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Specialty Program Group LLC Privacy Statement

(Effective January 1, 2023)

Last Reviewed: December 28, 2022

This Privacy Policy (this “Policy”) describes how Specialty Program Group LLC and its subsidiaries listed here use your Personal Information (as defined below) both during and after our direct business relationship with you. This Policy applies to your Personal Information that we may from time to time collect, use and disclose in the course of (1) performing insurance brokerage or other insurance industry services on your behalf and (2) making available our websites, including specialtyprogramgroup.com. We take very seriously our privacy responsibilities to you, and we are committed to treating your Personal Information in a manner that is consistent with applicable law and this Policy. Please read this Policy carefully.

Updates to Policy, Accessibility of Policy, and Regional Differences

Updates to Policy. From time to time, we may change our privacy practices which will require changes to this Policy. The latest version of this Policy will be posted on our websites at the page it has historically appeared and the date it was last reviewed will be displayed. We encourage you to look for updates and changes to this Policy when you access our websites.

Your continued use of our websites following the posting of changes constitutes your acceptance of such changes with respect to your use of our websites.

Accessibility. If you have special needs with regard to accessing the content of this Policy, we recommend that you or someone on your behalf, contact us at: information.requests@specialtyprogramgroup.com

Notice to California Residents. If you are a California resident, you may have additional privacy rights. Due to the detailed requirements under California privacy laws, please review the SPG Privacy Notice for California Residents for information about these additional rights.

Notice to Residents of Colorado, Connecticut, Utah, Virginia. If you are a resident of Colorado, Connecticut, Utah, Virginia you may also have additional rights such as the right to know, access, correct, transfer, restrict the processing of, and delete certain Personal Information or as may be otherwise described below in this Privacy Policy.

Definition and Exclusions of Personal Information at Specialty Program Group LLC

Generally, “Personal Information” means information that identifies (whether directly or indirectly) you, such as your name, postal address, email address, and telephone number. Due to the nature of our business as described under “Information Collection” below, Personal Information may also include:
• your name, Social Security Number, driver’s license or other government-issued identification;
• assets and income, occupation and employment status, dependent information and other relevant financial information;
• information relating to any of your past claims;
• information from reporting agencies and state and federal government agencies, such as state motor vehicle departments;
• information from other sources, such as medical or health care providers and other third parties with which you or we maintain a relationship;
• your account activity and premium payment history;
• credit card, bank account or other account information as may be required to facilitate your payment of insurance premium or similar amounts, which payment generally is made through systems maintained by third parties, such as insurance carriers;
• details about your business and status as an insurance agent, broker or other intermediary; and
• passive tracking information from our website or the Internet, including information obtained through the use of internet “cookies.”

Personal Information does not include aggregated or anonymous information which does not identify and cannot reasonably be used to identify you.

Information Collection

We are generally unable to perform insurance brokerage or other insurance industry services on your behalf without collecting, using, or disclosing your Personal Information. Typically, you will provide this required information to us directly within insurance applications or in connection with other communications or indirectly depending on your relationship with us – whether as an individual client, agent, broker, claimant, employee of our corporate, program or association clients, family member of any of such employees or other person who SPG employs or with whom we may do business. For example, we may receive this and other

Personal Information from third parties, including insurance carriers and other industry service providers, and other third parties with which you maintain a relationship (for example, your employer or financial service or medical or health providers). We may also develop this information over time based on your direct or indirect interactions with us, such as through the use of “cookies” on our websites.

Please keep in mind that when you provide information to us on a third party site or platform, the information you provide may be separately collected by the third party site or platform. We encourage you to read the privacy policies of other sites that may collect your Personal Information.

We generally collect the amount and types of Personal Information that are required for us to perform or support services on your behalf, whether directly or indirectly. This includes information that may be required by an insurance carrier or an industry service provider in the course of providing you with insurance coverage or related services. If you use our websites, we may collect information about your device, browser and other information regarding your web usage using tracking tools described in this policy. This and other information may include the Personal Information as defined above.

Cookies and Other Web Technologies

We may use “cookies” and other technologies such as web beacons on our websites. These technologies help us to better understand user behavior including for security and fraud prevention purposes, for information about which parts of our websites people have visited, and to facilitate and measure the effectiveness of advertisements and web searches.

