Privacy Notice

This Privacy Notice applies to the processing of personal information by Corix Insurance Services, LLC and its affiliates (“Corix,” “we,” “us,” or “our”) including on our website available at www.corixinsurance.com and our other online or offline offerings which link to, or are otherwise subject to, this Privacy Notice (collectively, the “Services”).

Disclosure Regarding the California Consumer Privacy Act (Notice at Collection). For information on our processing of personal information that is subject to the California Consumer Privacy Act (“CCPA”), please see Annex A – Supplemental U.S. Privacy Notice below.

‍Disclosure Regarding Customer Data. This Privacy Notice does not apply to the personal information that we process on behalf of our customers pursuant to a written agreement we have entered into with such customers (“Customer Data”). Our customers’ respective privacy notices or policies govern their collection and use of Customer Data. Our processing of Customer Data is governed by the contracts that we have in place with our customers, not this Privacy Notice. Any questions or requests relating to Customer Data should be directed to our customer.

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1. UPDATES TO THIS PRIVACY NOTICE

2. PERSONAL INFORMATION WE COLLECT

3. HOW WE USE PERSONAL INFORMATION

4. HOW WE DISCLOSE PERSONAL INFORMATION

5. YOUR PRIVACY CHOICES AND RIGHTS

6. INTERNATIONAL TRANSFERS OF PERSONAL INFORMATION

7. CHILDREN’S PERSONAL INFORMATION

8. THIRD-PARTY WEBSITES/APPLICATIONS

9. CONTACT US

ANNEX A – SUPPLEMENTAL U.S. PRIVACY NOTICE

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1. UPDATES TO THIS PRIVACY NOTICE

We may update this Privacy Notice from time to time in our sole discretion. If we do, we’ll let you know by posting the updated Privacy Notice on our website, and/or we may also send other communications.

2. PERSONAL INFORMATION WE COLLECT

We collect personal information that you provide to us, personal information we collect automatically when you use the Services, and personal information from third-party sources, as described below.‍

    A. Personal Information You Provide to Us Directly

    We may collect personal information that you provide to us.

• Account Information. We may collect personal information in connection with the creation or administration of your account. This personal information may include, but is not limited to, your name, email address, phone number, and other information you store with your account.

• Purchases. We may collect personal information and details associated with your purchases, including payment information. Any payments made via our Services are processed by third-party payment processors, such as Stripe and Ascend. We do not directly collect or store any payment card information entered through our Services, but we may receive information associated with your payment card information (e.g., your billing details).

• Your Communications with Us. We, and our service providers, may collect the information you communicate to us, such as through email or our web chat tool.  

• Surveys. We may contact you to participate in surveys. If you decide to participate, we may collect personal information from you in connection with the survey.

• Interactive Features. We and others who use our Services may collect personal information that you submit or make available through our interactive features (e.g., messaging features, commenting functionalities, forums, blogs, and social media pages).  Any information you provide using the public sharing features of the Services will be considered “public.”‍

• ‍Conferences, Trade Shows, and Other Events. We may collect personal information from individuals when we attend or host conferences, trade shows, and other events.‍

• ‍Business Development and Strategic Partnerships. We may collect personal information from individuals and third parties to assess and pursue potential business opportunities.

• Job Applications. If you apply for a job with us, we will collect any personal information you provide in connection with your application, such as your contact information and CV.

    B. Personal Information Collected Automatically

    We may collect personal information automatically when you use the Services.

• Device Information. We may collect personal information about your device, such as your Internet protocol (IP) address, user settings, cookie identifiers, other unique identifiers, browser or device information, Internet service provider, and location information (including, as applicable, approximate location derived from IP address and precise geo-location information).

• Usage Information. We may collect personal information about your use of the Services, such as the pages that you visit, items that you search for, the types of content you interact with, information about the links you click, the frequency and duration of your activities, and other information about how you use the Services.

• Cookies and Other Technologies. We, as well as third parties, may use cookies, pixel tags, and other tracking technologies (“Technologies”) to automatically collect personal information through your use of the Services.

• Cookies. Cookies are small text files stored in device browsers.

• Pixel Tags/Web Beacons. A pixel tag (also known as a web beacon) is a piece of code embedded in the Services that collects personal information about use of or engagement with the Services. The use of a pixel tag allows us to record, for example, that a user has visited, a particular web page or clicked on a particular advertisement. We may also include web beacons in e-mails to understand whether messages have been opened, acted on, or forwarded.

