Privacy Policy

Last Updated: October 17, 2022

Palms Insurance Privacy Policy: Lock icon on blue background, security

 

Palms Insurance Company, Limited; Palms Specialty Insurance Company Inc; and our affiliated entities (collectively “Palms Insurance,”  “we,” “us,” or “our”), provide insurance and reinsurance products to corporate customers. This privacy policy (“Privacy Policy”) is designed to help you understand how we collect, use, process, and share your personal information, and to help you understand and exercise your privacy rights.

PLEASE REVIEW THIS PRIVACY POLICY CAREFULLY. By using the website, www.palms-insurance.com, as well as any mobile apps, online services, or other websites where this Privacy Policy is posted (together, the “Site”), you accept the terms of this Privacy Policy and our Terms of Use, confirm that you are not located outside the United States, and consent to our processing of your information as described in this Privacy Policy. If you do not agree to this Privacy Policy, you should discontinue any further access or use of the Site.

  1. SCOPE AND UPDATES TO THIS PRIVACY POLICY
  2. PERSONAL INFORMATION WE COLLECT
  3. HOW WE USE YOUR PERSONAL INFORMATION
  4. HOW WE DISCLOSE YOUR PERSONAL INFORMATION
  5. YOUR PRIVACY CHOICES AND RIGHTS
  6. SECURITY OF YOUR INFORMATION
  7. RETENTION OF PERSONAL INFORMATION
  8. SUPPLEMENTAL NOTICE FOR  RESIDENTS OF CALIFORNIA
  9. CHILDREN’S INFORMATION
  10. OTHER PROVISIONS
  11. CONTACT US
 

 

1.   SCOPE AND UPDATES TO THIS PRIVACY POLICY

This Privacy Policy applies to personal information processed by us, including via the Site. To make this Privacy Policy easier to read, our Site, and other offerings are collectively called the “Services.”

Changes to our Privacy Policy. We may revise this Privacy Policy from time to time in our sole discretion. If there are any material changes to this Privacy Policy, we will notify you as required by applicable law. You understand and agree that you will be deemed to have accepted the updated Privacy Policy if you continue to use our Services after the new Privacy Policy takes effect.  The effective date of this Privacy Policy is the “Last Updated” date that appears at the beginning of this Privacy Policy.

 

 

2.  PERSONAL INFORMATION WE COLLECT

The categories of personal information we collect depend on how you interact with us, our Services, and the requirements of applicable law. We collect information that you provide to us, information we obtain automatically when you use our Services, and information from other sources, such as third-party services and organizations, as described below.

A.   Personal Information You Provide to Us Directly

We may collect personal information that you provide to us.

  • Your Communications with Us. We may collect personal information, such as an email address, phone number, or mailing address when you contact us online, request information about our Services, request customer or technical support, or otherwise communicate with us.
  • Conferences, Trade Shows, and Other Events. We may collect personal information from individuals when we attend or host conferences, trade shows, and other events.
  • Business Development and Strategic Partnerships. We may collect personal information from individuals and third parties to assess and pursue potential business opportunities with them.
  • Insurance-related Information. We may collect personal information from individuals and third parties to provide our insurance products and Services. More information about the scope of the insurance products we offer is available here.

B.   Personal Information Collected Automatically

We may collect personal information automatically when you use our Services.

  • Automatic Collection of Personal Information. We may collect certain information automatically when you use our Services, such as your Internet protocol (IP) address, user settings, MAC address, cookie identifiers, mobile advertising and other unique identifiers, browser or device information, and location information (including approximate location derived from IP address). We may also automatically collect information regarding your use of our Services, such as pages that you visit before, during and after using our Services, information about the links you click, the types of content you interact with, the frequency and duration of your activities, and other information about how you use our Services.
  • Cookie Policy (and Other Technologies). We, as well as third parties that provide content, advertising, or other functionality on our Services, may use cookies, pixel tags, and other technologies (“Technologies”) to automatically collect information through your use of our Services. For example:
    • Cookies. Cookies are small text files placed in device browsers that store preferences and facilitate and enhance your experience.
    • Pixel Tags/Web Beacons. A pixel tag (also known as a web beacon) is a piece of code embedded in our Services that collects information about engagement on our Services. The use of a pixel tag allows us to record, for example, that a user has visited a particular web page or clicked on a particular advertisement. We may also include web beacons in e-mails to understand whether messages have been opened, acted on, or forwarded.

