Privacy Policy - California CCPA

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CCPA Privacy Notice

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This California Consumer Privacy Act (the "CCPA") Privacy Notice supplements the information contained in the Important Notice of Privacy Policy and Information Practices of American National Insurance Company and its affiliates, including American National Life Insurance Company of Texas, Garden State Life Insurance Company, Standard Life and Accident Insurance Company, American National Property And Casualty Company, American National General Insurance Company, American National Lloyds Insurance Company, ANPAC Louisiana Insurance Company, and Pacific Property And Casualty Company (collectively, the "Company", "we", "us", or "our"). We adopt this notice to comply with the California Consumer Privacy Act of 2018 ("CCPA"), and it applies solely to persons who reside in the State of California ("consumers" or "you").

Information We Collect

We collect information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household ("personal information"). In particular, we have collected the categories and specific pieces of personal information about consumers outlined below (some categories overlap).

Category of Information

Examples of Specific Pieces of Information

Identifiers

Name, alias, mailing address, online identifier, internet protocol address, email address, account number, social security number, driver’s license number, and passport number

Customer Records

Name, signature, social security number, physical characteristics such as height, weight, and build, mailing address, telephone number, passport number, driver’s license number, insurance policy number, education information, employment or professional related information, bank account number, credit card number, debit card number, financial information, medical information, and health insurance information

Protected Characteristics

Age, race, color, ancestry, national origin, citizenship, religion, marital status, medical condition, physical or mental disability, sex, sexual orientation, pregnancy, veteran or military status, and genetic information

Commercial Information

Personal property records and purchase histories

Biometric Information

Fingerprints, voice prints, facial scans, retinal scans, physical patterns such as keystroke and gait, and sleep, health, or exercise data

Internet or Network Activity

Browsing history, search history, and information on a person’s interaction with a website, application or advertisement

Geolocation Data

Physical location or movements in relation to an internet-connected device

Sensory Data

Audio, electronic, visual, thermal, olfactory, or similar information such as continuous voice recordings, personal driving information, and building temperatures

Professional or Employment Related Information

Applications, job histories, and performance evaluations

Non-public Education Information

Grades, transcripts, class lists, student schedules, student identification codes, student financial information, and student disciplinary records

Inferences from Personal Information

Profile reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes

We obtain the categories of personal information listed above from one or more of the following categories of sources:

Applicants and agents, such as the information submitted on applications and administrative forms;
Health care providers, laboratories, pharmacies, and health information exchanges;
Health plans, group policy holders, and benefit plan administrators;
Other insurance companies and reinsurers;
Government agencies, including departments of insurance and departments of motor vehicles;
Consumer reporting agencies and third party databases;
Third parties that help us process or service transactions you request. For example, business application and technology companies, claims adjusters, appraisers, body shops, financial advisors, and attorneys;
Employees and independent contractors;
Employers, employment agencies and education institutions;
Customer service and client communications; and
Activity on our websites collected through third party software.

Use and Sharing of Personal Information

We may use or disclose the personal information we collect for one or more of the following business purposes:

To provide you with information, products, or services that you request from us;
To fulfill or meet the reason for which the information is provided, such as underwriting, reinsurance, rate-making, policy service, claims administration, and compliance;
To carry out our obligations and enforce our rights arising from any contracts between us, including billing and collections;
To provide customer service and quality assurance;
To improve our website and present its contents to you;
To market our products and services to you;
To prevent and detect fraud and to verify your identity;
To determine eligibility for new and continued appointment or employment;
To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations;
For internal uses such as refining business processes and increasing efficiency;
As necessary or appropriate to protect the rights or property of our clients or others; and
As otherwise described to you when collecting your personal information.

We disclose personal information for a business purpose to the following categories of third parties:

Third parties that help us process or service transactions you request, such as group policy holders, benefit plan administrators, business application and technology companies, employment agencies, claim adjusters, appraisers, body shops, car dealerships, financial advisors, title companies, mortgage companies, attorneys, and auditors;
Health care providers, laboratories, pharmacies, health information exchanges, and health plans;
Other insurance companies and reinsurers;
Governmental agencies such as departments of insurance and departments of motor vehicles;
Consumer reporting agencies and third party databases;
Banks and other financial institutions;
Independent contractors, agents, and agencies;
Third party administrators; and
Other third parties to whom you authorize us to disclose your personal information in connection with the products or services we provide you.

