Last Updated: September 2022
To make this document more readable, “Company”, “we”, “us”, and “our” refer to Vantage. “You” and “your” refers to anybody using our Sites and Services.
Personal Information We Collect and Have Collected in the Past 12 Months – Sources and Categories
In the 12 months preceding the date of this Policy, we may have collected your personal information when you used our Sites and Services. We may collect personal information about you either from you or your agents or representatives. The personal information that Vantage collects, uses, and shares relating to you will depend on Vantage’s relationship or interaction with you (for example, as a policyholder; insured person under another policyholder’s policy, or claimant; commercial broker or appointed representative; employee or applicant for employment or other person relating to our business).
Personal information we may have collected from these sources during the 12 months preceding the date of this Policy, and will continue to collect, includes:
- Personal Identifiers such as name, physical address, email address, unique personal identifier, account name, Social Security number, driver’s license or state identification card number, passport number, signature, physical characteristics or description, (re)insurance policy information, financial information, medical information, or other similar identifiers or personal information;
- Other sensitive information such as age, race, ethnicity, ancestry, national origin, citizenship, political opinions, religious or philosophical beliefs, trade union membership, marital status, medical condition, disability, sex (including gender, gender identity, gender expression, pregnancy/childbirth and related medical conditions), sexual orientation, veteran or military status, biometric or genetic information, and criminal convictions;
- Commercial information such as records of products or services purchased, obtained or considered, or other purchasing or consuming histories or tendencies;
- Internet or other electronic activity information such as online identifiers (e.g., Internet Protocol address), internet or other electronic network activity regarding your interaction with our Sites and Services, social media pages, applications or advertisements;
- Geolocation data such as physical location;
- Sensory information such as audio, electronic, visual or similar information, which may include recording of training sessions;
- Professional or employment-related information such as current or past job history;
- Educational information such as records directly related to a student maintained by an educational or institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes and student disciplinary record; and
- Inferences drawn from any of the information above.
Personal information does not include publicly available information from government records, or deidentified or aggregated information.
How We Use Your Data
Vantage may use personal information as may be necessary to:
- Contact you, or send information you have asked to receive about Vantage products and services;
- Update you with news and other information about the Company, including marketing materials;
- Service your (re)insurance needs, including to process claims you have submitted relating to Vantage products and services or to confirm or correct information you have submitted;
- Personalize your experience while using Vantage’s Sites and Services or other digital platforms;
- Conduct research and data analytics to support Vantage’s risk management and operational purposes, including actuarial analysis and the development of actuarial and pricing tools and models;
- Contact you for other business reasons;
- Inform you of Vantage jobs and to decide if you have the skills for a job;
- Protect Vantage’s privacy and property, as well as the privacy and property of you or others;
- Resolve complaints and handle any requests for access to or correction of your personal data;
- Prevent, detect and investigate fraud and other activities that violate our terms or that are illegal;
- Comply with laws and legal processes, including responding to court, regulatory or governmental requests;
- As otherwise allowed, or required, by applicable law including laws other than those of your location; and
- In any other way we may describe when you provide the information.
We also may anonymize, combine or aggregate any of the information we collect for any of these purposes, or to analyze trends or statistics or to provide risk management or (re)insurance services to our clients.
Disclosure of Personal Information for Business Purposes in the Past 12 Months
Vantage does not sell your personal information or provide it to third-parties for their direct marketing purposes. The following chart describes the categories of personal information that we may have disclosed to third-parties for a business purpose in the 12 months prior to the date of this Policy:
|Categories of Consumers’ Personal Information
|Categories of Third-parties With Which We Shared Personal Information for a Business Purpose
|Personal identifiers: name, physical address, email address, unique personal identifier, account name, Social Security number, driver’s license or state identification card number, passport number, signature, physical characteristics or description, (re)insurance policy information, financial information, medical information, or other similar identifiers or personal information.
|Contractors, third-parties, and service providers that assist us in providing (re)insurance products and financial information processing services; assist us in operating, analyzing, and displaying content on our website; assist us in analyzing, organizing, and maintaining financial and (re)insurance information; conduct research and data analytics; advertise or market our products; provide legal and accounting services.
|Other sensitive information: age, race, ethnicity, ancestry, national origin, citizenship, political opinions, religious or philosophical beliefs, trade union membership, marital status, medical condition, disability, sex (including gender, gender identity, gender expression, pregnancy/childbirth and related medical conditions), sexual orientation, veteran or military status, biometric or genetic information, and criminal convictions.
|Contractors, third-parties, and service providers that assist us in providing (re)insurance products and services including adjusting claims; assist us in operating, analyzing, and displaying content on our website; conduct research and data analytics; advertise or market our products; and provide legal and accounting services.
|Commercial information: records of products or services purchased, obtained or considered, or other purchasing or consuming histories or tendencies.
|Contractors, third-parties, and service providers that assist us in providing (re)insurance products and services policy administration, services and claims adjusting; assist us in operating, analyzing, and displaying content on our website; conduct research and data analytics; and advertise or market our products.
|Internet or other electronic network activity information: online identifiers (e.g., Internet Protocol address), Internet or other electronic network activity regarding your interaction with our Sites and Services, social media pages, applications or advertisements.
|To service providers that provide data security services and cloud-based data storage; host our Sites and assist with other IT-related functions; provide website hosting, webcast and teleconference services; advertise and market our products; and conduct research and data analytics.
|Geolocation data: physical location.
|Contractors, third-parties, and service providers that assist us in providing (re)insurance products; assist us in operating, analyzing, and displaying content on our website; conduct research and data analytics; and advertise or market our products.
|Sensory information: audio, electronic, visual or similar information, which may include recordings of training sessions.
|Contractors, third-parties, and service providers that provide physical security services and audio and visual information storage and host our training platforms.
|Professional/employment-related or educational information: current or past job history, records directly related to a student maintained by an educational institution, or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes and student disciplinary record.
|Contractors, third-parties, and service providers that assist in us in analyzing job applications and providing benefits for our employees.
