PRIVACY POLICY
WCF National Insurance Company (“WCF”) appreciates the trust that you have placed in us, and we continuously strive to earn and maintain that trust. We understand the importance of protecting the confidentiality and security of your personal information. This Privacy Policy (“Policy”) lays out WCF’s California Consumer Protection Act (“CCPA”) policy. This Policy describes the types of personal information that we collect, how we may use that information and with whom we share it. This Policy describes your privacy rights and how to submit requests for information. This Policy tells you how you can reach us to ask us to answer any questions that you may have about our privacy practices.
You are being provided this Policy before WCF or its agents collect personal information about you. Please read this policy before providing any personal information. A copy of this Policy may also be found on our internet website, or in hard copy upon request.
Please be aware that certain information is not covered by the CCPA because it is already covered by other state or federal law. That information includes:
Information governed by the Health Insurance Portability and Accountability Act of 1996, the California Medical Information Act, the Gramm-Leach-Bliley Act of 1999, the California Financial Information Privacy Act, the Fair Credit Reporting Act, or the Driver’s Privacy Protection Act of 1994.
Information that is publicly available or included in federal, state, or local government records, information in public media such as newspapers or magazine articles, or by some other person to whom you have disclosed personal information if we do not have knowledge that you intended that disclosure to be private.
Categories of Information We Collect
Internet Data
Protected Class Information
Video and Audio Data
Personal Identifiers
Commercial Information
Education
Professional and Employment Information
Sources of Information We Collect and Purposes for which Your Information is Collected or Used
Because the sources and purposes related to your personal information may change from time to time, WCF provides that information in Appendix A for ease of modification.
Whether Your Information is Sold, Shared or Disclosed
WCF does not sell your personal information or share your personal information with third parties. WCF does disclose your personal information to service providers and contractors, but such disclosures are limited to those necessary business purposes for which WCF has a relationship with the service provider or contractor.
How Long Your Information is Retained
Different pieces of information are retained for different periods of time depending on many factors. Because any of our categories of information may include pieces of information maintained by different departments within WCF we cannot specify a period of time for a category. The factors which govern how long a particular piece of information will be retained include, but are not necessarily limited to:
- The purpose for which the piece of information was collected.
- Our need to retain the information to protect our rights.
- Laws or regulations that require or allow us to retain the information.
- Our ability to continue to maintain your coverage or your continued relationship with WCF.
Your Rights Regarding Your Personal Information
The CCPA provides several rights regarding your personal information. This section describes each of those several rights and identifies any limitations or special considerations that may apply.
Right to Know and To Request Disclosure
All California consumers have the right to know what personal information WCF is collecting, including personal information that WCF’s service providers or contractors collected during the year before your request and how that information will be used. Consumers also have the right to request that WCF provide specific disclosures to the consumer. Those specific disclosures include the following:
- The categories of personal information WCF has collected about the consumer.
- The categories of sources from which the personal information is collected.
- The business or commercial purpose for collecting, selling, or sharing personal information. (WCF does not sell or share your personal information.)
- The categories of recipients to whom WCF discloses personal information.
- The specific pieces of personal information WCF has collected about that consumer.
We will provide the information to you after we receive a verified consumer request from you. You may submit a consumer request to us to access personal information via our privacy portal, or you may submit your request by sending an email to privacy@wcf.com, by calling 1-866-648-5618, or by mailing to the address below. We will review the information WCF has collected about you with information that identifies you such as an address or zip code to confirm that you made the request. Once we verify your request to access personal information, we will promptly take steps to disclose and deliver, for free, the personal information required in this Policy. The information will be delivered securely to you via our online privacy portal. The information we provide to you will be in an easy to access format that allows you to transmit it to another party without difficulty.
We are required to respond to any of your requests to exercise these above rights within 45 days. If we are not able to comply with your request within 45 days we will, within that initial 45 days, inform you of the reason why we are unable to comply and the additional time we will need, not to exceed at total of 90 days.
We do not have to retain personal information that we collect for a single, one-time transaction because we do not retain that information. We are not required to provide personal information to you more than twice in a 12-month period.
Limitations on Right to Request Personal Information
WCF will provide an individualized response to a consumer for any of the information governed by this Policy. WCF may, but is not required to, provide information to a consumer more than twice in a 12-month period.
WCF does not have to retain personal information collected for a single, one-time transaction, if such information is not sold or retained by WCF or used to reidentify or otherwise links information that is not, in the ordinary course of business, maintained in a manner that would be considered personal information
The right of consumers to know and request disclosure of information does not extend to personal information about the consumer that WCF maintains on behalf of another natural person.
WCF is not required to provide this information if doing so would be impossible or would involve disproportionate effort.