• Communications Cookies. These cookies are used to enable network traffic to and from our systems, including by helping us detect any errors.
• Strictly Necessary Cookies. These cookies are set as required to provide a specific feature or service that you have accessed or requested and that cannot be provided without the use of such cookies.
• Other Cookies. These cookies are used to understand how visitors interact with our websites and online services, including by helping us to assess the effectiveness web searches and so we can provide you with a more customized experience.

If you prefer that we not use certain cookies, we provide you with the means to disable their use where possible. Certain features of our website may not be available if all cookies are disabled, and therefore, disabling, particularly of strictly necessary cookies, may not be available. We generally treat data we collect using these cookies and similar technologies as nonpersonal data.

Disclosure of Personal Information

We generally only disclose your Personal Information to perform services on your behalf and provide you with the insurance products and services you expect from us. In addition, in order to operate our business and to you with the services you request from us, information technology and other support service providers with which we maintain an arrangement may also have access to your Personal Information. We do not sell your Personal Information to third parties, other than in connection with a merger, sale, or other transfer of organizational assets where Personal Information held by us about our clients is among the assets transferred.

We may from time to time disclose your Personal Information for the following reasons:
to fulfill or meet the reason you provided the information and for our everyday business purposes, such as to obtain quotations for insurance or other insurance industry services (including those procured proactively and/or in connection with the movement of a book of business from one provider to another) on your behalf (or for whom the information was provided); to obtain insurance (or similar products) on your behalf (or for whom the information was provided) or to facilitate the performance of related services by other industry service providers; to maintain or service your account or insurance, including by reporting claims of loss to other industry service providers, such as insurance carriers and adjusters; to evaluate our performance or offerings; and to make reports to credit bureaus. We may also save your information to facilitate new quotations or placements.
for legal reasons, such as to make required or advisable reports to insurance regulatory, law enforcement or other similarly situated authorities; to respond to and comply with court orders, applicable law and other legal requirements; and to defend ourselves against claims and to enforce our rights or protect our employees or property.
for our own marketing purposes so that we may offer you our products and services, including through the use of targeted or similar advertising on the internet.
for joint marketing purposes so that we and any third party product or service provider may together offer you products and Specialty Program Group LLC and its affiliated entities, including its subsidiaries (“affiliates”) will not rent or redistribute your Personal Information without your consent, unless legally required to do so.
for our affiliates’ everyday business purposes, such as to process or service transactions or to provide or receive shared organizational services. Specialty Program Group LLC and its affiliates will not rent or redistribute your Personal Information without your consent, unless legally required to do so.
for our affiliates’ marketing purposes so that they may offer you their products and services.
for other purposes as may be permitted by law.

However, we will only disclose your decision to opt-in to receive text message (SMS) marketing with affiliates or other third parties if we obtain your consent, or if we are legally required to make such a disclosure.

To Limit Our Disclosure of Information

To limit our disclosure of your Personal Information with affiliates or non-affiliates for marketing purposes (and for any other purpose which applicable law provides you a right to require us to limit our sharing of your Personal Information), you may at any time submit a request to us by:

• Calling us at 866-415-2207
• Emailing us at: information.requests@specialtyprogramgroup.com

California Residents: You may have additional rights concerning the disclosure or sharing of Personal Information under California privacy laws. See the SPG Privacy Notice for California Resident for more information.

Other Important Website Information

Our website contains links to third party sites that are not sites of SPG affiliates or divisions. If you click on one of those links, you will be taken to websites we do not control. This policy does not apply to the information practices of those sites. You should read the privacy policy of those other websites carefully. We are not responsible for those third party sites. Links to outside sites do not constitute or imply endorsement by us of the linked site or any material displayed on those sites.

Our websites are not intended for children under 13 years of age. No one under age 13 may provide any information through our websites, and we do not knowingly collect Personal Information from children under 13. If you are under 13, do not use or provide any information on this website or otherwise provide any information about yourself to us, including your name, address, telephone number, email address, or any screen or username you may use. If we learn we have collected or received Personal Information from a child under 13 without verification of parental consent, we will use commercially reasonable efforts to delete that information. If you believe we might have any information from or about a child under 13 without parental consent, please contact us at the mailing address shown beneath the heading “Your Right to Review Your Information.”

