Enterprise Financial Group Privacy Notice

Enterprise Financial Group Inc. and its affiliates (collectively “EFG”, “we”, “us”, “our”) respect your privacy and are committed to protecting it through our compliance with this policy.

This privacy notice (our “Privacy Notice”) describes the types of information we may collect from you or that you may provide when you visit our websites https://www.efgcompanies.com/, https://simplicityprotection.com,  and http://owneressentials.com/ (collectively, our “Website”), or call one of our representatives for a quote on one of our consumer protection products, (“Services”), and our practices for collecting, using, maintaining, protecting, and disclosing that information.

This policy applies to information we collect:

• on our Website;
• through our Services;
• in email, text, and other electronic messages between you and us; and
• when you contact us or otherwise submit information to us, whether in-person, by telephone, via email or through other means; and
• from our affiliated entities and other third parties.

It does not apply to information collected by:

• us through any other means, including on any other website operated by EFG or any third-party;
• any third party, including through any application or content (including advertising) that may link to the Website.

Please read this policy carefully to understand our policies and practices regarding your information and how we will treat it. If you do not agree with our policies and practices, your choice is not to use our Website. By accessing or using our Website or using our Services, you agree to this Privacy Notice. This Privacy Notice may change from time to time (see Changes to Our Privacy Notice). Your continued use of our Website or Services after we make a change is deemed to be acceptance of those changes, so please check this Privacy Notice periodically for updates.

Our Website and Services are not intended for children under 18 years of age. No one under age 18 may directly provide any information to or on the Website or for Services. We do not knowingly collect Personal Data from children under 18. If you are under 18, do not use or provide any information on our Website or on or through any of its features, or use our Services, including providing your name, address, telephone number, or email address. If we learn we have collected or received Personal Data from a child under 18, we will delete that information. If you believe we might have any information from a child under 18, please contact us at the Contact Information below.

Generally

The types of information we collect may vary depending on your relationship with us. This may include information:

• by which you may be personally identified, such as first and/or last name, residential and/or billing address(es), e-mail address, telephone number, driver’s license number, government issued identification details, passport number, insurance policy or contract/certificate number, financial information, loan number, and bank account number or credit or debit card information (for payment purposes only), and other related information obtained through your use of our Website and/or Services (collectively, “Personal Data”);
• that is about you but individually does not identify you, such as gender; information related to auto, home warranty or other claims; information about your vehicle, health, occupation, employment history, insurance coverage, purchase and claims history, and premiums, and other information about your use of our Website and/or Services; and/or
• about your internet connection, the equipment you use to access our Website and usage details.

We collect this information:

• directly from you when you provide it to us, such as when you request a quote, submit a claim or apply for a product through or otherwise use our Services;
• automatically as you navigate through the Website. Information collected automatically may include usage details, IP addresses, advertising ID, browser type, device information, and information collected through cookies, and other tracking technologies and online browsing data (like date and time of access to our website, referring website address, pages viewed, features used, links clicked, and other actions you take in connection with the Website, sometimes referred to as “clickstream data”); and
• from our affiliated entities and other third parties.

Information You Provide to Us

The information we collect may include:

• information that you provide by filling in forms, whether in writing, in person, by phone, electronically (such as via our Website or email), through our third parties, or by other means. This includes information provided when requesting a quote, purchasing a product, submitting a claim, or requesting further information from us;
• information that you provide when requesting a quote, submitting a claim, or purchasing a product through one of our representatives;
• records and copies of your correspondence (including telephone and email addresses and any transcript of a call), if you contact us;
• your responses to surveys that we might ask you to complete for research purposes;
• information when you opt-in to our SMS service; and
• information you provide on or through our Website or when you use our Services.

Information We Collect Through Automatic Data Collection Technologies

As you navigate through and interact with our Website, we may use automatic data collection technologies to collect certain information about your equipment, browsing actions, and patterns. We collect the details of your visits to our Website, as described above.

The information we collect automatically may include Personal Data, or we may maintain it or associate it with Personal Data we collect in other ways or receive from third parties. It helps us to improve our Website and to deliver a better and more personalized service by enabling us to (i) estimate our guest size and usage patterns, and (ii) recognize you when you return to our Website.