Additional Information About How We May Share Personal Information
Generally speaking, we may share your personal information to transfer data to our affiliates from time to time for our legitimate business purposes. Affiliates are defined as subsidiaries, parent companies, joint ventures, and other corporate entities under common Vantage ownership. We may also share your personal information as required or permitted by law to comply with a subpoena or similar legal process or government request, or when we believe in good faith that disclosure is legally required or otherwise necessary to protect our rights and property or the rights, property or safety of others, including to law enforcement agencies, and judicial and regulatory authorities. We may also share your personal information with third-parties to help detect and protect against fraud or data security vulnerabilities, and we may transfer your personal information to a third-party in the event of a sale, merger, reorganization of our entity or other restructuring.
We are committed to maintaining your confidence and trust and take steps to help protect the personal information you provide to us. However, no transmission or electronic storage of information is guaranteed to be secure. We therefore urge you to always use caution when transmitting information over the internet.
Your Privacy Rights
California Privacy Rights
If you are a California resident, you may have separate rights regarding your personal information, in accordance with California law.
California Consumer Privacy Act
The California Consumer Privacy Act (“CCPA”) gives California residents rights described below with respect to their personal information.
The CCPA defines “personal information” to mean information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a California consumer or household.
Your Right to Request Disclosure of Information We Collect and Share About You
We are committed to ensuring that you know what personal information we collect. To that end, you can ask us for any or all of following types of personal information we have collected about you in the 12 months prior to our receipt of your request:
- Specific pieces of personal information we have collected about you;
- Categories of personal information we have collected about you;
- Categories of sources from which such personal information was collected;
- Categories of personal information that the business sold or disclosed for a business purpose about the consumer;
- Categories of third-parties to whom the personal information was sold or disclosed for a business purpose; and
- The business or commercial purpose for collecting or selling your personal information.
Your Right to Request Deletion of Personal Information We Have Collected About You
Upon your request, we will delete the personal information we have collected about you, except for situations where the CCPA authorizes us to retain specific information, including when it is necessary for us to provide you with a good or service that you requested; perform a contract we entered into with you; maintain the functionality or security of our systems; or comply with or exercise rights provided by the law. The law also permits us to retain specific information for our exclusively internal use, but only in ways that are compatible with the context in which you provided the information to us or that are reasonably aligned with your expectations based on your relationship with us. We will act on your deletion request within the timeframes set forth below.
Sale of Personal Information
As explained above, we do not sell your personal information.
Exercising Your Rights and How We Will Respond
To exercise any of the rights above, or to ask a question, contact us at 833-552-1772, or email us at [email protected].
For requests for access or deletion, we will first acknowledge receipt of your request within 10 business days of receipt of your request. We will provide a substantive response to your request as soon as we can and generally within 45 days from when we receive your request; although we may be allowed to take longer to process your request under certain circumstances. If we expect that your request will take us longer than normal to fulfill, we will let you know.
We usually act on requests and provide information free of charge, but we may charge a reasonable fee to cover our administrative costs of providing the information in certain situations. In some cases, the law may allow us to refuse to act on certain requests. When this is the case, we will endeavor to provide you with an explanation as to why.
Our Commitment to Respect Your Rights
If you exercise any of the rights explained in this Policy, we will continue to treat you fairly. If you exercise your rights under this Policy, you will not be denied or charged different prices or rates for goods or services or provided a different level or quality of goods or services than others.
Verification of Identity – Access or Deletion Requests
We will ask you for identifying information and attempt to match it to information that we maintain about you.
If we are unable to verify your identity with the degree of certainty required, we will not be able to respond to your request. We will notify you to explain the basis of the denial.
You may designate an agent to submit requests on your behalf. The agent must be a natural person or a business entity that is registered with the California Secretary of State.
If you would like to designate an agent to act on your behalf, you and the agent will be required to provide us with proof of the agent’s identity and proof that you gave the agent signed permission to submit a request on your behalf. Additionally, you will be required to verify your identity by providing us with certain personal information as described above or provide us with written confirmation that you have authorized the agent to act on your behalf.
Please note that this subsection does not apply when an agent is authorized to act on your behalf pursuant to a valid power of attorney. Any such requests will be processed in accordance with California law pertaining to powers of attorney.
Requests for Household Information
There may be some types of personal information that can be associated with a household. Requests for access or deletion of household personal information must be made by each member of the household. We will verify the identity of each member of the household using the verification criteria explained above and will also verify that each household member is currently a member of the household.
California Shine the Light
Vantage does not share your personal information or provide it to third-parties for their direct marketing purposes.
California Do Not Track
Some browsers have a “do not track” feature that lets you tell websites that you do not want to have your online activities tracked. At this time, our Sites do not respond to browsers’ do not track signals.
Our Site is hosted in the United States. All personal information you submit to us via the Site will be transferred to the United States.
Choices about the Collection and Use of Your Information
Third-party Services and Websites
Collection of Information from Children
Vantage does not knowingly collect personal information from anyone under the age of 13.
We are committed to ensuring that our communications are accessible to people with disabilities. To make accessibility-related requests or report barriers, please contact us via the information in the “Contact Us” section below.
Feedback or Questions
If you have questions or comments, please refer to the “Contact Us” section below.
If there are any questions regarding this Policy, or to request a copy of this Policy in another format, you may contact us using any of the methods below:
- Phone: 833-552-1772.
- E-mail: [email protected]
- Mail: Vantage Services LLC
123 N Wacker Dr., STE 1300
Chicago, IL 60606