For more information about the Technologies we use, please see our “Cookie Notice.”  See “Your Privacy Choices and Rights” below to understand your choices regarding these Technologies.

    C. Personal Information Collected from Third Parties

      We may collect personal information about you from third parties.  For example, if you access the Services using a Third-Party Service (defined below), we may collect personal information about you from that Third-Party Service that you have made available via your privacy settings. In addition, users of the Services may upload or otherwise provide personal information about others.

3. HOW WE USE PERSONAL INFORMATION

We use personal information for a variety of business purposes, including to provide the Services, for administrative purposes, and to provide you with marketing materials, as described below.

    A. Provide the Services

    We use personal information to fulfill our contract with you and provide the Services, such as:

• Managing your information;
• Providing access to certain areas, functionalities, and features of the Services;
• Answering requests for support;
• Communicating with you;
• Sharing personal information with third parties as needed to provide the Services;
• Processing your financial information and other payment methods for products and Services purchased;
• Processing applications if you apply for a job we post on our Services; and
• Allowing you to register for events.

    B. Administrative Purposes

    We use personal information for various administrative purposes, such as:

• Pursuing our legitimate interests such as direct marketing, research and development (including marketing research), network and information security, and fraud prevention;
• Detecting security incidents, protecting against malicious, deceptive, fraudulent or illegal activity, and prosecuting those responsible for that activity;
• Carrying out analytics;
• Measuring interest and engagement in the Services;
• Improving, upgrading, or enhancing the Services;
• Developing new products and services;
• Creating de-identified and/or aggregated information. If we create or receive de-identified information, we will not attempt to reidentify such information, unless permitted by, or required to comply with, applicable laws;
• Ensuring internal quality control and safety;
• Authenticating and verifying individual identities, including requests to exercise your rights under this Privacy Notice;
• Debugging to identify and repair errors with the Services;
• Auditing relating to interactions, transactions, and other compliance activities;
• Enforcing our agreements and policies; and
• Carrying out activities that are required to comply with our legal obligations.

    C. Marketing

    We may use personal information to tailor and provide you with marketing and other content. We may provide you with these materials as permitted by applicable law.

    If you have any questions about our marketing practices, you may contact us at any time as set forth in “Contact Us” below.

    D. With Your Consent or Direction

    We may use personal information for other purposes that are clearly disclosed to you at the time you provide personal information, with your consent, or as otherwise      directed by you.

    E. Automated Decision Making

    Corix's processing of your personal information will not result in a decision based solely on automated processing that has a legal or other similarly significant effect      on you unless such a decision is necessary as part of a contract we have with you, we have your consent, or we are permitted by law to engage in such automated      decision making.

    If you have questions about our automated decision making, you may contact us as set forth in “Contact Us” below.

4. HOW WE DISCLOSE PERSONAL INFORMATION

We disclose personal information to third parties for a variety of business purposes, including to provide the Services, to protect us or others, or in the event of a major business transaction such as a merger, sale, or asset transfer, as described below.

    A. Disclosures to Provide the Services

    We may disclose any of the personal information we collect to the categories of third parties described below.

• Service Providers. We may disclose personal information to third-party service providers that assist us with the provision of the Services. This may include, but is not limited to, service providers that provide us with hosting, customer service, analytics, marketing services, IT support, and related services. In addition, personal information and chat communications may be disclosed to service providers that help provide our chat features.

    Some of the service providers we may use include:

• Google Analytics. For more information about how Google uses your personal information, please visit Google Analytics’ Privacy Policy (http://www.google.com/policies/privacy/partners/). To learn more about how to opt-out of Google Analytics’ use of your personal information, please reference this link: http://tools.google.com/dlpage/gaoptout.

• LinkedIn Analytics. For more information about how LinkedIn uses your personal information, please visit LinkedIn Analytics’ Privacy Policy (https://www.linkedin.com/legal/privacy-policy). To learn more about how to opt-out of LinkedIn’s use of your information, please reference this link: https://www.linkedin.com/help/linkedin/answer/62931?trk=microsites-frontend_legal_privacy-policy&lang=en.

