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CCPA Privacy Notice

To exercise your privacy rights and choices, fill out the California Resident Request Form or call us at (877) 327-6329.

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:

• Directly from you;
• Applicants, clients, and agents, such as the information submitted on applications and administrative forms
• Health care providers, laboratories, pharmacies, and health information exchanges;
• Health plans, group policy holders, and benefit plan administrators;
• Other insurance companies and reinsurers;
• Government agencies, including departments of insurance and departments of motor vehicles;
• Consumer reporting agencies and third party databases;
• Service providers or third parties that help us process or service transactions you request. For example, business application and technology companies, claims adjusters, appraisers, body shops, financial advisors, and attorneys;
• Job applicants, employees, agents, contractors, and consultants;
• Employers, employment agencies and education institutions;
• Customer service and client communications;
• Marketing and advertising services;
• Social media services;
• Activity on our websites collected through third party software and/or our technologies; and
• Other service providers or third parties.

Use, Disclosure, and Potential Sale/Sharing of Personal Information

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:

• To provide you with information, products, or services that you request from us;
• To fulfill or meet the reason for which the information is provided, such as underwriting, reinsurance, rate-making, policy service, claims administration, and compliance; 
• To carry out our obligations and enforce our rights arising from any contracts between us, including billing and collections;
• To provide customer service and quality assurance;
• To improve our website and present its contents to you;
• To market our products and services to you, including cross-context behavioral advertising; 
• To prevent and detect fraud and to verify your identity; 
• To respond to law enforcement requests and as required by applicable law, subpoenas, court order, or governmental regulations;
• To meet internal and regulatory compliance requirements, respond to regulatory exams, and to conduct internal and external audits; 
• To create backups and archives;
• For internal uses such as to refine business processes, increase efficiency and for other research and strategic purposes, such as business, product, strategy, and technological development;
• As necessary or appropriate to protect the rights or property of our clients or others; 
• To determine eligibility, verify information, recruit and evaluate applicants, employees, and independent contractors, manage relationships, manage access to the Company’s facilities, equipment, and systems, and conduct internal audits and investigations for new and continued appointment or employment;
• To research and analyze benefits provided as part of your employment; 
• To maintain insurance policies and coverages, including workers’ compensation and other liability insurance; and
• As otherwise described to you when collecting your personal information.

We disclose personal information for a business purpose to the following categories of service providers or third parties:

• Service providers or third parties that help us process or service transactions you request, such as group policy holders, benefit plan administrators, business application and technology companies, employment agencies, claim adjusters, appraisers, body shops, car dealerships, financial advisors, title companies, mortgage companies, attorneys, and auditors;
• Service providers or third parties that engage in marketing and advertising; 
• Health care providers, laboratories, pharmacies, health information exchanges, and health plans;
• Other insurance companies and reinsurers; 
• Governmental agencies such as departments of insurance and departments of motor vehicles;
• Consumer reporting agencies and third party databases;
• Banks and other financial institutions;
• Independent contractors, agents, and agencies;
• Third party administrators; and
• Other service providers or third parties to whom you authorize us to disclose your personal information in connection with the products or services we provide you.

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.

Your Rights and Choices

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:

• The categories of personal information we collected about you;
• The categories of sources for the personal information we collected about you;
• Our business purpose for collecting your personal information;
• The categories of third parties with whom we share your personal information;
• The specific pieces of personal information we collected about you unless doing so would be impossible or would involve disproportionate effort; and
• If we disclosed your personal information for a business purpose, the categories of personal information we have disclosed for such purposes.

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:

• Complete the transaction for which we collected the personal information, provide a product 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;
• To enable internal uses that are reasonably aligned with your expectations based on your relationship with us;
• Comply with a legal obligation; or
• Other internal and lawful uses of that information that are compatible with the context in which you provided it.

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: 

• To perform the services or provide goods reasonably expected by you; 
• To detect security incidents that compromise the availability, authenticity, integrity, and confidentiality of stored or transmitted personal information; 
• To resist malicious, deceptive, fraudulent, or illegal actions directed at us, and to prosecute those responsible for those actions; 
• To ensure the physical safety of natural persons; 
• For short-term, transient use, including, but not limited to, non-personalized advertising shown as part of your current interaction with us (provided that the information is not used to build a profile about you or alter your experience outside your current interaction with the business);  
• To perform services on behalf of us, such as maintaining or servicing accounts, providing customer service, processing transactions, verifying your information, processing payments, providing analytics services, providing storage, or other similar services; and
• To verify or maintain the quality of a service and to improve that service. 

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:

Website
Completing the California Resident Request Form

Toll-free telephone
Calling us at (877) 327-6329.

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.

Exceptions

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:

• Identifiers (such as name, mailing address, email address, telephone number, driver’s license number, social security number, and date of birth); and
• Customer records (such as age, gender, marital status, physical characteristics, medical information, health insurance information, annual income, policy values, account transactions, payment history, claims history, consumer reports, and motor vehicle records).

Additionally, the privacy rights established under the CCPA do not apply to:

• Publicly available information from government records; 
• De-identified or aggregated consumer information; and
• Clinical trial data or other qualifying research data

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.

Changes to Our Privacy Notice

We reserve the right to amend this CCPA Privacy Notice at any time. We will post the updated notice on our website here and any changes will become effective upon the posting of the updated CCPA Privacy Notice on the website.

Contact Information

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.