Insurance Benefits of America CCPA Disclosure

PRIVACY ADDENDUM FOR CALIFORNIA RESIDENTS This PRIVACY ADDENDUM CALIFORNIA RESIDENTS (“Notice”) supplements the information contained in our Privacy Policy and applies solely to visitors, users, and others who reside in the State of California (“consumers” or “you”). We adopt this Notice to comply with the California Consumer Privacy Act of 2018 (“CCPA”) and other California privacy laws. This Notice describes the personal information we collect from visitors to and users of our website (“Site”) and how we collect, use, and share personal informational. Any terms defined in the CCPA have the same meaning when used in this Notice. Information We Collect In order to be provided with a quote, you must first provide certain information. During the registration process, we collect personal information such as your name and email address. When you choose to use certain other features of the Site, we collect personal information, such as your phone number, email address, name, zip code. Generally, the information we collect 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”). We will only collect, use, and share your personal information where we are satisfied that we have an appropriate legal basis to do this. The chart below summarizes the personal information that we collect from consumers, the category of information, a description of the information collected, examples of what the information may include and a statement indicating whether the information was actually collected within the last twelve (12) months:

B.

Protected classification characteristics under California or federal law.

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.

YES

C.

Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).

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).

YES

Personal information does not include:

• Publicly available information from government records.
• De-identified 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 customers or their agents. For example, from information submitted to us via our website.
• Indirectly from our customers or their agents. For example, through information we collect from our customers in the course of providing services to them.
• Directly and indirectly from activity on our website. For example, from submissions through our website portal or website usage details collected automatically.
• Use 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 provide you with email alerts, event registrations and other notices concerning our products or services, or events or news, that may be of interest to you.
• To carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collections.
• To improve our website and present its contents to you.
• For testing, research, analysis and product development.
• As necessary or appropriate to protect the rights, property or safety of us, our customers or others.
• 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 evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by us is among the assets transferred.

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 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 disclosed the following categories of personal information for a business purpose: Category A: Identifiers. Category B: California Customer Records personal information categories. Category C: Protected classification characteristics under California or federal law. Category E: Internet or other similar network activity. We disclose your personal information for a business purpose to the following categories of third parties:

• Our business affiliates.
• Third party service providers
• Other third parties to whom you or your agents authorize us to disclose your personal information in connection with products or services we provide to you

For more information about the use and disclosure of personal information, please consult our general Privacy Policy 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 and use of your personal information over the past 12 months. Once we receive and confirm 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 or commercial purpose for collecting or selling that personal information
• The categories of third parties with whom we share that personal information
• The specific pieces of personal information we collected about you (also called a data portability request).

If we sold or disclosed your personal information for a business purpose, two separate lists disclosing:
sales, identifying the personal information categories that each category of recipient purchased; and
disclosures for a business purpose, identifying the personal information categories that each category of recipient obtained.

Deletion Request Rights You have the right to request that we 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, 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 providers 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 his or her free speech rights, or exercise another right provided for by law.
Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 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.

Rights to Opt-Out of Sale of Your Personal Information California privacy laws require us to provide California residents with the option to opt-out of current or future sales of their information. This information includes, but is not limited to name, postal or email address, and other personally-identifying information. You need not be physically present in California to exercise this right so long as you have a current California residence. This right is subject to certain exemptions. For example, the law does not apply to information that has been aggregated and/or de-identified such that it could not reasonably be used to identify you. It also does not apply to information that we share with third-party service providers in order for them to perform certain business functions for us. Exercising Access, Data Portability, Deletion, and Opt-Out Rights If you would like to exercise any of your rights provided by the CCPA, such as the right to access or delete your personal information, or to opt-out of the sale or future sale of your personal information you or your authorized agent or representative may contact us in writing via email at support@insurancebenefitsofamerica.org. As with the right to opt-out, the other rights provided by the CCPA are subject to certain exemptions and exceptions, as specified in the applicable federal statutes and/or associated regulations issued by California’s Office of the Attorney General. Those statutes and/or regulations may also stipulate the maximum time allowed for acknowledging and responding to a request. There is no charge for making privacy-related requests. Verifying a Request Please note that 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. You may also make a verifiable consumer request on behalf of your minor child. In order to better safeguard your privacy and the privacy of others, we may be required to verify your identity before processing certain data-related requests. 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. Additionally, in some cases, we may be unable to fulfill your request because we have no way to verify your identity to the standard the law and/or its associated regulations require. For example (but without limitation), if you have visited our website, but never left a comment, submitted a Contact Form, completed a financial transaction with us, or interacted with us via email or other means, we probably do not have enough information to confirm your identity to even a “reasonable degree of certainty” (as the applicable regulations may define that term). Please note that making a verifiable consumer request does not require you to create an account with us. We will only use personal information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.

Please be aware that, in addition to any other exemptions applicable law and/or regulation may provide to your rights under the CCPA, specifically with regard to the deletion of your personal information, we may be unable to delete certain information due to regulatory requirements or other technical reasons (e.g., our web host’s server and error logs). Response Timing and Format We 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. If you have an account with us, we will deliver our written response to that account. If you do not have an account with us, we will deliver our written response by mail or electronically, at your option. 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. Non-Discrimination 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.

Changes to Our Privacy Notice We reserve the right to amend this Privacy Notice at our discretion and at any time. When we make changes to this Privacy Notice, we will notify you by email or through a notice on our website homepage. Contact Information If you have any questions or comments about this Notice, our Privacy Policy, 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 California law, please do not hesitate to contact us via: support@insurancebenefitsofamerica.org