Request to Delete
A consumer has the right to request that WCF delete any personal information about the consumer which WCF has collected from the consumer. Once WCF receives a verifiable request from a consumer to delete the consumer’s personal information WCF will, to the extent feasible under this Policy, delete the consumer’s personal information from its existing systems and direct any service providers or contractor to delete the consumer’s personal information from their systems.
WCF does not need to comply with a consumer’s request to delete the consumer’s personal information if the information is necessary for WCF business purposes, which may include:
- To complete a transaction for which the personal information was collected.
- To facilitate security.
- To identify and repair system errors.
- To comply with a legal obligation.
WCF also does not need to delete the information if doing so is impossible or involves disproportionate effort. WCF will inform the consumer of the extent to which it was able to comply with the consumer’s request. If we deny your request for deletion because of the reasons above, or any other reason identified in the CCPA, we will notify you via our privacy portal and send you a letter that explains the information that was not deleted and why it was not deleted.
Request to Correct Inaccurate Personal Information
A consumer has the right to request that WCF correct any inaccurate personal information maintained by WCF. Upon receipt of a verifiable consumer request to correct inaccurate personal information, WCF shall use commercially reasonable efforts to correct the information. WCF will use the totality of circumstances to determine the accuracy of the personal information. WCF must accept and review any documentation you provide and may require you to provide documentation if necessary to rebut WCF’s own documentation that the personal information is accurate. Consumers should make a good-faith effort to provide WCF with all documentation supporting their claim that any information is inaccurate. WCF may deny a request to correct if WCF determines that the contested personal information is more likely than not accurate based on the totality of the circumstances, where the same request to correct has been submitted within the past six months, where WCF has a reasonable documented belief that the request is fraudulent or abusive, or where WCF is not the source of the inaccurate information. WCF may at its discretion delete the contested personal information if doing so would not negatively impact the consumer or the consumer consents to the deletion.
In responding to the request to correct, WCF shall inform the consumer of the extent it can comply with the consumer’s request and explain the basis for any denial of the request.
Request to Opt-Out of Sharing
WCF shall honor the request of a consumer that the consumer’s personal information not be shared with third parties. WCF does disclose personal information to service providers and contractors for necessary business purposes but, under the CCPA, service providers or contractors with a CCPA-compliant contract with WCF are not considered third parties. Although WCF does not currently share personal information with third parties, should WCF elect to share personal information with third parties, the consumer will be given notice of the intent to share and informed of the consumer’s right to opt-out of sharing. Do not sell or share my personal information.
Request to Limit Use or Disclosure Sensitive Personal Information
WCF acknowledges the right of consumers to direct that the collection and use of sensitive personal information be limited to WCF’s necessary business purposes. Because WCF does not share, use, or disclose sensitive personal information, other than for necessary WCF business purposes, WCF does not provide an opt-out link on WCF’s website. Should WCF elect to use or disclose sensitive personal information for other purposes, notice of the intended disclosure shall be provided to consumers and informing them of their right to limit those intended disclosures and directing them to a link that would be created for that purpose.
If we deny your request for deletion because of the reasons above, or any other reason identified in the CCPA, we will notify you via our privacy portal and send you a letter that explains the information that was not deleted and why it was not deleted.
Exercising Your Rights:
If you want to exercise your rights, you may contact WCF Insurance via our privacy portal, at its toll-free telephone number, dedicated email address or dedicated mailing address. You may designate an authorized agent to act on your behalf in submitting a request to us. We may require you to provide your authorized agent written permission to act on your behalf. For us to respond to your request, we must know who you are. We will not respond to any request if we are unable to verify your identity and therefore confirm the Personal Information in our possession relates to you. You are not required to create an account with us to submit your request. We will use any Personal Information collected from you in connection with the verification of your request solely for verification and shall not further disclose the Personal Information, retain it longer than necessary for purposes of verification, or use it for unrelated purposes. If we are unable to verify the authorized agent’s identity, we may deny a request from that agent, and we are not obligated to provide the information to you.
WCF Insurance
Address: 100 West Towne Ridge Parkway, Sandy, UT 84070
Phone: 1-866-648-5618
Email: privacy@wcf.com
Privacy Point of Contact
Attn: Privacy Office
Address: 100 West Towne Ridge Parkway, Sandy, UT 84070
Email: privacy@wcf.com
Non-Discrimination
We will not discriminate against you because you exercised any of your rights or you have made a request. If you exercise any of your rights, we will not (1) deny goods or services, (2) charge different prices or rates for goods or services, including using discounts or other benefits or imposing penalties, (3) provide a different level or quality of goods or services, (4) suggest that you will receive a different price or rate for goods or services or a different level or quality of goods or services, or (5) retaliate against an employee, applicant for employment, or independent contractor for exercising their rights under the CCPA.
Changes to Our Privacy Policy
We keep this Policy under regular review, and we will place any updates on our website. This privacy policy was last updated on June 28, 2023.