Privacy Policy

California Consumer Privacy Act (CCPA/CPRA) Privacy Notice

 

This California Privacy Notice supplements the information contained in our general Privacy Policy and applies solely to California residents. It does not apply to nonpublic personal information collected, processed, or disclosed in connection with the provision of financial products or services subject to the Gramm-Leach-Bliley Act (GLBA). Instead, this Notice describes how we collect, use, and disclose personal information outside of insurance transactions but otherwise in connection with the services we offer, including in connection with our websites, marketing activities, and prospective employment (the “Services”), and how we have done so in the past 12 months.

Please read this Notice carefully to understand our policies and practices regarding your information and how we treat it. By interacting with our Services or providing us with your information, you agree to the collection, use, and sharing of your information as described in this Notice. This Notice may change from time to time. Your continued use of the Services after we make changes as described here is deemed to be acceptance of those changes, so please check the Notice periodically for updates.

 

1. What We Collect

We may collect the following categories of personal information, for the purposes described below:

  • Identifiers: Such as contact information, account information, and email addresses.
  • Employment Information (prospective employees and agency verification): Such as resumes submitted by job applicants, and state license information used to verify agency partners.
  • Geolocation: We collect approximate geolocation data.
  • Marketing Information: Such as lead forms and contact details collected through our website.
  • Audio/Visual Information: We record customer service, claims, and sales calls through our VoIP phone system for quality assurance purposes. We may also collect photos from industry events hosted by or in connection with Orion 180.

We do not collect categories of sensitive personal information outside of what is necessary to service insurance transactions.

Additionally, our services are not intended for, and we do not knowingly collect any personal data from, children under the age of 18. If we learn we have collected or received personal data from a child under 18 years old without verification of parental consent, we will delete that information.

 

2. How We Collect Your Personal and Other Data

You Provide Information to Us

We collect information about you when you interact with our services, such as when you create or update an account, participate in surveys, or submit a form.

Automatically Through Our Services

As you navigate through and interact with our services, we may use automatic data collection technologies to collect information that may include personal data. Information collected automatically may include usage details, IP addresses, operating system, and browser type, and information collected through cookies, web beacons, and other tracking technologies, including details of your interactions with our Services, such as traffic data, location data, logs, and other communication data, and which resources and Services features that you access and use.

We may use these automatic collection technologies to collect information about your online activities over time and across third-party sites or other online Services (behavioral tracking). 

Using automatic collection technologies helps us to improve our Services and to deliver a better and more personalized experience.

The technologies we use for this automatic data collection includes:

  • Cookies. A cookie is a small file placed on your device when you interact with the Services. You may refuse to accept or disable cookies by activating the appropriate setting on your browser or device. However, if you select this setting, you may be unable to access certain features of the Services. 
  • Web Beacons. Some parts of the Services and our emails may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit the Company, for example, to count users who have visited those parts or opened an email and for other related statistics (such as recording the popularity of certain content and verifying system and server integrity). 

To the extent any of these automated technologies are considered a personal data sale, targeted advertising, or profiling under California law, you may opt out from their use through the methods described in Section 7 of this Notice. Please note that some Services features may be unavailable as a result.

When you interact with the Services, there are third parties that may use automatic collection technologies to collect information about your or your device. These third parties include:

  • Advertisers, ad networks, and ad servers.
  • Analytics companies.
  • Your device manufacturer.
  • Your internet or mobile service provider.

These third parties may use tracking technologies to collect information about you when you use the Services. The information they collect may be associated with your personal data or they may collect information, including personal data, about your online activities over time and across different websites, apps, platforms, and other online Services. They may use this information to provide you with interest-based (behavioral) advertising or other targeted content.

We do not control these third parties' tracking technologies or how they may be used. If you have any questions about an advertisement or other targeted content, you should contact the responsible provider directly.

From Business Partners and Service Providers

We may receive personal data about you from other sources and combine that with information we collect directly from you. For example, we may obtain information about you from service providers that we engage to perform services on our behalf, such as content delivery services, analytics, security and anti-fraud services, lead generation services, and data brokers.

 

3. How We Use Information

We use information that we collect about you or that you provide to us, including any personal data, to:

  • Provide you with the Services and any content, features, and information that we make available through the Services.
  • Improve our Services, including by analyzing your information and creating aggregated data derived from your information) to develop, maintain, analyze, improve, optimize, measure, and report on our Services and their features and how users interact with them.
  • Promote our Services, business, and offerings by publishing advertising on our own Services and by placing ads on third parties' services. We may use your information to model, segment, target, offer, market, and advertise our Services.
  • Carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collection.
  • Notify you when Services updates are available and about changes to any products or services we offer or provide though them.
  • In any other way we may describe when you provide the information.
  • Fulfill any other purpose for which you provide it.
  • For any other purpose with your consent.

The usage information we collect, whether connected to your personal data or not, helps us improve our Services and deliver a better and more personalized experience by enabling us to:

  • Estimate our audience sizes and usage patterns.
  • Store information about your preferences, allowing us to customize the Services according to your individual needs and interests.

  • Recognize you when you return to our Services.

     

4. Disclosures to Third Parties

We may disclose aggregated information about our users, and information that does not identify any individual, without restriction. 

