Effective Date: June 30, 2023
The Privacy Policy describes how Toa Reinsurance Company of America (“Toa Re”, ”us,” “we,” and “our”), collects, stores, uses and discloses personal information about you as a job applicant to work for us. This notice describes how we use that personal information, to whom we disclose it, how you can exercise your data choices, and how you can contact us.
California Residents: See the California Privacy Rights section below for important information about your personal information and rights under applicable state privacy laws.
Not in scope. This Privacy Policy does not apply to interactions with Toa Re outside of the job application context, such as browsing our website. Please click here to review our Privacy Policy to learn more about our privacy practices related to those types of interactions.
We may also collect, generate, use and disclose aggregate, anonymous, and other non-identifiable data, which is not personal information subject to this Privacy Policy.
If you have any questions, please contact us as provided below. If you need to receive this Privacy Policy in a different format, please contact us at 973-898-9480 or compliance@toare.com.
Contents
Categories of Personal Information We Collect
Sources Of Personal Information
Purposes for Collecting Personal Information
How We Disclose Personal Information
How Long We Keep Personal Information
Categories of Personal Information We Collect
Toa collects information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with you or your household (“personal information”). We collect, and in the preceding 12 months have collected, the below categories of applicant personal information with your consent or as otherwise required or permitted by law.
- Identifiers, such as your name, signature, email address, mailing address, phone number, social security number, driver’s license or state identification number, and mailing address.
- Characteristics of Protected Classifications, such as your date of birth, age, and veteran/military status, if you provide this information.
- Professional or Employment Information, such as information related to your employment history, including your resume.
- Education Information, such as your education history.
Sources Of Personal Information
We collect, and in the preceding 12 months have collected, personal information in the following ways:
- Directly from you. We may collect personal information directly from you, such as during the job application and recruitment process.
- From third parties. We may collect certain Personal Information about you from third parties. For example, this includes from vendors that run background checks once a conditional offer of employment is provided. This also includes information from references. Our employees may provide us with information about you in connection with your application to work for us. We may combine information that we collect from different sources.
Purposes for Collecting Personal Information
We use personal information for the following business and commercial purposes:
- Recruiting and Hiring. We use identifiers, characteristics of protected classifications, professional or employment information, and education information we collect from your application and through the application and interview process to evaluate your qualifications and eligibility for employment, including eligibility for veteran preference.
- Background Checks. After receiving a conditional offer of employment, we may use the identifiers, characteristics of protected classifications, professional or employment information, and education information we collect to complete a background check on our Applicants to verify your identity, check for criminal history, and confirm the validity of your application.
- Legal Compliance and Protection. We use identifiers, characteristics of protected classifications, professional or employment information, and education information we collect to comply with mandatory government reporting requirements and applicable laws, our legal obligations and in our defense of our company, property, and others through legal proceedings.
How We Disclose Personal Information
We disclose personal information in the following circumstances:
- Service Providers. We share personal information with vendors and service providers who support the operation of our business, including our payroll provider(s), benefits administrator(s), insurance administrator(s), and retirement plan administrator(s). In some cases, the service provider may directly collect the information from you. In the past 12 months, we have disclosed identifiers, characteristics of protected classification, and professional or employment information to our service providers.
- Professional Advisors. We may share information with professional advisors, such as lawyers, bankers, tax consultants, auditors, and insurers, where necessary in the course of the professional services that they render to us. In the past 12 months, we have disclosed identifiers, characteristics of protected classifications, professional or employment information, and education information to our professional advisors.
- Government Entities. We share information with regulatory and government entities including government, administrative, law enforcement and regulatory agencies; tax authorities; and other public agencies or authorities if we think we should in order to comply with any applicable law, regulation, legal process or other legal obligation. This includes cooperating with law enforcement when we think it is appropriate, obtaining legal remedies or limiting our damages, and to enforcing or protecting our contracts, legal rights or the rights of others, including by responding to claims asserted against us. In the past 12 months, we have not disclosed any personal information to government entities in the last 12 months.
- Affiliates. We may share some or all of your personal information with our parent company, subsidiaries, and other companies under common ownership or control with us for purposes consistent with this Privacy Policy.