• VWO (Visual Website Optimizer). We use VOW’s session replay analytics services. This allows us to record and replay an individual’s interaction with the Services. For more information about how VWO      uses your personal information, please visit the VWO Privacy Policy (https://vwo.com/privacy-policy/). To learn more about how to opt-out of VWO’s use of your personal information, please reference this link: https://vwo.com/opt-out.

• Third-Party Services You Share or Interact With. The Services may link to or allow you to interface, interact, share information with, direct us to share information with, access and/or use third-party websites, applications, services, products, and technology (each a “Third-Party Service”).
  
  Any personal information shared with a Third-Party Service will be subject to the Third- Party Service’s privacy policy. We are not responsible for the processing of personal information by Third-Party Services.

• Business Partners. We may share your personal information with business partners to provide you with a product or service you have requested. We may also share your personal information with business partners with whom we jointly offer products or services.
  
  Once your personal information is shared with our business partner, it will also be subject to our business partner’s privacy policy. We are not responsible for the processing of personal information by our business partners.

• Corix Customers (Authorized Users Only) In cases where you use our Services as an employee, contractor, or other authorized user of a Corix customer, that customer may access information associated with your use of the Services including usage data and the contents of the communications and files associated with your account. Your personal information may also be subject to the Corix customer’s privacy policy. We are not responsible for the Corix customer’s processing of your personal information.

• Affiliates. We may share your personal information with our corporate affiliates.

• Advertising Partners. We may share your personal information with third-party advertising partners, such as  Google, LinkedIn, and HubSpot.  These third-party advertising partners may set Technologies and other tracking tools on our Services to collect information regarding your activities and your device (e.g., your IP address, cookie identifiers, page(s) visited, location, time of day). These advertising partners may use this information (and similar information collected from other services) for purposes of delivering personalized advertisements to you when you visit digital properties within their networks. This practice is commonly referred to as “interest-based advertising,” “personalized advertising,” or “targeted advertising.”  
  
  Some of the advertising partners we engage include:
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• Google.  For more information about Google’s use of your personal information, please visit Google’s Data Policy (https://policies.google.com/privacy?hl=en-US.)  To learn more about how to opt-out of Google’s use of your information, please reference this link: https://support.google.com/websearch/contact/content_removal_form?hl=en.

• HubSpot. For information about how HubSpot uses your personal information, please review the HubSpot Privacy Policy (https://legal.hubspot.com/privacy-policy?__hstc=159311909.1d02d22a07ae145ea9ee13870bd79ac0.1728067511426.1736466046121.1736527073768.88&__hssc=159311909.3.1736527073768&__hsfp=336580338). To submit a request to opt-out of HubSpot’s use of your personal information, please submit your written request to privacy@hubspot.com.

• LinkedIn. For more information about how LinkedIn uses your personal information, please visit LinkedIn’s Privacy Policy (https://www.linkedin.com/legal/privacy-policy). To learn more about how to opt-out of LinkedIn’s use of your information, please reference this link: https://www.linkedin.com/help/linkedin/answer/62931?trk=microsites-frontend_legal_privacy-policy&lang=en.

    B. Disclosures to Protect Us or Others‍
    We may access, preserve, and disclose any information we store associated with you to external parties if we, in good faith, believe doing so is required or appropriate to: comply with law enforcement or national security requests and legal process, such as a court order or subpoena; protect your, our, or others’ rights, property, or safety; enforce our policies or contracts; collect amounts owed to us; or assist with an investigation or prosecution of suspected or actual illegal activity.

    C. Disclosure in the Event of Merger, Sale, or Other Asset Transfers

    If we are involved in a merger, acquisition, financing, reorganization, bankruptcy, receivership, purchase or sale of assets, transition of service to another provider, or other similar corporate transaction, your personal information may be disclosed, sold, or transferred as part of such a transaction.

5. YOUR PRIVACY CHOICES AND RIGHTS

Your Privacy Choices. The privacy choices you may have about your personal information are described below.

• Email Communications. If you receive an unwanted email from us, you can use the unsubscribe functionality found at the bottom of the email to opt out of receiving future emails. Note that you will continue to receive transaction-related emails. We may also send you certain non-promotional communications regarding us and the Services, and you will not be able to opt out of those communications (e.g., communications regarding the Services or updates to this Privacy Notice).