Information Security Practices

We maintain technical and organizational security measures reasonably designed to protect the security of your Personal Information against loss, misuse, unauthorized access, disclosure, or alteration. Specialty Program Group LLC and its affiliates take steps in accordance with the Systems Information and Standards of our Code of Business Conduct and Ethics to secure your Personal Information with appropriate levels of security around storage and use. Despite this, the security of information cannot be guaranteed. If you have reason to believe that your Personal Information maintained by us is no longer secure, please immediately notify us utilizing contact information set forth below. In the event of a breach impacting your Personal Information, we intend to provide you with notification to the extent required by applicable law.

Your Right to Review Your Information

You may have the right to review your Personal Information that we could reasonably locate and retrieve, and to request that we correct, amend, or delete any inaccurate information. To make a related request, or to ask any question concerning this Policy, you can write us at:

Chief Legal Officer
Specialty Program Group LLC
150 N Riverside Plaza, 17th Floor
Chicago, IL 60606

Or by:

• Calling us at 866-415-2207
• Emailing us at: information.requests@specialtyprogramgroup.com

Please include your name, address, telephone number and email address whenever you contact us, including by email. This helps us handle your request correctly and allows us to verify your identity to protect your information.

As noted above, California Residents may have additional rights concerning the disclosure or sharing of Personal Information under California privacy laws. See the SPG Privacy Notice for California Residents for more information.

As noted above, residents in Colorado, Connecticut, Utah, Virginia may also have additional rights regarding the right to know, access, correct, transfer, restrict the processing of, and delete certain Personal Information and should exercise such rights by contacting the phone number or email address listed above.

Situations Where Rights Cannot Be Granted. There may be situations where we cannot grant a particular request — for example, if you ask us to delete your transaction data but we are legally obligated to keep a record of that transaction to comply with law or if we are unable to verify your identity through standard and reasonable requirements. We may also decline to grant a request where doing so would undermine our legitimate use of data for antifraud and security purposes, such as when you request deletion of an account that is being investigated for security concerns. Other reasons your privacy request may be denied could be that granting the request would jeopardize the privacy of others; that the request is substantively frivolous or vexatious; or that granting the request would be highly impractical in the context of our legitimate business purposes.

Privacy Policy Organizations

Each of the Specialty Program Group LLC Privacy Policy and Privacy Notice for California Residents is provided on behalf of Specialty Program Group LLC and the following organizations:

  • Avant, LLC
  • The Advantage Association, LLC
  • Avant Brokerage, LLC
  • Avant Care, LLC
  • Avant Leasing Services, LLC
  • Avant Specialty Claims, LLC
  • Avant Underwriters, LLC
  • CS Risk Healthcare, LLC
  • Independent Contractor Specialty Group, LLC
  • Independent Contractor Service Providers Association, LLC
  • National Association of Independent Contractor Professionals, LLC
  • SafeHerb, LLC
  • HDOL LLC
  • MGU of the West Insurance Services, Inc.
  • SBR Administrative Services, LLC
  • SBR Services, LLC
  • SBR Analytics, LLC
  • American Medical Professional Alliance, Inc.
  • Biz Choice Last Mile Logistics Purchasing Group
  • Boater Rewards Association, PBC
  • National CPA Risk Purchasing Group, Inc.
  • SPG Crane & Boom Truck Risk Purchasing Group, Inc.
  • SHEL Risk Purchasing Group Association

Privacy Notice for California Residents

Effective Date: January 1, 2023

Last Reviewed on: December 28, 2022

This Privacy Notice for California Residents (this “Notice”) supplements the information contained in the SPG Privacy Policy (the “Policy”) and is provided on behalf of Specialty Program Group LLC and its subsidiaries listed here.

This Notice provides our “notice at collection” and provides certain mandated disclosures about our treatment of California residents’ information, both online and offline. We adopt this Notice to comply with the California Consumer Privacy Act of 2018 as supplemented by the California Privacy Rights Act of 2020 (collectively, the “CCPA”) and any terms defined in the CCPA have the same meaning when used in this Notice (unless separately defined in this Notice). This Notice applies solely to residents of the State of California as defined in the CCPA (“California Residents”) who do business with us directly and/or visit the websites of Specialty Program Group LLC and its subsidiaries (“our websites”).

