La Playa: Insurance with Intelligence®

Privacy Policy

La Playa: Insurance with Intelligence®

Privacy Notice:

At La Playa, we’re committed to protecting and respecting the privacy and confidentiality of personal data.

This Privacy Policy explains how La Playa LLC and its affiliates (“we” or “us” or “La Playa”) collect, handle and process personal information about individuals who visit our website or seek our services, the conditions under which we may disclose it to others and how we keep it secure. 

What information do we collect?

We collect and process the following personal data: 

Category Description Collected

Identifiers

Name, alias, postal address, unique personal identifier, online identifier Internet Protocol address, email address, account name, social security number, driver’s license number, passport number or “other similar identifiers.

Yes

Protected classifications under California or federal law

Race, sex, age, religion, national origin, disability, citizenship status, and genetic information.

Yes

Financial information

 

Bank account number, credit card number, debit card number.

Yes

Insurable risk information

Paper and electronic customer records containing personal information, such as name, signature, physical characteristics or description, address, telephone number, education, current employment, employment history, social security number, passport number, driver’s license or state identification card number, insurance policy number, bank account number, credit card number, debit card number, or any other financial or payment information, medical information, or health insurance information.

Yes

Commercial information

Records of personal property, products or services purchased, obtained or considered or other purchasing or consuming histories or tendencies.

Yes

Internet/electronic activity information

Browsing history, search history, information on a consumer’s interaction with a website, application, or advertisement.

Yes

Geolocation data

Precise geographic location information about a particular individual or device.

No

Audio, electronic, visual, thermal, olfactory or similar information

Audio, electronic, visual, thermal, olfactory, or similar information such as, CCTV footage, photographs, and call recordings.

No

Employment history

Professional or employment-related information.

No

Biometric information

Genetic, physiological, behavioural, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as, fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data.

No

Inferences drawn from other personal information

Profile reflecting a person’s preferences, characteristics, psychological trends, predispositions, behaviour, attitudes, intelligence, abilities, and aptitudes.

No

We may also collect sensitive information about you such as criminal convictions or health information in relation to providing our services to you. We will provide specific data processing information to you regarding how we process sensitive data and your rights regarding the processing.

Children

We do not knowingly collect online information from children under the age of 13. If we are notified that we have collected personal information, as defined by the Children’s Online Privacy Protection Act, of a child under the age of 13, we will immediately delete the information.

How do we collect your information?

La Playa collects personal information depending on the relationship we have with you. We can collect personal information in the following ways:

  • Directly from you or someone else on your behalf in providing our service to you;
  • From other brokers who act directly for you and have approached us to facilitate the placement of an insurance policy for you; 
  • From other third parties who might introduce clients to us;
  • From third parties involved in your insurance claim;
  • Publicly available sources (e.g. search engines and social media sites);
  • Credit reference agencies;
  • Government agencies or professional regulators;
  • When you register with or use our websites;
  • When you attend a La Playa event;
  • When you engage with us over social media;
  • Directly from you through forms on our website and your interactions on our website; or
  • Cookies.

Further information about our use of cookies can be found in our Cookie Notice

How do we use your information?

We may process your information for the following purposes:

  • Evaluate your insurance needs and get a quote for you;
  • Carry out fraud, credit and anti-money laundering checks;
  • Communicate with you and respond to any enquiries you have;
  • Arrange appropriate insurance cover and provide policy documentation;
  • Contact you in order to arrange the renewal of the insurance policy;
  • Facilitate premium finance arrangements;
  • Manage insurance claims; 
  • Marketing analytics and direct marketing;
  • Communicate with you regarding any queries you raise via the website;
  • Monitor usage of the website;
  • Manage our business operations such as maintaining accounting records, analyzing financial results, complying with internal audit requirements and receiving professional advice; 
  • Transferring books of business, company sales and reorganisations; or
  • Comply with our legal or regulatory obligations.

Some jurisdictions require us to inform you of the legal grounds for processing your personal data.  The legal grounds that we may rely on are as follows:

Legal Ground Details

Performance of our contract of services with you

Processing is necessary for the performance of our contract of services or in order to take steps at your request prior to you entering into a contract of services with you.

Compliance with a legal obligation 

Processing is necessary for compliance with a legal obligation to which we are subject.

For our legitimate business interests 

Processing is necessary for the purposes of the legitimate interests pursued by us or by a third party, except where such interests are overridden by your interests or fundamental rights and freedoms which require protection of personal data.

Explicit consent

You have given your explicit consent to the processing of those personal data for one or more specified purposes. You are free to withdraw your consent, by contacting our Data Protection Contact. 

 

However, withdrawal of this consent may impact our ability to provide the services

Legal claims

Processing is necessary for the establishment, exercise or defence of legal claims or whenever courts are acting in their
judicial capacity.