• Text Messages. If you receive an unwanted text message from us, you may opt out of receiving future text messages from us by following the instructions in the text message you have received from us or by otherwise contacting us as set forth in “Contact Us” below.

• Do Not Track signals and Global Privacy Control. Certain web browsers and other programs may transmit “do-not-track” “opt-out” signals, also called a Global Privacy Control (or “GPC”) signal (we refer to these as “GPC Signals”), to websites with which the browser communicates.  In most cases you will need to change your web browser’s settings or add an application to your web browser to enable your browser to send a GPC Signal. Our websites will recognize GPC Signals for website users differently, based on the location of the user when they access our websites.  For users that access our websites from U.S. states that have laws requiring recognition of GPC Signals, we will recognize and apply the GPC Signal to inactivate all the cookies for that website, except for cookies that are necessary for the website to operate.  Additionally, if you are accessing our websites from one of these states, you can determine if your browser GPC Signal has been recognized by clicking on the “Do Not Sell or Share My Personal Information” link in the footer of the website and checking that appropriate cookies have been turned off.  For users from states not currently requiring recognition of the GPC Signal, our website servers may recognize and apply the GPC Signal for only advertising and social media cookies but will not apply the GPC Signal to functional or performance cookies. You can always check and adjust your cookie settings by going to the “Do Not Sell or Share My Personal Information” link in the footer of this website.
  
  Some web browsers incorporate other "do-not-track" (“DNT”) or similar features that signals to websites with which the browser communicates that a visitor does not want to have their online activity tracked. As of the Effective Date, not all browsers offer a DNT option and DNT signals are not yet uniform. For this reason, we along with many other digital service operators do not respond to all DNT signals. We recognize GPC signals as required under certain state privacy laws, but we do not currently recognize other DNT signals. For more information about the Global Privacy Control, please visit https://globalprivacycontrol.org.

• Cookies. You may stop or restrict the placement of Technologies on your device or remove them by adjusting your preferences as your browser or device permits. However, if you adjust your preferences, the Services may not work properly.
  
  Please note that cookie-based opt-outs are not effective on mobile applications. However, you may opt-out of certain tracking on some mobile applications by following the instructions for Android (https://support.google.com/googleplay/android-developer/answer/6048248?hl=en), iOS (https://support.apple.com/en-us/HT202074), and others (https://www.networkadvertising.org/mobile-choice/).
  
  The online advertising industry also provides mechanisms that may allow you to opt out of receiving targeted ads from organizations that participate in self-regulatory programs. To learn more, visit the Network Advertising Initiative (http://www.networkadvertising.org/managing/opt_out.asp) and the Digital Advertising Alliance (http://www.aboutads.info/choices/).
  
  Please note you must separately opt out in each browser and on each device.

Your Privacy Rights. In accordance with applicable law, you may have the right to:

• Confirm Whether We Are Processing Your Personal Information;

• Request Access to or Portability of Your Personal Information;

• Request Correction of Your Personal Information;

• Request Deletion of Your Personal Information;

• Request Restriction of or Object to our Processing of Your Personal Information;

• Request to Opt-Out of Certain Processing Activities including, as applicable, if we process your personal information for “targeted advertising” (as “targeted advertising” is defined by applicable privacy laws),  if we “sell” your personal information (as “sell” is defined by applicable privacy laws), or if we engage in “profiling” in furtherance of certain “decisions that produce legal or similarly significant effects” concerning you (as such terms are defined by applicable privacy laws); and

• Withdraw Your Consent to our Processing of Your Personal Information. Please note that your withdrawal will only take effect for future processing and will not affect the lawfulness of processing before the withdrawal.

If you would like to exercise any of these rights, please contact us as set forth in “Contact Us” below. We will process such requests in accordance with applicable laws.

Only you, or someone legally authorized to act on your behalf in certain jurisdictions, may make a request to exercise the rights listed above regarding your personal information. If your personal information is subject to a law that allows an authorized agent to act on your behalf in exercising your privacy rights and you wish to designate an authorized agent, please provide written authorization signed by you and your designated agent using the information found in “Contact Us” below and ask us for additional instructions.

To protect your privacy, we will take steps to verify your identity before fulfilling requests submitted under applicable privacy laws. These steps may involve asking you to provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative. Examples of our verification process may include [asking you to confirm the email address we have associated with you.