Changes to this Notice

We reserve the right to amend this Notice at our discretion and at any time. When we make changes to this Notice, we will post the updated Notice on the websites and update the Notice’s effective date. We encourage you to look for updates and changes to this Notice when you access our websites. Your continued use of our websites following the posting of changes constitutes your acceptance of such changes with respect to your use of the websites.

Accessibility

We collect information that identifies, relates to, describes, references, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer, household, or device (“personal information”). Personal information does not include:

  • Publicly available information from government records.
  • Deidentified or aggregated consumer information.
  • Information excluded from the CCPA’s scope, like:
    • health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and the California Confidentiality of Medical Information Act (CMIA) or clinical trial data; and
    • personal information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FCRA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA) and the Driver’s Privacy Protection Act of 1994.
      In particular, we have collected the following categories of personal information from consumers within the last twelve (12) months:

Definition and Exclusions of Personal Information and Sensitive Personal Information under the CCPA and at Specialty Program Group LLC

Generally, Personal Information under the CCPA and in this Notice means information that identifies (whether directly or indirectly) you, such as your name, postal address, email address, and telephone number. Due to the nature of our business as described in “Information We Collect” section below, Personal Information may also include:

• your name, Social Security Number, driver’s license or other government-issued identification;
• assets and income, occupation and employment status, dependent information and other relevant financial information;
• information relating to any of your past claims;
• information from reporting agencies and state and federal government agencies, such as state motor vehicle departments;
• information from other sources, such as medical or health care providers and other third parties with which you or we maintain a relationship;
• your premium payment history;
• credit card, bank account or other account information as may be required to facilitate your payment of insurance premium or similar amounts, which payment generally is made through systems maintained by third parties, such as insurance carriers; and
• passive tracking information from our websites or the Internet, including information obtained through the use of internet “cookies.”

Personal Information as defined under the CCPA does not include:
• Publicly available information from government records as defined under Civil Code Section 1798.140;
• Deidentified or aggregated consumer information;
• Health or medical information to the extent covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and the California Confidentiality of Medical Information Act (CMIA) or clinical trial data; and
• Personal information to the extent covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FCRA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA) and the Driver’s Privacy Protection Act of 1994.

Certain types of Personal Information are considered “Sensitive Personal Information” under the CCPA. Specifically, Sensitive Personal Information is defined under the CCPA as information that reveals a consumer’s:

• Social Security, driver’s license, state identification card, or passport number;
• Account login, financial account, debit card, or credit card number in combination with any required security or access code, password, or credentials allowing access to an account;
• Precise geolocation;
• Racial or ethnic origin, religious or philosophical beliefs, or union membership;
• Mail, email, and text message content, unless the business is the intended recipient of the communication;
• and/or Genetic data;
• Biometric information, which may reference certain physiological, biological, or behavioral characteristics; or DNA information; which could potentially establish an individual’s identity. Retina scans, fingerprints or voice recordings could also be considered such information.

Personal Information We Collect

The following categories of Personal Information and/or Sensitive Personal Information may have been collected from California Residents within the last twelve (12) months. Personal Information that falls under the definition of Sensitive Personal Information under the CCPA has been noted in the second column below.

CATEGORY
California Sensitive Personal Information may be considered to be within this Category (YES or NO)
EXAMPLES
COLLECTED
A. Identifiers
YES
A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, Social Security number, driver's license number, passport number, or other similar identifiers.
YES
B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).
YES
A name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver's license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information. Some personal information included in this category may overlap with other categories.
YES
C. Protected classification characteristics under California or federal law.
YES
Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information).
YES
D. Commercial information.
YES
Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.
YES
E. Biometric information.
YES
Genetic, physiological, behavioral and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as, fingerprints, faceprints and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns and sleep, health, or exercise data.
NO
F. Internet or other similar network activity.
NO
Browsing history, search history, information on a consumer's interaction with a website, application, or advertisement.
YES
G. Precise geolocation data.
YES
Physical location or movements within a geographic area that is equal to or less than the area of a circle with a radius of 1,850 feet.
YES
H. Sensory data.
YES
Audio, electronic, visual, thermal, or similar information.
NO
I. Professional or employment-related information.
NO
Current or past job history.
YES
J. Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)).
NO (if de-identified)
Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records.
NO
K. Inferences drawn from other personal information.
YES
Profile reflecting a person's preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities and aptitudes.
NO

Sources of Personal Information We Collect

We may obtain the categories of Personal Information listed above from the following categories of sources:

• Directly from you – for example, from insurance applications or in connection with your other communications with us.
• From third parties – for example, from insurance carriers and other industry service providers, and other third parties with which you maintain a relationship, such as an employer, financial service or medical or health providers, or any industry provider from which we purchase or acquire industry assets or operations. This may occasionally include referral sources.
• Indirectly from you – for example, from observing your actions on our websites, including through the use of “cookies” as described on our websites, or as may otherwise be developed over time based on your interactions with us.