You have made the information public

You have made your special category information manifestly public.

Substantial public interest

Processing is necessary for reasons of substantial public interest.

How long is your personal information retained?

We will retain your personal information for the period necessary to fulfil the purposes outlined in this privacy notice unless a longer period is required by law.  Your Personal Information will be deleted when it is no longer required.

Disclosure of personal information

La Playa may disclose your personal information to any La Playa group company to provide services requested by you, market other products and services offered by other businesses across the La Playa group where you have opted in or to assist with managing this site. Additionally, we may disclose your personal information with:

  • Insurance carriers or third-party brokers/agents to provide quotes, handle claims, bind coverages and other services as required to perform the services you request from us;
  • Government agencies to comply with applicable laws, regulations or governmental requests;
  • Affiliates to enable them to provide any requested services to you;
  • Third party service providers such as entities providing customer financing, auditing, hosting our website or other services; or
  • Third parties in connection with a merger, sale, assignment, or transfer of all or a portion of our business.

The third parties we may share your information with will only use your personal information under our strict instruction and are under a contractual obligation to ensure appropriate security measures are in place to keep your information confidential and secure.

We will not disclose, share, sell or otherwise disclose your information to unaffiliated third parties unless authorized by you.

How do we protect your information? 

La Playa has physical, electronic, and procedural safeguards in place to protect the security of your data against loss, misuse, unauthorised access, disclosure or alteration. These safeguards include the encryption of communications and information storage, firewalls, access controls, and a separation of duties. 

Unfortunately, the transmission of information via the internet is not completely secure. Although we do our best to protect your personal information, we cannot guarantee the security of your personal information transmitted to our Website. Any transmission of personal information is at your own risk.

Links to other websites

Our website may contain links to other websites run by other organizations. This privacy policy applies only to our website‚ so we encourage you to read the privacy statements on the other websites you visit. We cannot be responsible for the privacy policies and practices of other sites even if you access them using links from our website.

In addition, if you linked to our website from a third party site, we cannot be responsible for the privacy policies and practices of the owners and operators of that third party site and recommend that you check the policy of that third party site.

International Data Transfer

La Playa is a part of a global business and may need to share data with recipients that are located outside of the jurisdiction in which you are located. We will ensure our affiliates or third-party service providers maintain a comparable level of protection of the personal data as set out in this privacy notice.

Your Rights

Subject to certain exemptions, you have certain rights in relation to your personal information. We may ask you for additional information to confirm your identity before disclosing personal information to you. If you need to contact us in relation to any of your rights, you can use the contact details listed in the “Contacts” section below.

We will promptly honor your request or inform you further information is required in order to fulfil your request.

Marketing

We may send you marketing information about products and services of ours and other companies in our group which may be of interest to you. An "unsubscribe" link appears in all our marketing emails. To unsubscribe from emails sent by us, simply click on the link.

If you have consented to receive marketing, you may opt out at any time. You have a right at any time to stop us from contacting you for marketing purposes or giving your information to other members of La Playa. If you no longer wish to be contacted for marketing purposes, please click here.

Access, Rectification, Erasure

You have the right to review your personal information, correct the information you have provided to us, and request that we remove your information from our records. Each request will be reviewed and responded to in accordance with applicable laws.

State Privacy Notices

California- See below for the California Privacy Notice. The California Privacy Notice is effective as of 01 January 2020 and applies solely to consumers who are California residents.

Contact Us

If you have any questions would like further information about our privacy and information handling practices, would like to discuss opt-outs or withdrawing consent, please contact our Data Protection Officer by e-mailing at [email protected].

Changes to this Statement

From time to time, we may change our privacy notice. When we do, we will post the current version on this site, and we will revise the version date located at the bottom of this page. You may request a copy of this privacy notice from us using the contact details set out above.

CALIFORNIA PRIVACY NOTICE

This Privacy Notice applies solely to consumers who are California residents.

This California Privacy Notice outlines the personal information we collect or process about California residents in connection with the services we provide or offer specifically to you as a consumer, including through any site, application, or product that links to this Privacy Notice (the “Service”), how we use, share, and protect that personal information, and what your rights are with respect to your personal information that we gather and process.

