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California Privacy Disclosure

Last Updated: March 2022

Your privacy is important to us. This California Consumer Privacy Act of 2018 (“CCPA”) Disclosure (“Disclosure”) is provided by Pumpkin Insurance Services Inc. (together with its affiliates, “we,” “our” or “us”). Our insurance programs are underwritten by United States Fire Insurance Company and administered by Pumpkin Insurance Services Inc. This Disclosure explains how we collect, use, and disclose personal information relating to California residents that are subject to the CCPA (“CA Users”).

What is Personal Information

Under the CCPA, “Personal Information” is information that identifies, relates to, or could reasonably be linked with a particular CA User. The CCPA, however, does not apply to certain information, such as information subject to certain federal and state privacy laws, such as the Gramm-Leach-Bliley Act (“GLBA”).

As a result, this Disclosure does not apply with respect to certain information that we collect about CA Users who request or obtain our financial products and services for personal, family or household purposes. For more information about how we collect, disclose, and secure information in these and other contexts, please refer to https://www.pumpkin.care/privacy-center/consumer-privacy-notice.

Personal Information does not include:

  • Publicly available information from government records.
  • De-identified or aggregated user information.
  • The name, age, breed and other characteristics of your pet
  • The name of your veterinary medical care provider that you provide to us
  • Information contained in your claims to us, including invoice and claimed amounts, pet medical services and expenses incurred, and pet medical records

Our Collection, Use and Disclosure of Personal Information

We collect Personal Information relating to CA Users in a variety of contexts. For example, we collect Personal Information relating to individuals who request or obtain our products or services for themselves or veterinarians whom we contact with information related to our products. The specific Personal Information that we collect, use, and disclose relating to a CA User will depend on our relationship or interaction with that individual.

Categories of Information We Collect

Listed below are the categories of Personal Information we have (1) collected from CA Users, and (2) disclosed for a business purpose, in the preceding 12 months.

Service Provider Your Veterinary Care Provider Our Underwriter

Personal Identifiers:

Name, postal address, unique personal identifier, online identifier, Internet Protocol (IP) address, email address, telephone number, or other similar identifiers

Customer and Other Records:

Name, signature, postal address, telephone number, insurance policy number, bank account number, credit card number and debit card number

Customer and Other Records:

Name, signature, postal address, telephone number, insurance policy number, bank account number, credit card number and debit card number

We collect this Personal Information directly from you and from the following types of sources: publicly available databases, internet service providers, social media platforms, third-party data brokers and aggregators, data analytics providers, service providers and affiliates.

In the preceding twelve (12) months, we have not “sold’ Personal Information relating to CA Users within the meaning of the CCPA. For the purposes of this Disclosure, “sold” means the disclosure of Personal Information for monetary or other valuable consideration.

Our Use of Personal Information

The purposes for which we use or disclose the personal information that we collect depends on our relationship with a specific CA User. We use the Personal Information:

  • To operate, grow, manage and maintain our business;
  • To provide products and services; and
  • To accomplish other business purposes.

For example, we use Personal Information to develop, and market our products and services or other pet-health related products or services; operate our services; conduct research and data analysis; maintain our facilities and infrastructure, protect health and safety; operate and manage IT and communications systems; facilitate communications; conduct risk and security control and monitoring; detect and prevent fraud; perform identity verification; perform accounting, audit, and other internal functions, such as internal investigations; comply with law, legal process, and internal policies; evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution or other sale or transfer of some or all of our assets; maintain records; and exercise and defend legal claims.

We 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 with notice.

Your Rights and Choices

The CCPA provides CA Users with specific rights regarding their Personal Information. This section describes your CCPA rights and explains how to exercise those rights. If you are a CA User, you may request that we disclose to you the following information covering the 12 months preceding your request, subject to certain exceptions:

  • The categories of Personal Information we collected about you
  • The categories of sources from which we collected Personal Information about you;
  • The business or commercial purpose for collecting Personal information about you;
  • The categories of Personal Information about you that we disclosed to third parties for a business purpose;
  • The categories of third parties to whom we have disclosed for a business purpose Personal Information; and
  • A copy of the specific pieces of Personal Information we collected about you

If you are a CA User, you may also request that we delete Personal Information we collected about you, subject to certain exceptions.

We may decline to honor your request, in full or part, for certain reasons, such as a legal exemption. For example, if the information you are requesting is subject to certain federal privacy laws, like the GLBA that are outside the scope of the CCPA, we may decline to honor your request. In some instances, we may decline to honor your request if we cannot verify your identity or confirm that the Personal Information that we maintain relates to you, or if we cannot verify that you have the authority to make a request on behalf of another individual. In other instances, we may decline to honor your request where an exception applies, such as where the disclosure of Personal Information would adversely affect the rights and freedoms of another consumer.

You have the right to be free from unlawful discrimination for exercising your rights under the CCPA.

How to Make Requests

If you are a CA User, you may make a request for the access rights described above or make a request to delete Personal Information we collected from you by contacting us:

  • Emailing us at: hello@pumpkin.care;
  • Sending us mail to: 251 W 30th Suite 9W New York NY 10001;
  • Calling the Pumpkin U.S. Privacy Toll-free Number: 866-273-6369

When you make a request, we will take steps to verify your request by matching the information that you provide with the information we have in our records, including your phone number, email address, city and state. In some cases, we may request additional information in order to verify your request or where necessary to process your request. If we are unable to adequately verify a request, we will notify the requestor. We will respond to you within the timeframe required by the CCPA.

When you make a request, we require that you:

  • Provide sufficient information that allows us to reasonably verify that you are the person about whom we collected Personal Information or an authorized representative.
  • Describe your request with sufficient detail that allows us to properly understand, evaluate and respond to it.

Requests by Authorized Agents

A CA User may authorize an agent to make a data access, or deletion request on behalf of the CA User. The authorized agent may make a request on behalf of the CA User by contacting us as set forth above. In general, if an authorized agent makes a request on behalf of a CA User, we will:

  • Inquire whether the authorized agent can provide proof of its registration with the California Secretary of State to conduct business in California;
  • Require the CA User provide the authorized agent with written permission signed by the CA User authorizing the agent to make the request on the individual’s behalf; and
  • Verify the identity of the CA User as we would if the CA User were making the request directly or obtain verification from the CA User that the authorized agent has permission to make the request.

Changes to this California Consumer Privacy Act Disclosure

We may change or update this Disclosure from time to time. When we do, we will post the revised Disclosure on this page with a new “Last Updated” date.

Contact Us

If you have any questions regarding this Disclosure or our privacy policies and practices, please do not hesitate to contact us by either:

  • Emailing us at: hello@pumpkin.care;
  • Sending us mail to: 251 W 30th Suite 9W New York NY 10001;
  • Calling the Pumpkin U.S. Privacy Toll-free Number: 866-273-6369

You may also refer to our Privacy Center: https://www.pumpkin.care/privacy-center