Use of Personal Information

We may use or disclose the Personal Information we collect for one or more of the following purposes:

• To fulfill or meet the reason you provided the information and for our everyday business purposes – for example, to obtain quotations for insurance or other insurance or financial industry services (including those procured proactively and/or in connection with the movement of a book of business from one provider to another) on your behalf; to obtain insurance (or similar products) on your behalf or to facilitate the performance of related services by other industry service providers; to maintain or service your account or insurance, including by reporting claims of loss to other industry service providers, such as insurance carriers and adjusters; to evaluate our performance or offerings; and to make reports to credit bureaus. We may also save your information to facilitate new quotations or placements.
• To comply with, or exercise rights under, applicable law – for example to make required or advisable reports to insurance regulatory, law enforcement or other similarly situated authorities; to respond to and comply with court orders, applicable law, and other legal requirements; and to defend ourselves against claims and to enforce our rights or protect our employees or property.
• To market products and services to you, including through the use of targeted or similar advertising on the internet.
• To provide or receive shared organizational services.
• As described to you when collecting your Personal Information or as otherwise set forth in the CCPA.
• To evaluate or effect a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, in which Personal Information held by us about our consumers is among the assets evaluated or transferred.

Sharing of Personal Information under the CCPA

Under the CCPA, the Sharing of Personal Information means sharing, renting, disclosing, disseminating, making available or otherwise communicating a consumer’s Personal Information to a third party for uses such as targeted advertising for the benefit of the business.

California residents have certain rights under the CCPA around limiting the Sharing of their Personal Information.

The CCPA addresses two distinct categories of information disclosure by businesses, differentiating the Sharing of Personal Information for a Commercial Purposes from the Disclosure of Personal Information for a Business Purpose, as described below.

Sharing of Personal Information for a Commercial Purpose

The CCPA defines the Sharing of Personal Information for a Commercial Purpose as including the sale of a customer’s Personal Information for monetary of other consideration paid to the sharing business.

In the preceding twelve (12) months, Specialty Program Group LLC has not Shared your Personal Information for a Commercial Purpose.

Disclosures of Personal Information for a Business Purpose

The CCPA excludes from the definition of Sharing Personal Information any use of Personal Information which was requested by you (the customer), including the expected and typical use of that information by a third party for the reasonably necessary purposes to achieve the requested service. Such an information transfer is considered the Disclosure of Personal Information for a Business Purpose under the CCPA.

In the preceding twelve (12) months, we may have Disclosed the following categories of Personal Information for a Business Purpose:

Category A: Identifiers.
Category B: California Customer Records Personal Information categories.
Category C: Protected classification characteristics under California or federal law.
Category D: Commercial information.
Category F: Internet or other similar network activity.
Category H: Sensory data.
Category I: Professional or employment-related information.

We may Disclose your Personal Information for a Business Purpose to perform services on your behalf and provide you with the insurance products and services you expect from us to the following categories of third parties:

• Service providers.
• Insurance carriers and other industry service providers.
• Other third parties with which you or we maintain a relationship regarding your insurance.

Sales of Personal Information

In the preceding twelve (12) months, we have not sold Personal Information.