In this California Privacy Notice, “personal information” has the same meaning as under the California Consumer Privacy Act (“CCPA”): information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household. Personal information does not include:

  • Until January 1, 2021, information regarding job applicants, employees, owners, directors, officers, or contractors, emergency contact information from the same, and information necessary for us to administer benefits to the same.
  • Until January 1, 2021, information we obtain from a consumer acting on behalf of a company and whose communications with us occur solely within the context of us conducting due diligence regarding, or providing or receiving a product or service to or from another company.
  • Information or organizations excluded from the CCPA’s scope, including medical information governed by the California Confidentiality of Medical Information Act (CMIA), protected health information collected by a covered entity or business associate governed by the Health Insurance Portability and Accountability Act of 1996 (HIPAA), or personal information collected, processed, sold, or disclosed pursuant to certain sector-specific privacy laws, including the Fair Credit Reporting Act (FCRA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver’s Privacy Protection Act of 1994 (DPPA).
  • Publicly available information from government records.
  • De-identified or aggregated consumer information.

Categories of Personal Information that we Collect and Disclose

Our collection, use and disclosure of personal information about a California resident will vary depending upon the circumstances and nature of our interactions or relationship with such resident.

In our role as an insurance broker or agent, we act as a service provider on behalf of our clients and insurance carriers. We may collect your personal information for the Service pursuant to a contract we have with a commercial client (our “Client”). In such instances, we may be acting as a “service provider” and are obligated to process the personal information we collect or are provided in connection with the Service in accordance with instructions from or the contract with our Client, which is the “business” ultimately responsible for determining how your personal information will be handled. Accordingly, if you are using the Service in connection with your role as an employee of our Client, or by virtue of some other relationship with our Client, we encourage you to review that Client’s privacy notice to understand the full scope of how your personal information will be handled. Further, in any case where we are acting as a service provider to a Client, if you or your authorized agent (together referred to hereinafter, where applicable, as “you”) wish to exercise any rights that may be available to you under certain data privacy laws (for example, the right to access or deletion under the CCPA if you are a resident of California as described below), you should direct your request to our Client, who is the party responsible for receiving, assessing, and responding to your requests, as we do not have any legal obligation, and, notwithstanding anything in this Privacy Notice to the contrary, may elect not, to respond to your requests.

Under the limited circumstances where we are acting as a business, and your personal information is not otherwise excluded as set forth above, the table in What information do we collect section above sets out the  categories of personal information (as defined by the CCPA) about California residents that we collect, sell, and disclose to others for a business purpose. We collect these categories of personal information from the sources described in the How do we collect your information section above, and for the purposes described in the How do we use your information section.

Categories of personal information disclosed. In the past twelve (12) months, we may have collected and disclosed the following categories of personal information for a business purpose:

  • Identifiers
  • Protected Classifications
  • Financial Information
  • Insurable Risk Information
  • Commercial Information
  • Internet/electronic activity information

Categories of personal information sold. We do not sell personal information to any third parties and have not done so in the preceding twelve (12) months.

Your Rights as a California Resident

Pursuant to California law, some California residents have specific rights regarding their personal information as described below. These rights are subject to certain exceptions.

Right to Request Disclosure of Information
You have the right to request that we disclose certain information regarding our business practices with respect to personal information. If you submit a valid and verifiable request and we confirm your identity and/or authority to make the request, we will disclose to you any of the following at your direction:

  • The categories of personal information we have collected about you in the last 12 months.
  • The categories of sources for the personal information we have collected about you in the last 12 months.
  • 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.
  • If we disclosed your personal information to a third party for a business purpose, a list of the personal information types that each category of recipient received.

Right to Request Deletion Personal Information
You have the right to request that we delete any of your personal information that we collected from you and retained, subject to certain exceptions. If you submit a valid and verifiable request and we can confirm your identity and/or authority to make the request, we will determine if retaining the information is necessary for us or our service providers to:

  • Complete a 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 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 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; and/or
  • Make other internal and lawful uses of that information that are compatible with the context in which you provided it.

If none of the above retention conditions apply, we will delete your personal information from our records and direct our service providers to do the same.

How to Exercise the Above Rights
To exercise your rights to disclosure or deletion described above, please use the contact details listed in the “Contacts” section above.

Only you or a person who can demonstrate that they are legally authorized to act on your behalf may make a verifiable consumer request related to your personal information.

You may make a verifiable consumer request for access or deletion no more than twice within a 12-month period. The verifiable 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. Such verification process will involve you confirming details of the personal information we have collected about you and will increase in scope in the event the nature of your request relates to the disclosure of sensitive personal information or the deletion of any personal information. In some instances, you may be required to submit proof of your identity (e.g., a driver’s license); and
  • Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

Right to Opt out of Sales of Your Personal Information
As a California resident, you have the right to direct a business that sells your personal information to third parties not to sell your personal information. This right is referred to as “the right to opt-out.”

Because we do not sell your personal information, we do not provide any mechanism for you to exercise the right to opt out.

Right to Non-Discrimination

  • You may exercise your rights under the CCPA without discrimination. For example, unless the CCPA provides an exception, 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; or
  • Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.

 

This Statement was last updated on November 15, 2020.

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