The technologies we use for this automatic data collection may include:

• Cookies (or browser cookies). We may use cookies to receive and store certain types of information whenever you interact with our Website through your computer. A cookie is a small file or piece of data sent from a website and stored on the hard drive of your computer. On your computer, you may refuse to accept browser cookies by activating the appropriate setting on your browser. However, if you select this setting you may be unable to access certain parts of our Website. Unless you have adjusted your browser or operating system setting so that it will refuse cookies, our system will issue cookies when you direct your browser to our Website.
• Google Analytics. We use Google Analytics, a web analytics service provided by Google, Inc. (“Google”) to collect certain information relating to your use of the Website. Google Analytics uses “cookies,” which are text files placed on your computer, to help the Website analyze how users use the site. You can find out more about how Google uses data when you visit our Website by visiting “How Google uses data when you use our partners’ sites or apps,” (located at www.google.com/policies/privacy/partners/). We may also use Google Analytics Advertising Features or other advertising networks to provide you with interest-based advertising based on your online activity. For more information regarding Google Analytics please visit Google’s website, and pages that describe Google Analytics, such as www.google.com/analytics/learn/privacy.html.
• Google Ads. Google Ads is an online advertising solution that we use to promote our products and services on Google Search, YouTube, and other sites across the web. Google Ads also allows advertisers to choose specific goals for their ads, like driving phone calls or website visits. With a Google Ads account, advertisers can customize their budgets and targeting, and start or stop their ads at any time. You can opt-out of Google Analytics for Display Advertising and customize the Google Display Network ads by visiting the Google Ads Settings page: http://www.google.com/settings/ads. Google also recommends installing the Google Analytics Opt-out Browser Add-on https://tools.google.com/dlpage/gaoptout – for your web browser. Google Analytics Opt-out Browser Add-on provides visitors with the ability to prevent their data from being collected and used by Google Analytics. For more information on the privacy practices of Google, please visit the Google Privacy & Terms web page: https://policies.google.com/privacy?hl=en.

Information From Third Party Sources

We also may receive from our affiliated entities and other third parties, such as those that help determine eligibility and process requests for Services and process your payment information.

We use information that we collect about you or that you provide to us, including any Personal Data:

• to present our Website and its contents to you;
• to allow you to participate in the interactive features of our Website;
• to support, personalize, or develop our Website and Services;
• to maintain, customize, and secure your account with us (including notices about subscriptions, expiration, and renewals, if applicable);
• to process your requests, purchases, transactions, and payments, prevent transactional fraud, and/or to support and respond to your inquiries (including to investigate and address concerns and monitor/improve our responses to the same);
• to provide you with information, products, or Services that you request from us;
• to administer sweepstakes, promotions, surveys, and other contests;
• to send you newsletters and other similar communications;
• to advertise or market our products and services or a third party’s products and services to you;
• to help maintain the safety, security, and/or integrity of our business, Website, Services, products, databases, and other technology assets;
• for internal testing, research, analysis, and product development, including to develop and improve our Website, and to develop, improve, or demonstrate our products and Services;
• to perform services on behalf of a third party;
• to undertake activities to verify or maintain the quality or safety of a service or device that is owned, manufactured, manufactured for, or controlled by us;
• to provide you with notices about your account or product, including notices about your purchase or repair status;
• to carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collection;
• to notify you about changes to our Website, account, or any products or Services we offer or provide though them;
• to exercise our rights or defend legal claims, or to comply with our legal, regulatory, and contractual obligations as well as any court order, law, or legal process, including to respond to any government or regulatory request; and
• for any other purpose with your consent or as otherwise permitted by law.

We do not share, sell, or otherwise disclose your Personal Data for purposes other than those outlined in this Privacy Notice. However, we may disclose aggregated information about our users, and information that does not identify any individual, without restriction.

We may disclose Personal Data that we collect, or you provide, as described in this Privacy Notice:

• to our affiliated entities;
• to our business partners, service providers and other vendors we use to support our business, including social media companies and internet cookie information recipients, such as analytics and/or behavioral advertising services, as well as those that help us provide customer service, manage claims, detect and prevent fraud, manage our Website, send out communications on our behalf, and process orders for our products; and
• to a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which Personal Data held by EFG about our users and customers are among the assets transferred.

We may also disclose your Personal Data:

• to comply with our legal, regulatory, and contractual obligations as well as any court order, law, or legal process, including to respond to any government or regulatory request;
• to enforce or apply our Website Terms of Use, terms of purchase, SMS Terms of Use   and other agreements, including for billing and collection purposes; and
• if we believe disclosure is necessary or appropriate to protect the rights, property, or safety of EFG, our staff, or others. This includes exchanging information with other companies and organizations for the purposes of deterring crime, fraud protection, and credit risk reduction.