Our uses of these Technologies fall into the following general categories:

  • Operationally Necessary. This includes Technologies that allow you access to our Services, applications, and tools that are required to identify irregular website behavior, prevent fraudulent activity, improve security, or allow you to make use of our functionality;
  • Performance-Related. We may use Technologies to assess the performance of our Services, including as part of our analytic practices to help us understand how individuals use our Services (see Analytics below);
  • Functionality-Related. We may use Technologies that allow us to offer you enhanced functionality when accessing or using our Services. This may include identifying you when you sign into our Services or keeping track of your specified preferences, interests, or past items viewed;
  • Advertising- or Targeting-Related. We may use first party or third-party Technologies to deliver content, including ads relevant to your interests, on our Services or on third-party digital properties.
    See “Your Privacy Choices and Rights” below to understand your choices regarding these Technologies. Our advertising partners include social media companies, such as:
    • Facebook Connect. For more information about Facebook’s use of your personal information, please visit Facebook’s Data Policy. To learn more about how to opt-out of Facebook’s use of your information, please click here while logged in to your Facebook account.
  •  Analytics. We may use Technologies and other third-party tools to process analytics information on our Services. These Technologies allow us to better understand how our digital Services are used and to continually improve and personalize our Services. Our analytics partners include:
  • Google Analytics. For more information about how Google uses your personal information (including for its own purposes, e.g., for profiling or linking it to other data), please visit Google Analytics’ Privacy Policy. To learn more about how to opt-out of Google Analytics’ use of your information, please click here.

C.   Personal Information Collected from Other Sources

Third-Party Services and Sources. We may obtain personal information about you from other sources, including through third-party services and organizations.  For example, if you access our Services through a third-party application or a social networking site, we may collect personal information about you from that third-party application (to the extent that you have made such information available via your privacy settings). We also may obtain personal information from third-parties, including insurance brokers, that share information relevant to our underwriting decisions.

 

 

3.   HOW WE USE YOUR PERSONAL INFORMATION

We use your personal information for a variety of business purposes, including to provide our Services, for administrative purposes, and to market our products and Services, as described below.

A.   Provide Our Services

We use your information to fulfil our contract with you and provide our Services, such as:

  • Evaluating risks related to our products and Services;
  • Handling insurance-related claims;
  • Managing your information and accounts;
  • Providing access to certain areas, functionalities, and features of our Services;
  • Answering requests for customer or technical support;
  • Modeling and analytics;
  • Communicating with you about your account, activities on our Services, and policy changes;
  • Processing your financial information and other payment methods for products or Services purchased; and
  • Allowing you to register for events.

B.   Administrative Purposes

We use your information for various administrative purposes, such as:

  • Pursuing our legitimate interests such as direct marketing, research, and development (including marketing research), network and information security, and fraud prevention;
  • Detecting security incidents, protecting against malicious, deceptive, fraudulent, or illegal activity, and prosecuting those responsible for that activity;
  • Measuring interest and engagement in our Services;
  • Short-term, transient use, such as contextual customization of ads;
  • Improving, upgrading, or enhancing our Services;
  • Developing new products and services;
  • Ensuring internal quality control and safety;
  • Authenticating and verifying individual identities, including requests to exercise your rights under this Privacy Policy;
  • Debugging to identify and repair errors with our Services;
  • Auditing relating to interactions, transactions, and other compliance activities;
  • Sharing personal information with third parties as needed to provide the Services;
  • Enforcing our agreements and policies; and
  • Carrying out activities that are required to comply with our legal obligations.

C.   Marketing and Advertising our Products and Services

We may use personal information to tailor and provide you with content and advertisements. We may provide you with these materials as permitted by applicable law. If you have any questions about our marketing practices, you may contact us at any time as set forth in the “Contact Us” section below.

D.   With Your Consent

We may use personal information for other purposes that are clearly disclosed to you at the time you provide personal information or with your consent.

E.   Other Purposes

We also use your personal information for other purposes not otherwise prohibited by applicable law.

  • De-identified and Aggregated Information. We may use personal information to create de-identified and/or aggregated information, such as demographic information, information about the device from which you access our Services, or other analyses we create.
 

 

4.   HOW WE DISCLOSE YOUR PERSONAL INFORMATION

We disclose your personal information to third parties for a variety of business purposes, including to provide our Services, to protect us or others, or in the event of a major business transaction such as a merger, sale, or asset transfer, as described below.

