I. Your Privacy

Privilege Underwriters Inc., and its subsidiaries and affiliates, including PURE Specialty Exchange, (collectively "PSE", “we” or “us”) are committed to protecting your privacy. This Privacy Policy discloses how we collect, protect, use and share information gathered about you (a) on our website, (b) offline or when you contact us via email or through our service and claims centers, and (c) from third parties, including publicly-available information.

II. Collection, Use, and Sharing of Personal Information

A. Collection of Personal Information

We collect information that can be used to identify or contact a particular person (we refer to this type of data as "personal information"). Personal information includes information that does not directly identify you by name or include your contact information, but which may be used to identify that a specific computer or device has accessed our website and which, if combined with certain other information, could be used to identify you. The types of personal information we collect and process depends on the product or service you have with us. In addition to the personal information you provide us, PSE collects personal information from various reporting or databases and agencies or bureaus. The personal information we collect about you can include:

• Identifiers: Full name; work or home postal address; work, mobile or home telephone number; work or personal email address; any other personal information you may provide when contacting us or submitting an inquiry, username, Social Security Number, date of birth, and driver’s license number
  Other Personal Information
  • Financial Information: Credit card information and credit reporting information such as credit scores.
  • Employment Information: Occupation.
• Commercial Information: Whether your own or rent your residence; information about your property; and products or services purchased, obtained, or considered.
• Internet or other electronic network activity information: Internet Protocol (IP) address and cookie data (including third-party cookies and related data).
• Vehicle information: motor vehicle and claims histories, vehicle operator information, mortgages, lien or lease holder information.

We collect your personal information, for example, when you:

• Apply for insurance, file a claim, contact us for information or with questions.
• Send us emails or other correspondence.
• Communicate with us by telephone (please note that we may record or monitor the call).
• Visit or interact with our website and online services (such as our member portal).

B. Use of Personal Information

PSE collects personal information necessary to underwrite insurance policies, adjust claims, operate the other functions necessary to provide you with the products and services we offer, improve our products and services, and improve our websites and services.

We use your personal information for the following purposes:

• If you apply for insurance or file a claim with us: we use your personal information to determine coverage, issue and administer your policy, process payment, adjudicate claims, and contact you regarding your policy and claims. In these situations, we may need to process your personal information to comply with relevant laws or fulfill our obligations under an insurance contract to which you are subject.
• If you are a broker logging on to PURE online: we use your personal information (including username and password) as necessary to register, maintain and secure your account (e.g., to identify you at sign-in and prohibit others from accessing your account) and communicate with you. These processing activities are based on your consent or our legitimate interest to secure our services and improve your experience while using our website.
• If you email us or otherwise submit an inquiry or request: we use your personal information as necessary to respond to you and provide you with the information requested. These processing activities are either based on your consent or our legitimate interest to communicate with you about our products and services, or are necessary to provide you with the products or services requested.
• A credit report or other consumer report about you may be used to develop an insurance score. Your insurance score may be used to review your application for insurance and subsequent amendments and renewals. An insurance score uses information from your credit and/or consumer report to help predict how often you are likely to file claims and how expensive those claims will be. Insurance score information may then be used to determine how much we will charge for insurance. Items from a credit report that could affect an insurance score include payment history, number of revolving accounts, number of new accounts, and the presence of collection accounts, bankruptcies and foreclosures. We will use information provided by LexisNexis (formerly ChoicePoint) or an equivalent third-party vendor in connection with the development of your insurance score. We engage in these processing activities based on our legitimate interest in properly assessing insurance eligibility, rates, and coverage.
• For any other purpose for which you provide consent;
• For any other legitimate business purpose. These processing activities are based on our legitimate interest to fulfill our services to you.