Information Specific to Employment Data of Specialty Program Group LLC

In addition, for recruitment and/or employment purposes, in the past twelve (12) months we have collected or may have collected and retained the following categories of Personal Information as necessary from California residents. Personal Information that falls under the definition of Sensitive Personal Information under the CCPA has been noted in the second column below:

CATEGORY
California Sensitive Personal Information may be considered to be within this Category (YES or NO)
EXAMPLES
COLLECTED
Additional personal details, contact details and identifiers.
YES
Additional personal details for recruitment/employment purposes, such as national identification number, social security number, insurance information, marital/civil partnership status, domestic partners, dependents, emergency contact information, and military history; professional/personal calendar availability/scheduling information for meeting/communication purposes.
YES
Education information and professional or employment-related information.
NO
Information about your education and professional or employment-related information, such as your employment history.
YES
Sensitive data for recruitment purposes.
YES
Certain types of sensitive information when permitted by local law or with your consent, such as health/medical information (including disability status), trade union membership information, religion, race or ethnicity, minority flag, and information on criminal convictions and offences. We collect this information for specific purposes, such as health/medical information in order to accommodate a disability or illness (subject to legal limits on the timing of collection of such information and other applicable limitations) and to provide benefits; background checks and diversity-related Personal Information (such as race or ethnicity) in order to comply with legal obligations and internal policies relating to diversity and anti-discrimination.
YES
Documentation required under immigration laws.
YES
Data on citizenship, passport data, and details of residency or work permit (a physical copy and/or an electronic copy).
YES, as to employees of Specialty Program Group LLC
Financial information for payroll/benefits purposes.
YES
Your banking and other relevant financial details we need for payroll/benefits purposes.
YES
Talent management information.
YES
Information necessary to complete a background check, details on performance decisions and outcomes, performance feedback and warnings, e-learning/training programs, performance and development reviews (including information you provide when asking for/providing feedback, creating priorities, updating your input in relevant tools), driver’s license and car ownership information, and information used to populate biographies.
YES
Requested recruitment information.
NO
Information requested to provide during the recruitment process, to the extent allowed by applicable law.
YES
Recruitment information you submit.
NO
Information that you submit in résumés / CVs, letters, writing samples, or other written materials (including photographs).
YES
Information generated by us during recruitment.
NO
Information generated by interviewers and recruiters related to you, based on their interactions with you or basic Internet searches where allowed under applicable law.
NO
Recruitment information received from third parties.
NO
Information related to you provided by third-party placement firms, recruiters, or job-search websites, where applicable.
NO
Audiovisual information processed during recruitment.
YES
Photograph, and images/audio/footage captured on CCTV or other video systems when visiting our office or captured in the course of recruitment events or video recruitment interviews.
NO
Recommendations.
NO
Recommendations related information provided on your behalf by others.
NO
Immigration.
YES
Documentation and related information required under immigration laws.
YES, as to employees of Specialty Program Group LLC
Employment history and background checks.
YES
Information about your prior employment, education, and where applicable and allowed by applicable law, credit history, criminal records or other information revealed during background screenings.
YES
Diversity related information.
YES
Information about race / ethnicity / religion / disability / gender and self-identified LGBT status, for purposes of government reporting where required by law, as well as to understand the diversity characteristics of our workforce, subject to legal limits.
YES
Assessment information.
YES
Information generated by your participation in psychological, technical or behavioral assessments. You will receive more information about the nature of such assessments before your participation in any of them.
YES

Your Rights and Choices

The CCPA at Section 7011 (e)(2) provides California Residents with specific rights regarding their Personal Information:

(A) Access. The right to know what Personal Information the business has collected about the consumer, including the categories of Personal Information, the categories of sources from which the Personal Information is collected, the business or commercial purpose for collecting, selling, or sharing Personal Information, the categories of third parties to whom the business discloses Personal Information, and the specific pieces of Personal Information the business has collected about the consumer;

(B) Deletion. The right to delete Personal Information that the business has collected from the consumer, subject to certain exceptions;

(C) Correction. The right to correct inaccurate Personal Information that a business maintains about a consumer;

(D) Opt-out of Sale or Sharing. If the business sells or shares Personal Information, the right to opt-out of the sale or sharing of their Personal Information by the business;

(E) Limitation on the Use of Sensitive Personal Information. If the business uses or discloses sensitive Personal Information for reasons other than those set forth in section 7027, subsection (lm), the right to limit the use or disclosure of sensitive Personal Information by the business; and

(F) Non-discriminatory Treatment. The right not to receive discriminatory treatment by the business for the exercise of privacy rights conferred by the CCPA, including an employee’s, applicant’s, or independent contractor’s right not to be retaliated against for the exercise of their CCPA rights.

The following sections describe these CCPA rights in further detail and explains how to exercise those rights.

