Old Republic Home Protection Master Privacy Notice

    Updated: December 15, 2019

    At Old Republic Home Protection we work to earn your trust and we are committed to protecting the privacy and confidentiality of your personal information.  This Privacy Notice tells you how we collect, use, share, and protect your personal information and what choices you have about how your information is used and shared. Our policy is to treat the personal information you provide us with the utmost respect and in accordance with applicable privacy laws and regulations. We will not collect, use or share your personal information except as described in this Privacy Notice.

    This Privacy Notice may be updated from time to time so that we can keep you updated as to our data privacy practices. If we make any material changes to our privacy practices the Privacy Notice will be updated by posting the revised version of this Notice on the Old Republic Home Protection website under the Privacy Notice link on the website homepage. The updated Privacy Notice is effective as of the date listed at the top of this document. By accessing any of our products, services, websites or mobile applications after this date you agree to the terms of our Privacy Notice as of the last effective date; however, we will honor the terms that were in effect when we first gathered data from you.

    Throughout this notice, the terms “we,” “us,” and “our” refer to Old Republic Home Protection while the term “you” may refer to prospective Plan Holders, as well as current and former Plan Holders and claimants.

    If you have questions regarding our Privacy Notice or practices, please contact us:

    • Phone:
      844.939.1512
    • Email:
      compliance@orhp.com
    • Mail:
      Old Republic Home Protection
      P.O. Box 5017
      San Ramon, CA 94583-0917
    What Personal Information We Collect
    Information We May Collect from Prospective Customers

    We collect information about you so that we can process service contract transactions, administer or service your Plan, and operate our business. We collect personal information that we receive from you and from others. Our goal is to limit the collection and retention of your personal information to that which is necessary to provide you with our products or services and to operate our business.

    Information We May Collect from Customers

    In order for us to provide you with requested products or services and to administer our business, we may collect certain information from you, including personal information. This personal information may include but is not limited to:

    • Contact information, which may include your name, address, e-mail address, and telephone number(s).
    • Relationship to the Plan Holder or claimant and claims history.
    • Information enabling us to provide products and services including location and identification of property covered by our service contract.
    • Recordings of telephone calls placed by you to our representatives and to call centers operated on our behalf.
    • If you register on our website or on one of our mobile applications, we collect the personal information you knowingly provide to access certain online services. We may also collect personal information from you indirectly when you browse our website, use one of our mobile applications or access one of our official social media pages. For additional information about what personal information may be collected in these instances, please review the portions of this Privacy Notice that reference the use of our website, mobile applications, or social media pages.
    Information We May Collect from Others

    To provide requested products or services, we may also collect information from other sources. Other sources may include your real estate agent, escrow holder, property manager, service provider, or our business partners. We may also collect information about you from public records, other insurance companies, anti-fraud databases, sanction lists, court records, government agencies, and credit reporting agencies when we believe it is necessary to prevent financial crime.

    Information We May Collect from Plan Holders when Placing Service Requests

    If you make a service request under a Plan, we may collect the following information from you, along with the service request details, in order to administer the service request:

    • Contact information, which may include your name, address, e-mail address and telephone number(s).
    • Plan information including Plan number, your relationship to the Plan Holder, and other details relevant to the service request process.
    • Recordings of telephone calls placed by you to our representatives and to call centers operated on our behalf.
    • Information to prevent or detect fraud or financial crime.
    • Photographs and video recordings created in connection with our service contracts or other business activities, including for service request administration, settlement and disputes or for other relevant purposes as permitted by law.
    • If you register on our website or on one of our mobile applications, we collect the personal information you knowingly provide to access certain online services. We may also collect personal information from you indirectly when you browse our website, use one of our mobile applications or access one of our official social media pages. For additional information about what personal information may be collected in these instances, please review the portions of this Notice that reference the use of our website, mobile applications, or social media pages.
    Information We May Collect from Others Regarding a Service Request

    To administer a service request, we may collect the above information from other sources including your real estate agent, escrow holder, property manager, service provider or other representative. We may also collect information about you from public records, government agencies and credit agencies when we believe it is necessary for service request administration.

    How We Use Your Personal Information
    Prospective Customers

    If you are a prospective Plan Holder, we may use your personal information to consider your application for a service contract and related services or products or for other business purposes as allowed by law. We may use it to communicate with you, your representatives, and others.  We may further use your personal information to prevent and detect fraud, unauthorized transactions, or other financial crimes and to comply with applicable laws and regulations such as those relating to money laundering, sanctions and anti-terrorism or to satisfy other legal or regulatory requirements. We may also use personal information to collect and process your premium and other payments.

