Last modified: June 30, 2023
This Privacy Policy helps you understand how Toa Reinsurance Company of America (“Toa Re”) collects, stores, uses, shares, and secures your personal information. In this Policy, the terms “company,” ”us,” “we,” and “our” refer to Toa Re and its affiliates and subsidiaries.
This Privacy Policy applies to information we collect or receive when you visit or use our website (“Site”); contact our customer service team; communicate with us; use, request, purchase, obtain or consider our products, or otherwise interact with us.
Not in scope. This Privacy Policy does not apply to: (1) job applicants; or (2) employees of Toa Re. Please click here to review our Applicant Privacy Notice. Please click here to review our Employee Privacy Notice. We may also collect, generate, use and disclose aggregate, anonymous, and other non-identifiable data related to our Services, which is not personal information subject to this Privacy Policy.
California Residents: See the California Privacy Rights section below for important information about your personal information and rights under applicable state privacy laws.
Please read this Privacy Policy carefully to understand our policies and practices. By using the Site or providing your personal information to us, you signify that you consent to the use of your information in accordance with this Privacy Policy. If you do not agree with any term in this Privacy Policy, you should not access and use the Site and please do not otherwise provide us with any personal information.
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
Sensitive Personal Information
How Long We Keep Personal Information
This Website is Not Intended for Minors
Notice At Collection to Website Visitors
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”). The type of information that we collect depends on your interaction and relationship with us. For example, personal information may be collected when you contact us or otherwise provide us personal information through our Services. We collect, and in the preceding 12 months have collected, the below categories and types of personal information with your consent or as otherwise required or permitted by law.
- Identifiers, such as your name, signature, email address, Internet Protocol (“IP”) address, telephone number, business contact information, and title/position.
- Commercial Information, such as records of products or services purchased, obtained, or considered and purchasing histories by you on behalf of the business(es) you represent in connection with our Services.
- Internet or Other Electronic Network Activity Information, such as your device ID, internet and network information, and cookie information.
- Audio/Visual Data or Similar Information, such as security camera footage and voicemails.
- Professional or Employment Information, such as information related to your employment history.
Cookies
Our website uses cookies, tags, pixels, and similar tracking technologies (“Cookie” or “Cookies”) to provide, customize, evaluate, improve, and secure our website and services.
A Cookie is a small piece of text that is placed on your website browser when you visit a website. These include our own first-party Cookies as well as third-party Cookies of our service providers and marketing partners. You can find out more about Cookies in general and how they work at https://cookiepedia.co.uk/. We use performance and functional Cookies to help us analyze how you interact with our website. This enables us to monitor and improve our website performance, services, and your experience.
If you wish to prevent Cookies from tracking your activity on our website or visits across multiple websites, you can set your browser to block certain Cookies or notify you when a Cookie is set. If you block cookies, certain features on our website may not work. For more information on how you can customize your browser’s Cookie setting, please access the settings of your web browser.
You may opt-out of interest-based advertising in general by visiting the Digital Advertising Alliance’s (https://digitaladvertisingalliance.org/) or Network Advertising Initiative’s (https://thenai.org/) websites. You can also turn off ad personalization from Google. We are not responsible for the completeness, effectiveness, or accuracy of any third party opt-out options or programs.
Sources Of Personal Information
We collect, and in the preceding 12 months have collected, personal information in the following ways:
- Directly from you. We collect identifiers, commercial information, audio/visual data, and professional or employment information that you provide directly to us.
- When you visit our locations. When you visit our offices or facilities, we also collect identifiers and audio/visual data.
- Automatically. When you access our Site, we may collect internet or electronic usage data using tools like functional cookies.
- From third parties. We may collect identifiers, commercial information, and professional or employment information from third-parties including our business contacts, customers, recruiters, and service providers.
Purposes for Collecting Personal Information
We use personal information for the following purposes:
- Providing our Services. We use identifiers, commercial information, audio/visual data, and professional and employment information to facilitate the generation of new business opportunities, to allow customers to contract for and purchase our Services, to provide the products and Services we have contracted for, and to provide updates and reports requested by customers.
- Transactional Purposes. We use identifiers, professional or employment information, and commercial information to: (i) communicate with you; (ii) provide you with customer assistance; (iii) administer contracts with our vendors, customers, and service providers; and (iv) provide supporting business activities such as billing, and procurement related activities.