C. Sharing of Personal Information

We disclose the following personal information about consumers for business purposes:

• Identifiers, Other Personal Information, and Commercial Information. We share this information with our service providers to allow them to perform services on behalf of PSE.
• Internet or other electronic network activity information. We share with or allow third parties to utilize cookies for marketing or advertising customized to your apparent interests or needs (more information located in the Cookies section)

We may also disclose your personal information for the following reasons:

• If we are required by law or in response to an investigation by law enforcement or other government authorities. In these situations, we may need to process your personal information to comply with relevant laws.
• If we reorganize or transfer our business, we may transfer your personal information to the reorganized or new business.

Access to this information is limited to those who require it in order to provide our products and services. Your information is secure as described below (Security). We also share limited personal information (such as your transactions and experiences with PSE) with our affiliates, including Privilege Underwriters, Inc. (PUI), Privilege Underwriters Reciprocal Exchange (PURE), PURE Specialty Risk Management, LLC (PSRM), and PURE Risk Management, LLC (PRM), for our legitimate interest in performing group administrative purposes.

III. Cookies

We use session cookies to ensure that your computer displays our website effectively and to track anonymously the usage of our website. We may also share with or allow third parties to utilize cookies for marketing or advertising customized to your apparent interests or needs. A session cookie is a small data file which is temporarily stored on your computer’s hard disk or website server and does not collect any personal information. You have the ability to accept or decline cookies using your web browser settings. If you choose to not accept cookies from our website, you may not be able to take full advantage of its features or to receive some of the services that it provides. To learn more about cookies and your ability to opt-out of certain advertising cookies, please visit the following websites: http://www.aboutads.info/choices or http://www.networkadvertising.org/choices.

Also, please note that we currently do not have technology that would respond to web browser “Do Not Track” signals.

We process this data for the legitimate interests to improve your experience while using the website and directly advertise related products and services.

Analytics Services

We may allow third parties to collect information about the users of our website. Such third parties may collect personal information about your online activities over time and across different websites when you use our website. We do not control these third parties, who may engage in practices that differ from those described in this Privacy Policy.

For example, the website uses Google Analytics, a web analytics service provided by Google, Inc. (“Google”). Google Analytics may set cookies on your browser or mobile device or read cookies that are already there to collect information. Google Analytics may also receive information about you from apps you have downloaded that partner with Google. Google Analytics collects information such as how often you use the website and how you use the website. We use the information provided by Google Analytics to improve the website and our services. For more information regarding how Google collects, uses and shares your information and how to opt out of certain uses please visit http://www.google.com/policies/privacy/partners/. By using the website, you consent to the processing of data about you by Google as described here and in Google's privacy policy.

IV. Non-Personal and Aggregated Information

We log certain non-personal information, such as your IP address and browser type, the name of the website from which you entered our website, which pages you visit on our website, and how much time you spend on each page. We use this information to monitor use of and to improve our website. We use IP addresses to analyze trends, administer the website, and gather information for aggregate use.

V. International Transfers of Information

Personal information that you send to PSE is sent to us and our server located in the United States. We may transfer such personal information to any office of PSE. Any email you send through the website to any personnel may be routed through the United States to your addressee, who may be located in the United States or elsewhere. In submitting personal information to us, you expressly consent to the transfer of that information across national borders and you acknowledge that such information may be processed and stored in a country with privacy laws that differ from those of your country.

VI. Security

Your information is presently stored on our servers located in the United States. We treat all data as an asset that must be protected and use tools (encryption, passwords, physical security, etc.) to protect your personal information against unauthorized access and disclosure. However, third parties may unlawfully intercept or access transmissions or private communications, and other users may abuse or misuse your personal information that they collect from our site. Therefore, we do not promise, and you should not expect, that your personal information provided through our website will always remain private.

VII. Consent

By providing personal information to us through our website, you consent to our use of it as set out in this privacy policy.

