an applicable legal obligation.
Third parties like Google Analytics may collect aggregate data such as statistical information about how users interact with our Website and other Services. We use this information to help us better improve our Website and Services.
B. Categories of Third Parties That Receive Personal Information
We share or otherwise disclose individuals’ Personal Information to the following categories of third parties:
- Government Agencies: We may, from time to time, be required to share information with government agencies such as the California Department of Insurance for compliance purposes.
- Insurance Providers / Brokers: In order to procure insurance coverage for our customers, we will share your Personal Information with affiliated insurance providers. Additionally, when one broker merges with or acquires another broker, CFP may transfer data to the resulting or acquiring entity.
- CFP Clearinghouse Participating Insurers: In order to reduce CFP’s concentration and number of policies, and encourage maximum use of the normal insurance market, the CFP uses a clearinghouse process to match clients with normal insurance market “participating insurers” for renewals. CFP may share the Personal Information of clients with CFP clearinghouse participating insurers to enable those participating insurers to review and process insurance information to provide such renewals.
- Inspection Companies: In order to ensure that policies are activated.
- Insurance Adjusters: To assist and facilitate claims processing and payment.
- Financial Institutions: To facilitate automated clearinghouse (ACH) payment and processing.
- Actuaries: To provide policy rate analysis and perform rate change filings.
C. Categories of Personal Information Disclosed for Business Purposes
CFP does not sell, rent, or trade its members’ Personal Information to third parties.
Please note that a “sale” of Personal Information does not include those instances when such information is part of a merger, acquisition, or other transaction involving all or part of our business. If CFP is involved in a merger, acquisition or other transaction involving all or part of our business, we may transfer your Personal Information to a third party as part of that transaction. If such transaction materially affects the manner in which your Personal Information is processed, we will notify you of such change prior to its implementation.
D. Categories of Personal Information Disclosed in the Preceding 12 Months
CFP has disclosed the categories of Personal Information described above for the described business purposes in the preceding 12 months.
Transfer of Data
CFP’s Services are offered and available to people who live in the State of California. However, due to our relationships with insurance providers, your information, including Personal Information, may be transferred to or maintained on computers outside of your state, country, or other governmental jurisdiction where the data protection laws may differ from those of your jurisdiction.
While CFP’s Website is publicly available for user’s informational purposes, CFP does not offer any other Services to individuals outside of the State of California. If you are located outside of the United States and choose to provide information to us, please note that we transfer the data, including Personal Information, to the United States and process it there. If you are located in the European Union, please note that U.S. data protection laws are not as stringent as those in the European Union. Your submission of such information represents your agreement to that transfer.
Security of Data
The security of your data is very important to us. However, no method of transmission over the Internet or method of electronic storage is 100% secure. While we strive to use and implement commercially acceptable means to protect your Personal Information from loss, misuse, and unauthorized access, alteration, disclosure, and destruction, we cannot guarantee its absolute security. By using or Website and Services, you acknowledge that there are data security and privacy limitations inherent to the use of the Internet, and that the security, integrity, and privacy of any and all information exchanged between you and CFP, or between you and other related entities, cannot be guaranteed. We cannot ensure or warrant the security of any information you transmit to us or that we store, and you do so at your own risk.
Our Policy on “Do Not Track” under the California Online Protection Act (“CalOPPA”)
We do not support Do Not Track (“DNT”). Do Not Track is a preference you can set in your web browser to inform websites that you do not want to be tracked. You can enable or disable Do Not Track by visiting the Preferences or Settings page of your web browser.
We do not track consumers’ online activities over time and across third-party websites or online services.
Third parties may collect data that relates to you. We cannot control third parties’ responses to do-not-track signals or other such mechanisms. Third parties’ use of data relating to you and responsiveness to do-not-track signals is governed by their respective privacy policies.
Your California Privacy Rights
California residents are afforded certain rights related to their information under state law. CFP aims to take reasonable steps to allow California residents to access, delete or limit the use of their Personal Information, where applicable, and exercise other rights available under applicable law. Where applicable under relevant law, California residents may be entitled to the following:
- Right to Know: to have access to their Personal Information upon simple request – that is, they may receive a copy of such data in a portable form upon receipt of a verifiable request, along with other information related to the collection or processing.
- Disclosure of Direct Marketers: to have access upon simple request, and free of charge, to the categories, names and addresses of third parties that have received their Personal Information for direct marketing purposes. Please see the “Direct Marketers Disclosure” section below for more information.