Some laws may allow you to appeal our decision if we decline to process your request. If applicable laws grant you an appeal right, and you would like to appeal our decision with respect to your request, you may do so by informing us of this and providing us with information supporting your appeal.

6. INTERNATIONAL TRANSFERS OF PERSONAL INFORMATION

All personal information processed by us may be transferred, processed, and stored anywhere in the world, including, but not limited to, the United States or other countries, which may have data protection laws that are different from the laws where you live.

7. CHILDREN’S PERSONAL INFORMATION‍

The Services are not directed to children under 18 (or other age as required by local law outside the United States), and we do not knowingly collect personal information from children.

If you are a parent or guardian and believe your child has uploaded personal information to the Services in violation of applicable law, you may contact us as described in “Contact Us” below.

8. THIRD-PARTY WEBSITES/APPLICATIONS

The Services may contain links to other websites/applications and other websites/applications may reference or link to our Services. These third-party services are not controlled by us. We encourage our users to read the privacy policies of each website and application with which they interact. We do not endorse, screen, or approve, and are not responsible for, the privacy practices or content of such other websites or applications. Providing personal information to third-party websites or applications is at your own risk.

9. CONTACT US

Corix is the controller of the personal information we process under this Privacy Notice.

If you have any questions about our privacy practices or this Privacy Notice, or to exercise your rights as detailed in this Privacy Notice, please contact us at:  

    Email Address:  corixprivacy@corixinsurance.com

    Toll-Free Phone Number: +1 (844) 400-1199  

‍ANNEX A – SUPPLEMENTAL U.S. PRIVACY NOTICE

This Supplemental U.S. Privacy Notice supplements our Privacy Notice and only applies to our processing of Personal Information from U.S. consumers residing in a state with a comprehensive privacy law.  

‍NOTICE AT COLLECTION

At or before the time of collection, U.S. consumers residing in a state with a comprehensive privacy law have a right to receive notice of our privacy practices. Such consumers can find this information below.

• ‍Personal Information Collected. See the section of this Supplemental U.S. Privacy Notice titled “Overview of Personal Information Collected, Disclosed, Sold and/or Shared” for a list of Personal Information which may be collected. ‍
• Uses of Personal Information. See the section of this Supplemental U.S. Privacy Notice titled “Uses of Personal Information” for a list of the purposes for which we use Personal Information. ‍
• Is Personal Information “Sold” or “Shared” for “Cross-Context Behavioral Advertising”? See the section of this Supplemental U.S. Privacy Notice titled “Overview of Personal Information Collected, Disclosed, Sold and/or Shared” for more details. See the section of this Supplemental U.S. Privacy Notice titled “‘Sales’ of Personal Information and/or ‘Sharing’ for ‘Cross-Context Behavioral Advertising” for instructions on how to opt-out of these activities.‍
• For How Long is Personal Information Retained? To determine the appropriate retention period for Personal Information, we consider applicable legal requirements, the amount, nature, and sensitivity of the Personal Information, certain risk factors, the purposes for which we process your Personal Information, and whether we can achieve those purposes through other means.‍
• Additional Information. For more information on our privacy practices, please review this Supplemental U.S. Privacy Notice and our Privacy Notice. Importantly, the section of our Privacy Notice titled “Your Privacy Rights” includes important details about how you can exercise some of the rights which you have under the CCPA.

CATEGORIES OF SOURCES FROM WHICH PERSONAL INFORMATION IS COLLECTED

We collect Personal Information you provide to us, collected automatically when you use the Services, and from third-party sources.

‍OVERVIEW OF PERSONAL INFORMATION COLLECTED, DISCLOSED, SOLD, AND/OR SHARED

U.S. consumers residing in a state with a comprehensive privacy law are provided with the right to know what categories of Personal Information Corix has collected about them, whether Corix disclosed Personal Information for a business purpose (e.g., to a service provider), whether Corix “sold” such Personal Information, and whether Corix “shared” such Personal Information for “cross-context behavioral advertising” in the preceding twelve (12) months. U.S. consumers residing in a state with a comprehensive privacy law may find this information below:

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Identifiers

• Third parties that provide marketing and data analytics services, such as social media platforms used to deliver our ads, website/email optimization providers, marketing communications providers (e.g., email, SMS, post), and data analytics providers.
• Payment processors, financial institutions, and others as needed to complete transactions and for authentication, security, and fraud prevention.
• Third parties that provide us with information technology services, such as internet service providers, operating systems and platforms, data centers/hosts/cloud service providers.
• Third parties that assist us with information technology and security programs.
• Third parties that assist us with fraud prevention, detection, and mitigation.

