INVESTORS HERITAGE LIFE INSURANCE COMPANY
PRIVACY NOTICE FOR CALIFORNIA RESIDENTS
Effective Date: January 1, 2020
Last Reviewed on December 31, 2019
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 device (“personal information”). In particular, we indicate below whether we have collected the following categories of personal information from consumers within the last twelve (12) months:
- Identifiers – (Collected): 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.
- Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)) – (Collected): 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.
- Protected classification characteristics under California or federal law – (Collected): 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).
- Commercial information – (Not collected): Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.
- Biometric information – (Not collected): 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.
- Internet or other similar network activity – (Collected): Browsing history, search history, information on a consumer’s interaction with a website, application, or advertisement.
- Geolocation data – (Not collected): Physical location or movements.
- Sensory data – (Not collected): Audio, electronic, visual, thermal, olfactory, or similar information.
- Professional or employment-related information – (Collected): Current or past job history or performance evaluations.
- Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)) – (Not collected): 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.
- Inferences drawn from other personal information – (Not collected): Profile reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.
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;
- Personal information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FRCA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver’s Privacy Protection Act of 1994.
We obtain the categories of personal information listed above from the following categories of sources:
- Directly from our clients or agents, for example, from documents that our clients provide to us related to the services for which they engage us.
- Indirectly from our clients or agents, for example, through information we collect from our clients in the course of providing services to them.
- Directly and indirectly from activity on our website (www.ihlic.com), for example, from submission through our website portal or website usage details collected automatically.
USE OF PERSONAL INFORMATION
We do not sell your 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. For example, if you share your name and contact information to request a price quote or ask a question about our products or services, we will use that personal information to respond to your inquiry. If you provide your personal information to purchase a product or service, we will use that information to process your payment and facilitate delivery. We may also save your information to facilitate new product orders or process returns.
- To provide, support, personalize, and develop our Website, products, and services.
- To create, maintain, customize, and secure your account with us.
- To process your requests, purchases, transactions, and payments and prevent transactional fraud.
- To provide you with support and to respond to your inquiries, including to investigate and address your concerns and monitor and improve our responses.
- To personalize your Website experience and to deliver content and product and service offerings relevant to your interests, including targeted offers and ads through our Website, third-party sites, and via email or text message (with your consent, where required by law).
- To help maintain the safety, security, and integrity of our Website, products and services, databases and other technology assets, and business.
- For testing, research, analysis, and product development, including to develop and improve our Website, products, and services.
- To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.
- As described to you when collecting your personal information or as otherwise set forth in the CCPA.
- To exercise or enforce our rights, including rights arising out of any agreement we have with you or our business relationship with you.
We will not collect additional categories of personal information or use the personal information we collected for materially different, unrelated, or incompatible purposes without providing you notice.
SHARING PERSONAL INFORMATION
We may disclose your personal information to a third party for a business purpose. When we disclose personal information for a business purpose, we enter into a contract that describes the purpose and requires the recipient to both keep that personal information confidential and not use it for any purpose except performing the contract.
In the preceding twelve (12) months, we have collected the following categories of personal information, obtained personal information from the following sources, collected the personal information for the following business purposes, and disclosed the personal information to the following categories of third parties:
|CATEGORY OF PERSONAL INFORMATION||SOURCE||BUSINESS PURPOSE||TO WHOM DISCLOSED (CATEGORIES)|
|Category A – Identifiers: 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.||Customer-provided information from forms and direct interactions. Data collected indirectly from customers or agents during the course of providing services.||To respond to inquiries; to provide products and services; to process requests and to provide support.||Service providers; affiliates; and parent or subsidiary organizations|
|Category B – CA Customer Records Statute categories: 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.||Customer-provided information from forms and direct interactions. Data collected indirectly from customers or agents during the course of providing services.||To respond to inquiries; to provide products and services; to process requests and to provide support.||Service providers; affiliates; and parent or subsidiary organizations|
|Category C – Protected Class Characteristics: 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).
