7. Choices Regarding Your Personal Information

If you have an account through the Sites, you may update or delete your personal information by contacting Broker Services by email at [email protected] or by phone at (800) 801-2300.

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If you no longer want to receive marketing communications or other announcement from us, you may unsubscribe by contacting us at [email protected] or following the unsubscribe options in the communication itself. 

Please note that you cannot unsubscribe from certain correspondence from us, including messages relating directly to your account or products and services that you have purchased from us.

8. Security

We maintain reasonable technical, administrative, and physical safeguards to protect personal information from loss, misuse, alteration, or unintentional destruction. We have implemented various security measures to protect  your personal information. Whenever you give out personal information online there is a risk that third parties may intercept and use that information. Although we seek to protect your personal information and privacy, we cannot guarantee the security of any personal information you disclose online. To the extent permitted under applicable law, we assume no liability or responsibility for disclosure of your personal information due to errors in transmission, unauthorized access by third parties, or other causes beyond our control.

You play an important role in keeping your personal information secure. You should not disclose your username or password with anyone. If you have reason to believe that your account is no longer secure, please contact us immediately at [email protected]. 

9. Location of Processing:

As detailed in Section 5 (How We Disclose Personal Information), Warner Pacific must disclose your personal information to a variety of service providers and other third parties in order to provide you with the Services. In some instances, these service providers and other third parties may be located, or may conduct their personal information processing and/or storage operations, outside of the United States. By accessing the Sites or using the Services, you acknowledge and agree that Warner Pacific may outsource the processing and/or storage of your personal information to service providers and other third parties located outside of the United States. If we do so, we will ensure that any service provider or other third party to which we disclose your personal information has agreed to comply with all applicable laws relating to the privacy and security of your personal information.

10. Additional Disclosures for California Residents

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For residents of California, this section describes how we collect, use, and disclose the personal information of California residents and the rights you may have under California law. These disclosures are intended to supplement this Privacy Policy with information required by California law. 
 

To understand what personal information we may have collected about you in the past 12 months, and from where we collected it, please see the section The Personal Information We Collect above. 

We collect this personal information, as further described in the How We Use Personal Information section above, to operate, manage, and maintain our business, to provide our products and services, and to accomplish our business purposes and objectives. We retain personal information for as long as necessary to fulfill the purposes for which the information was collected and as needed to address tax, compliance, employment, litigation, and other legal rights and obligations. 
 

We may disclose personal information to the third parties listed above in the section How We Disclose Personal Information. Below we have provided more detail regarding the way we disclose personal information for our business purposes and other instances. We do not sell personal information, and we do not engage in cross-context behavioral advertising. Similarly, we only disclose personal information, including sensitive personal information, where such disclosure is requested by you, is reasonably necessary to perform our Services, or is reasonably necessary to detect security incidents and protect against malicious, deceptive, fraudulent, or illegal activity.  
 

To manage our business and provide Services to you, we sometimes disclose personal information to third parties. These third parties cannot further collect, sell, or use the personal information we disclose to them except as necessary to perform our purposes, as instructed by us.
 

In the past 12 months, we may have disclosed the following categories of personal information to the following third parties for our operational business purposes:

Identifiers

• Service Providers

• Advisers and Financial Institutions

Financial and Insurance Information

• Service Providers

• Advisers and Financial Institutions

Demographic Information

• Service Providers

• Advisers and Financial Institutions

Professional, Employment, and Education
Information

• Service Providers

• Advisers and Financial Institutions

Device Information

• Service Providers

• Advisers and Financial Institutions

Internet Activity

• Service Providers

• Advisers and Financial Institutions

We do not sell, or have actual knowledge of any sale of, the personal information of minors under 16 years of age.

Under California law, consumers have a right to notice, upon collection, of the categories of personal information collected and the purposes for which the information will be used. We provide this notice through this Privacy Policy.

In addition, subject to certain exceptions, California residents have the following additional rights:

• Access: You may have the right to access a copy of the categories and specific pieces of personal information that we have collected, used, and/or disclosed.

• Correction: You may have the right to request that we correct inaccurate personal information that we hold about you, taking into account the nature of the personal information and the purposes of the processing of the personal information.

• Deletion: You may have the right to request that we delete or anonymize your personal information, with certain exceptions.

• No Retaliation: You have the right to be free from discrimination for exercising your rights.

• Portability: When you exercise your right to access, you also have the right to receive your personal information in a portable and, to the extent technically feasible, readily usable format. 

• Opt-Out. You have the right to opt-out of targeted advertising, sale of your personal information, profiling, and limit the use of sensitive personal information.

If you wish to exercise the rights described above, or if you have any questions or concerns regarding the processing of your personal information, please call us at (800) 801-2300 or by sending an email to [email protected]. Please include “California Privacy” in the subject line of your email so that we can get your email to the right team. We will respond to your request consistent with applicable law. Some of the rights above do not apply to personal information we collect in connection with financial and/or insurance products and services we provide to consumers. 
 

Please note, however, before we will be able to process your request for access, correction, or deletion of your personal information, we will need to properly verify your identity for security purposes. If we possess appropriate information about you (e.g., name, email, address), we will attempt to verify your identity using that information. Depending on the nature of your request and the sensitivity of your personal information, we may require additional information and documents. If it is not possible to identify you using commercially reasonable methods, we may not be able to respond to your request. 