A.   Disclosures to Provide our Services

The categories of third parties with whom we may share your personal information are described below.

  • Service Providers. We may share your personal information with our third-party service providers and vendors that assist us. This includes service providers and vendors that provide us with IT support, hosting, payment processing, customer service, insurance account administration, and related services.
  • Business Partners. We may share your personal information with business partners to provide you with products or Services you have requested. We may also share your personal information with business partners with whom we jointly offer products or Services.
  • Affiliates. We may share your personal information with our company affiliates, for example: for our administrative purposes, IT management, or for them to provide services to you or support and supplement the Services we provide.
  • Advertising Partners. We may share your personal information with third-party advertising partners. These third-party advertising partners may set Technologies and other tracking tools on our Services to collect information regarding your activities and your device (e.g., your IP address, cookie identifiers, page(s) visited, location, time of day) over time and across different websites when you use our Services.
  • Government Entities. We may disclose your personal information to government entities when such information is required for licensure or other similar purposes.

B.   Disclosures to Protect Us or Others

We may access, preserve, and disclose any information we store associated with you to external parties if we, in good faith, believe doing so is required or appropriate to: comply with law enforcement or national security requests and legal process, such as a court order or subpoena; protect your, our, or others’ rights, property, or safety; enforce our policies or contracts; collect amounts owed to us; or assist with an investigation or prosecution of suspected or actual illegal activity.

C.   Disclosure in the Event of Merger, Sale, or Other Asset Transfers

If we are involved in a merger, acquisition, financing due diligence, reorganization, bankruptcy, receivership, purchase or sale of assets, or transition of service to another provider, your information may be sold or transferred as part of such a transaction, as permitted by law and/or contract.

 

 

5.   YOUR PRIVACY CHOICES AND RIGHTS

  • Your Privacy Choices. The privacy choices you may have about your personal information are determined by applicable law and are described below.
  • Email Communications. If you receive an unwanted email from us, you can use the unsubscribe link found at the bottom of the email to opt out of receiving future emails. Note that you will continue to receive transaction-related emails regarding products or Services you have requested. We may also send you certain non-promotional communications regarding us and our Services, and you will not be able to opt out of those communications (e.g., communications regarding our Services or updates to our Terms of Use or this Privacy Policy).
  • “Do Not Track.” Do Not Track (“DNT”) is a privacy preference that users can set in certain web browsers. Please note that we do not respond to or honor DNT signals or similar mechanisms transmitted by web browsers.
  • Cookies and Personalized Advertising. You may stop or restrict the placement of Technologies on your device or remove them by adjusting your preferences as your browser or device permits. However, if you adjust your preferences, our Services may not work properly. Please note that cookie-based opt-outs are not effective on mobile applications. However, you may opt-out of personalized advertisements on some mobile applications by following the instructions for Android, iOS, and others.

    The online advertising industry also provides websites from which you may opt out of receiving targeted ads from data partners and other advertising partners that participate in self-regulatory programs. You can access these and learn more about targeted advertising and consumer choice and privacy by visiting the sites for the Network Advertising Initiative or the Digital Advertising Alliance.

    Please note you must separately opt out in each browser and on each device.
 

 

6.   SECURITY OF YOUR INFORMATION

We take steps to ensure that your information is treated securely and in accordance with this Privacy Policy. Unfortunately, no system is 100% secure, and we cannot ensure or warrant the security of any information you provide to us. To the fullest extent permitted by applicable law, we do not accept liability for unauthorized access, use, disclosure, or loss of personal information.

By using our Services or providing personal information to us, you agree that we may communicate with you electronically regarding security, privacy, and administrative issues relating to your use of our Services. If we learn of a security system’s breach, we may attempt to notify you electronically by posting a notice on our Services, by mail, or by sending an email to you.

 

 

7.   SUPPLEMENTAL NOTICE FOR  RESIDENTS OF CALIFORNIA

This section describes the rights of California residents (“Consumers”) under the California Consumer Privacy Act (“CCPA”) (as amended by the California Privacy Rights Act (“CPRA”)) and explains how Consumers may exercise these rights.

The CCPA provides individuals with the right to know what categories of personal information Palms Insurance has collected about them, whether Palms Insurance disclosed that personal information for a business purpose (e.g., to a service provider) in the preceding twelve months, and, to the extent applicable, the business purpose for which this information was disclosed.