VIII. European Union Users

If you are a European Union user, you may have certain rights with respect to the collection, use, transfer and processing of your personal information, as described below. However, we reserve the right to limit these rights at any time where permitted under applicable law, including where your identity cannot be reasonably verified or to the extent your rights adversely affect the rights and freedoms of others. To exercise any of the rights below, please contact us using the applicable contact information below.

Access Right

You have the right to obtain confirmation as to whether or not your personal information is being processed by PSE. Where we are processing your personal information, you have the right to access the data and to obtain certain information about the processing of such data.

Right to Rectification

You have the right to obtain rectification of any personal information that is inaccurate or incomplete, including by means of providing a supplementary statement.

Right to Erasure

Where required under applicable law, you have the right to have your personal information erased where one of the following applies:

• Your personal information is no longer necessary with regards to the purposes for which it was collected.
• You withdraw your consent (where the processing is based on such consent).
• You object to the processing where such processing is based on PSE's (or a third party's) legitimate interest and there are no overriding legitimate grounds for the processing.
• Your personal information must be erased in order to comply with a legal obligation under applicable law.

However, this right to erasure will not apply to the extent the processing is necessary for:

• Compliance with a legal obligation which requires processing by applicable; or
• Archiving purposes in the public interest, scientific or historical research purposes, or statistical purposes, to the extent permitted under applicable law.

Right to Restriction of Processing

Where required under applicable law, you have the right to restrict the processing of your personal information where one of the following applies:

• The accuracy of the personal information is contested.
• The processing is unlawful and you oppose the erasure of your personal information and request the restriction of its use instead.
• PSE no longer needs the personal information for the purposes of the processing, but it is required by you for the establishment, exercise or defense of legal claims.
• Where the processing is based on PSE's (or a third party's) legitimate interest and you have objected to processing (as described immediately below).

Right to Object

Where required under applicable law, you have the right to object (on grounds relating to your particular situation) at any time to the processing of your personal information for direct marketing purposes or where the processing is based on PSE's (or a third party's) legitimate interest. When objecting to processing based on our legitimate interest, PSE will no longer process your personal information unless PSE demonstrates compelling legitimate grounds for the processing which override your interests, rights and freedoms or for the establishment, exercise, or defense of legal claims.

Right to Withdraw Consent

Where the processing of your personal information is based on your consent, you have the right to withdraw such consent at any time, without affecting the lawfulness of processing based on consent before such withdrawal.

Right to Data Portability

Where required under applicable law, you have the right to receive your personal information, which you have provided to PSE, in a structured, commonly used and machine-readable format, and have the right to transmit such data to another entity without hindrance from PSE, where each of the following conditions are met:

• Your request does not adversely affect the rights of others;
• Your request does not adversely affect PSE's rights (including intellectual property rights);
• The processing is based on your consent or the performance of a contract to which you are a party; and
• The processing is carried out by automated means.

Right Not to Be Subject to Solely Automated Decisions

Where required under applicable law, you have the right not to be subject to a decision based solely on automated processing (including profiling) which produces legal effects concerning you or similarly significantly affects you, unless permitted under applicable law.

Right to Submit a Complaint to Supervisory Authorities (EU Residents Only)

You have the right to lodge a complaint with an applicable European data protection authority. If you reside in Europe, you have the right to lodge such a complaint in the European country of your habitual residence, place of work, or place of an alleged infringement if you consider that the processing of your personal information infringes applicable EU data protection laws. A list of all European supervisory authorities and their respective contact information is available here.

IX. California Users

If you are a California user, you may have certain rights with respect to the collection, use, transfer and processing of your personal information, as described below. However, we reserve the right to limit these rights at any time where permitted under applicable law, including where the Personal Information collected about you is subject to the Gramm Leach Bliley Act (GLBA) or the California Financial Information Privacy Act (CalFIPA), where your identity cannot be reasonably verified or to the extent your rights adversely affect the rights and freedoms of others. To exercise any of the rights below, please contact us using the applicable contact information below. Only you or a person registered with the California Secretary of State that you authorize to act on your behalf, may make a verifiable consumer request related to your personal information.