- Business Operations. We use identifiers, commercial information, audio/visual data, professional or employment information, and internet or other electronic network activity information, for our day-to-day business operations including maintaining records, managing and securing our facilities, planning, budgeting, calibration, headcount, database administration, surveys, evaluations, reports, compliance, regulatory, audit, investigative purposes and other ethics and compliance reporting tools, and to support our business operations.
- Marketing and Promotional Purposes. We use identifiers, professional or employment information, and commercial information to improve our marketing efforts, conduct market research, prospect for new clients, engage in client relationship management, client engagement, administering promotions, and to provide you with information about us, including personalized marketing communications.
- Maintenance and Improvement of our Site and Systems. We use identifiers and internet or other electronic network activity information to improve our Site and systems, provide and maintain functionality on our Site and systems, and help us diagnose technical and service problems and administer our Site and systems. Maintenance of our systems includes activities such as applying security controls for company systems, providing new system implementations, applying change management processes, and providing IT support services
- Develop and Improve Our Services. We use commercial information to help us develop new services and to improve and analyze our existing service offerings.
- Security and Fraud Prevention. We use identifiers, commercial information, internet or other electronic network activity information, audio/visual data, and professional or employment information to: (i) protect us, our employees, and our Site, premises, assets, systems, products, services and intellectual property, including from fraud, theft, and misconduct; (ii) enforce our policies and terms; (iii) conduct vendor and customer due diligence; and (iv) detect and prevent fraud, theft and misconduct including by verifying the identity of those we are conducting business with.
- Complying with Legal and Ethical Obligations and Legal Process. We use identifiers, commercial information, internet or other electronic network activity information, audio/visual data, and professional or employment information to comply with our legal obligations, including responding to CCPA requests, reporting requirements and responding to court orders, warrants, or subpoenas, defend ourselves in legal proceedings, and protect our company and our property, employees, and others through legal proceedings.
How We Disclose Personal Information
We disclose personal information in the following circumstances:
- Service Providers. We may share personal information with vendors and service providers who support the operation of our Services, Site, and our business and who need access to such information to carry out their work for us (including, for example, cloud hosting, email delivery, recruitment, marketing, insurance, operating systems and platforms, transportation, and customer support services). In some cases, the vendor or service provider may directly collect the information from you on our behalf. In the past 12 months, we have disclosed identifiers, professional or employment information, and commercial 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, commercial information, internet or other electronic network activity information, audio/visual data, professional or employment 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.
- 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.
Sensitive Personal Information
Unless specifically requested, we ask that you not send us, and you not disclose to us, through the Services or otherwise, any Sensitive Personal Information (e.g., social security number, taxpayer identification number, passport number, driver’s license number, or other government-issued identification number; credit or debit card details or financial account number, with or without any code or password that would permit access to the account, credit history; or information on race, religion, ethnicity, sex life or practices or sexual orientation, medical or health information, genetic or biometric information, biometric templates, political or philosophical beliefs, political party or trade union membership, background check information, judicial data such as criminal records, or information on other judicial or administrative proceedings).
How Long We Keep Personal Information
We will retain and use your information for as long as we need it to provide you services or products, or as long as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements. Where we process personal information for marketing purposes, we process the data until you ask us to stop and for a short period after this (to allow us to implement your requests). 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.
Links to Other Websites
Our Site may include links to other websites or applications whose privacy practices may differ from ours. If you submit personal information to any of those websites or applications, your information is governed by their privacy policies. We encourage you to carefully read the privacy policy of any website you visit or application that you use.
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 over the Internet, or method of electronic storage, is 100% secure, however. Therefore, we cannot guarantee its absolute security and encourage you to use websites and share information with caution.
This Website is Not Intended for Minors
Our Site is not intended for use by individuals under the age of 16. We do not knowingly collect or store any personal information from anyone under the age of 16. If we become aware that we have collected or stored personal information from an individual under age 16, we will remove their personal information from our files. If you are a parent or guardian and believe we may have inadvertently collected personal information from your child, please notify us by sending an email to compliance@toare.co].
California Privacy Rights
If you are a California resident, this section applies to you.
Shine The Light. The California Shine the Light law (Cal. Civ. Code § 1798.83) permits residents of California to request certain details about how their information is shared with third parties for the third-parties’ direct marketing purposes. If you are a California resident and would like to make such a request, please contact us at compliance@toare.com and include “CA Shine the Light” in the subject line of your email.
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 to “third parties”, as that term is defined in the CCPA. We do not knowingly sell or share the personal information of minors under the age of 16.
