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://simplicityprotection.com, https://efgcompanies.com/, and http://owneressentials.com/ (our “Website”), or call one of our representatives for a quote on our consumer product, home, lease or vehicle 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; and
• by email, telephone and other electronic messages between you and us.

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 13 years of age. No one under age 13 may directly provide any information to or on the Website or for Services. We do not knowingly collect Personal Data from children under 13. If you are under 13, 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 13, we will delete that information. If you believe we might have any information from a child under 13, please contact us at the Contact Information below. 

Generally

We collect several types of information from and about users of our Website (“Personal Data”):

• by which you may be personally identified, such as first and/or last name, postal address, e-mail address, telephone number, driver’s license number, government issued identification details, passport number, insurance policy number, financial information, loan number, and bank account number or credit card information (for payment information only);
• that is about you but individually does not identify you, such as date of birth, gender, information related to auto, home warranty or other claims, information about your vehicle, health information, other information we receive from you on forms (e.g., occupation, current employer, insurance coverage, purchase and claims history, and premiums), and other information about your use of our Website; 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 our Services;
• automatically as you navigate through the Website. Information collected automatically may include usage details, IP addresses, 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 affiliates and third parties, for example, that help determine eligibility and process requests for Services and process your payment information. 

Information You Provide to Us

The information we collect are:

• information that you provide by filling in forms on our Website or through our third parties. 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 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; and
• when you report a problem with our Website.

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:

• details of your visits to our Website. We collect traffic data, location data, logs, referring/exit pages, date and time of your visit to our Website, error information, clickstream data, and other communication data and the resources that you access and use on the Website; and
• Information about your computer and internet connection, i.e. your IP address, operating system, and browser type.

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:

• estimate our guest size and usage patterns;
• recognize you when you return to our Website.

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

• Cookies (or browser cookies). A cookie is a small file placed on the hard drive of your computer. Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies when you direct your browser to our Website. You can configure your computer 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 find more information about cookies at https://www.allaboutcookies.org and https://www.youronlinechoices.com. 
• Google Analytics.We use Google Analytics, a web analytics service provided by Google, Inc. (“Google”) to collect certain information relating to your use of our Websites. Google Analytics uses cookies to help our Websites analyze how users use the site. You can find out more about how Google uses data when you visit our Websites by visiting “How Google uses data when you use our partners’ sites or apps”, (located at www.google.com/policies/privacy/partners/).

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 provide you with information, products or services that you request from us, including to customize our communications with you and provide personalized content, offers, and advertising;
• to administer offers, promotions and surveys;
• to fulfill any other purpose for which you provide it;
• 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 protect against, and identify, fraud and other criminal activity or to exercise our rights or defend legal claims;
• to perform data analyses and other processing (including market and consumer research, trend analysis, and financial analysis);
• to comply with applicable legal or regulatory obligations, including but not limited to, use in connection with legal claims, compliance, and regulatory or investigative purposes;
• in any other way we may describe when you provide the information; and
• for any other purpose with your consent.

We may also use your information to contact you about our goods and services that may be of interest to you. If you do not want us to use your information in this way, you may send us a return email asking to be omitted from future email distributions. For more information, see Choices About How We Use and Disclose Your Information.

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 subsidiaries and affiliates;
• to contractors, service providers, and other third parties that support our business, including those that help us to provide customer service, manage claims, detect and prevent fraud, manage our website, send out communications on our behalf, and process orders for our products;
• to evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of EFG’s assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which Personal Data held by EFG about our customers are among the assets transferred;
• to fulfill the purpose for which you provide it;
• for any other purpose disclosed by us when you provide the information; and
• with your consent.

We may also disclose your Personal Data:

• to comply with 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, 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 Advertising. 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.
• Promotional Offers from EFG. We may also use your information to contact you about our goods and services that may be of interest to you. If we have sent you a promotional email, you may send us a return email asking to be omitted from future email distributions. 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 a claim request.

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.

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.

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 with a notice that the Privacy Notice has been updated on the Website’s home page, indicating when it was last updated. If we make material changes to how we treat our users’ Personal Data, we will post a prominent notice on our Websites and/or provide other notice as required by law. 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. Use of our Website following such changes constitutes your acceptance of the revised Privacy Notice then in effect.

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. 

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 on: August 5, 2020

This Privacy Addendum for California Residents (“Privacy Addendum”) supplements the information contained in the EFG Privacy Notice that this is attached to and applies solely to all visitors, users, and others who reside in the State of California (“consumers” or “you”). 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 notice. 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 Privacy Addendum applies solely to the Personal Information as defined below. We may update this Privacy Addendum for California Residents as necessary and in the event of changes in the CCPA. Note that this notice does not apply to our personnel. Please contact your supervisor if you are personnel and would like additional information about how we process your personal information. 

INFORMATION WE COLLECT

Our Website and your participation in Services collects 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”). In particular, EFG collects and has collected Personal Information through its Website and through Services from its consumers, as provided below.

Categories of Personal Information EFG has collected in the preceding 12 months:

• Identifiers (e.g., name, title, mailing address, email address, driver’s license number, unique personal or contract identifier, online identifier, health information or health insurance information or other similar identifiers)
• Personal Information categories listed in the California Customer Records statute (e.g., name, signature, address (home and correspondence address, if different), home and mobile telephone number, driver’s license, insurance policy number, employment, employment history, bank account number, credit card or debit card number, loan number, or any other financial information. Note, some of this information may overlap with other categories)
• Commercial information (e.g., records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies)
• Internet or other similar network activity (e.g., information on a consumer’s interaction with a website, application, or advertisement)
• Professional or employment related information (e.g., current or past job history)

Personal Information does not include information that is: (a) publicly available information from government records; (b) deidentified or aggregated consumer information; or (c) certain information excluded from the scope of CCPA, including the Fair Credit Reporting Act (FRCA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver’s Privacy Protection Act of 1994.

