This 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 New York, 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, Farm Family Casualty Insurance Company, and United Farm Family Insurance Company (collectively, the “Company”, “we”, “us”, or “our”). We adopt this notice to comply with the California Consumer Privacy Act of 2018 as amended by the California Privacy Rights Act of 2020 (“CCPA”), and it applies solely to persons who reside in the State of California (“consumers” or “you”). Any terms defined in the CCPA have the same meaning when used in this privacy notice.
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 within the last twelve (12) months (some categories overlap). We follow our records retention policy and schedule to ensure that each category of information is kept only as is reasonably necessary for the disclosed collection purposes. The records retention policy and schedule is based on criteria including legal and regulatory requirements, contractual obligations, security risks, storage constraints, and business needs.
We obtain the categories of personal information listed above from one or more of the following categories of sources:
We may use, disclose, sell, or share the personal information we collect, including any sensitive personal information, for one or more of the following business purposes:
We disclose personal information for a business purpose to the following categories of service providers or third parties:
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 do not have actual knowledge that we have sold personal information of minors under age 16.
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:
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:
Right to Opt-Out of Sale or Sharing of Personal Information (“Right to Opt-Out”)
Subject to exceptions, you also have the right to opt-out of the “sale” or “sharing” of personal information. “Sale” means the disclosure of your personal information by us to a third party (and not a service provider) for monetary or other valuable consideration. “Sharing” means the disclosure of your personal information by us to a third party for cross-context behavioral advertising. “Cross-context behavioral advertising” means the targeted advertising based on your personal information obtained from your activity across distinctly branded websites, applications, or services other than the business’s distinctly branded website, application, or service with which you intentionally interact.
Right to Limit the Use and Disclosure of Sensitive Personal Information (“Right to Limit”)
Subject to exceptions, you also have the right to limit the use and disclosure of your sensitive personal information. Sensitive personal information does not include information that is collected or processed without the purpose of inferring characteristics about you.
If the use of the sensitive personal information is reasonably necessary and proportionate to the following purposes, we will not limit the following uses of sensitive personal information:
We may also use or disclose the Sensitive Personal Information to a service provider or contractor for additional, specified purposes; however, you have the right to limit such use and disclosure.
Right to Request Correction of Inaccurate Personal Information (“Right to Correct”)
If it is determined that the Company maintains inaccurate personal information about you, and if the Company can verify your identity, you have the right to request the Company correct that personal information, taking into account the nature and processing purposes of that personal information.
The Company may deny your request to correct inaccurate personal information after considering the totality of circumstances related to the contested personal information and after determining the contested personal information is more likely than not accurate. We may require that you provide documentation to rebut our own documentation that the personal information is accurate. As an alternative, the Company may choose to delete the contested personal information rather than correcting it if the deletion does not negatively impact you or if you consent to the deletion. We may also deny your request to correct if we have denied your request to correct the same alleged inaccuracy within the past six months of receiving your request. We may also deny your request to correct if we have a good-faith, reasonable, and documented belief that the request is fraudulent or abusive.
If we are not the source of the allegedly inaccurate information, we may provide you with the name of the source from which we received the alleged inaccurate information.
Right to Not Receive Discriminatory Treatment
We will not discriminate against you for exercising any of your CCPA rights.
Exercising Rights
To exercise your rights, please submit a request to us by either:
Only you or a person that you authorize to act on your behalf, may make a request related to your personal information. A parent or guardian must make a 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; employee, agent or contractor identification number; former employee, agent, or contractor termination date; policy type; policy number; and claim number, as applicable, 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
For requests to delete, correct, and/or know, 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. For requests to limit and/or opt out of the sale or sharing, we will endeavor to respond to your request within 15 business days of its receipt.
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. Additionally, we may deny your request if it restricts our ability to exercise or defend legal claims.
The CCPA contains certain exceptions. For example, privacy rights established under the CCPA do not apply to personal information collected or disclosed pursuant to the Gramm-Leach-Bliley Act (GLBA), California Financial Information Privacy Act (FIPA), the Health Information Portability and Accountability Act (HIPAA), the California Confidentiality of Medical Information Act (CMIA), the Fair Credit Reporting Act (FCRA), and the Driver's Privacy Protection Act. Such personal information may include, but is not limited to:
Additionally, the privacy rights established under the CCPA do not apply to:
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.
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.
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.