Privacy policy for California residents
For California residents:
Effective: January 1, 2020.
This Privacy Policy for California Residents (“CCPA Privacy Policy”) applies to The Hanover Insurance Group, Inc.’s (including our subsidiaries and affiliates, “Hanover,” “we,” “us,” or “our”) processing of personal information of California residents to the extent the information is subject to the California Consumer Privacy Act of 2018 (“CCPA”). There are several exemptions from the CCPA, and in accordance with the CCPA this CCPA Privacy Policy does not apply to personal information collected pursuant to: (i) the Gramm-Leach-Bliley Act and its implementing regulations (such as information collected in connection with an insurance policy or claim for personal, family or household purposes); (ii) the California Financial Information Privacy Act; (iii) the Health Insurance Portability and Accountability Act (“HIPAA”); or (iv) certain business-to-business transactions. This CCPA Privacy Policy supplements and does not replace our Online Privacy Statement, Customer Privacy Policy or website Terms and Conditions.
We do not sell consumers’ Personal Information (defined below).
Categories of personal information we collect, use, or disclose
Hanover collects information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household (“Personal Information”).
In general, within the last twelve (12) months Hanover has collected consumers’ Personal Information so we can provide you with products and services and satisfy our legal obligations. Further, we share consumers’ Personal Information with other businesses who provide services to us, and with government agencies and regulators so that we can provide our products and services to consumers. We may also share a consumer’s Personal Information with our affiliates or in the event of a business transfer. Additional detail on how Hanover processes Personal Information of consumers is set forth below.
- Category of personal information – Identifiers
-
Examples
Real name, alias, postal address, unique personal identifier, Social Security number, driver’s license number, passport number or other similar identifiers.
Categories of sources of personal information
Directly from you, for example when you fill out an application or file a claim, from your transactions with us, and from third parties as permitted by law, such as independent agents and brokers, consumer reporting agencies, insurance companies, our service providers, as well as anti-fraud databases.
Business or commercial purpose(s) for which used
We use this Personal Information for performance of our services and for our business operations as required or permitted by law. For example:
- Providing you with the services that you request, such as by completing transactions, finding an agent, processing claims, or providing a quote for one of our products, or
- Communicating with you, for example to respond to inquiries.
Categories of third parties with whom personal information is shared, if anyWe share Personal Information as permitted or required by law in connection with performance of our services and for our business operations, including:
- Financial or other service providers, such as independent agents, brokerage firms, insurance companies,
- Insurance regulators or other government agencies to verify information or protect the rights of our insureds, our company, and others,
- Administrative service providers, or
- Data aggregators who may provide services such as fraud detection.
- Category of personal information – Identifiers (continued)
-
Examples
In addition, through online facilities or services, (e.g., our website) we collect the following identifiers: online identifier, Internet Protocol address, email address, account name, user name, password and password hint information.
Categories of sources of personal information
Directly from you, for example when you fill out an online form or set up an online account, and as a result of your use of our website or other online services, and from third parties such as website analytics providers.
Business or commercial purpose(s) for which used
We use this information to provide services to you and to maintain our website or other online services, such as:
- To help maintain the safety, security, and integrity of our website, information systems, databases and other technology assets, or
- To maintain secure accounts with us,
- To provide alerts or other messages via email and/or text messages concerning our products or services that may be of interest to you, or
- For testing, research, analysis, and product development, including to develop and improve our website, products and services.
Categories of third parties with whom personal information is shared, if any
We may share this information as described above as well as with third parties providing:
- Application and security services,
- Website or other online hosting services, or
- Information technology services.
Our website may provide links to content or services controlled or owned by third parties. When website visitors interact with such third-party content or services, they may be sharing their Personal Information with such third parties.
- Categories of personal information – Identified in the California Customer Records Statute
-
Examples
A name, signature, Social Security number, address, telephone number, driver's license or state identification card number, insurance policy number, education, employment, employment history, bank account number, financial information, medical information, or health insurance information.
Categories of sources of personal information
We collect this information from the categories of sources of Personal Information listed next to “Identifiers” above as well as from your employer or health care provider where applicable.
Business or commercial purpose(s) for which used
We use this Personal Information for performance of our services and for our business operations as required or permitted by law. For example:
- Underwriting and analysis,
- Business or audit operations,
- Providing you with the services that you request, such as by completing transactions, processing claims, or providing a quote for one of our products, or
- Communicating with you, for example to respond to inquiries.
Categories of third parties with whom personal information is shared, if any
We may share Personal Information as permitted or required by law in connection with performance of our services, and for our business operations, such as:
- Underwriting services providers,
- Financial or other service providers, such as independent agents, brokerage firms, insurance companies,
- Insurance regulators or other government agencies to verify information or protect the rights of our insureds, our company, and others, or
- Data aggregators who may provide services such as fraud detection.