We may also disclose personal data that we collect or you provide as described in this Notice:

  • To our subsidiaries and affiliates.
  • To contractors, service providers, and other third parties we use to support our organization, such as lenders, mortgage companies, or industry partners.
  • To a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of Orion 180's assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal data held by Orion 180 is among the assets transferred.
  • For any other purpose disclosed by us when you provide the information.
  • With your consent.

We may also disclose your personal data:

  • To comply with any court order, law, or legal process, including to respond to any government or regulatory request.
  • To enforce or apply our terms of use and other agreements, including for billing and collection purposes.
  • If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of our organization, our customers, or others. This includes exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction.

The categories of personal data we may disclose include:

  • Account and contact information.
  • Location information
  • Device information.
  • Content and information you elect to provide to us.

 

5. Our Safeguards

We maintain administrative, technical, and physical safeguards designed to protect the confidentiality, integrity, and availability of your information. This includes oversight by Orion180’s Board of Directors, Executives, and management team through a data security program that is supported by periodic testing, audits, and risk assessments to ensure that data security measures are adequate, appropriate, effective and in compliance with applicable laws and regulations. We maintain measures to protect against loss or damage of information due to environmental hazards or technological failures, provide regular training to employees and contractors, require due diligence of our service providers, and maintain an incident response plan to address and resolve security events in a timely manner and to meet any required regulatory reporting obligations. 

 

6. Your Rights and Choices

This section describes mechanisms you can use to control certain uses and disclosures of your information and rights you may have under applicable state law.

Advertising, marketing, cookies, and other tracking technologies choices: 

  • Cookies and Other Tracking Technologies. You can set your browser to refuse all or some browser cookies or other tracking technology files, or to alert you when these files are being sent. You can also choose whether or not to allow the Services to collect information through other tracking technologies by opting out below. If you disable or refuse cookies or similar tracking files, some Services features may be inaccessible or not function properly. Some browsers include a "Do Not Track" (DNT) setting that can send a signal to the online services you visit indicating you do not wish to be tracked. Because there is not a common understanding of how to interpret the DNT signal, our Services may not respond to all browser DNT signals. Instead, you can use the range of other tools to control data collection and use, including the cookie controls and advertising controls described in this Notice.
  • Targeted Advertising by the Company. If you do not want us to use information that we collect or that you provide to us to deliver advertisements according to our advertisers' target audience preferences, you may opt out. Note that for this opt out to function, you must have your browser set to accept all browser cookies from us. 
  • Disclosure of Your Information for Third-Party Advertising. If you do not want us to share your personal data with unaffiliated or non-agent third parties for advertising and marketing purposes, you can opt out through one of the methods below, or through the “Do Not Sell or Share My Personal Information” link at the bottom of the page. We do not control third parties' collection or use of your information to serve interest-based advertising. However, these third parties may provide you with ways to choose not to have your information collected or used in this way. To learn more about opting out of receiving targeted ads from members of the Network Advertising Initiative ("NAI"), including how to add the NAI Global Privacy Control (GPC) extension to your browser, see NAI: How to Opt Out.

Location data choices:

Location Data. You can choose whether or not to allow the Services to collect and use real-time information about your device's location through the device's privacy settings. If you block the use of location information, some Services features may become inaccessible or not function properly.

Your State Privacy Rights

Subject to certain exceptions, you have rights under California law related to your personal data, including: 

  • Access and Data Portability. You may confirm whether we process your personal data and access a copy of the personal data we process. To the extent feasible and required by state law, data will be provided in a portable format.
  • Correction. You may request that we correct inaccuracies in your personal data that we maintain, taking into account the information's nature and processing purpose.
  • Deletion. You may request that we delete personal data about you that we maintain, subject to certain exception under applicable law. 
  • Opt-Out of Using Personal Data for Cross-Context Behavioral Advertising. You may request that we do not use your personal data for this purpose. Please note that we don’t sell or share data for monetary value. Therefore your opt-out right only applies to cross-context behavioral advertising, as defined under the CCPA.

Please note that these rights are subject to various exceptions where we may not have an obligation to fulfill your request.

 

7. How to Exercise Your Rights

To exercise the rights described in this Notice, submit requests or opt-outs by any of the following methods:

  • Email: support@orion180.com
  • Toll-free: 866-590-3550
  • Mail: 
    Orion180 Insurance Company
    Attention: Customer Service
    930 S. Harbor City Blvd., Suite 302
    Melbourne, FL 32901

Please include your full name, address, and policy/claim number (if applicable), and a description of your request. We may ask for additional information to help verify your identity. You may designate an authorized representative to act for you, subject to verification.

 

8. Data Retention

We keep the categories of personal data described in this Notice for as long as reasonably necessary to fulfill the purposes described or for as otherwise legally permitted or required, such as maintaining the Services, operating our organization, complying with our legal obligations, resolving disputes, and for safety, security, and fraud prevention. For example, Customer service call recordings are retained for seven years. We consider our legal and business obligations, potential risks of harm, and nature of the information when deciding how long to retain personal data. At the end of the retention period, personal data will be deleted, destroyed, or deidentified

 

9. Changes to this Notice

We may update this Notice from time to time, and we will provide notice of any such changes to the Notice as required by law. The date the Notice was last updated is identified at the top of the page. We will notify you of changes by updating the "last updated" date and posting the updated Notice on the Services. We may email or otherwise communicate reminders about this Notice, but you should check our Services periodically to see the current Notice and any changes we have made to it.

 

10. Contact Us

To ask questions or comment about this Notice or our privacy practices, contact us at: privacy@orion180.com.