Access to Specific Information and Data Portability Rights

You have the right to request that we disclose certain information to you about our collection and use of your Personal Information over the past twelve (12) months. Once we receive and confirm your verifiable consumer request (see “Exercising Access, Data Portability and Deletion Rights”), we will disclose to you:

• The categories of Personal Information we collected about you.
• The categories of sources for the Personal Information we collected about you.
• Our business or commercial purpose for collecting or selling that Personal Information.
• The categories of third parties with whom we share that Personal Information.
• The categories of Personal Information shared for a business purpose for each category of recipients.
• The specific pieces of Personal Information we collected about you (also called a data portability request).

In addition to the rights listed above, you may request limitations on the use of your Sensitive Personal Information consistent with the terms and limitations described in the CCPA, and pursuant to Civil Code Section 1798.120 et.seq. Limited use of Sensitive Information may continue to include those uses which the average consumer would reasonably expect in context, and for uses which are reasonably necessary and proportionate for our business.

Deletion Request Rights

You have the right to request that we delete any of your Personal Information that we collected from you and retained. Once we receive and confirm your verifiable consumer request (see “Exercising Access, Data Portability and Deletion Rights”), we will delete your Personal Information from our records, unless an exception applies.

We may deny your deletion request in whole or in part for other reasons and exceptions described in the CCPA.

Exercising Access, Data Portability and Deletion Rights

To exercise the access, data portability and deletion rights described above, please submit a verifiable consumer request to us by:

• Calling us at 866-415-2207
• Emailing us at: information.requests@specialtyprogramgroup.com

To protect your information and privacy, only you, or someone legally authorized to act on your behalf, may make a verifiable consumer request related to your Personal Information. Designated agents making any request will be required to provide signed permission for the agent to submit a request. In addition, when an authorized agent submits a request, we may also require that you verify your own identity directly to us or confirm with us that you have requested that the agent to submit the request. You may also make a verifiable consumer request on behalf of your minor child.

You may only make a verifiable consumer request for access or data portability twice within a 12-month period. The verifiable consumer request must:

• Provide sufficient information as we may request that allows us to reasonably verify you are the person about whom we collected Personal Information or an authorized representative of such person, which may include personal and/or commercial identifiers, such as an insurance policy number. Depending on the sensitivity of the information you are requesting, we may ask for additional information to verify your identity.
• Describe your request with sufficient detail that allows us to properly understand, evaluate and respond to it.

We cannot provide you with Personal Information if we cannot verify your identity or authority to make the request and confirm the Personal Information relates to you. We will only use Personal Information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.

Response Timing and Format

We will acknowledge receipt of your request within ten (10) days. We will endeavor to respond in substance to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time, we will inform you of the extension period which may not exceed an additional forty-five (45) days beyond the original forty-five (45) day period.

Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request’s receipt. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your Personal Information that is readily usable and should allow you to transmit the information from one entity to another entity without significant hindrance.

We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.

Non-Discrimination

We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not:

• Deny you goods or services.
• Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.
• Provide you a different level or quality of goods or services.
• Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.

Other California Privacy Rights

California’s “Shine the Light” law (Civil Code Section § 1798.83) permits users of our website who are California Residents to request certain information regarding our disclosure of Personal Information to third parties for their direct marketing purposes. To make such a request, please write us at the mailing address shown beneath the heading “Contact Information for Requests under this Notice.”

Contact Information for Requests under this Notice

If you have any questions or comments about this Notice, the ways in which we collect and use your Personal Information described herein, and in the Policy, your choices, and rights regarding such use, or wish to exercise your rights under California law, please contact us at:

Postal Address:
Chief Legal Officer
Specialty Program Group LLC
150 N Riverside Plaza, 17th Floor
Chicago, IL 60606

Phone: 866-415-2207

Email: information.requests@specialtyprogramgroup.com

Situations Where Rights Cannot Be Granted

There may be situations where we cannot grant a particular request — for example, if you ask us to delete your transaction data but we are legally obligated to keep a record of that transaction to comply with law, or if we are unable to verify your identity through standard and reasonable requirements. We may also decline to grant a request where doing so would undermine our legitimate use of data for antifraud and security purposes, such as when you request deletion of an account that is being investigated for security concerns. Other reasons your privacy request may be denied could be that granting the request would jeopardize the privacy of others; that the request is substantively frivolous or vexatious; or that granting the request would be highly impractical in the context of our legitimate business purposes.

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