INSHUR is subject to the investigatory and enforcement powers of the Federal Trade Commission (FTC).
THE INFORMATION WE COLLECT
Non-public personally identifiable information (“Information”) is information that identifies you and is not available to the general public. The following sections tell you more about how and when we collect your Information.
INFORMATION WE OBTAIN FROM YOU
In all cases, we will collect personal data about you in accordance with the principles
outlined in this Policy and applicable local law. You should be aware that our “lawful basis” for processing personal data about you may be impacted by the legal requirements in the country in which you reside. As such, outside of the European Economic Area (EEA), we may at times rely on consent to process personal data about you, whereas within the EEA we will seldom rely on consent as the lawful basis for processing personal data about you, except as indicated below.
The personal data about you that we collect includes the following categories of data:
If you gave us your email or mailing address, INSHUR may use it from time to time to notify you of such things as new services, special offers, or to confirm transactions. If you do not wish to be contacted by email for non-policy related communications, you may unsubscribe by following the instructions at the bottom of any INSHUR email you receive.
INFORMATION ABOUT YOUR TRANSACTIONS
We may collect Information about your transactions and experiences with us and others, such as your payment history, claims, coverage, and vehicle changes.
INFORMATION FROM THIRD PARTIES
We may receive Information about you from reporting agencies, which provide us with motor vehicle reports.
As permitted by law, we may also review your motor vehicle record and claims history with any renewal.
ACCESS AND CORRECTION OF PERSONAL INFORMATION
If you’d like to correct information that you provided to us, our representative will make the appropriate adjustments to INSHUR’s records. If you wish to correct personal information provided to INSHUR by a third party (such as a motor vehicle reporting agency) the representative will provide you with the applicable third party’s contact information. We will take reasonable steps to verify the accuracy of the personal information in our records.
THE INFORMATION WE DISCLOSE
Information about our customers or former customers will only be disclosed as permitted or required by law. Information about you that has been collected is maintained in your policy and/or claims records.
We use this Information to process and service your policy; to settle claims; with your consent; or as directed by you. We may also disclose it to persons or organizations as necessary to perform transactions you request or authorize. Information about our former customers and about individuals who have obtained quotes from us is safeguarded to the same extent as Information about our current policyholders.
The following are some examples of how we may disclose Information:
— We must exchange Information about you with underwriters, appraisers, attorneys, and other persons who are or will become involved in processing your application and servicing your policy or any claims you may make.
— When you are involved in a claim, policy information is provided to adjusters and the businesses that will repair your vehicle.
— We may share Information with persons or organizations that we have determined need the Information to perform a business, professional, or insurance function for us. These include businesses that help us with administrative functions. All of these entities are obligated to keep the Information that we provide to them confidential and to use the Information only for the purpose for which the Information was provided.
— Information may be provided to organizations conducting actuarial research or audits. In this case, you will not be individually identified in any research report. The organization must agree not to redisclose the Information and the Information will be returned to us or destroyed when it is no longer needed.
We may also share your Information for other permitted purposes, including:
— with another insurance company if you are involved in an accident with their insured
— with your insurance company as needed for claims and underwriting purposes
— with state insurance departments or other governmental or law enforcement authorities if required by law or to protect our legal interests or in cases of suspected fraud or illegal activities if ordered by a subpoena, search warrant or other court order
— with a third party loss control partner
We do not disclose your personal data to non-affiliated third parties for those third parties’ direct marketing purposes, nor do we sell your personal data.
In addition, California law entitles California residents who have used our services for personal purposes, to request information concerning whether we have disclosed certain information about you within the past year to any third parties for the third parties’ direct marketing purposes. California users who wish to request further information in compliance with this law or have questions or concerns about our privacy practices and policies may contact us as specified in the “What to do if you have Privacy or Security concerns” section below.
You have the right to choose (opt out) whether your personal data is (i) to be disclosed to a third party or (ii) to be used for a purpose that is materially different from the purpose(s) for which it was originally collected or subsequently authorized by you.