    Customers and Service Providers

    If you are a Plan Holder, we may use your personal information to communicate with you, verify your identity, respond to your inquiries or complaints, and provide you with requested information or services. We may use personal information to send you important information and alerts about changes to our Plans, information about our other products and services or for administrative or marketing purposes. We may also use your personal information for internal business operations such as auditing, finance and accounting, billing and collections, data management and security, and records management or other business purposes as allowed by law. Personal information may be used to respond to law enforcement requests, subpoenas and court orders, and to respond to requests from government authorities and regulators and to comply with applicable laws. We may also use personal information if we believe it necessary to establish and protect our legal rights, protect our operations, privacy, safety or property, and/or that of our affiliate companies, you or others.

    If you place a service request, we may use your personal information for the above purposes and to administer, investigate, litigate and/or potentially settle your service request. We may also use your personal information to detect, prevent and report fraud or other illegal activity.

    How We Share Your Personal Information

    We consider your personal information confidential and limit sharing it outside of Old Republic Home Protection. In the course of conducting our business, there are circumstances in which we may disclose your personal information to others. We share your personal information only with your authorization or as otherwise permitted or required by law. When personal information is shared with another party to perform services on our behalf, we expect them to maintain the confidentiality of your personal information, to use the information only for the limited purpose for which it was shared and to abide by all applicable federal and state privacy laws. Such sharing may include:

    • Old Republic affiliates and/or subsidiaries for administrative, legal, or audit purposes.
    • Business partners or service providers for operational, administrative, and marketing purposes.
    • Regulators, government authorities, or law enforcement to comply with applicable law, regulation, inquiry, investigation, subpoena, summons, or legal process.
    • Consumer reporting agencies, insurance-support organizations, or other organizations to prevent or detect fraud.
    • Other third parties in any actual or proposed sale, merger, joint venture, assignment, transfer or other transaction related to any part or portion of our business.
    • Third-party administrators, agents/brokers.
    • Participants in a legal process including lawyers, witnesses, investigators, and others we believe necessary or appropriate in the administration of a legal matter.
    Visitors to Our Website and Mobile Applications

    You may also provide information through your use of technology when you access and interact with our website or mobile application(s) (“sites”) through your computer, tablet or mobile device. We may collect information you provide to us through forms on our sites such as applications and login pages. In addition, we may also collect information about your visits so that you may access certain services and so that we may better understand the interests of those that visit our sites. If applicable, when you use our mobile applications or visit our sites from a mobile device, like a smartphone, we may also collect additional information from your device, including your location, device identifier, and information about your mobile network. We may use a variety of tracking technologies to collect this information, including without limitation, the following:

    •   Browser Log Data

    We may use technologies that automatically collect information when you visit our sites, view our advertisements, or use our products or services ("Browser Log Data"). This browser log data may include information such as your IP address (or other unique device identifier, including one that we may assign); certain details about your browser, operating system, and hardware; your location, if available; the URL that referred you to our sites; your activities on our site, including your preferences; and other logging information, such as the date and time of your visit. We also use web server logs to collect and store information about site usage. We may use this information for fraud detection and prevention, security, and to ensure our sites are function properly.

    •   Web Cookies

    When you visit our sites, we may use tracking technology such as cookies to automatically record details about your visit. Cookies are small text files stored by your internet browser on your computer's hard drive that allow sites to remember information about users. A cookie, by itself, does not tell us your email address or who you are. It cannot be used to collect data from your hard drive or personal information about you. We may use cookies and other device identifiers to collect information (such as browser type, time spent on the site and pages visited) and to support certain features of our site. For example, we may use these technologies and information collected for security purposes, to facilitate navigation, to display information more effectively, and to personalize your experience with the site. Your internet browser and other software used to enhance your online experience—e.g., Adobe Flash—can be set to reject cookies or alert you when a cookie is placed on your device. Follow the instructions provided with your internet browser or other software. Please note that if you disable cookies on your browser, you may not be able to access certain features or content on our sites.

    •   Beacons

    A Beacon is a small graphic image or other web programming code (also known as “1x1 GIFs” or “clear GIFs”) that may be included in our site’s pages and messages. Beacons may be invisible to you, but any electronic image or other web programming code inserted into a page or e-mail can act as a Beacon. Beacons or similar technologies may be used for a number of purposes, including, without limitation, counting website visitors, monitoring website visitor navigation, counting e-mail open rates, or counting online article/post views and link clicks.