Collection of Personal Information

When California consumers access our website we collect the following Personal Information.

Internet or other electronic network activity information

• Browsing history
• Search history
• Information regarding a consumer’s interaction with an Internet Web site, application, or advertisement
• Internet Protocol address
• Device ID
• Cookies
• Beacons
• Pixel Tags
• Mobile Ad Identifiers

We may also collect the following Personal Information in order to provide California consumers with insurance products that we believe they may be interested in purchasing.

Identifiers

• Personal Identifiers
• Name
• Address
• Email address
• Telephone number
• Date of Birth
• Social Security number
• Signature

The foregoing pieces of Personal Information have been collected about California consumers in the past 12 months. All other Personal Information collected about California consumers is in connection with the furnishing of insurance or in response to a request for insurance. Such Personal Information is collected and handled pursuant to California insurance laws and the GLBA and is therefore exempt from the requirements of the CCPA, including the disclosure requirements.

Sources from which Personal Information is Collected

• We collect your identifiers, through third-party lead generators and credit services.
• We collect your internet or other electronic network activity information from your interactions with our website.

Business or Commercial Purposes for which Personal Information is Collected

Your Personal Information is used for the following purposes:

• Authenticate your identity;
• For marketing purposes;
• Respond to court orders and legal investigations;
• Provide you with customer service and support;
• Safeguard against potential fraud;
• Protect data from unauthorized parties and comply with legal requirements;
• Enforce this Privacy Policy, Terms of Use, and any other agreements you have entered into with us;
• Send you offers and promotions for our products and services;
• Operate, understand, optimize, develop, or improve our sites, applications, products, services and operations;
• Detecting security incidents, protecting against malicious, deceptive, fraudulent, or illegal activity, and prosecuting those responsible for that activity;
• Debugging to identify and repair errors that impair existing intended functionality; and
• Investigate and prevent activities that may violate our policies.

Third Parties with whom Personal Information is Shared

PSE shares your Personal Information with affiliates, analytics providers, service providers, IT vendors, and law enforcement (if necessary).

In the preceding 12 months, we have not sold Personal Information about California consumers.

In the preceding 12 months, we have not sold Personal Information about minors.

In the preceding 12 months, we have disclosed Personal Information about California consumers to third parties for business or commercial purposes as described below:

1. Auditing related to a current interaction with the consumer and concurrent transactions, including, but not limited to, counting ad impressions to unique visitors, verifying positioning and quality of ad impressions, and auditing compliance with this specification and other standards.
   • Internet or other electronic network activity information
2. Detecting security incidents, protecting against malicious, deceptive, fraudulent, or illegal activity, and prosecuting those responsible for that activity.
   • Identifiers
3. Debugging to identify and repairs errors that impair existing intended functionality
   • Identifiers
   • Internet or other electronic network activity information
4. Performing services on behalf of the business including maintaining or servicing accounts, providing customer services, processing or fulfilling orders and transactions, verifying customer information, processing payments, providing financing, providing advertising or marketing services, providing analytic services, or providing similar services on behalf of my business or service provider.
   • Identifiers
   • Internet or other electronic network activity information
5. Undertaking internal research for technological development and demonstration.
   • Internet or other electronic network activity information

Individual Rights

Right to Know About Personal Information Collected, Disclosed, or Sold

California consumers have the right to request that PSE disclose the Personal Information it collects, uses, and discloses about you to third parties. There are two types of Right to Know requests you can make:

1. Right to Know (Abbreviated Request): If you make a Right to Know (Abbreviated Request), you will receive the following information about you:
   • Categories of Personal Information collected;
   • Categories of sources from which Personal Information is collected;
   • Business or commercial purpose for collecting or disclosing Personal Information; and
   • Categories of third parties to whom Personal Information is disclosed for a business purpose.