To use an authorized agent to make a consumer request for access, deletion, or correction on your behalf, we may need the authorized agent to provide proof that you gave the authorized agent signed permission to submit the request on your behalf. We may also require you to verify your identity directly with us. 
 

Please note that certain exceptions and limitations apply to the rights discussed above. For example, the rights described above may be limited or inapplicable to certain types of information and to information collected and used in connection with our business relationship with other business entities.

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CCPA requires a link to a separate webpage/form where consumers can exercise their consumer rights. We recommend keeping the email address until such webpage/form is made available. The email address, here, could then be deleted, but an email we recommend keeping an email address in the privacy policy to address privacy questions.

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Please note that responding to a consumer request depends on the nature of the request and the sensitivity of the personal information. California law requires that no more information than needed to identify the individual in your internal database should be collected, unless the request presents a heightened risk to the consumer.

Please let us know if you would like further guidance on responding to consumer requests. Under CCPA, businesses have 45 days to respond to a consumer request and must provide confirmation of receipt. It does, however, provide for a 45 day extension, provided the consumer is notified within the initial 45 day window.

11. Additional Disclosures for Colorado Residents
 

For residents of Colorado, this section describes rights you may have under Colorado law. These disclosures are intended to supplement this Privacy Policy with information required by Colorado law. 

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To understand what personal information we may collect, use and disclose about you, and from where we collected it, please see the section The Personal Information We Collect. We disclose personal information with the categories of third parties described in the section How We Disclose Personal Information.

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We collect this personal information, as further described in the How We Use Personal Information section above, to operate, manage, and maintain our business, to provide our products and services, and to accomplish our business purposes and objectives. In particular, we have identified the categories of personal information that we use or disclose for each purpose below: 

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Providing the Service

• Identifiers

• Financial and Insurance Information

• Demographic Information

• Professional, Employment, and Education Information

• Health Information

Communicating with you

• Identifiers

• Financial and Insurance Information

• Professional, Employment, and Education Information

Marketing purposes

• Identifiers

Analytics and personalization

• Identifiers

Security and fraud prevention

• Identifiers

• Financial and Insurance Information

• Professional, Employment, and Education Information

• Device Information

• Internet Activity

Legal rights and obligations
 

• Identifiers

• Financial and Insurance Information

• Demographic Information

• Professional, Employment, and Education Information

• Device Information

• Internet Activity

We do not use your personal information to make decisions with legal or similarly significant effects for you based on the automated processing of your personal information.

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We do not sell personal information, and we do not engage in cross-context behavioral advertising. Similarly, we only disclose personal information, including sensitive personal information, where such disclosure is requested by you, is reasonably necessary to perform our Services, or is reasonably necessary to detect security incidents and protect against malicious, deceptive, fraudulent, or illegal activity.  
 

We do not sell, or have actual knowledge of any sale of, the personal information of minors under 13 years of age.

Under Colorado law, consumers have a right to notice, upon collection, of the categories of personal information collected and the purposes for which the information will be used. We provide this notice through this Privacy Policy.
 

In addition, in certain circumstances, Colorado residents may have additional rights, including:
 

• Access: You may have the right to access a copy of the categories and specific pieces of personal information that we have collected, used, and/or disclosed.
   

• Portability: When you exercise your right to access, you also have the right to receive your personal information in a portable and, to the extent technically feasible, readily usable format. 
   

• Correction: You may have the right to request that we correct inaccurate personal information that we hold about you, taking into account the nature of the personal information and the purposes of the processing of the personal information.
   

• Deletion: You may have the right to request that we delete or anonymize your personal information, with certain exceptions. 

• Opt-Out. You have the right to opt-out of targeted advertising, sale of your personal information, and profiling.
   

If you wish to exercise the rights described above, or if you have any questions or concerns regarding the processing of your personal information, please call us at (800) 801-2300 or by sending an email to [email protected]. Please include “Colorado Privacy” in the subject line of your email so that we can get your email to the right team. We will respond to your request consistent with applicable law. Some of the rights above do not apply to personal information we collect in connection with financial and/or insurance products and services we provide to consumers. 
 

Please note, however, before we will be able to process your request to exercise any of the rights above, we will need to properly verify your identity for security purposes. If we possess appropriate information about you (e.g., name, email, address), we will attempt to verify your identity using that information. If is not reasonably possible to identify you, we may not be able to respond to your request. 
 

To use an authorized agent to make a request on your behalf, we may need the authorized agent to provide proof that you gave the authorized agent signed permission to submit the request on your behalf. We may also require you to verify your identity directly with us. 
 

Please note that certain exceptions and limitations apply to the rights discussed above. For example, the rights described above may be limited or inapplicable to certain types of information, to information collected and used in connection with our business relationship with other business entities, and to information pertaining to hiring and employment. 

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Right to Appeal
If we deny your request to exercise any of the rights described above, you may appeal our decision by contacting us at [email protected]. Please include “Colorado Privacy Appeal” in the subject of your email. If we, again, deny your request, you may appeal our decision to the Attorney General (https://coag.gov/).