- Other Reasons. We may disclose personal information for other reasons we may describe to you, including if you consent to the disclosure or direct us to disclose your information.
How Long We Keep Personal Information
To the extent permitted by applicable law, the Company will retain your personal information for as long as reasonably necessary to fulfill the purposes for which it was collected, including to meet any legal, accounting, or other reporting requirements or obligations. We use the following criteria to determine retention periods:
- how long the information is needed to provide our services and operate our business;
- whether there are contractual or legal obligations that exist that require us to retain the information for period of time;
- whether any law, statute, or regulation allows for a specific retention period;
- whether an individual has agreed to a longer retention period;
- whether the data is considered to be sensitive data; and
- what the expectation for retention was at the time the data was provided to us.
Security
We follow generally accepted industry standards to protect the personal information submitted to us and have implemented reasonable technical, organization, administrative and physical measures to protect personal information. No method of transmission or method of electronic storage, is 100% secure, however.
California Privacy Rights
If you are a California resident, this section applies to you.
California Consumer Privacy Act (“CCPA”), as Amended by the California Privacy Rights Act (“CPRA”).
Sale or Sharing of Personal Information. In the preceding 12 months, we have not “sold” or “shared” (as those terms are defined in the CCPA) any personal information (including sensitive personal information) to “third parties”, as that term is defined in the CCPA.
Use or Disclosure of Sensitive Personal Information. The following forms of data listed above constitutes “sensitive personal information”: Your social security, driver’s license, or state identification number. We do not use or disclose sensitive personal information for any purpose other than those permitted by the CCPA and its interpretive regulations.
Your Rights Under the CCPA. Subject to certain exceptions and limitations, the CCPA affords California consumers the following rights:
- You have the right to request that we tell you (i) what personal information we have collected about you, (ii) the sources of that information, (iii) the purposes for collecting, selling or sharing the personal information; and (iv) the categories of third-parties to whom we have disclosed personal information.
- You have the right to request that we provide you with a copy of your personal information.
- You have the right to request that we delete personal information that we have collected from you. We may not delete all of your personal information if one of the exceptions to the CCPA applies.
- You have the right to correct inaccurate personal information that we hold about you.
- You have the right to not be discriminated against for exercising any of your CCPA rights. We will not discriminate against you if you exercise any of your CCPA rights.
Exercising Your Rights. To exercise any of your rights, you may email us at compliance@toare.com, call us at 973-898-9480, or use the webform Contact Us on our website to submit a request. We cannot process your request if you do not provide us with sufficient detail to allow us to understand and respond to it. You can ask to appeal any denial of your request in the same manner through which you may submit a request.
For all requests, you should provide us with your name, email address, phone number, and mailing address. We will verify your identity by matching the information we have regarding our job applicants against the information you have provided. Failure to provide the foregoing information may prevent us from processing your request. If you have requested that we correct your personal information, we may contact you to request additional information about the personal information that you believe is inaccurate, including supporting documentation.
Authorized Agents. Your authorized agent may be able to make a request on your behalf. However, we may need to verify your authorized agent’s identity and authority to act on your behalf. We may require a copy of a valid power of attorney given to your authorized agent pursuant to applicable law. If you have not provided your agent with such a power of attorney, we may ask you to take additional steps permitted by law to verify that your request is authorized, such as by providing your agent with written and signed permission to exercise your rights on your behalf, the information we request to verify your identity, and confirmation that you have given the authorized agent permission to submit the request.
Contact Us
If you have any questions about this Policy or our privacy practices, please contact email us at compliance@toare.com, call us toll free at 973-898-9480. In addition, you may contact VP, Human Resources at bmuccia@toare.com or call 973-898-9468.
Updates to Our Privacy Policy
This Applicant Privacy Policy may be updated from time to time for any reason. If we make material changes to this Privacy Policy we will notify you by posting the new Privacy Policy here and changing the effective date listed at the top of this Privacy Policy. If required by law we will also provide notification of changes in another way that we believe is reasonably likely to reach you, such as via e-mail or another manner with which we communicate with you as a job applicant. Any modifications to this Applicant Privacy Policy will be effective upon our posting the modified version as described above (or as otherwise indicated at the time of posting).