Category of Personal Information Collected by Palms Insurance

 

Additional Privacy Rights

The categories of sources from which we collect personal information and our business and commercial purposes for using personal information are set forth in “Personal Information We Collect” and “How We Use Your Personal Information” above, respectively.

You have the right to request that we delete any personal information about you which we have collected from you. The CCPA provides certain exceptions to the right to have personal information deleted, which may prevent us from honoring such requests.

You have the right to request the correction of your personal information where it is inaccurate or incomplete. In some cases, we may provide self-service tools that enable you to update your personal information.

You have the right to request, free of charge, that we disclose to you the following information covering the 12 months preceding your request:

  • The categories of personal information and sensitive personal information we have collected about you;
  • The categories of sources from which the personal information is collected;
  • The business or commercial purpose for collection or selling personal information;
  • The categories of third parties with whom we share your personal information; and
  • The specific pieces of personal information we have collected about you.
  • The length of time we intend to retain each category of personal information, or the criteria used to determine such period.

You have the right to request, free of charge, that if we sell personal information about you or disclose it for a business purpose, we disclose to you the following information covering the 12 months preceding your request:

  • The categories of personal information we have collected about you.
  • The categories of sources from which the personal information is collected.
  • The business or commercial purpose for collecting, selling, or sharing personal information.
  • The categories of third parties with whom we disclose personal information.
  • The specific pieces of personal information we have collected about you.

You also have the right, at any time, to opt-out if we (i) sell personal information about you to third parties or (ii) share information with third parties for purposes of cross-contextual behavioral advertising. We do not engage in any such selling or sharing activities involving your personal information. We shall not discriminate against you because you exercised any of your rights under the law.

In some instances, you also have the right to limit the use and disclosure of certain sensitive personal information (as defined in the CCPA).  Furthermore, we do not process sensitive personal information for purposes other than those specified in Cal. Civ. Code § 1798.121.

Please note that these rights may not extend to financial information to the extent such information is governed by the federal Gramm-Leach-Bliley Act (GLBA).

Authorized Agent. In California, only you, or someone legally authorized to act on your behalf, may make a verifiable consumer request to exercise the rights described above related to your personal information. You may also make a verifiable consumer request on behalf of your minor child. To authorize an agent, provide written authorization signed by you and your designated agent and contact us as set forth in the “Contact Us” section below for additional instructions.

Verification. To protect your privacy, we will take steps to reasonably verify your identity before fulfilling any such requests. These steps may involve asking you to provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative, or to answer questions regarding your account and use of our Services.

If you are a resident of California and would like to exercise any of your rights, please contact us as set forth in the “Contact Us” section below. We will process such requests in accordance with applicable laws.

De-Identified Information. If we create or receive de-identified information, we will not attempt to reidentify such information, except to comply with applicable law.

 

 

8.   RETENTION OF PERSONAL INFORMATION

We store the personal information we collect, including information from California residents, for a period of seven years. Please note that this retention period may be longer based on your engagement with us, including instances in which your personal information is required to provide our Services, resolve disputes, establish legal defenses, conduct audits, pursue legitimate business purposes, enforce our agreements, and comply with applicable laws.

 

 

9.   CHILDREN’S INFORMATION

The Services are not directed to children under 13, and we do not knowingly collect personal information from children.

If you are a parent or guardian and believe your child has uploaded personal information to our Site without your consent, you may contact us as described in the “Contact Us” section below. If we become aware that a child has provided us with personal information in violation of applicable law, we will delete any such personal information we have collected, unless we have a legal obligation to keep it.

 

 

10.   OTHER PROVISIONS

Third-Party Websites/Applications. The Services may contain links to other websites/applications and other websites/applications may reference or link to our Services. These third-party websites/applications  are not controlled by us. We encourage our users to read the privacy policies of each website and application with which they interact. We do not endorse, screen, or approve, and are not responsible for, the privacy practices or content of such other websites or applications. Providing personal information to third-party websites or applications is at your own risk.

 

 

11.   CONTACT US

If you have any questions about our privacy practices or this Privacy Policy, or to exercise your rights as detailed in this Privacy Policy, please contact us at:

Palms Insurance
700 Universe Boulevard, Juno Beach, Florida 33408
561-304-5532
Contact@Palms-Insurance.com