Privacy Notice for CALIFORNIA RESIDENTS

This Privacy Policy Disclosure for California Residents (this “CCPA Disclosure”) supplements the information contained in American Brokerage Service’s (“ABS” or “we”, “our” or “us”) Privacy Policy located at https://www.absgo.com/privacy-notices and applies solely to all visitors, users, agents of ABS and others who reside in the State of California (“you” or “your”). We adopt this CCPA Disclosure to comply with the California Consumer Privacy Act of 2018 (the “CCPA”) and any terms defined in the CCPA have the same meaning when used in this CCPA Disclosure. Any terms defined in our Privacy Policy have the same meaning when used in this CCPA Disclosure.

Information We Collect

Our Website collects information that identifies, relates to, describes, references, is reasonably capable of being associated with, or could be linked, directly or indirectly, with a particular consumer, house or device. The types of Personal Information collected depends on your relationship with us. Similarly, depending on your relationship with us, we may disclose your Personal Information for the purposes described in the Privacy Policy to one or more of the categories of recipients set forth in the chart below. The chart below details which categories of Personal Information we disclose to third parties for our operational business and commercial purposes, including within the twelve (12) months preceding the date this CCPA Disclosure was last updated. The chart also details the categories of Personal Information that we “sell” or “share” for purposes of cross-context behavioral advertising, including within the twelve (12) months preceding the date this CCPA Disclosure was last updated. For context, the CCPA defines a “sale” broadly as any disclosure of Personal Information for payment or other valuable consideration, including certain types of targeted advertising. The CCPA defines “sharing for cross-context behavioral advertising” as the disclosure of Personal Information for retargeting or other interest-based advertising.

Under the CCPA, as amended by California Resident Privacy Act (the “CPRA”), “Personal Information” is information that identifies, relates to, describes, references, or is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular California resident or device located in the state of California. The CCPA, as amended by the CPRA, however, does not apply to certain information, such as information subject to certain federal privacy laws, such as the Gramm-Leach-Bliley Act (“GLBA”) and the Health Insurance Portability and Accountability Act (“HIPAA”).

Our Website obtains the categories of Personal Information listed above from the following categories of sources:

Directly from you: from forms you complete, or products and services purchased.
Indirectly from you: from observing your actions on our Website.
Our commercial customers or plan sponsors: if you participate in one of our plans or receive certain group benefits from your employer.
Other sources: such as companies that help us maintain the accuracy and completeness of data and help enhance our records.

Use of Personal Information

We may share your Personal Information with our subsidiaries, affiliates, and service providers to help us with the following business and commercial purposes:

Providing the information, products or services requested or reasonably expected by you given the context in which the Personal Information was collected, including, maintaining or servicing accounts, providing customer service, processing, fulfilling orders and transactions, verifying customer information, processing payments or providing similar services.
Responding to your inquiries and fulfilling your requests.
Conduct marketing and advertising activities.
Undertaking market research and data analytics.
Carrying out user experience surveys.
Ensuring security and integrity to the extent the use of Personal Information is reasonably necessary and proportionate to the use.
Enhancing and improving our products and services.
Managing our recruitment processes and career opportunities.
Complying with legal, reporting, and similar requirements.
Investigating and responding to claims against AVBS, its personnel and its customers
Protecting ABS, yours, our customers’ and other third parties’ safety, property or rights.
Detecting, preventing, and responding to security incidents and protecting against malicious, deceptive, fraudulent, or illegal activity.
Safeguarding against, identifying and preventing fraud and unlawful activities; or
Executing information technology and administrative support functions.

We exclusively share or sell Personal Information within the framework of our advertising technology programs, which includes mechanisms like cookies, designed for cross-context behavioral advertising, or other marketing and advertising services we employ on our Website. We do not possess actual knowledge that we share or sell Personal Information of consumers under the age of 16. We do not employ or disclose sensitive Personal Information for purposes that fall under the right to limit use and disclosure, as provided in the CCPA.

The length of time we retain your Personal Information depends on the type of information and the reason we collected it. We may retain your Personal Information for as long as necessary to: (i) provide you with our products and services; (ii) communicate with you about your account; (iii) comply with legal requirements; (iv) establish, exercise or defend our legal rights; (v) in connection with an investigation of suspected or actual illegal activity; or (vi) in the event we sell or transfer all or a portion of our business or assets (including in the event or a reorganization, dissolution or liquidation).

We will also retain your Personal Information for as long as necessary to allow us to exercise our legitimate business interests, such as improving our products and services, preventing fraud, and enforcing our terms of service.

In some cases, we may anonymize your Personal Information so that it can no longer be associated with you. In this case, we may retain the anonymized information indefinitely. We reserve the right to use anonymized, de-identified or aggregated information for any purpose permitted by law.

Your California Consumer Privacy Rights

The CCPA provides California Residents with specific rights regarding their Personal Information. This section describes your CCPA rights and explains how to exercise those rights.

The Right to Know

You have the right to request that we disclose to you the following information about your Personal Information:

The categories and specific pieces of Personal Information we have collected about you.
The categories of sources from which your Personal Information was collected.
Whether we have shared or sold your Personal Information.
The business or commercial purpose for collecting, sharing or selling your Personal Information.
The categories of third parties with whom we have disclosed your Personal Information.

Right of Correction

You have the right to request that we correct any inaccurate Personal Information that we have collected about you. We may require you to provide documentation to support your request. If you request that we correct your Personal Information, we may delete it instead, if deletion does not negatively impact you or you consent to the deletion. We will not correct your Personal Information if it is necessary or permissible for us not to correct it under the CCPA or other applicable law.

Right of Deletion

You have the right to request that we delete Personal Information we have collected about you, subject to our legal rights or obligations to retain such information.

Right to Opt-Out

You have the right to choose not to have your Personal Information sold or shared for advertising purposes. To do this, click the [“Do Not Sell or Share My Personal Information”] link in the footer of our Website. You can also set your web browser to disable certain tracking technologies. However, disabling certain tracking technologies may affect the functionality of some features on our Website.

Right to Non-Discrimination for Exercise of Privacy Rights

If you choose to exercise your privacy rights, we will not discriminate against you. We will not deny our products or services to you, charge you different prices for such products or services or provide a different level or quality of products or services unless the difference is related to the value of your Personal Information. We will not retaliate against you for exercising your privacy rights under the CCPA.

How to Exercise Your Rights

You can exercise the rights list above or contact us with questions or concerns about privacy notices and practices:

Calling us at 888-227-3131 x249
Emailing us at privacy@absgo.com
Writing to us at: American Brokerage Services, Inc., Attn: Privacy Notice Inquiries, 805 E Willow Grove Ave, Wyndmoor PA 19038.

To verify your identity and fulfill your CCPA request, we will ask you to provide some information, such as your name, phone number, postal address, email address and date of birth. We may also call you to request additional information, such as your Social Security Number, to further verify your identity. We will not store or use this information for any other purpose.

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.

If you want to designate someone else to submit a CCPA request on your behalf, you will need to give them written permission and verify your own identity. We will also need the authorized agent to submit proof that you have authorized them to act on your behalf.

Limiting or Declining Your CCPA Request

We may limit or decline to respond to your CCPA request if:

Providing the information would be impossible or require a disproportionate amount of effort, such as if you are requesting information that we collected more than 12 months ago.
We cannot verify your identity or confirm that the Personal Information we have relates to you.
We cannot verify that you have the authority to make a request on behalf of another individual.
There is an exception that applies, such as if disclosing the information would harm the rights of another individual.
The Personal Information we have collected about you is not subject to the CCPA’s right to know and/or deletion right.

Rev. Nov-23