We do not control the collection and use of your information collected by third parties described above in Disclosure of Your Information. When possible, these organizations are under contractual obligations to use this data only for providing the services to us and to maintain this information strictly confidential. These third parties may, however, aggregate the information they collect with information from their other customers for their own purposes.

In addition, we strive to provide you with choices regarding the Personal Data you provide to us. We have created mechanisms to provide you with control over your Personal Data:

• Tracking Technologies and Cookies. You can set your browser to refuse all or some cookies, or to alert you when cookies are being sent. However, if you choose to refuse cookies you may be unable to access certain parts of our Website. You can learn more about interest-based advertisements and your opt-out rights and options from members of the Network Advertising Initiative (“NAI”) on its website (www.networkadvertising.org) and from members of the Digital Advertising Alliance on its website (www.aboutads.info).
  We do not control third parties’ collection or use of your information to serve interest-based advertising. However, these third parties may provide you with ways to choose not to have your information collected or used in this way. You can also opt out of receiving targeted ads from members of the NAI on its website.
• Promotional Offers from EFG (Email). We may also use your information to contact you about our goods and services that may be of interest to you (with your consent, if required by law). If you do not wish to have your email address used by us to promote our own products and services, you can opt-out at any time by clicking the unsubscribe link at the bottom of any email or other marketing communications you receive from us. This opt out does not apply to information provided to EFG as a result of a request for a quote or to order a product or to submit a claim or otherwise in connection with a product purchase, your use of our Services, or other transaction.
• SMS/Text Communications. When you opt-in to receive SMS communications from us, you consent to receive communications via SMS, text message, or other electronic means. To participate in this service, you are required to provide a mobile phone number. For more information regarding our SMS communications, including how to opt-out of receiving these communications, see our SMS Terms of Use.
  
  We may share the mobile phone number you provided to us when you opted-in to receiving SMS communication with service providers who support these services, but we will not share your mobile phone number with third parties for their own marketing purposes without your consent. Text messages are distributed via third party mobile network providers and, therefore, we cannot control certain factors relating to message delivery. Depending on the recipient’s mobile carrier, it may not be possible to transmit the text message to the recipient successfully; nor is content available on all carriers. We do not claim or guarantee availability or performance of this service, including liability for transmission delays or message failures.

If you have created an account with us on our Website, you can review and change the Personal Data that we maintain about you by logging into our Website and visiting your account profile page. You may also notify us through the Contact Information below.

If you have not created an account with us, you may notify us through the Contact Information below of any changes or errors in any Personal Data we have about you to ensure that it is complete, accurate, and as current as possible.

We may not be able to accommodate your request if we believe it would violate any law or legal requirement or cause the information to be incorrect.

The law in some states may provide you with additional rights regarding our use of Personal Data. To learn more about any additional rights that may be applicable to you as a resident of one of these states, please see the privacy addendum for your state that is attached to this Privacy Notice.

We also may use automated data collection technologies to collect information about your online activities over time and across third-party websites or other online services (behavioral tracking). Some web browsers permit you to broadcast a signal to websites and online services indicating a preference that they “do not track” your online activities. Because there is no standard for these signals at this time, we currently do not honor such signals and we do not modify what information we collect or how we use that information based upon whether such a signal is broadcast or received by us.

We have implemented security measures designed to secure your Personal Data from accidental loss and from unauthorized access, use, alteration, and disclosure. All payment transactions are performed by our third-party payment processor, who must comply with appropriate industry standards to protect your payment information.

Unfortunately, the transmission of information via the Internet is not completely secure. Although we take security measures to protect your Personal Data, including providing training and communications programs designed to educate employees about the meaning and requirements of our data security and confidentiality measures, we cannot guarantee the security of your Personal Data transmitted to our Website or by telephone to our representatives. Any transmission of Personal Data is at your own risk. We are not responsible for circumvention of any security measures contained on the Website.

Our Website may contain links to third party websites or services that are not owned or controlled by us. Please be aware that we are not responsible for the privacy practices of such other websites or services. The privacy practices of these third parties, including details on the information they may collect about you, are subject to the privacy policies of these parties, which we suggest you review.

We may change this Privacy Notice at any time. It is our policy to post any changes we make to our Privacy Notice on this page. If we make material changes to how we treat our users’ Personal Data, we will notify you by email to the email address specified in your account, through a notice on our Website’s home page, or using a similar method. The date this Privacy Notice was last revised is identified at the top of the page. You are responsible for periodically visiting our Website and reviewing this Privacy Notice to check for any changes.

