US Privacy Notice

Last Updated and Effective Date: May, 21 2024

This US Privacy Notice supplements the Southwestern Privacy Notice and includes additional information and disclosures we are required to provide to you under US State Data Protection Laws (defined below). You should read them both carefully.
To make it simple, we use the same terms as defined in our Privacy Notice. Any new terms will be defined below. This US Privacy Notice should be read together with our Privacy Notice.
While this US Privacy Notice contains information required by the California Consumer Privacy Act (“CCPA”), as amended by the California Privacy Rights Act, the Colorado Privacy Act, the Virginia Consumer Data Protection Act, the Utah Consumer Privacy Act, the Connecticut Data Privacy Act, and other US data protection laws, as amended or replaced from time to time, along with any implementing regulations (collectively, “US State Data Protection Laws”), Southwestern applies certain privacy controls to all US users.

Effective Date and Changes to this US Privacy Notice

Like the Privacy Notice, this US Privacy Notice is effective as of the “Last Updated and Effective Date” above and will remain in effect except with respect to any provisions that are changed in the future. Southwestern may make changes to this US Privacy Notice from time to time and will notify you by posting a revised version on the Site. Any changes will be effective immediately upon their posting to the Site or upon you being otherwise notified. You are expected to check this page regularly so you are aware of any changes, as they are binding on you. Your continued use of our products, services, or the Site following the posting of a revised US Privacy Notice means that you accept and agree to the changes. We will also revise the date found at the beginning of this US Privacy Notice when we post changes to it.

Personal Information We May Collect about You, the Purposes for Which We Collect It, and the Recipients which We Disclose it to

In the chart below, we list the categories of Personal Information as defined under the CCPA for California residents. Some of the categories below require separate opt-in consent and these categories do not necessarily reflect all of the types of information that we may collect about you. We will provide you a separate notice if we collect any additional Personal Information about you. Some Personal Information included in the categories may overlap with other categories.

In the last 12 months, we have collected the following categories of Personal Information.

Category	Data Elements
Identifiers	Real name, postal address, email address, unique personal identifier, online identifier, Internet Protocol address, phone number, or account name.
Personal information categories listed in the California Customer Records provisions	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.
Demographic information which may be protected classification characteristics under state or federal law	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, or genetic information (including familial genetic information).
Commercial information	Records of products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.
Internet and network activity information	Browsing or search history, device and application identification numbers, and data about your interactions with websites, applications, or advertisements (e.g., through cookies, tracking pixels, session replay technologies, and chat bots; see our Cookie Notice).
Sensory data	Audio, electronic, or visual information. This may include audio recordings, photographs, or videos captured during meetings, events, or calls with you.
Professional or employment-related information	Current or past job history or performance evaluations.
Non-public education information	Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records.
Inferences	When we combine information we learn about you that is not Personal Information (information related to your preferences or Technical Information, described below) with Personal Information we have collected about you, we treat those inferences as Personal Information.
Sensitive personal information	Social security, driver’s license, state identification card, or passport number; account log-in, financial account, debit card, or credit card number in combination with any required security or access code, password, or credentials allowing access to your account; precise geolocation; racial or ethnic origin, religious or philosophical beliefs, or union membership; mail, email, and/or text messaging contents where Southwestern is not an intended recipient; biometric information; and genetic data.

Depending on our interactions with you, the categories of Personal Information that we may have collected from you in the last 12 months that may include Sensitive Personal Information are:

Category	Data Elements
Identifiers	Social Security, driver’s license, state identification card, or passport number.
California Customer Records	Financial account information (usernames, account numbers, credit or debit card numbers, and access/security codes or passwords necessary to access associated accounts).
Demographic information which may be protected classification characteristics under state or federal law	Racial or ethnic origin, religious or philosophical beliefs, union membership, health, sex life, or sexual orientation information.
Other sensitive personal information	Genetic data, mail, email, or text message contents not directed to us.

Generally, when you provide the Sensitive Personal Information listed above, you do so voluntarily. In certain instances, we may require your Sensitive Personal Information in order to process certain requests. We may deny your request if you do not provide the required information.

If you would like to review the purposes for which we collect and use Personal Information and the categories of sources of Personal Information, please see the Privacy Notice.

In the chart below, we list categories of the recipients to which we disclosed Personal Information for a business purpose and which categories of Personal Information that Southwestern has shared with third parties for cross-contextual behavioral advertising in the preceding 12 months.

Please note, we do not sell your Personal Information.