Categories of sources from which EFG has collected Personal Information:

• Directly from you. For example, from forms you complete when requesting a quote, purchasing a product, or submitting a claim
• Indirectly from you. For example, from our operating systems and platforms
• Affiliates, parents and subsidiary organizations of EFG
• Service providers
• Businesses whom we work with to offer our products and services 
• Advertising networks

USE OF PERSONAL INFORMATION

We may use or disclose the Personal Information we collect for one or more of the following business purposes: 

• To fulfill or meet the reason you provided the information. For example: if you share your name and contact information to ask a question about our products or services, we will use that Personal Information to respond to your inquiry; if you provide your Personal Information for a quote (whether through our Website or by telephone with one of our representatives), we will use that information to process your request or payment and facilitate fulfilling your order. We may also save your information to process claims related to our products. 
• To provide, support, develop and improve our Website, products and services.
• To process your requests, purchases, transactions, and payments and prevent transactional fraud.
• To provide you with support and to respond to your inquiries, including to investigate and address your concerns and to monitor and improve our responses.
• To help maintain the safety, security, and integrity of our Website, products and services, databases and other technology assets, and business, including to detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, and prosecute those responsible for that activity, and to debug to identify and repair errors that impair existing intended functionality.
• To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.
• Undertaking internal research for technological development and demonstration.
• As described to you when collecting your Personal Information or as otherwise set forth in the CCPA.
• To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of EFG assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which Personal Information held by EFG about our customers are among the assets transferred.

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

SHARING PERSONAL INFORMATION

We do not sell, rent, release, disclose, disseminate, make available, transfer, or otherwise communicate your Personal Information to another organization for monetary or other valuable consideration. However, EFG may disclose your Personal Information to a third party for one or more business purposes. When we disclose Personal Information for a business purpose, we enter a contract that describes the purpose and requires the recipient to both keep that Personal Information confidential and not use it for any purpose except performing the contract. 

We share your Personal Information with the following categories of third parties: 

• Service providers
• Affiliates, parents and subsidiary organizations of EFG

Disclosures of Personal Information for a business purpose:

In the preceding twelve (12) months, EFG has disclosed the following categories of Personal Information for a business purpose: 

• Identifiers
• California Customer Records Personal Information categories
• Commercial information

We disclose your Personal Information for a business purpose to the following categories of third parties: 

• Service providers.

Sales of Personal Information:

In the preceding twelve (12) months, EFG has not sold Personal Information.

YOUR RIGHTS AND CHOICES

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

Access request rights

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

• The categories of Personal Information we collected about you.
• The categories of sources for the Personal Information we collected about you.
• Our business or commercial purpose for collecting or selling that Personal Information.
• The categories of third parties with whom we share that Personal Information.
• The specific pieces of Personal Information we collected about you.
• If we sold or disclosed your Personal Information for a business purpose, two separate lists disclosing:
  • sales, identifying the Personal Information categories that each category of recipient purchased; and 
  • disclosures for a business purpose, identifying the Personal Information categories that each category of recipient obtained. 

Deletion request rights 

You have the right to request that EFG delete any of your Personal Information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request (see Exercising Access 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. Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et. seq.).
5. Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
6. Comply with a legal obligation.
7. Make other internal and lawful uses of that information that are compatible with the context in which you provided it.

Exercising Access and Deletion Rights

To exercise the access 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 Representative”), 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. 

You may only make a verifiable consumer request for access or data portability twice within 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 Representative; and 
• Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

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. With few exceptions, we will only review and fulfill a request from your Authorized Representative if (a) you grant the Authorized Representative written permission to make a request on your behalf, (b) you or the Authorized Representative provides us notice of that written permission, and (c) we are able to verify your identity in connection with that notice and the request. 

Making a verifiable consumer request does not require you to create an account with us. 

We will only use Personal Information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request. 

For instructions on exercising sale opt-out rights, see Personal Information Sales Opt-Out and Opt-In Rights.

Response Timing and Format

We endeavor to respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time (up to 45 days), we will inform you of the reason and extension period in writing.

If you have an account with us, we will deliver our written response to the contact information you provided in that account. If you do not have an account with us, 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. 

Personal Information Sales Opt-Out and Opt-In Rights

We do not sell the Personal Information of consumers and therefore do not provide any opt-in or opt-out capabilities on our website or otherwise.

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.

CHANGES TO OUR CALIFORNIA 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.

OTHER CALIFORNIA PRIVACY RIGHTS

California Civil Code Section 1798.83 (California’s “Shine the Light” law) permits users of our Website that are California residents and who provide Personal Information in obtaining products and services for personal, family, or household use to request certain information regarding our disclosure of Personal Information to third parties for their own direct marketing purposes. If applicable, this information would include the categories of Personal Information and the names and addresses of those businesses with which we shared your Personal Information with for the immediately prior calendar year (e.g. requests made in 2019 will receive information regarding such activities in 2018). You may request this information once per calendar year. To make such a request, please send an email to legaldepartment@efgusa.com or write us at the mailing address shown in the Privacy Notice that this addendum is attached to.

EFG Privacy Addendum for Nevada Residents

Effective Date: January 1, 2020

Last Reviewed on: August 5, 20202

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

EFG does not sell your personal information to any outside companies.

You are entitled, nevertheless, under Nevada law to formally request that we not sell any of your personal information. Please email us at legaldepartment@efgusa.com to submit your request and we will confirm your request.