Privacy Policy

    Introduction

    At Clinton Polley Group, Inc (CPG) we are committed to maintaining the accuracy, confidentiality and security of our customers' personal information. This Privacy Policy describes the personal information that CPG collects from or about our customers, and how we use and to whom we disclose that information.

    Application

    CPG has adopted a series of Privacy Policies in order to address the specific privacy concerns of our customers. This Privacy Policy applies to the personal information of all individuals who seek to be, are, or were customers of CPG.

    If you are unsure of which Privacy Policy applies to you, please contact the office of our Privacy Officer for more information.

    Organizations Covered by this Policy

    Clinton Polley Group, Inc. (CPG), also known as Clinton Polley Insurance Brokers, is a corporation located in Folsom, CA.

    All references in this Privacy Policy to "CPG", "we", "us", "our" and like terms should be interpreted accordingly.

    Policy of Compliance

    It is CPG's policy to comply with the privacy legislation within each jurisdiction in which we operate. Sometimes the privacy legislation and / or an individual's right to privacy are different from one jurisdiction to another. This Privacy Policy was developed to guide the activities of CPG. In addition, specific privacy practices may be adopted to address the specific privacy requirements of particular jurisdictions. This Privacy Policy has a limited scope and application and the rights and obligations contained in this Privacy Policy may not be available to all individuals or in all jurisdictions. If you are unsure if or how this Privacy Policy applies to you, please contact the office of our Privacy Officer for more information.

    What is Personal Information?

    For the purposes of this Privacy Policy, personal information is any information about
    an identifiable individual, other than the person's business title or business contact information when used or disclosed for the purpose of business communications. Personal information does not include anonymous or non-personal information (i.e., information that cannot be associated with or tracked back to a specific individual).

    What Personal Information do we Collect?

    We collect and maintain different types of personal information in respect of those individuals who seek to be, are, or were customers of CPG, including the personal information contained in:

  • applications and forms;
  • photographs and video;
  • letters and other correspondence
  • In addition to the examples listed above, personal information also includes information such as name, home address, telephone, personal email address, date of birth, employee identification number and any other information necessary to CPG's business purposes, which is voluntarily disclosed in the course of a business relationship between CPG and our customers. As a general rule, CPG collects personal information directly from our customer. In most circumstances where the personal information that we collect about our customers is held by a third party, we will obtain your permission before we seek out this information from such sources (such permission may be given directly by you, or implied from your actions). From time to time, we may utilize the services of third parties in our business and may also receive personal information collected by those third parties in the course of the performance of their services for us or otherwise. Where this is the case, we will take reasonable steps to ensure that such third parties have represented to us that they have the right to disclose your personal information to us. Where permitted or required by applicable law or regulatory requirements, we may collect information about you without your knowledge or consent.

    Why Do We Collect Personal Information?

    The personal information collected is used and disclosed for our business purposes, including establishing, managing or terminating your business relationship with CPG.

    How do we Use Your Personal Information?

    We may use your personal information:
  • for the purposes described in this Privacy Policy; or
  • for any additional purposes that we advise you of and where your consent is required by law we have obtained your consent in respect of the use or disclosure of your personal information.
  • We may use your personal information without your knowledge or consent where we are permitted or required by applicable law or regulatory requirements to do so.

    When do we Disclose Your Personal Information?

    We may share your personal information with our employees, contractors, consultants and other parties who require such information to assist us with establishing, managing or terminating our relationship with you, including: parties that provide products or services to us or on our behalf and parties that collaborate with us in the provision of products or services to you. In some instances, such parties may also provide certain information technology and data processing services to us so that we may operate our business. When we share personal information with such parties we typically require that they only use or disclose such personal information in a manner consistent with the use and disclosure provisions of this Privacy Policy. Further, your personal information may be disclosed:
  • as permitted or required by applicable law or regulatory requirements. In such a case, we will endeavor to not disclose more personal information than is required under the circumstances;
  • to comply with valid legal processes such as search warrants, subpoenas or court orders;
  • to protect the rights and property of CPG;
  • where the personal information is publicly available; or
  • with your consent where such consent is required by law.
  • How is Your Personal Information Protected?

    CPG endeavors to maintain physical, technical and procedural safeguards that are appropriate to the sensitivity of the personal information in question. These safeguards are designed to prevent your personal information from loss and unauthorized access, copying, use, modification or disclosure.

    How Long is Your Personal Information Retained?

    Except as otherwise permitted or required by applicable law or regulatory requirements, CPG endeavors to retain your personal information only for as long as it believes is necessary to fulfill the purposes for which the personal information was collected (including, for the purpose of meeting any legal, accounting or other reporting requirements or obligations).

    Updating Your Personal Information

    It is important that the information contained in our records is both accurate and current. If your personal information happens to change during the course of your relationship with CPG, please keep us informed of such changes. I

    Inquiries or Concerns?

    If you have any questions about this Privacy Policy or concerns about how we manage your personal information, please contact the office of our Privacy Officer by telephone,
    in writing or by e-mail. We will endeavor to answer your questions and advise you of any steps taken to address the issues raised by you.

    Privacy Officer

    We have appointed a Privacy Officer to oversee compliance with this Privacy Policy.
    The contact information for our Privacy Officer is as follows: (916) 984-2705 Direct veronica@cpgib.com

    Revisions to this Privacy Policy

    CPG may from time to time make changes to this Privacy Policy to reflect changes in its legal or regulatory obligations or in the manner in which we deal with your personal information. We will communicate any revised version of this Privacy Policy. Any changes to this Privacy Policy will be effective from the time they are communicated, provided that any change that relates to why we collect, use or disclose your personal information will not apply to you, where your consent is required to such collection, use or disclosure, until we have obtained your consent to such change. This Privacy Policy was last updated on May 19, 2011.

    Interpretation of this Privacy Policy

    Any interpretation associated with this Privacy Policy will be made by the Privacy Officer. This Privacy Policy includes examples but is not intended to be restricted in its application to such examples, therefore where the word 'including' is used, it shall mean 'including without limitation. This Privacy Policy does not create or confer upon any individual any rights, or impose upon CPG any rights or obligations outside of, or in addition to, any rights or obligations imposed by the privacy laws applicable to such individual's personal information. Should there be, in a specific case, any inconsistency between this Privacy Policy and such privacy laws, this Privacy Policy shall be interpreted, in respect of that case, to give effect to, and comply with, such privacy laws.