Personal Information Category	Categories of Third-Party Recipients
	Business Purpose Disclosures	Sharing
Identifiers	Business Communication and Collaboration, Analytics, Customer Relationship Management, Customer Support, Cybersecurity, Finance and Accounting, Legal, Order Fulfillment, Payment Processing, Payment Collections, and Sales and Marketing	Advertising and Marketing Partners, and Social Media Networks
California Customer Records	Business Communication and Collaboration, Analytics, Customer Relationship Management, Customer Support, Cybersecurity, Finance and Accounting, Legal, Order Fulfillment, Payment Processing, Payment Collections, and Sales and Marketing	None
Demographic information which may be protected classification characteristics under state or federal law	Business Communication and Collaboration, Customer Relationship Management, Order Fulfillment, and Legal	None
Commercial Information	Business Communication and Collaboration, Customer Relationship Manager, Customer Support, Finance and Accounting, Legal, Order Fulfillment, Payment Processing, Payment Collections, and Sales and Marketing	None
Internet and network activity information	Analytics, Customer Support, Cybersecurity, Hosting, Payment Processing, Legal, and Sales and Marketing	Advertising and Marketing Partners, and Social Media Networks
Sensory data	Business Communication and Collaboration, Legal, and Order Fulfillment	None
Professional or employment-related information	Business Communication and Collaboration, Customer Relationship Manager, Legal, and Order Fulfillment	None
Non-public education information	Business Communication and Collaboration, Customer Relationship Manager, Legal, and Order Fulfillment	None
Inferences	None	Advertising and Marketing Partners, and Social Media Networks
Sensitive personal information	Business Communication and Collaboration, Customer Relationship Management, Customer Support, Order Fulfillment, Payment Processing, Payment Collections, and Legal	Advertising and Marketing Partners, and Social Media Networks

Additionally, we may collect NPI about you for certain products and services. NPI is associated with the provision of a financial product or service (for example, a product or service from Southwestern Insurance Group or Southwestern Legacy Insurance Group), including identifying and transactional information such as name, postal address, email address, Social Security number, account numbers, payment history, loan or deposit balances, and credit or debit card purchases.

How We Use Your Personal Information

We disclose some of your Personal Information for cross-context behavioral advertising, and certain state laws consider this “Selling” or “Sharing” Personal Information. Based on this broad definition, some of our companies may sell your Personal Information to third parties, subject to rights you may have to opt-out of those sales.

The chart above indicates the categories of Personal Information that Southwestern companies have shared for cross-context behavioral advertising purposes in the preceding 12 months and the categories of third parties to which Southwestern has made these disclosures. Our Personal Information sharing does not include information about individuals we know are under age 16. If you would like to opt out of this sharing, please click Do Not Sell or Share My Personal Information.

At the same time, consumers have the right to opt out of Southwestern’s disclosures of NPI to nonaffiliated third parties by clicking here.

Video Data

When you purchase Southwestern’s services that include videos and during other interactions you may have with our services, products, and Site, we may collect and use video viewing data in order to provide you with personalized recommendations and other features. This data may include information about the videos you have watched, the time and date of viewing, and other similar information. We may disclose this data to third parties, including the service providers that assist us with providing those videos and related services to you and to social media networks for cross-contextual behavioral advertising.

Your US State Law Privacy Rights

You have certain choices regarding your Personal Information. Some of these choices and rights may vary based on where you live. We will not discriminate against you because you exercise these rights.

Right to Know and Data Portability/Right of Access

Consumers may 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 (the “Right to Know”) or to confirm whether Southwestern is processing your personal data and to access this personal data (the “Right to Access”).

Once we receive your request and confirm your identity (see Exercising Your Rights), we will disclose to you:

The categories of Personal Information we collected about you (disclosed above).
The categories of sources of the Personal Information we collected about you (disclosed above).
Our business or commercial purpose for collecting, selling, or sharing that personal information (disclosed above).
The categories of third parties to whom we disclose that personal information (disclosed above).
The specific pieces of Personal Information we collected about you in a portable and readily usable format when Southwestern processes the information through automated or searchable means (also called a “data portability” request).

Right to Delete

Consumers may have the right to request that we delete the Personal Information that you have provided or that we have collected or obtained about you, subject to certain exceptions.

Once we receive your request and confirm your identity (see Exercising Your Rights), we will review your request to see if an exception allowing us to retain the information applies. We will delete from our records or deidentify Personal Information not subject to a lawful exception and will direct our service providers to take similar action.

Right to Correct Inaccurate Information

Consumers may have the right to request correction of any inaccurate personal information that we maintain about you, taking into account the nature of the Personal Information and the purposes of the Personal Information processing. We will use commercially reasonable efforts to correct this information.

