CA Privacy Notice
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a. California Consumer Privacy Act of 2018
The following applies to California residents, supplements this Policy, and is provided as part of our efforts to comply with the California Consumer Privacy Act of 2018 (“CCPA”). Information concerning the CCPA may be found here.
Please note that the CCPA does not currently apply in all respects to personal information that We collect from a person in the course of the person acting as a job applicant, employee, owner, director, officer, or contractor of Asteya to the extent that the person’s personal information is collected and used by Us solely within the context of the person’s role, or former role, as a job applicant, employee, owner, director, officer, or a contractor of Asteya. The CCPA also does not apply to personal information that We collect that constitutes emergency contact information of a person acting in any of the aforementioned roles to the extent that the personal information is collected and used solely within the context of having an emergency contact on file. Lastly, the CCPA does not apply to personal information that is necessary for Us to retain in order to administer benefits relating to a person’s capacity in any of the aforementioned roles to the extent that the personal information is collected and used by Asteya solely within the context of administering those benefits.
Collection of Personal Information
The CCPA defines “Personal Information” as: “information that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household. The disclosures and explanations of your rights in this Section 8 apply only to the Personal Information that We collect about you now or that We may collect about you in the future.
Please note that the categories of Information including any Personal Information that We collect may vary by individual.
Sources of the Personal Information We Collect
We may collect Personal Information from the following sources:
- Insurance Application Form
- Insurance Claim Form
- Employment Application
- Website Usage
- Security Monitoring
- Call Recording
- Referral providers, agents, and other Third Parties
We may obtain Personal Information about you from third parties and may combine this information with other Personal Information We maintain about you. If We do so, this Policy governs any combined information that We maintain in personally-identifiable format.
Purposes for Which We Collect Personal Information
We use Personal Information to support our business functions including with respect to the following, where applicable:
- Market Insurance Products and Services
- Underwriting Insurance Policies
- Issue Insurance Policies
- Processing Insurance Claims
- Website User Experience
- Website Security
- Employment
- Minimum Age Requirements for Employment
- Facility Security
- Sales Optimization
- Quality Assurance
- Other Business Purposes
We may combine Personal Information and non-personal information that We collect. We also may share your Personal Information within our corporate family of companies for these purposes, as permitted by law.
The Categories of Third Parties with Whom, and Purposes for Which, We Share Personal Information
We may obtain Personal Information about you from third parties and may combine this information with other Personal Information We maintain about you. If We do so, this Policy governs any combined information that We maintain in personally-identifiable format.
As noted above, Asteya shares information with its affiliates and Joint Venture Partners consistent with the provisions of the California Consumer Privacy Act. At this time, Asteya shares certain information with [FSL…but if others add here]. FSL’s own California Notice of Collection can be found here.
We may share Personal Information with the following categories of third parties:
- Affiliated Companies and Joint Venture Partners
- Identity Verification Services
- Insurance / Reinsurance Companies and Administrators
- Collection Agencies
- Marketing Service Providers
- Employment Benefits Service Providers
- Referral providers
- Other Service Providers
We may share Personal Information with third parties for the following purposes:
- Marketing Campaign Optimization
- Fraud Protection
- Debt Collection
- Processing Insurance Applications and Claims
- Employment Benefits Administration
- Other Business Purposes
Access to Personal Information
You have the right to request, in accordance with applicable law, that We disclose certain information to you about our collection and use of your Personal Information over the past twelve (12) months. Please note that the CCPA limits our ability to provide you with the requested information only after We receive a verifiable consumer request from you or a person registered with the Secretary of State that is authorized by you to act on your behalf. Once We receive a 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 or commercial purpose for collecting that Personal Information
- The categories of third parties with whom We share that Personal Information
- The specific pieces of Personal Information We collected about you (also called a data portability request)
- If We disclosed your Personal Information for a business purpose, and the Personal Information categories that each category of recipient obtained
Please note that the CCPA does not require Us to retain any Personal Information collected for a single, one-time transaction, if that Personal Information is not sold or retained by Us. It also does not require Us to reidentify or otherwise link information that is not maintained in a manner that would be considered Personal Information.
Deletion Requests
You may request, in accordance with applicable law, that Asteya delete the Personal Information that We collected about you and retained, subject to certain exceptions. Once We receive a verifiable consumer request, We will delete (and direct our service providers to delete) your Personal Information from our records, unless an exception applies in support of our business need to retain some or all of your Personal Information.
We may deny your deletion request if retaining the Personal Information is necessary for Us or our service provider(s) to:
- Complete the transaction for which We collected the Personal Information, provide a good 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;
- Debug products to identify and repair errors that impair existing intended functionality;
- Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law;
- Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et. seq.);
- Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the Personal Information’s deletion may likely render impossible or seriously impair the research’s achievement, if you previously provided informed consent;
- Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with Us;
- Comply with a legal obligation; or
- Make other internal and lawful uses of that Personal Information that are compatible with the context in which you provided it.
Access, Data Portability, and Deletion Requests
To access, seek data portability, or request that We delete your Personal Information, please submit a verifiable consumer request to Us by either:
- Calling Us at + 1 954-246-3509
- Emailing Us at support@asteya.world
Only you, or someone legally authorized to act on your behalf, may make a verifiable consumer request related to your Personal Information. You may also make a verifiable consumer request on behalf of your minor child.
You may only make a verifiable consumer request for access or data portability twice within a twelve (12) month period. The verifiable consumer request must:
- Provide sufficient information that allows Us to reasonably verify you are the person about whom We collected Personal Information or an authorized representative
- Describe your request with sufficient detail that allows Us to properly understand, evaluate, and respond to it
After We receive a verifiable consumer request from you, We will take steps to determine whether the request being made is a verifiable consumer request. Given the nature of the Personal Information requested, We will require authentication of your identity. We cannot respond to your request or provide you with Personal Information if We cannot verify your identity or authority to make the request and confirm the Personal Information relates to you.
Making a verifiable consumer request does not require you to create an account with Us.
We will only use Personal Information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.
Response Timing and Format
We will make every effort to respond to a verifiable consumer request within forty-five (45) days of its receipt. If We require more time, We will inform you of the reason and extension period in writing.
Any disclosures We provide will only cover the twelve (12) month period preceding our receipt of your verifiable consumer request. The response We provide will also explain the reason(s) 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 to 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 consumer 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.
Personal Information Sales Opt-Out and Opt-In
Asteya does not sell Personal Information.
Non-Discrimination
We will not discriminate against you for exercising any of your privacy rights. We will not:
- Deny you goods or services
- Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties
- Provide you a different level or quality of goods or services
- Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services
- Call Recording
b. California Shine The Light Law
Asteya does not share your Information with non-affiliated third parties for their own marketing use without your consent. Asteya does share your Information with corporate affiliates.
Effective Date: July 22, 2021
Last modified: July 22, 2021