Last Modified: November 3, 2020
This Policy applies to Information (as defined below) We collect:
Ø On this Website.
Ø Through mobile and desktop applications you download from this Website.
Ø In email, text, and other electronic messages between you and this Website.
Ø From hardcopy documents exchanged between you and Us.
Ø From telephone calls, video conferences, or other verbal discussions between you and Us.
Please read this Policy carefully to understand our policies and practices regarding your information and how We will treat it. If you have any questions about this Policy you can contact Us at Asteya, Inc., 1110 Brickell Avenue, STE 515, Miami, Florida, 33131, or by telephone at + 1 954-246-3509.
This Policy may change from time to time. Your continued use of this Website after We make changes is deemed to be acceptance of those changes, so please check the Policy periodically for updates.
We collect several types of information from and about users of our Website, including:
- The e-mail address of visitors to the Website;
- the e-mail addresses of users who communicate with us via e-mail;
- aggregate information on what pages on our Website users access or visit;
- information voluntarily provided by users, including information necessary to apply for insurance on the Website, by which a user may be personally identified, for example full name, postal address, e-mail address, and telephone number, employment information, financial information, medical information and information related to a users’ health; and
- information voluntarily provided by users through our affiliate partners or third parties.
- information about your transactions with Us or others (collectively, “Information”);.
We collect this Information directly from you either when you provide it to Us or automatically as you navigate through the Website.
The Information We collect on or through our Website may include: · Information that you provide by filling in forms on our Website including, for example, information provided by you when applying for insurance; · records and copies of your correspondence (including email addresses), if you contact Us; · details of transactions you carry out through our Website which may include Information; and · your search queries on the Website.
As you navigate through and interact with our Website, We may use automatic data collection technologies to collect certain Information about your equipment, browsing actions, and patterns, including:
- details of your visits to our Website, including location data, logs, and other communication data and the resources that you access and use on the Website; and
- Information about your computer and internet connection, including your IP address, operating system, and browser type.
The information We collect automatically is only statistical data and does not include Information. It helps Us to improve our Website and to deliver a better and more personalized service, including by enabling Us to:
- estimate our audience size and usage patterns;
- store information about your preferences, allowing Us to customize our Website according to your individual interests;
- speed up your searches; and
- recognize you when you return to our Website.
The technologies We use for this automatic data collection may include:
- Flash Cookies. Certain features of our Website may use local stored objects (or Flash cookies) to collect and store information about your preferences and navigation to, from, and on our Website. Flash cookies are not managed by the same browser settings as are used for browser cookies.
- Web Beacons. Pages of the Website 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 pages and for other related website statistics (for example, recording the popularity of certain website content and verifying system and server integrity).
We use information that We collect about you or that you provide to Us, including any Information:
- to generate a quote or application for an insurance policy;
- to present and administer our Website and its contents to you;
- to monitor Website usage and traffic-levels;
- to contact you regarding improvements We can make to our Website and our services;
- to provide you with information, products, or services that you request from Us or that We believe may be of interest to you;
- to help Us prevent fraud, money laundering or other crimes by verifying what We know about you;
- for our business purposes;
- to fulfill any other purpose for which you provide it; and
- for any other purpose with your consent.
Except as disclosed in this Policy, We will not use your information for any purpose that you have not expressly authorized.
Your information is not sold, rented or shared with other organizations for unrelated commercial purposes or in ways different than what is disclosed in this Policy. We may disclose Information that We collect or you provide as follows:
- to our subsidiaries and affiliates;
- to insurers, contractors, service providers, and other third parties We use to support our business and who are bound by contractual obligations to keep such Information confidential and use it only for the purposes for which We disclose it to them;
- to a prospective or actual buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of the Company's assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which Information held by Us about Website users is among the assets transferred; or
- to any other parties with your consent.
We may also disclose your Information:
- to comply with any court order, law, legal process or regulatory obligation including to respond to any government or regulatory request;
- if We believe disclosure is necessary or appropriate to protect Asteya’s or others’ rights or property, or to protect the safety of or to prevent harm to our customers or others.
Our Website is not intended for children under 18 years of age. No one under age 18 should use the Website or provide any information (including Information) to the Website. We do not knowingly collect Information from children under 18. If We learn We have collected or
received Information from a child under 18 without verification of parental consent, We will delete that information. If you believe We might have any information from or about a child under 18, please contact Us at the contact information provided above
You may always limit the amount and type of information that We collect from you by choosing not to enter or provide Information requested from you on the Website. However, some Website features – requesting a quote, for example – can only be provided to you if you provide Us with requested Information.
We strive to provide you with choices regarding the Information you provide to Us. We have created mechanisms to provide you with the following control over your Information:
- Promotional Offers from Asteya. If you do not wish to have your contact information used by Asteya to promote our own or third parties’ products or services, you can opt-out by sending an email to firstname.lastname@example.org. If We have sent you a promotional email, you may send Us a return email asking to be omitted from future email distributions. This opt out does not apply to information provided to Asteya as a result of a product purchase or other transactions.
Targeted Advertising. 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 can opt-out by sending an email to email@example.com.
Customer reviews and surveys. We may provide you the opportunity to participate in reviews and customer surveys conducted via email. If you participate, we will request certain personally identifiable information from you. Participation in these reviews is completely voluntary and you therefore have a choice whether or not to disclose this information. The requested information typically includes contact information (such as name and address), and demographic information (such as zip code).
We use this information to evaluate our level of customer service. With your consent we may post your reviews on our website along with your name or pass on your information to a third-party service or product provider if you so select.
We have implemented physical, electronic, and procedural security measures to protect your information that is under our control from loss, unauthorized access, misuse, and alteration. The personal information that you provide to us is stored on servers which are located in secured facilities with restricted access and protected by protocols and procedures. We provide training to our employees on how to safeguard personal information and only authorized employees are permitted to access personal information, which may only be used for permitted business purposes. Unfortunately, no server, computer or communications network or system, or data transmission of information via the internet is completely secure. Although We do our best to protect your Information, We cannot guarantee the security of your Information transmitted to our Website. Any transmission of Information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on the Website.
You can review and change your Information by sending an email to firstname.lastname@example.org.
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: https://oag.ca.gov/privacy/ccpa.
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.
Certain categories of the Information identified in Section 1 above constitute “Personal Information” as defined in the CCPA. 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.
acPlease note that the categories of Information including any Personal Information that We collect may vary by individual.
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.
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
- 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.
Categories of Personal Information that We collect may be shared in limited circumstances with third parties for business purposes. We do not sell your Personal Information.
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
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.
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.
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 email@example.com
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.
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.
Asteya does not sell Personal Information.
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
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: November 3, 2020
- Last modified: November 3, 2020