    •   Embedded Scripts

    An embedded script is programming code that is designed to collect information about your interactions with the sites, such as the links you click on. The code is temporarily downloaded onto your computer, tablet or phone from our web server or a third party service provider, and is active only while you are connected to the sites, and is deactivated or deleted thereafter.

    •   Browser Fingerprinting

    Browser fingerprinting is the process of collection and analysis of information from your computer, tablet or phone, such as, without limitation, your operating system, plug-ins, system fonts and other data, for purposes of identification.

    •   ETag, or Entity Tag

    ETag is a feature of the cache in browsers. It is an opaque identifier assigned by a web server to a specific version of a resource found at a URL. If the resource content at that URL ever changes, a new and different ETag is assigned. Used in this manner, ETags are a form of device identifier. ETag tracking may generate unique tracking values even where the consumer blocks HTTP, Flash, and/or HTML5 cookies.

    •   Recognition Technologies

    Recognition technologies are technologies, including application of statistical probability to data sets, which attempt to recognize or make assumptions about users and devices (e.g., that a user of multiple devices is the same user).

    •   Location-identifying Technologies

    The sites may use GPS (global positioning systems) software and other location-based technologies such as iBeacons to locate you so we may verify your location, deliver you relevant content based on your location, as well as allow you to share your location to other users as part of the services we provide via the sites. In addition to traditional GPS location-based services, others we work with may install low power Bluetooth, wifi, radio transmitters, or other devices in physical locations, which emit a signal that your smart phone can detect to pinpoint your location or otherwise interact with the sites. In addition, you may be able to send your location information via the sites to other users. You should consider the pros and cons involved in disclosing your location information to us and to other people. Where a user of the sites requests that their location information be revealed to other persons, the user will be provided options for managing sharing services, which may be through third party services such as through Twitter and Facebook. We are not responsible for the acts, omissions or policies of such third parties.

    Visitors to Our Social Media Pages

    Old Republic Home Protection has official pages on social media websites such as Facebook®, Instagram®, Twitter®, LinkedIn®, and YouTube® that enable customers to discuss their experiences with Old Republic products and services. When you interact with us on social media websites we may collect information such as your feedback, preferences, user ID and/or user name associated with that social media service, and any information or content you have permitted the social media service to share with us, such as your profile picture, email address or friends list, and any information you have made public with that social media service. Old Republic Home Protection recommends you never include sensitive personal, financial or other confidential information when posting or commenting online. Any posts you make on our official social media pages (including posts that contain pictures, comments, suggestions, opinions, complaints or personal information), are available to others who use those pages and are subject to the terms of use and privacy policies of those sites. Please refer to the policies of those companies to understand your rights and obligations regarding your posts.

    Analytic Services and Targeted Ads

    We may use third-party analytics services, like Google Analytics and Google Tag Manager, to collect, monitor and analyze visitor data (such as Browser Log Data, cookies and other tracking data), and trends for marketing optimization and to increase the functionality of our website and mobile applications. These services may track details about your online activities over time and across different websites. These services may also allow us and others to provide you with targeted advertisements or other content that you may be interested in based on your online activities.

    The Google Analytics service tracks and reports website traffic and provides us insight into behavior information relating to visitor age, gender and interests.  Google Analytics Demographics and Interest Reporting give us insight into behavior to help us understand browsing behavior and give you a better experience when you visit our website. You can opt-out of Google Analytics for Display Advertising and customize Google Display Network ads using the Ads Settings.

    These third-party services have their own privacy policies addressing how they use such information. If you want to prevent your data from being used by Google Analytics, you may wish to take advantage of Google Analytics' currently available opt-outs for the web.  We use Google Tag Manager to capture certain non-individually identifiable customer traffic data, including: time spent on page, pdf file downloads, video activity (plays, pauses, percent of video watched, etc.), scroll depth (how far down a webpage a user scrolls), and social actions taken on a website (shares and outbound links to social channels).

    If you would like to learn more about targeted ads that may be based on your online activities, and the choices that you may exercise for certain sites and advertisers, you may wish to visit the Network Advertising Initiative or the Digital Advertising Alliance.

    Do Not Track Disclosure

    “Do not track” is a technology that enables users to opt-out of tracking by websites they do not visit. We do not disclose personal information to third parties for their own marketing purposes. Additionally, we do not collect personal information from your online activities over time and across other websites or online services and we do not allow third parties to use these technologies on our sites. Because we do not use these technologies, we currently do not monitor, respond to or take any action to web browser “do not track” signals or other similar mechanisms.