- Collecting, Selling, Sharing, or Disclosing Personal Information: upon receipt of a verifiable request, to obtain a list of:
- The specific pieces of their Personal Information CFP holds;
- The categories of Personal Information collected about them, sold to third parties, or disclosed to third parties for business purposes;
- The categories of Personal Information sold within the last 12 months;
- The categories of sources from which Personal Information is collected;
- The business or commercial purpose for collecting or selling Personal Information; and
- The categories of third parties with whom Personal Information is shared, sold, or disclosed for a business purpose.
As noted elsewhere, however, CFP does not sell individuals’ Personal Information.
- Right to Opt-Out of the Sale of Personal Information: California residents have the right under the California Consumer Privacy Act (CCPA) to opt-out of the sale of their Personal Information under certain circumstances. As noted elsewhere, however, CFP does not sell individuals’ Personal Information.
- Right to Deletion: California residents have the right to obtain the deletion of their Personal Information in the situations set forth by applicable data protection law and upon receipt of a verifiable request.
- Right to Non-Discrimination. As defined under relevant law, California residents have the right to non-discrimination in the Services or quality of Services they receive from us for exercising their rights.
Please contact us at the information in “Contact Us” Section below in relation to exercising these rights. Note that we may ask you to verify your identity before responding to such requests.
Direct Marketing Disclosures
If you are a California resident, you have the right to request information from us regarding the manner in which we share certain categories of Personal Information with third parties for their direct marketing purposes, in addition to the rights set forth above. Under California law, you have the right to send us a request at the designated address listed below to receive the following information:
- The categories of information we disclosed to third parties for their direct marketing purposes during the immediately preceding calendar year;
- The names and addresses of the third parties that received the information; and
- If the nature of the third party’s business cannot be determined from their name, examples of the products or services marketed.
To make such a request, please provide sufficient information for us to determine if this applies to you, and attest to the fact that you are a California resident. Please also provide a current California address for our response. You may make this request in writing to us at the below address. Any such request must include “California Privacy Rights Request” in the first line of the description, and include your name, street address, city, state and ZIP code. Please note that we are only required to respond to one request per person each year, and we are not required to respond to requests made by means other than through the address provided for this purpose below. Responsive information may be provided in a standard format that is not specific to you.
Please note that CFP does not share Personal Information with third parties for their direct marketing purposes.
All of our Services, including our Website, are intended for adult audiences, and are not meant to address anyone under the age of 18 (“Children”). As such, Children under 18 may not use our Website. If you are under 18, do not attempt to register for or use any of our Services, including our Website, and do not provide us any Personal Information about yourself.
Submitting a Verifiable Request
As mentioned above, California residents have certain rights to access, delete, or otherwise control the use, collection, and/or disclosure of their information. CFP will respond to an individual’s “verifiable request” to exercise his or her rights under such laws – that is, where CFP has received a request purporting to be from a particular individual, and CFP has been able to verify the individual’s identity. The need to verify an individual’s identity is critical to protecting your information, and ensuring that your information is not shared with anyone pretending to be you or someone who is not authorized to act as your agent on your behalf.
You may submit a verifiable request via our email address, mailing address, or toll-free number, listed in the “Contact Us” section below, or as otherwise provided on our Website. CFP will ask you to provide information about yourself so that we can verify your identity as part of this process. This information may include your name, your address, your account information, and any other information deemed necessary by CFP to reasonably verify your identity, to ensure that your information is not shared with anyone impersonating you.
We may ask for additional information if we have difficulty confirming your identity. We will not share your information or honor other requests in those situations in which we are unable to confirm a request for your information is a “verifiable request.”
Under California law a consumer can appoint an “authorized agent” to make certain verifiable requests upon their behalf, such as the right to know what information we collect about the consumer or to request deletion of the consumer’s information. Because the security and privacy of your information is paramount, we will ask that you identify and provide permission in writing for such persons to act as your authorized agent and exercise your applicable rights under California law in such situations. This may require us to contact you directly and alert you that an individual has claimed to be your agent and is attempting to access or delete your information. We will also independently verify your identity to ensure that an unauthorized person is not attempting to impersonate you and exercise your rights without authorization. We will not share your information or honor any other requests in those situations where you cannot or do not grant permission in writing for an identified authorized agent to act on your behalf, or where we cannot independently verify your identity.
If you have any questions about this privacy statement, the practices of this site or your dealings with this site, please contact CFP:
- By Email: firstname.lastname@example.org
- By Phone: 866-951-9376
- By Mail: 725 S. Figueroa St., Ste. 3900, Los Angeles, CA 90017