Supplemental Privacy Notice for
California Residents.

This Supplemental Privacy Notice for California Residents supplements other privacy notices provided by Arcova. The purpose of this notice is to comply with the California Consumer Protection Act and the California Privacy Rights Act (collectively referred to herein as “CCPA”) and to advise California residents of certain rights that may or may not apply, based upon individuals’ relationships to us.

Information We May Collect

We may collect information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or device (“personal information”). In particular, we have potentially collected the following categories of personal information from consumers within the last twelve (12) months:

Some types of personal information that we collect may be separately defined as “sensitive data”

under applicable law. These types of data include:

• Personal information that reveals Social Security, driver's license, state identification card,or passport number
• Personal information that reveals an account log-in, financial account, debit card, or credit card number in combination with any required security or access code, password, or credentials allowing access to an account
• Personal information that reveals a consumer’s precise geolocation
• Personal information that reveals a consumer’s racial or ethnic origin, citizenship, or immigration status, religious or philosophical beliefs, or union membership
• Personal information reveals the contents of a consumer’s mail, email, and text messages of which we were not the intended recipient (such as emails that we receive by mistake or non-business emails sent by our employees).
• Personal information that reveals a consumer’s genetic data
• Processing of biometric information for the purpose of uniquely identifying a consumer
• Personal information collected and analyzed concerning a consumer’s health
• Personal information collected and analyzed concerning a consumer’s sex life or sexual orientationPlease note that personal information as defined in this notice does not include:
• Publicly available information from government records.
• De-identified or aggregated consumer information.
• Information excluded from the CCPA's scope, like:
  • health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and the California Confidentiality of Medical Information Act (CMIA) or clinical trial data;
  • personal information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FRCA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver's Privacy Protection Act of 1994.We obtain the categories of personal information listed above from the following categories of sources:
• Directly from you or your employer. For example, from an employee eligibility file from youremployer to let us know you are able to purchase products from us.
• Indirectly from you. For example, information we learn about you through the course of providing you with services.
• Directly and indirectly from activity on our websites. For example, from information you enter into our webforms.
• From third-parties that interact with us in connection with the services we perform. For example, from our third party claims administrators when you provide them with information or from entities that administer background checks for our job applicants.
  

  Use of Personal Information

  We may use or disclose the personal information we collect for one or more of the following business purposes:

• To fulfill the purpose, we stated when you provided us with the information.
• To provide you with information, products or services that you request from us.
• To provide you with email alerts, event registrations and other notices concerning our products or services, or events or news that may be of interest to you.
• To carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collections.
• To improve our website and present its contents to you.
• As necessary or appropriate to protect the rights, property or safety of us, our clients or others.
• To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.
• As described to you when collecting your personal information or as otherwise set forth in the CCPA.
  

  Your Rights and Choices

  The CCPA provides consumers (California residents) with specific rights regarding their personal

  information. This section describes your CCPA rights and explains how to exercise those rights.

  Access to Specific Information and Data Portability Rights

  You have the right to request that we disclose certain information to you about our collection and use of your personal information over the past 12 months. Once we receive and confirm your verifiable consumer request, we will disclose to you:

• The categories of personal information we collected about you.
• The categories of sources for the personal information we collected about you.
• Our business or commercial purpose for collecting or selling that personal information.
• The categories of third parties with whom we share that personal information.
• The specific pieces of personal information we collected about you (also called a dataportability request).
• If we sold or disclosed your personal information for a business purpose, two separate lists disclose:
  • sales, identifying the personal information categories that each category of recipient purchased; and
  • disclosures for a business purpose, identifying the personal information categories that each category of recipient obtained.
    

    Deletion Request Rights

    You have the right to request that we delete any of your personal information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer 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 deletion request if retaining the information is necessary for us or our service providers too:

• Complete the transaction for which we collect 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 fulfil 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 § 1546seq.).
• 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 achievement of the research, 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.
  

  ‌Additional Rights Under CCPA

  ‌Right to Correct Inaccurate Personal Information

  If you believe that the personal information that we maintain about you is inaccurate, you have the right to request that we correct that information.

  ‌Right to Opt Out of Sale or Sharing of Personal Information

  You have the right, at any time, to opt out of the sale or sharing of your personal information to third parties. (We do not sell personal information…) To opt out, please contact us using one of the options below.

  ‌Right to Limit Use and Disclosure of Sensitive Information

  You have the right, at any time, to request that we limit the use of your sensitive personal information to uses which are necessary to perform the services or provide the goods as requested, as authorized by regulations, or as otherwise permitted by the CCPA.

  ‌Exercising Access, Data Portability, and Deletion Rights

  To exercise the access, data portability, and deletion rights described above, please submit a verifiable consumer request to us by choosing one of these options:

  [Complete a Personal Data Request Form]

  (703) 564-7525

  Send a letter to:

  Arcova

  Attn: Privacy Officer 101 South Tryon Street Charlotte, NC 28280

  Only you or a person registered with the California Secretary of State that you authorize to act on your behalf, could make a verifiable consumer request related to your personal information. You may also make a verifiable consumer request on behalf of your minor child.

  You may only make a verifiable consumer request for access or data portability twice within a 12-month period. The verifiable consumer request must:

• Provide sufficient information that allows us to reasonably verify you are the person with 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.

  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. Making a verifiable consumer request does not require you to create an account with us. We will only use personal information provided in a verifiable consumer request to verify the requestor's identity or authority to make the request.

  ‌Response Timing and Format

  We will try to respond to a verifiable consumer request within 45 days of its receipt. If we require more time (up to 90 days), we will inform you of the reason and extension period in writing. Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request's receipt. The response we provide will also explain the reasons we cannot comply with a request, if applicable.

  We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.

  ‌Non-Discrimination

  We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not:

• Deny you with goods or services.

• Charging you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.

• Providing you with a different level or quality of goods or services.

• Suggest that you receive a different price or rate for goods or services or a different level or quality of goods or services.

‌Changes to Our Privacy Notice

We reserve the right to amend this privacy notice at any time. When we make changes to this privacy notice, we will post the changes here.

‌Notice to Consumers Under 16 Years of Age

American Fidelity does not knowingly sell any personal information about consumers under 16 years of age.

‌Contact Information

If you have any questions or comments about this notice, our Privacy Statement, the ways in which we collect and use your personal information, your choices and rights regarding such use, or wish to exercise your rights under California law, please do not hesitate to contact us at:

Phone: (703) 564-7525

Mail:

Arcova

Attn: Privacy Officer 101 South Tryon Street Charlotte, NC 28280