Use or Disclosure of Sensitive Personal Information. We do not collect “sensitive personal information” as that term is defined by the CCPA.
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 Site 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 sufficient information to verify your identity and process your request. Failure to provide identifying 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 email us at compliance@toare.com.
Updates to Our Privacy Policy
This 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 through the Services. Any modifications to this Privacy Policy will be effective upon our posting the modified version as described above (or as otherwise indicated at the time of posting). In all cases, your continued use of the Services after the posting of any modified Privacy Policy indicates your acceptance of the modified Privacy Policy.
Notice At Collection to Website Visitors
This Notice explains your rights under the CCPA and helps you understand how we collect and use your personal information when you use our Site and submit information through our webform.
- Information We Collect From Website Visitors
When you use our Site we collect personal information in the form of Internet or Other Electronic Network Activity Information, such as your device ID, internet and network information, and cookie information. This personal information is collected automatically from the device you use to access our Site.
If you submit a CCPA request through the webform on our Site, we may also collect personal information in the form of Identifiers, such as your name, email address, and telephone number.
- How We Use the Information We Collect
We use the personal information we collect for the following purposes:
- Business Operations. We use internet or other electronic network activity information for our day-to-day business operations including maintaining records, database administration, evaluations, reports, compliance, regulatory, audit, investigative purposes and other ethics and compliance reporting tools, and to support our business operations.
- Maintenance and Improvement of our Site and Systems. We use internet or other electronic network activity information to improve our Site and systems, provide and maintain functionality on our Site and systems, and help us diagnose technical and service problems and administer our Site and systems. Maintenance of our systems includes activities such as applying security controls for company systems, providing new system implementations, applying change management processes, and providing IT support services
- Security and Fraud Prevention. We use internet or other electronic network activity information to: (i) protect us, our employees, and our Site, premises, assets, systems, products, services and intellectual property, including from fraud, theft, and misconduct; (ii) enforce our policies and terms; and (iii) detect and prevent fraud, theft and misconduct including by verifying the identity of those we are conducting business with.
- Complying with Legal and Ethical Obligations and Legal Process. We use identifiers and internet or other electronic network activity information to comply with our legal obligations, including responding to requests under the CCPA, reporting requirements and responding to court orders, warrants, or subpoenas, defend ourselves in legal proceedings, and protect our company and our property, employees, and others through legal proceedings.
- Additional Rights Under California Law
You may have certain rights under California law. This may include a right to access, correct, or delete certain personal information we collect about you, subject to applicable exceptions. To exercise your rights, you may email us at compliance@toare.com, call us at 973-898-9480, or use the webform Contact Us on our Site to submit a request.
Under California law, we are required to tell Californians if we “sell” or “share” information as that term is defined by applicable law. Sell is defined under the law as disclosing personal information to a third party for monetary or other valuable consideration. Share is specifically defined under the law as well. Sharing means sharing personal information with a third party for cross-context behavioral advertising.
We do not do “sell” or “share” data collected on our Site, based upon our understanding of those terms. If you interact with Toa Re in other ways, you may have different rights. If you are a customer or consumer, the Privacy Policy on our Site applies to our interactions with you as a customer or consumer.
- How We Retain Your Personal Information
To the extent permitted by applicable law, Toa Re will retain your personal information for as long as reasonably necessary to fulfill the purposes for which it was collected, including to meet any business, 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.
- How You Are Protected Against Discrimination & Retaliation
Toa Re will not unlawfully discriminate against you for exercising any of your rights under the CCPA.
- Disclaimer
Nothing in this Notice restricts our ability to:
- Comply with federal, state, or local laws;
- Comply with a civil, criminal, or regulatory inquiry, investigation, subpoena, or summons by federal, state, or local authorities;
- Cooperate with law enforcement agencies concerning conduct or activity that the business, service provider, or third party reasonably and in good faith believes may violate federal, state, or local law;
- Exercise or defend legal claims;
- Detect security incidents and protect against fraudulent or illegal activity and prosecute those responsible for such activity; or
- Transfer personal information as part of a merger or acquisition, dissolution, bankruptcy, or any other transaction in which a third party assumes control of all or part of Toa Re.
- Changes to This Notice
This Notice is reviewed and updated annually to ensure it accurately captures our practices and procedures. The effective date of this version is posted at the top of the Privacy Policy.
- Privacy Policy
Please click here to view our Privacy Policy.
- Resolving Concerns and How to Contact Us
If you have questions or concerns regarding this Notice or the handling of your personal information, please contact us at compliance@toare.com.