We do not sell any Personal Information of California consumers. If we did sell your Personal Information, you would have the right to know the categories of Personal Information we sell, the business or commercial purpose of the sale, and to whom it sells such Personal Information.

1. Right to Know (Specific Pieces of Information Request): If you make a Right to Know (Specific Pieces of Information Request), you will receive the following information about you:

• Specific pieces of Personal Information collected about you.

This information will be provided to you free of charge, unless we determine that your request is manifestly unfounded or excessive. You may request this information twice in a 12-month period.

Right of Deletion

You have the right to request that PSE and our service providers delete any Personal Information about yourself that PSE has collected from you upon receipt of a verifiable request. This right is subject to exceptions.

Personal Information Collected Pursuant to California insurance law and GLBA.

Much of the Personal Information collected about you by PSE is in connection with the furnishing of insurance or in response to a request for insurance. Such Personal Information is collected and handled pursuant to California insurance law and the GLBA and is therefore exempt from the requirements of the CCPA, including the consumer request requirements described in this section.

Submitting Requests

You can submit your request by calling us at 914.992.0012. You may also submit a request via email at privacyofficer@pureinsurance.com.

Verifying Requests

PSE provides California consumers with the ability to submit requests through our request website, our telephone number, and our email address. PSE must verify that the person requesting information or deletion is the California Consumer about whom the request relates in order to process the request. To verify a California Consumer’s identity, we may request up to up to three (3) pieces of Personal Information about you when you make a request to compare against our records. We cannot respond to your request or provide you with Personal Information if we cannot verify your identity. Making a verifiable consumer request does not require you to create an account with us. We will only use Personal Information provided in your request to verify your identity. PSE reserves the right to take additional steps as necessary to verify the identity of California Consumers where we have reason to believe a request is fraudulent.

Authorized Agent

You may choose a person registered with the California Secretary of State that you authorize to act on your behalf to submit your requests (“Authorized Agent”). If you choose to use an Authorized Agent, PSE requires that you provide the Authorized Agent with written permission to allow them to submit your request and that you verify your identity directly with us. Failure to do so may result in PSE denying your request.

Right to Equal Service

PSE will not discriminate against you because you exercised any of your rights, including, but not limited to, by:

• Denying goods or services to you.
• Charging different prices or rates for goods or services, including through the use of discounts or other benefits or imposing penalties.
• Providing a different level or quality of goods or services to you.
• Suggesting that you will receive a different price or rate for goods or services or a different level or quality of goods or services.

X. Retention and Deletion of Personal Data

PSE implements and maintains reasonable restrictions on the retention of personal information and generally disposes of such personal information once it is no longer necessary for the purposes for which it was collected or further processed. However, we may continue to store archived copies of your personal information for legitimate business purposes and as necessary to comply with applicable law. In addition, we may continue to store anonymous, aggregated or anonymized information for any legitimate business use described in this privacy policy.

XI. Children’s Information

Our services are not intended for use by children. We do not knowingly collect personal information from children under the age of 16 years. Please contact us if you believe we may have unknowingly collected information about a child under 16 years of age, and we will take immediate steps to delete any such personal information.

XII. Updates to this Policy

The effective date of our most recent privacy policy is indicated at the top of this page. We may change this privacy policy from time to time by updating this page. By using our website or sending us any personal information after the indicated effective date, you signify your agreement with this policy and you will be deemed to be bound to the policy in effect as of the date of such use.

XIII. Contact Us

If you would like to review or ask us to correct information you have submitted to us through our website, you may do so by contacting us as follows:

Kirk Raslowsky, Senior Vice President

44 S. Broadway, Suite 301, White Plains, NY 10601
t: 914.992.0012
f: 914.328.3883
e: privacyofficer@pureinsurance.com

Effective Date: December 19, 2018

NY State Insurance Law §2612, Confidentiality Notice.
Click here to access a printable version of the NY State Insurance Law §2612, Confidentiality Notice.