Right to Opt-Out of Sale or Sharing (Opt-In for Minors or Sensitive Data)

Consumers may have the right to opt-out of Personal Information sales or sharing or the right to opt-in to Personal Information sales or sharing if the consumer is a minor or if the information at issue is Sensitive Personal Information.

Specifically, consumers may have the right to request to opt out of the processing of the personal data for purposes of (i) targeted advertising, (ii) the sale of personal data, or (iii) profiling in furtherance of decisions that produce legal or similarly significant effects concerning the consumer.

Southwestern does not generally sell any Personal Information, but it does use cookies. Therefore, please review our Cookie Notice and Your Cookie Rights and Choices regarding cookies.

In addition to your cookie preferences, if you are age 16 or older, you may have the right to direct us to not sell or share your Personal Information at any time. We do not sell or share the Personal Information of consumers we actually know are less than 16 years old. Consumers who opt-in to Personal Information sales or sharing may opt-out of future sales at any time.

To exercise the right to opt-out or opt-in, you (or your authorized representative) may submit a request to us by visiting the following Internet Web page link: Do Not Sell or Share My Personal Information.

Once you make an opt-out request, we will wait at least 12 months before asking you to reauthorize Personal Information sales or sharing. However, you may change your mind and opt in again to Personal Information sales or sharing at any time.

You do not need to create an account with us to exercise your opt-out rights. We will only use Personal Information provided in an opt-out request to review and comply with the request.

Right to Non-Discrimination

We will not discriminate against you for exercising any of your state law privacy rights. Unless permitted by law, we will not:

Deny you products or services.
Charge (or suggest you may receive) different prices for products or services, including through granting discounts or other benefits or imposing penalties.
Provide (or suggest you may receive) a different level or quality of products or services.

However, we may offer you certain financial incentives permitted by state privacy laws that can result in different prices, rates, or quality levels, such as offering coupons, discounts, promotions, other price reductions, or promotional offers for products and services in exchange for providing your Personal Information. Any financial incentive we offer will comply with state privacy laws and will reasonably relate to your Personal Information’s value and contain written terms that describe the program’s material aspects. Participation in a financial incentive program requires your prior opt-in consent, which you may revoke at any time. Do not provide your Personal Information if you do not want to opt-in to these offers. After you receive a promotional offer, you may opt-out by contacting us as specified. For more information, please see Exercising Your Rights, below.

Profiling

Additionally, Southwestern does not generally engage in profiling with the information we collect about you, except to the extent that our use of cookies for targeted advertising qualifies as profiling under applicable law. Therefore, please review our Cookie Notice and Your Cookie Rights and Choices regarding cookies.

Exercising Your Rights

To exercise your rights, please contact us at:

Form: here
Phone: (888) 551-5901
Postal Address:
c/o the Vice President of I.T. of the Southwestern Family of Companies
2451 Atrium Way
Nashville, Tennessee 37214

The deletion or cessation of collection of information may result in cancellation of programs and subscriptions or other services initially provided to you.

Your request must:

Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.
Provide sufficient information, which will likely need to match information we previously collected from you, that allows us to reasonably verify you are the person about whom we collected Personal Information or someone legally authorized to act on your behalf (an “Authorized Agent”). In some instances, we may ask you to provide a signed declaration under penalty of perjury that you are the consumer whose personal information is the subject of the request. For requests seeking particularly Sensitive Personal Information, we may require additional proof of identification.

Only you, or sometimes an Authorized Agent, may make requests related to your Personal Information. If you would like, you may designate an Authorized Agent to make a request under some state privacy laws. We will deny requests from agents that do not submit proof of authorization from you. If you designate an Authorized Agent to make a request, to verify that an Authorized Agent has authority to act for you, we may require:

A copy of a power of attorney or require that you provide the Authorized Agent with written permission.
You to verify your own identity with us directly.

We will only use Personal Information provided in the request to verify the requestor’s identity or authority to make it, except for record-keeping purposes. We will delete this information as soon as practicable after complying with the request.

Response Timing and Format

We aim to confirm receipt of your request within ten business days. If you do not receive confirmation within the ten-day timeframe, please contact [email protected].

We endeavor to substantively respond to a verifiable consumer request within 45 days of its receipt. If we require more time (up to another 45 days), we will inform you of the reason and extension period in writing. We will de

liver our written response by mail or electronically, at your option.

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 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.

Appeal Process

If you would like to submit an appeal for any decision with regard to any Consumer request, please contact [email protected] with the subject line: DSAR Appeal.

Other California Privacy Rights

Shine the Light Law

Southwestern does not make any disclosures of Personal Information to third parties for the third party’s direct marketing purposes, but California’s “Shine the Light” law permits users of our Site that are California residents to request information about such disclosures, if applicable. To make such a request, please contact us through the information above.