If you wish to opt out, all you need to do is contact us using the information in the section called “What to do if you have privacy or security”.
Applicable law allows certain exceptions to your ability to opt out, such as where we are parties to a contract that is still being performed, where law requires us to maintain information. Where applicable law permits us to retain and continue to use such information and we do so, we will do so only to the extent permitted or required by law. If you contact us to opt out, we will explain the options available and comply with your request as required by the Principles and applicable law.
The above choice/opt-out doesn’t apply where the sharing of your personal data is with a third party who is acting as our agent (such as our service providers who perform services that help us to run our business). We won’t provide your personal data to a third party under these circumstances unless we have a contract in place with that third party that requires the third party to comply with the Principles.
We will obtain your affirmative express consent (opt in) from you if we collect sensitive information and that information is to be (i) disclosed to a third party or (ii) used for a purpose other than those for which it was originally collected or subsequently authorized by the individuals through the exercise of opt-in choice. We also treat as sensitive any personal data received from a third party where the third party identifies and treats it as sensitive.
CONFIDENTIALITY AND SECURITY
We restrict access to your Information to employees who we have determined need it in order to provide products or services to you. We train our employees to safeguard customer information. We maintain strict physical, electronic, and procedural safeguards to protect your Information from unauthorized access by third parties.
INSHUR complies with the EU-U.S. Privacy Shield Framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information transferred from the European Union to the United States.
INSHUR commits to cooperate with EU data protection authorities (DPAs) and comply with the advice given by such authorities with regards both non-human resources data and to human resources data transferred from the EU in the context of the employment relationship.
In cases of onward transfer to third parties of Personal Data received pursuant to the EU-U.S. Privacy Shield, Inshur is potentially liable.
STORAGE AND PROCESSING PERSONAL DATA
We store personal data about you on computer systems operated by or under the supervision of INSHUR or our affiliates or service providers and/or at our facilities. Our primary data center is located in United States of America. We will maintain personal data about you for as long as necessary in connection with both our and your legal rights and obligations for the purposes for which it was collected, to defend or advance legal claims, or as otherwise required by applicable laws. We will delete personal data about you within 10 years of the expiration of a required retention period, as described above, at your request (where such request conforms to the relevant legal requirements and is not otherwise limited), and in any case, upon expiration of the maximum storage term set forth by applicable law.
ADDITIONAL INFORMATION FOR OUR INTERNET USERS
We continuously improve INSHUR.com. We are interested in how visitors use our website, what they like and dislike, and where they have problems. We may gather data on how users navigate our site so we can make INSHUR.com an easy place to do business. Our tools may gather data such as what browser a person uses or even what pages are most popular.
Some browsers have incorporated “Do Not Track” (DNT) features that can send a signal to the websites you visit indicating you do not wish to be tracked. Because there is not yet a common understanding of how to interpret the DNT signal, our services do not currently respond to browser DNT signals. For more information on DNT, see https://allaboutdnt.com/.
We do not knowingly collect personal information directly from individuals under 17 years of age. INSHUR’s services are not intended for individuals under 17 years of age. No one under 17 years of age should submit personal information through our services.
WHAT TO DO IF YOU HAVE PRIVACY OR SECURITY CONCERNS
In compliance with the Privacy Shield Principles, INSHUR commits to resolve complaints about our collection or use of your personal information. If you have a concern about privacy or security at INSHUR, we want to hear about it by mail or email. There is also the possibility, under certain conditions, for you to invoke binding arbitration.
Please write to us at:
315 W36TH Street
New York, NY 10018
or email us at [email protected].
EU individuals with inquiries or complaints regarding our Privacy Shield policy should first contact INSHUR at:
INSHUR UK LTD,
1 Jubilee Street,
or email us at [email protected].
INSHUR has further committed to cooperate with the panel established by the EU data protection authorities (DPAs) with regard to unresolved Privacy Shield complaints concerning data transferred from the EU.