We will not collect additional categories of personal information or use the personal information collected for materially different, unrelated, or incompatible purposes without providing notice.

In the preceding twelve (12) months, we have not sold any personal information.

Your Rights and Choices

The CCPA provides specific rights to California residents regarding their personal information. This section describes your CCPA rights and explains how to exercise those rights.

Access to Specific Information through Verifiable Consumer Request ("Right to Know")
Subject to exceptions below, you have the right to request that we disclose certain information to you about our collection and use of your personal information. Once we process your verifiable consumer request, 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 purpose for collecting your personal information;
The categories of third parties with whom we share your personal information;
The specific pieces of personal information we collected about you; and
If we disclosed your personal information for a business purpose, the categories of personal information we have disclosed for such purposes.

Deletion Request Rights through Verifiable Consumer Request ("Right to Delete")
Subject to exceptions below, you also have the right to request that we delete any of your personal information that we have collected and retained. Once we process your verifiable consumer request, we will delete (and direct our service providers to delete) your personal information from our records, unless an exception applies.

We may deny your deletion request if, among other reasons, retaining the information is necessary for us, or our service providers, to:

Complete the transaction for which we collected the personal information, provide a product or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you;
Detect security incidents; protect against malicious, deceptive, fraudulent, or illegal activity; or prosecute those responsible for such activities;
To enable internal uses that are reasonably aligned with your expectations based on your relationship with us;
Comply with a legal obligation; or
Other internal and lawful uses of that information that are compatible with the context in which you provided it.

Exercising Access and Deletion Rights
To exercise the access and deletion rights described above, please submit a verifiable consumer request to us by either:

Website
Completing the California Resident Request Form at:
americannational.com/wps/portal/an/home/legal/ccpa/california-resident-request-form
Toll-free telephone
Calling us at (877) 327-6329.

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. A parent or guardian must make a verifiable consumer request on behalf of a minor child (less than 13 years old).

You may only make a verifiable consumer request for access twice within a 12-month period. The verifiable consumer request must include sufficient information to reasonably verify you are the person about whom we collected personal information, or an authorized agent, and describe your request with sufficient detail to allow us to properly respond to it. Specifically, we will ask you to submit personal information, such as your email address, telephone number, mailing address, date of birth, last four digits of your social security number, policy type, policy number, and claim number, that we will compare and match to our records. You will need to confirm an online request to delete personal information by clicking "confirm request" during the request submission process before we can move forward with deleting any personal information. We cannot respond to your request if we cannot verify your identity or authority to make the request.

Response Timing and Format
We will endeavor to respond to a verifiable consumer request within 45 days of its receipt. If we require more time (up to 90 days), we will inform you of the reason and extension period in writing. The response will also explain the reasons why we need additional time, if applicable. 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 is excessive, repetitive, or manifestly unfounded, we may charge a reasonable fee, or refuse to act on the request and notify you of the reason for refusing the request.

Non-Discrimination
We will not discriminate against you for exercising any of your CCPA rights.

Exceptions

The CCPA contains certain exceptions. For example, privacy rights established under the CCPA (including the right to know and right to delete) do not apply to personal information collected or disclosed pursuant to the Gramm-Leach-Bliley Act (GLBA), the Health Information Portability and Accountability Act (HIPAA), and the Fair Credit Reporting Act (FCRA). Such personal information may include, but is not limited to:

Identifiers (such as name, mailing address, email address, telephone number, driver’s license number, social security number, and date of birth); and
Customer records (such as age, gender, marital status, physical characteristics, medical history, annual income, policy values, account transactions, payment history, claims history, consumer reports, and motor vehicle records).

Please refer to the Company’s Important Notice of Privacy Policy and Information Practices and/or Notice of HIPAA Privacy Practices for more information regarding our privacy practices under GLBA and/or HIPAA.

Changes to Our Privacy Notice

We reserve the right to amend this CCPA Privacy Notice at any time. We will post the updated notice on our website at: https://www.americannational.com/wps/portal/an/home/legal/ccpa and any changes will become effective upon the posting of the updated CCPA Privacy Notice on the website.

Contact Information

If you have any questions or comments about this CCPA Privacy Notice, the ways in which we collect and use your personal information, your choices and rights regarding such use, or wish to exercise your rights under the CCPA, please do not hesitate to contact us at (877) 327-6329 and ask to speak to a representative.