If you have any questions, concerns, complaints or suggestions regarding our Privacy Notice or our privacy practices, have any requests related to your Personal Data pursuant to applicable laws, or otherwise need to contact us, you contact us at contact information below or through the “Contact” page on our Website.

EFG Companies
122 West Carpenter Frwy.
Sixth Floor
Irving, TX 75039
1-800-527-1984
legaldepartment@efgusa.com

EFG Privacy Addendum for California Residents

 Effective Date: January 1, 2020
 Last Reviewed: September 1, 2022

This Privacy Addendum for California Residents (“California Privacy Addendum”) supplements the information contained in the EFG Privacy Notice to which this California Privacy Addendum is attached and applies solely to all visitors, users, and others who reside in the State of California (“consumers,” “you,” or “your”). We adopt this notice to comply with the California Consumer Privacy Act of 2018 (“CCPA”) and any terms defined in the CCPA have the same meaning when used in this California Privacy Addendum.

Personal Information that is regulated under the CCPA may represent a limited portion of Personal Data as described in the EFG Privacy Notice; therefore, this California Privacy Addendum applies solely to consumers’ Personal Information, as defined below.

Unless otherwise noted, this California Privacy Addendum will not apply to the following types of information until January 1, 2023: (i) employment-related Personal Information collected from our California-based employees, job applicants, contractors, or similar individuals; and (ii) Personal Information collected as part of a business-to-business communication (verbal or written) or transaction between EFG and a consumer who is acting as an employee, owner, director, officer, or independent contractor on behalf of another company, and the communication or transaction solely relates to providing or receiving products or services to or from such company.  

1. Information We Collect

We collect information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or device (“Personal Information”). The type of Personal Information we collect may vary depending on your relationship with us. For this reason, we may collect, and over the prior 12 months have collected, the following categories of Personal Information from consumers:  

• Identifiers, such as name, contact information (e.g., residential and/or billing address, email address, telephone number(s)), IP address, government-issued identification numbers (e.g., Social Security, driver’s license, and passport numbers), account name, unique personal, online, or contractual identifiers, and other similar identifiers.
• Personal information as defined in the California Customer Records law, such as name, signature, contact information, government-issued identification numbers, loan number, insurance policy numbers and other health insurance information, payment card data and other financial account information, as well as information regarding your education, employment (current and former), and health.
• Characteristics of protected classifications under California or federal law, such as age, marital status, gender, medical condition, and physical or mental disability.
• Commercial information, such as records of personal property, information relating to your auto, home warranty or other claims, insurance coverage, or purchase and claims history.
• Internet or other electronic network activity (“Internet or Network Activity”) information, such as information regarding a consumer’s interaction with our Website.
• Audio, visual, or similar information, such as audio or call recordings created in connection with our business activities.
• Professional or employment-related information, such as job title as well as current and past work history or experience.

Personal Information does not include: (i) publicly available information from government records; (ii) deidentified or aggregated consumer information; (iii) information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act, Gramm-Leach-Bliley Act or California Financial Information Privacy Act, and the Driver’s Privacy Protection Act of 1994; (iv) medical information governed by the California Confidentiality of Medical Information Act or protected health information collected by a covered entity or business associate governed by the Health Insurance Portability and Accountability Act of 1996; and (v) other information as set forth in the CCPA.

2. Sources of Personal Information

We have obtained the categories of Personal Information listed above from the same categories of sources described in the Information We Collect About You and How We Collect It section of our Privacy Notice.

3. Use of Personal Information

We use or disclose the Personal Information we collect and, over the past 12 months have used or disclosed the Personal Information we have collected for one or more of the following business or commercial purposes listed in the How We Use Your Information section of our Privacy Notice.

EFG will not collect additional categories of Personal Information or use the Personal Information we collected for additional purposes without providing you notice.

 

4. Sharing Personal Information

Disclosures of Personal Information for a Business Purpose

In the preceding 12 months, we have disclosed all categories of Personal Information listed above to administer claims or otherwise provide the status of a contract to our affiliated entities, business partners, and service providers who we use to support our business.  

Sales of Personal Information: We do not sell consumers’ Personal Information and have not sold consumers’ Personal Information in the preceding 12 months.