    How We Protect Your Personal Information

    The security of your personal information is important to us, and we strive to implement and maintain reasonable, commercially acceptable, security procedures and practices appropriate to the nature of the information we store, to protect it from unauthorized access, destruction, use, modification, or disclosure. We restrict access to personal information about you to those employees who need to know the information in order to provide products and services to you. Unfortunately, no data transmission over the internet or electronic database can be guaranteed to be 100% secure. If you have reason to believe that your interaction with us is no longer secure, please immediately notify us in accordance with the “contact us” section below.

    You are also responsible for taking reasonable steps to protect your personal information against unauthorized disclosure or misuse. We recommend you utilize the latest, updated version of your web browser. It is important that you create a strong password and protect against unauthorized access to your user name, password and your computer. You should not share your user name and password and be sure to log out and close your browser when you have completed your session.

    Links to Other Websites

    Our website or mobile application(s) may contain links to other websites or internet resources that are not operated by us. We have no control over, and assume no responsibility for the content, privacy policies or practices of any third-party websites or services. If you click on a third-party link, you will be directed to that third-party's website. We strongly advise you to review the privacy policy and terms of use of every website you visit.

    Children's Privacy

    Only persons that are the age of majority in your jurisdiction or older have permission to access our website or mobile applications. Our website and mobile applications are not designed for, or target, children under the age of 13. We do not knowingly collect, use, or disseminate personal information from children. If you are a parent or guardian and you learn that your child has provided us with personal information, please contact us and we will promptly delete it. If we become aware that we have collected personal information from a child without verification of parental consent, we will take steps to remove that information from our servers as quickly as possible. If you believe that we might have any personal information from or about a child, contact us:

    • Phone:
      844.939.1512
    • Email:
      compliance@orhp.com
    • Mail:
      Old Republic Home Protection
      P.O. Box 5017
      San Ramon, CA 94583-0917
    Cross Border Transfers of Your Personal Information

    Our website and mobile applications are directed to residents of the United States. Residents of other countries should not use our websites or mobile applications. If, however, you are located outside of the United States and chose to provide personal information to us, please note that we transfer the information to the United States and treat the information in a manner consistent with United States law. The data protection laws in the United States may differ from those of the country in which you are located, and your personal information may be subject to access requests from governments, courts, or law enforcement in the United States.

    State Privacy Rights

    You may have other privacy protections under applicable state laws. To the extent these laws apply, we will comply with them when we collect, use and share information about you.

    California Privacy Rights

    For Plan Holders in AZ, GA, MN, NC, OH, OR and VA:

    We may share your personal information with non-affiliates without your prior authorization as stated in this Privacy Notice and as permitted by law. Information we obtain from a report prepared by an insurance-support organization may be retained by that insurance-support organization and disclosed to others. In general, you have a right to learn the nature and substance of any personal information about you in our files. You also have a right to obtain a copy of that information, subject to limited exceptions. To access the information about you, send a signed written request to us at P.O. Box 5017, San Ramon, CA 94583, or e-mail us at compliance@orhp.com and include your name, covered property address, and your Plan number. For your protection, we may use reasonable means to verify your identity prior to sending you this personal information.  If you believe that any information about you is inaccurate, you may notify us in writing about any correction, amendment, or deletion you believe should be made. We will carefully review your request and, where appropriate, make the necessary change. We are unable to change the information that other companies—e.g., credit reporting agencies—provide to us.

     

    Privacy Notice for California Consumers

    This Privacy Notice for California Consumers supplements the information contained in the Master Privacy Notice for Old Republic Home Protection and applies to consumers that reside in the State of California. The terms used in this Privacy Notice have the same meaning as the terms defined in the California Consumer Privacy Act (“CCPA”).

    What Personal Information We Collect

    In accordance with the CCPA, personal information is information that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household. Personal information does not include:

    Information outside the scope of the CCPA such as:

    • Health or medical information covered by the Health Insurance Portability Act of 1996 (HIPAA) and the California Confidentiality of Medical Information Act (CMIA).
    • Personal Information covered by the Gramm-Leach-Bliley Act (GLBA), the Fair Credit Reporting Act (FCRA), the California Financial Information Privacy Act (FIPA), and the Driver’s Privacy Protection Act of 1994,
    • Publicly available information that is available from federal, state, or local government records, and
    • De-identified or aggregated consumer information.

    Please review this chart to learn what categories of personal information we may have collected about California consumers within the preceding twelve months, the sources of and business purposes for that collection, and the third parties with whom the information is shared, if any.

    What Personal Information We Share and Why We Share It

    The CCPA requires us to tell you what categories of personal information we “sell” or “disclose.” We do not “sell,” and will not sell, your personal information as that term is commonly understood.

