Fidelity Security Life Insurance Company® Notice to California Residents
The California Consumer Privacy Act of 2018 (CCPA), gives California residents rights and control over their personal information. Fidelity Security Life Insurance Company® (“FSL”, “we", “us” or “our”) provides this notice to those California residents ("you", “your”) in accordance with requirements under the CCPA to make certain disclosures about the collection and processing of your personal information. Most of the personal information we collect is already protected and governed by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and certain federal Financial privacy laws (Gramm-Leach-Bliley Act (GLBA)) and is therefore exempt from most CCPA obligations. As such, this notice provides disclosures and information for California residents regarding the limited personal information we collect that is subject to the CCPA.
Your Rights Under the CCPA
If you are a California resident, you have certain rights under the CCPA regarding your personal information, including:
Right to Access
You have the right to request that we disclose the following information to you about our collection and use of your personal information for the preceding 12- month period:
- The categories and specific pieces of personal information we have collected about you;
- The categories of sources from which your personal information was collected;
- The business or commercial purpose for collecting or selling your personal information (we do not sell your personal information); and
- The categories of third parties with whom we have shared your personal information.
Right to Request Deletion
You have the right to request that we and our service providers delete any personal information which we have collected about you. We and our service providers will not delete your personal information if it is necessary or permissible for us or our service providers to maintain the personal information pursuant to the CCPA or other applicable state laws or federal law such as HIPAA or GLBA.
Right to Non-Discrimination
You have the right not to be discriminated against for exercising your rights under the CCPA. Specifically, we may not deny you goods or services; charge you different prices or rates for goods or services; provide you a different level or quality of goods or services; or suggest that you receive a different price or rate for goods or services or a different level or quality of goods or services.
How to Exercise Your Rights
To exercise one or more of your rights, you or your authorized agent may make a request by emailing us at CCPA-Request@fslins.com with subject line “CCPA Consumer Rights Request” and include the following information:
Date of Birth*
By submitting a request, you consent to receive phone calls from FSL, at the phone number above, including your wireless number if provided, for purposes of processing your CCPA request.
Or, you may call us at 800-648-8624 and let the operator know you are calling with a “CCPA Consumer Rights Request”. Our hours of operation are 6:30 a.m. to 6:30 p.m. CST, Monday through Friday, except holidays.
If you choose to submit a request through an authorized agent, we will require proof that the authorized agent has your written permission to submit a request on your behalf.
There are some situations where we will not, or may not be able to, fulfill some or all of your CCPA request:
- If you are not a California resident
- If we cannot verify the identity of you or your authorized agent
- If we cannot match the data that we have on file to your verified credentials
- If we are required or permitted to keep some or all your personal information under state or federal laws or regulations.
Categories, Sources, Purpose, Use and Disclosure of Personal Information
The information that follows shows the types of personal information we may collect about California residents who are subject to the CCPA, the sources from which we collect it, the purpose for collection, and the ways in which we use it and disclose it to third parties.
Categories of Personal Information
The categories of personal information we may collect that are subject to the CCPA are:
- Personal identifiers (such as name, address, email address)
- Internet or other network or device activity (such as browsing history or usage information and associated device IDs and IP addresses).
Personal information does not include:
- Publicly available information
- Information specifically excluded from the CCPA’s scope:
- Health or medical information covered by HIPAA*; and
- Personal information covered by GLBA
*Please see our HIPAA Notice of Privacy Practices at fslins.com for information about how we handle your personal information subject to HIPAA.
Sources of Personal Information
We obtain personal information from the following sources:
- We obtain your personal information when you provide it to us (e.g., where you contact us via email or telephone, or by any other means)
- We receive your personal information from third parties that interact with us in connection with the services we perform
- We collect or obtain personal information when you visit any of our websites or use any features or resources available on or through our website. When you visit a website, your device and browser may automatically disclose certain information (such as device type, operating system, browser type, browser settings, IP address, language settings, dates and times of connecting to a website and other technical communications information), some of which may constitute personal information
Purposes for Which We Use of Personal Information
We may use or disclose personal information we collect about you for one or more of the following purposes:
- Marketing and providing insurance to California residents;
- Determining your eligibility for a quote;
- Calculating your premium;
- Administering claims;
- Answering questions and providing notifications;
- Supporting day-to-day business operations and insurance related functions;
- Detecting security incidents, protecting against fraudulent or illegal activity, and to comply with regulatory and law enforcement authorities;
- Confirming your identity and servicing your policy;
- Providing customer and technical support;
- Enhancing your customer experience and improving our products and services;
- Creating, maintaining, customizing and securing accounts;
- Undertaking internal research for technological development;
- Developing and offering new products and services;
- Marketing products and services with strategic partners;
- Exercising and defending our legal rights and positions;
- Managing risk and securing our systems, assets, infrastructure, and premises;
- Responding to law enforcement requests and as required by applicable law, court order, or governmental regulations;
- To fulfill FSL’s contractual obligations;
- To help ensure the safety and security of FSL’s staff, assets, and resources, which may include, but is not limited to, physical and virtual access controls and access rights management; supervisory controls and other monitoring and reviews, as allowed by law; and emergency and business continuity management; and
- As otherwise required by federal or state law.
Disclosure of Information to Third Parties
We do not share your information with companies, organizations and individuals outside of FSL unless one of the following circumstances applies:
As Necessary to Provide You the Products and Services You Request
We may share your information with insurance companies, reinsurance companies and their respective administrators, vendors, agents, and third-party service providers, including but not limited to insurance support organizations, that are engaged in services related to underwriting, claims administration and issuing insurance policies as needed to provide you the insurance products and services you request.
We may also share your information with third-party vendors, agents and other service providers that perform services on our behalf, as needed to carry out their work for us, which may include billing, payments, background check services, service fulfillment, web hosting or providing analytic services. We provide only as much information as is needed for these third-party vendors, agents and other service providers to perform services on our behalf.
For Legal Reasons
In Connection with Our Sale or Other Significant Transaction
We may share your information with companies, organizations or individuals in connection with a significant transaction, such as a merger, sale of our assets or shares, reorganization, financing, change of control or acquisition of all or a portion of our business by another company or third party or in the event of a bankruptcy or related or similar proceedings.
With Our Affiliates
We may share your information with other companies owned by or under common ownership as FSL. These companies will use your personal information in the same way as we can under this notice.
Sale of Personal Information
We do not offer an opt-out from the sale of personal information because we do not engage in the sale of personal information as contemplated by the CCPA. As noted elsewhere in this notice, we share personal information with other businesses for a variety of reasons.
Changes to this Notice
We may change this notice from time to time. When we do, we will let you know by appropriate means such as by posting the revised notice on our web site with a new “Last updated” date. Any changes to this notice will become effective when posted unless indicated otherwise. For questions or concerns about our privacy policies and practices, please contact:
Fidelity Security Life Insurance Company®
Kansas City, MO 64111
Last updated 1/29/2020