California Insurance Privacy Notice and Notice of Information Practices

Important Privacy Notice

This notice explains how Encore handles data for insurance. It tells you what we collect, why we use it, and when we share it. It also explains your rights under California law.

This notice is separate from our Website Privacy Policy. That policy does not limit the rights described in this notice.

A carrier or other firm may give you its own privacy notice. That notice covers that firm’s own practices.

1. What We May Collect

What we collect depends on the insurance product or service you ask about. We may collect:

• your name, address, email, phone number, and date of birth;
• facts about current insurance, coverage, values, premiums, riders, beneficiaries, claims, and goals;
• facts about income, assets, debts, net worth, retirement accounts, cash needs, and source of funds;
• work, job, and business ownership facts;
• health or medical facts when needed for underwriting or another lawful insurance purpose;
• forms, applications, messages, appointments, and service records; and
• consumer reports or insurance reports when law allows their use.

We may get data from you. We may also get data from other people or sources.

2. Where We May Get Data

We may get data from:

• you, an insured person, owner, applicant, beneficiary, or authorized representative;
• licensed insurance professionals;
• insurance carriers and insurance organizations;
• public or government records;
• consumer reporting agencies and insurance-support organizations;
• doctors, labs, or medical facilities when allowed by law;
• employers or businesses when relevant and allowed by law; and
• service providers that help Encore or help with an insurance transaction.

We may use forms and interviews. We may also use secure document requests, public records, reports, and underwriting sources.

If we ask a question only for marketing or research, we will clearly say so.

3. Investigative Consumer Reports

An investigative consumer report may use personal interviews.

If Encore asks for this type of report, we will give the notice required by law. This applies to an insurance transaction. You may ask to be interviewed for the report. You may also ask for a copy of the report as provided by law.

4. Why We Use Data

We may use data to:

• respond to you;
• learn about your insurance needs and goals;
• complete reviews required for a case;
• seek quotes or carrier data;
• apply for, process, or service insurance;
• work with carriers and licensed professionals;
• prevent fraud and protect accounts and systems;
• keep required records; and
• meet legal and regulatory duties.

5. When We May Share Data Without Separate Written Consent

California law allows some sharing without separate written consent. Common cases are listed below.

• To perform services. We may share data with a person or firm that performs a task for Encore or an insured. The task may support our business. It may also support a professional or insurance service.
• To handle an insurance case. We may share data with insurers, licensed producers, and insurance-support organizations. They may help quote, underwrite, issue, replace, or service insurance you request.
• To check eligibility or fraud. We may share limited data to check eligibility. We may also use it to detect or prevent fraud, false statements, or unlawful acts.
• For health-related purposes allowed by law. Where it applies, data may be shared with a doctor or medical-care institution. The purpose must be allowed by California insurance law.
• With regulators or government. We may share data with insurance regulators, law enforcement, courts, or other government bodies. We do so only when law allows or requires it.
• For research or actuarial work. We may share data for lawful research or actuarial work when required safeguards are used.
• For a business transfer. We may share data as allowed by law for a sale, merger, transfer, or reorganization. This can include a proposed deal.
• For group insurance. Where it applies, limited data may be shared with a group policyholder. This may be for claims experience or an audit.
• As otherwise allowed by law. We may make other disclosures allowed by California Insurance Code section 791.13 or another law.

We do not sell nonpublic insurance data for money.

6. Marketing Choices

Encore does not share covered financial data with outside firms for their own marketing unless law allows it. California privacy rules still apply. If California opt-out rules apply, you may opt out.

If this policy changes, we will first give you an IMPORTANT PRIVACY CHOICES notice. It will tell you what data may be shared and who may receive it. It will also tell you how to opt out at no cost. We will wait the time required by law before any covered sharing starts.

If the law requires your written consent, we will get it before we share the data.

We will not unfairly discriminate against you for using an applicable privacy right.

7. Medical Record Data

We do not ask for medical records through general public website forms.

When medical data is needed, it should be sent through an approved insurance or secure process. We do not share nonpublic medical record data without the consent California law requires. The law may allow or require some sharing without that consent.

8. Your Right to See Your Data

California law may give you a right to see certain data we keep about you.

Send us a written request. Give us enough details to identify you and find the records. We will respond to a qualifying request within 30 business days, as required by law.

Where the law applies, you may receive:

• the nature and substance of the recorded data;
• a copy or a chance to inspect it;
• the source, when the source is an institutional source;
• facts about recorded sharing during the period set by law; and
• steps for asking us to correct, amend, or delete data.

Special rules may apply to medical data. Special rules may also apply to data prepared for a claim or legal case.

9. Your Right to Correct, Amend, or Delete Data

You may send us a written request about recorded personal data. You may ask us to correct, amend, or delete data when California law applies.

We will respond to a qualifying request within 30 business days. If we deny the request, we will explain why when the law requires it. We will also explain your right to file a short statement of disagreement.

When required, we will send an accepted change to past recipients or sources. We may also send your statement of disagreement.

10. Insurance-Support Organization Reports

Information obtained from a report prepared by an insurance-support organization may be retained by the insurance-support organization and disclosed to other persons.

11. How We Protect Data

We work to keep customer data safe. We use administrative, technical, and physical safeguards.

We limit access. Only people who need the data for an authorized job may use it.

We use due care when we select service providers that handle customer data. When California law applies, our contracts require those providers to use safeguards.

12. Former Customers

We protect retained data about former customers as the law requires.

We apply the same marketing limits to retained data about former customers. If California opt-out rules apply, those rules still govern.

We may keep or share former-customer data when law allows or requires it.

13. Minors Under 18

Encore does not advertise insurance directly to minors under 18.

A parent, legal guardian, or another authorized adult must take part in insurance involving a minor. Carrier rules and applicable law also apply.

A minor should not submit an insurance application through a public Encore form. A minor also should not submit medical or sensitive financial data.

14. How to Use Your Rights

You may ask to see your data. You may also ask for a correction, amendment, deletion, or paper copy of this notice.

Contact:

Encore Family Life Insurance Solutions — Privacy
P.O. Box 601913
San Diego, CA 92160
privacy@encorefamilysolutions.com
(619) 841-2943 ext. 800

We may verify your identity before we release or change data. We may also verify your legal authority to act for another person.

15. When We Give This Notice

We give this notice at the times required by California law.

For a continuing customer relationship, we give a privacy notice at least once in each 12-month period. We do this when California law requires it.

For an electronic insurance transaction, the notice will be available in a form you can keep. If we use electronic delivery to meet a notice duty, you may need to acknowledge receipt. We will require this when the law calls for it.

A footer link gives easy access. It does not replace a notice or acknowledgment required for an insurance transaction.

16. Contact Information

Encore Family Life Insurance Solutions
California-Licensed Independent Insurance Agency
California Insurance License #6009388
State of domicile: California
Principal place of business: San Diego, California

P.O. Box 601913
San Diego, CA 92160
privacy@encorefamilysolutions.com
(619) 841-2943 ext. 800
encorefamilysolutions.com