- Characteristics of protected classifications under California or federal law
-
Examples
Age, ethnicity, citizenship, marital status, medical condition, physical or mental disability, sex, gender, gender identity, veteran or military status, and genetic information.
Categories of sources of personal information
Directly from you, for example as part of the employment process if you are a Hanover employee or applicant, when you fill out an application or file a claim, from your transactions with us, as the result of your use of our website and from third parties as permitted by law, such as consumer reporting agencies, independent agents and brokers, our service providers, and your employer or healthcare providers, if applicable.
Business or commercial purpose(s) for which used
We use this Personal Information for performance of our services and for our business operations, including our obligations as an employer and as required or permitted by law. For example:
- Providing you with the services that you request, such as by completing transactions, processing claims, or providing a quote for one of our products,
- To provide support and to respond to consumer inquiries, including to investigate and address concerns, and to monitor and improve our responses, or
- Underwriting and analysis.
Categories of third parties with whom personal information is shared, if any
We may share Personal Information as permitted or required by law in connection with performance of our services and for our business operations, including:
- Underwriting service providers,
- Financial service providers, such as independent agents, brokerage firms, insurance companies,
- Data analysis service providers,
- Legal service providers,
- Accounting service providers, or
- Administrative service providers.
- Commercial information
-
Examples
Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.
Categories of sources of personal information
Directly from you, for example when you fill out an application or file a claim, from your transactions with us, and from third parties as permitted by law, such as consumer reporting agencies, agents and brokers, our service providers, and your employer or healthcare providers, if applicable.
Business or commercial purpose(s) for which used
We use this Personal Information for performance of our services and for our business operations as required or permitted by law. For example:
- Providing you with the services that you request, such as by completing transactions, processing claims, or providing a quote for one of our products,
- Providing you with information about our products or services that may be of interest to you,
- Developing additional products or services, or
- Communicating with you, for example, to respond to inquiries.
Categories of third parties with whom personal information is shared, if any
We may share Personal Information as permitted or required by law in connection with performance of our services, and for our business operations, including:
- Financial service providers, such as independent agents, brokerage firms, insurance companies,
- Businesses that assist us with our marketing and promotions,
- Accounting service providers, or
- Administrative service providers.
- Internet or other electronic network activity information
-
Examples
Browsing history, search history, and information regarding a consumer’s interaction with a website, application, or advertisement.
Categories of sources of personal information
As the result of your use of our online services, such as our website, consumer portals or mobile applications (if any), including through the use of cookies, Web beacons, embedded scripts, and other recognition and/or tracking technologies.
Business or commercial purpose(s) for which used
We use this Personal Information for performance of our services and for our business operations as required or permitted by law. For example:
- To provide access to our website and the information about our products and services contained therein,
- To facilitate the processing of claims or payment of bills, for example through our consumer bill pay portal,
- For the security of our website and information systems,
- Providing you with information, including communications about our products or services that may be of interest to you
- To support, personalize, improve our website, products or services.
Categories of third parties with whom personal information is shared, if any
We may share Personal Information as described next to the “Identifiers (Continued)” category above, and for our business operations, including:
- Website support services, such as businesses that assist us with bill payment processing on our website,
- Services that help us manage and secure online access to account information,
- Services that facilitate claims reporting, or
- Advertising or social media networks to direct content from us to our consumers.
- Geolocation data
-
Examples
Geographic tracking data, physical location and movements.
Categories of sources of personal information
Directly from you as the result of your use of our website or online services, including through a mobile device, and from third parties such as website hosting and data analytics provider applications
Business or commercial purpose(s) for which used
We use this Personal Information for performance of our services and for our business operations as required or permitted by law. For example:
- Detecting security incidents,
- Preventing malicious, deceptive or illegal activity, or
- Facilitate services provided via our mobile applications, including mobile applications designed to promote safe driving.
Categories of third parties with whom personal information is shared, if any
We may share personal information as permitted or required by law in connection with performance of our services, and for our business operations, including:
- Website hosting,
- Information technology, software application, and security service providers,
- Advertising or social media networks to direct content to consumers, or
- Services that allow you to download our mobile application, such as the Apple App Store or Google Play
- Sensory data
-
Examples
Audio, electronic, visual, or similar information.
Categories of sources of personal information
Directly from you as the result of, using our website, filling out an online form or claim or calling for customer support
Business or commercial purpose(s) for which used
We use this Personal Information for performance of our services and for our business operations as required or permitted by law. For example:
- Providing you with the services that you request, such as by completing transactions, processing claims, or providing a quote for one of our products, or
- Communicating with you, for example to respond to inquiries.
Categories of third parties with whom personal information is shared, if any
We may share sensory data, such as audio or video recordings, as permitted or required by law in connection with the performance of our services, and for our business operations, Including:
- Claims and administrative service providers.