• Third parties that provide marketing and data analytics services, such as social media platforms used to deliver our ads, website/email optimization providers, marketing communications providers (e.g., email, SMS, post), and data analytics providers.

USES OF PERSONAL INFORMATION

We may use and disclose the personal information that we collect for the following business and commercial purposes:

• Providing the Services as further described in our Privacy Notice;
• Processing for administrative purposes as further described in our Privacy Notice;
• Processing for marketing purposes as further described in our Privacy Notice;
• Processing with your consent or direction as further described in our Privacy Notice;
• Processing to carry out automated decision making as further described in our Privacy Notice;
• Auditing related to counting ad impressions to unique visitors, verifying positioning and quality of ad impressions, and auditing compliance with this specification and other standards;
• Helping to ensure security and integrity to the extent the use of personal information is reasonably necessary and proportionate for these purposes;
• Debugging to identify and repair errors that impair existing intended functionality;
• Short-term, transient use, including, but not limited to, non-personalized advertising shown as part of your current interaction with Corix;
• Maintaining or servicing accounts, providing customer service, processing or fulfilling orders and transactions, verifying customer information, processing payments, providing financing, providing analytic services, providing storage, or providing similar Services;
• Providing advertising and marketing services;
• Undertaking internal research for technological development and demonstration;
• Undertaking activities to verify or maintain the quality or safety of a service or device that is owned, manufactured, manufactured for, or controlled by Corix, and to improve, upgrade, or enhance the service or device that is owned, manufactured, manufactured for, or controlled by Corix.

RIGHT TO OPT OUT OF “SALES” OF PERSONAL INFORMATION AND/OR “SHARING” FOR “CROSS-CONTEXT BEHAVIORAL ADVERTISING”

We may “sell” your personal information or “share” your personal information for “cross-contextual behavioral advertising” to provide you with information about Corix's products and services.

California residents have the right to opt out of the “sale” of personal information and the “sharing” of personal information for “cross-context behavioral advertising.” California residents may exercise these rights by sending an email to corixprivacy@corixinsurance.com.

DISCLOSURE REGARDING INDIVIDUALS UNDER THE AGE OF 16

Corix does not have actual knowledge of any “sale” of personal information of minors under 16 years of age. Corix does not have actual knowledge of any “sharing” of personal information of minors under 16 years of age for “cross-context behavioral advertising.”

DISCLOSURE REGARDING SENSITIVE PERSONAL INFORMATION

Corix only uses and discloses sensitive personal information for the following purposes:

• To perform the services or provide the goods reasonably expected by an average consumer who requests those goods or services.
• To prevent, detect, and investigate security incidents that compromise the availability, authenticity, integrity, and or confidentiality of stored or transmitted personal information.
• To resist malicious, deceptive, fraudulent, or illegal actions directed at Corix and to prosecute those responsible for those actions.
• To ensure the physical safety of natural persons.
• For short-term, transient use.
• Maintaining or servicing accounts, providing customer service, processing or fulfilling orders and transactions, verifying customer information, processing payments, providing financing, providing analytic services, providing storage, or providing similar services.
• To verify or maintain the quality or safety of a product, service, or device that is owned, manufactured, manufactured for, or controlled by Corix, and to improve, upgrade, or enhance the service or device that is owned, manufactured by, manufactured for, or controlled by Corix.
• For purposes that do not infer characteristics about individuals.

RIGHT TO LIMIT USE AND DISCLOSURE OF SENSITIVE PERSONAL INFORMATION

U.S. consumers residing in a state with a comprehensive privacy law may have the right to limit certain uses and disclosures of “sensitive Personal Information” by Corix. Such consumers may exercise these rights by following the instructions on that page or by emailing us at:  corixprivacy@corixinsurance.com.

NON-DISCRIMINATION

U.S. consumers residing in a state with a comprehensive privacy law have the right not to receive discriminatory treatment by us for the exercise of their rights conferred under applicable comprehensive privacy law.