|Customer-provided information from forms and direct interactions. Data collected indirectly from customers or agents during the course of providing services.||To respond to inquiries; to provide requested products and; to process requests and to provide support.||Service providers; affiliates; and parent or subsidiary organizations|
|Category F – Internet/network activity: i.e. Browsing history, search history, information on a consumer’s interaction with a website, application, or advertisement||Customer interactions with a website, including page clicks, time spent, or other automatically collected meta-data; internet cookies; search terms; and social media services.||To respond to inquiries; to provide products and services; to process requests and to provide support.||Service providers; affiliates; parent or subsidiary organizations; and internet cookie recipients|
|Category I – Professional/employment-related information: Current or past job history.||Customer-provided information from forms and direct interactions. Data collected indirectly from customers or agents during the course of providing services.
|Service providers; affiliates; and parent or subsidiary organizations|
YOUR RIGHTS AND CHOICES
The CCPA provides consumers (California residents) with specific rights regarding their personal information. This section describes your CCPA rights 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, use, and disclosure, of your personal information over the past 12 months. After receiving a verifiable consumer request from you, we will disclose the categories of personal information we collected about you, the categories of sources for such personal information, our business or commercial purpose(s) for collecting such personal information, the categories of third parties with whom we have shared that personal information, and the specific pieces of personal information we have collected about you during the 12-month period preceding your request. If we have disclosed your personal information for a business purpose, we will list the disclosures made for a business purpose and identify the personal information categories that each category recipient received.
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 either:
- Calling us at 800-422-2011
- Emailing us at firstname.lastname@example.org
Only you, or an authorized agent acting on your behalf, may make a verifiable consumer request related to your personal information. 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 that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative.
- Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.
We cannot respond to your request or 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.
RESPONSE TIMING AND FORMAT
We will confirm receipt of your request within ten (10) days and in doing so, we will describe our verification process and provide an expected response timeframe. We endeavor to respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time, we will inform you of the reason and extension period in writing.
There is a two-step process for requests for deletion. First, you must submit a verifiable request for deletion in accordance with the instructions above. Second, you must separately confirm that you want the personal information deleted.
To verify a request to know categories of personal information or to delete non-sensitive information with a low risk of harm, we may require you to provide at least two data points that we can match with information we hold. To verify a request for a non-account holder requesting disclosure of specific pieces of personal information or deletion of sensitive information with a high risk of harm, we may require you to provide us with at least three pieces of personal information that we can match with information we hold and we may require a declaration signed by you under penalty of perjury stating that you are the consumer whose personal information is the subject of the request.
We will deliver our written response by mail or electronically, at your option.
If an authorized agent makes a request on your behalf, we may require proof of authorization in the form of written permission signed by you and we may require you to verify your own identity. Alternatively, your authorized agent may prove authorization with a valid power of attorney under California’s Probate Code.
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 useable and should allow you to transmit the information from one entity to another entity without 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.
DELETION REQUEST RIGHTS
You have the right to request that Investors Heritage Life Insurance Company delete any of your personal information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request (see Exercising Access, Data Portability, and Deletion Rights), 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 retaining the information is necessary for us or our service provider(s) to:
- Complete the transaction for which we collected the personal information, provide a good 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.
- Debug products to identify and repair errors that impair existing intended functionality.
- Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
- Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et. seq.).
- Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information’s deletion may likely render impossible or seriously impair the research’s achievement, if you previously provided informed consent.
- Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
- Comply with a legal obligation.
- Make other internal and lawful uses of that information that are compatible with the context in which you provided it.
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.
Notwithstanding the foregoing, we may offer financial incentives permitted under the CCPA that could result in different prices, rates, or quality levels. Such incentives will relate to the value of your personal information and include terms that describe the incentive’s material aspects. You must opt in to participate in any such financial incentive and you may revoke your consent at any time.
OTHER CALIFORNIA PRIVACY RIGHTS
California’s “Shine the Light” law (Civil Code Section § 1798.83) permits users of our Website that 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 send an email to email@example.com, or write us at: Investors Heritage Life Insurance Company, PO Box, 717, Frankfort, KY 40602.
CHANGES TO OUR PRIVACY NOTICE
Investors Heritage Life Insurance Company reserves the right to amend this privacy notice at our discretion and at any time. When we make changes to this privacy notice, we will post the updated notice on the Website and update the notice’s effective date. Your continued use of our Website following the posting of changes constitutes your acceptance of such changes. You are responsible for periodically checking the Website and this Privacy Notice for California Residents for any changes.
Investors Heritage Life Insurance Company
PO Box 717
Frankfort, KY 40602