- Professional or employment-related information
-
Examples
Current or past employment history, performance evaluations, disciplinary records, investigations, awards, earnings, compensation and payroll records, benefit records, employment application, resume, background checks, contracts and agreements or termination records, leave documentation, medical records or workers compensation records.
Categories of sources of personal information
Directly from you, for example when you fill out an application or file a claim, from your transactions with us, and from third parties as permitted by law, such as agents and brokers, our service providers, your employer where applicable, as well as anti-fraud databases.
Business or commercial purpose(s) for which used
We use this Personal Information for performance of our services and for our business operations as required or permitted by law. For example,
- Audit or operational purposes,
- Facilitating claims processing,
- To underwrite end-to-end insurance solutions, such as workers’ compensation products.
Categories of third parties with whom personal information is shared, if any
We may share Personal Information as permitted or required by law in connection with performance of our services, and for our business operations, including:
- Underwriting service providers,
- Financial service providers, such as independent agents, brokerage firms, insurance companies,
- Data analysis service providers,
- Legal service providers,
- Accounting service providers, or
- Administrative service providers.
- Non-public education information (as defined in the Family Educational Rights and Privacy Act (20 U.S.C. § 1232g, 34 C.F.R. Part 99))
-
Examples
Education records maintained by an educational agency or institution, including grades, transcripts, or course lists.
Categories of sources of personal information
From educational agencies or institutions.
Business or commercial purpose(s) for which used
We may collect information about your education history directly from you for the same purpose described above, and we may otherwise collect information directly from education agencies or institutions.
Categories of third parties with whom personal information is shared, if any
Not applicable.
- Inferences drawn from other Personal Information
-
Examples
Information used to create a profile about a consumer reflecting the consumer’s preferences, characteristics and behavior.
Categories of sources of personal information
We may draw inferences using Personal Information obtained from you (e.g., based on the products or services you have purchased, and from the other sources of information listed above).
Business or commercial purpose(s) for which used
We use this Personal Information for performance of our services and for our business operations as required or permitted by law. For example:
- Providing you with the services that you request, such as by completing transactions, processing claims, or providing a quote for one of our products,
- To develop, operate, deliver, maintain, improve, enhance, and protect our services and in connection with other Hanover offerings and operations, or
- Providing you with information, including communications about products or services that may be of interest to you.
Categories of third parties with whom personal information is shared, if any
We may share Personal Information as permitted or required by law in connection with performance of our services, and for our business operations, including:
- Service providers who help us improve existing products or services or develop new products or services,
- Website hosting or applications service providers, or
- Advertising or social media networks to direct content to consumers.
Disclosure or sale of personal information for a business or commercial purpose
Our disclosures of Personal Information for business or commercial purposes in the preceding twelve (12) months are disclosed above.
We do not sell consumers’ Personal Information.
Your privacy rights as a California resident
Right to Know
You have the right to request that we disclose to you the Personal Information we collect, use, disclose, or sell about you.
You can submit an email request at privacy@hanover.com or call 800-446-8379 to make a disclosure request. You may make up to two requests in any 12-month period.
Only you, or someone legally authorized to act on your behalf, 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.
Making a verifiable consumer request does not require you to create an account with us.
To verify the identity of the requestor and authority to make the request, you will be required to provide your name, email address and other unique information that we may determine is required in order to connect you to the information that we retain (e.g., Hanover policy number, claim number, government-issued identification number).
We will only use Personal Information provided in a verifiable consumer request to verify the requestor's identity or authority to make the request.
In accordance with the CCPA and in order to safeguard 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 confirm the Personal Information relates to you.
Right to Request Deletion
You have the right to request that we delete your Personal Information. You may make such a request by submitting an email to privacy@hanover.com or calling 800-446-8379.
You should be aware, however, that California law allows us to retain your Personal Information under certain conditions, even if you have asked us to delete it, such as when retaining your Personal Information is necessary for us to complete a transaction with you or provide you with a good or service you have requested. In such circumstances, we will notify you of any denial of your deletion request and the reason for such denial.
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 services,
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, or
Suggest that you will receive a different price or rate for goods or services or a different level or quality of goods or services.
Using an authorized agent
You may use an authorized agent to submit a “request to know” or “request to delete.” To use an authorized agent, you will need to (i) provide written instruction to your agent, and verify your identity to us, or (ii) provide a power of attorney pursuant to California Probate Code Sections 4000 to 4465.
Contact us
If you have questions about this CCPA Privacy Policy, please contact us at:
Phone:
800-446-8379
Email:
privacy@hanover.com
Address:
The Hanover Insurance Group, Inc.
Attn: Chief Privacy Officer
440 Lincoln Street N435
Worcester, MA 01653