 

5. Your Rights and Choices

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

Access to Specific Information and Data Portability Rights

You have the right to request that EFG disclose certain information to you about our collection, use, disclosure, and sale of your Personal Information over the past 12 months. Once we receive and confirm your verifiable consumer request (see Exercising Access, Data Portability and Deletion Rights), we will disclose to you:

• The categories of Personal Information we collected about you.
• The categories of sources from which the Personal Information was collected.
• Our business or commercial purpose for collecting or selling that Personal Information.
• The categories of third parties with whom we share that Personal Information.
• If we sold or disclosed your Personal Information for a business purpose, two separate lists identifying: (i) the categories of Personal Information disclosed, and the categories of third parties to whom the Personal Information was disclosed, and (ii) the categories of Personal Information sold, and the categories of third parties to whom the Personal Information was sold.
• The specific pieces of Personal Information we collected about you.

If you make a request for the specific pieces of Personal Information electronically, we will, to the extent permitted by law, provide you with a copy of your Personal Information in a format we select that is readily useable and allows you to transmit the Personal Information to another person or entity.

Deletion Request Rights

You have the right to request that EFG delete any of your Personal Information that we have collected from you and maintained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request (see Exercising Access, Data Portability and Deletion Rights), we will delete (and direct our service providers to delete) your Personal Information from our records, unless an exception applies.

We may deny your deletion request if retaining the information is necessary for us or our service provider(s) to:

1. Complete the 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.
2. Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
3. Debug products to identify and repair errors that impair existing intended functionality.
4. Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
5. Comply with the California Electronic Communications Privacy Act.
6. 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.
7. Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
8. Comply with a legal obligation.
9. Make other internal and lawful uses of that information that are compatible with the context in which you provided it.

Exercising Access, Data Portability, and Deletion Rights

To exercise the access, data portability, and deletion rights described above, please submit a verifiable consumer request to us by either:

• Calling us at 1-800-527-1984
• Emailing us at legaldepartment@efgusa.com

Only you, or a person registered with the California Secretary of State that you authorize to act on your behalf (an “Authorized Agent”), may make a verifiable consumer request related to your Personal Information. You may also make a verifiable consumer request on behalf of your minor child. We are not obligated to provide information to you in response to your verifiable consumer request for access or portability more than twice in a 12-month period. The verifiable consumer request must:

• Provide sufficient information that allows us to reasonably verify you are the person about whom we collected Personal Information or an Authorized Agent.
• Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

We are unable to fulfill 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. With few exceptions, we will only review and fulfill a request from your Authorized Agent if (i) you grant the Authorized Agent written permission to make a request on your behalf, (ii) you or the Authorized Agent provides us notice of that written permission, and (iii) we are able to verify your identity in connection with that notice and the request. We will only use Personal Information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.

Verifying Your Identity

Before completing your request to exercise the below, we will verify that the request came from you by comparing the identifying information provided by you in your request with any Personal Information we maintain about you at that time. For all requests, we will need the consumer’s full name plus the following information: (i) residential or billing address; (ii) telephone number; (iii) email address; and/or (iv) contract number.

To protect the privacy and security of your Personal Information, we may request additional information from you to help us verify your identity and process your request. This information may include your driver’s license or other government-issued identification number. We may also contact you to ask you for further information in relation to your request to speed up our response. You may also be asked to complete and provide a signed declaration under penalty of perjury that you are the consumer who is the subject of the request in certain circumstances. We will only use Personal Information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.  

Response Timing and Format

We endeavor to respond to a verifiable consumer request within 45 days of its receipt. If we require more time (up to 45 additional days), we will inform you of the reason and extension period in writing. We will deliver our written response by mail or electronically, at your option.

Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request’s receipt. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your Personal Information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance.

We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.  

6. Non-Discrimination

We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, 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. However, we will continue to offer you discounts and other benefits if you choose to participate in EFG Rewards.
• Provide you a different level or quality of goods or services.
• Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.

7. Changes to Our California Privacy Addendum

We reserve the right to amend this California Privacy Addendum as described in our Privacy Notice. When we make changes to this California Privacy Addendum, we will inform you of such updates as described in our Privacy Notice

EFG Privacy Addendum for Nevada Residents  

Effective Date: January 1, 2020
Last Reviewed: September 1, 2022

This Privacy Addendum for Nevada Residents (“Nevada Privacy Addendum”) supplements the information contained in the EFG Privacy Notice to which this Nevada Privacy Addendum is attached and applies solely to all visitors, users, and others who reside in the State of Nevada (“consumers,” “you,” or “your”). We adopt this Nevada Privacy Addendum to comply with Nevada’s Online Privacy Law (“OPL”).

Nevada provides its residents with a limited right to opt-out of certain covered information sales under the OPL. However, EFG does not currently sell information triggering the OPL’s opt-out requirements.