    We also do not “sell”, and will not sell, your personal information, including the personal information of persons under 16 years of age, as that term is defined by the CCPA.  When it is necessary for a business purpose, we share or disclose your personal information with a service provider, and we enter a contract with the service provider that limits how the information may be used and requires the service provider to protect the confidentiality of the information.

    In the preceding twelve months, we have disclosed the categories of personal information on this chart for the business purposes indicated.  Where the personal information is shared with third parties, as that term is defined in the CCPA, the category of the third party is indicated.

    We may also transfer to a third party the personal information of a consumer as an asset that is part of a merger, acquisition, bankruptcy, or other transaction in which the third party assumes control of all or part of the business.

    Your Rights and Choices

    The CCPA provides California consumers with certain rights regarding their personal information. This chart describes those rights and certain limitations to those rights.

    Right
    What This Means

    Notice

    At or before the time your personal information is collected, you will be given written notice of the categories of personal information to be collected and the purposes for which the categories of personal information will be used.

    Access

    At your verifiable request, but no more than twice in a twelve month period, we shall disclose to you: 1) the categories of personal information we have collected about you, 2) the categories of sources for the personal information we collected about you, 3) our business purpose for collecting your personal information, 4) the categories of third parties with whom we share your personal information, 5) the specific pieces of information we have collected about you, and, 6) the categories of personal information disclosed for a business purpose.

    Deletion

    You have the right to request that we delete any of your personal information that we collected from you, subject to certain exceptions. Once we receive and verify your request, we will delete (and direct our service providers to delete) your personal information from our records unless an exception applies. We may deny your request if retention of the information is necessary for us or our service providers to:

    • 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.
    • Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
    • Debug products to identify and repair errors that impair existing intended functionality.
    • Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
    • Comply with the California Electronic Communications Privacy Act (Cal. Penal Code §1546 et seq.).
    • 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.
    • Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
    • Comply with a legal obligation.
    • Make other internal and lawful uses of that information that are compatible with the context in which you provided it.
    • Or if it is the type of personal information that falls outside the scope if the CCPA (HIPAA, CIMA, GLBA, or publicly available information).

    Opt-Out of Sale

     

    Opt-In to Sale

    With some limitations, you may direct a business that sells personal information to third parties (not under contract limiting use of the personal information), not to sell the personal information to these third parties.

    A business may not sell the personal information of persons less than sixteen years of age without their affirmative consent, and in the case of those less than thirteen years of age, the consent must come from a parent.

    Non-Discrimination

    We will not discriminate against you for exercising your rights under the CCPA. Unless otherwise permitted by the CCPA we will not:

    • Deny you goods or service
    • Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties
    • Provide a different level or quality of goods or services
    • Suggest that you will receive a different price or rate for goods or services or a different level or quality of goods or services

     

    To Exercise Your Rights:

    To Opt Out of the Sale of Your Personal Information

    The CCPA gives consumers the right to direct a business that sells personal information about the consumer to third parties not to sell the consumer’s personal information.  We do not sell, and will not sell, your personal information as that term is commonly understood.  We also do not sell, and will not sell, your personal information as that term is defined by the CCPA.

    To Request Access to or Deletion of Your Personal Information

    To exercise your access or deletion rights described above, please submit a verifiable consumer request by either calling us at 844.939.1512 or emailing us at compliance@orhp.com.

    Only you or your representative that you authorize to act on your behalf (Authorized Agent) can make a verifiable consumer request for your personal information. You may also make a request for your minor child. The verifiable request must provide enough information that allows us to reasonably verify you are the person about whom we collected personal information. 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 to confirm the personal information relates to you.

    We use several layers of authentication in order to verify your identity and safeguard access to your personal information. We may request that you respond to a text message from our representative. We will also request that you provide certain information such as your first and last name, your address, and your date of birth and respond to other questions designed to authenticate your identity. If we are unable to verify your identity we may require additional authentication or your request may be rejected.

    We work to respond to a verifiable consumer request within 45 days of its receipt. If we require additional time, we will inform you of the extension period (up to an additional 45 days), and the reason for the extension in writing. We will deliver our response by mail or electronically, depending on your preference. The response we provide will also explain any reasons why we cannot comply with a request.

    You may only make a consumer request for access twice within a twelve-month period. Any disclosures we provide will apply to the twelve-month period preceding the consumer request’s receipt.

    Contact Us

    If you have any questions regarding our Privacy Notice or practices, please contact us:

    • Phone:
      844.939.1512
    • Email:
      compliance@orhp.com
    • Mail:
      Old Republic Home Protection
      P.O. Box 5017
      San Ramon, CA 94583-0917