Last revised February 6, 2024
California Residents: For information about the categories of personal information we collect and your rights under California privacy laws, review Section 11. Additional Information for California Residents.
For information about the privacy choices you have regarding your personal information, review Section 5. Your Privacy Choices.
Table of Contents
- Personal Information Collected
- Purposes of Collection and Processing
- Disclosures of Personal Information
- Cookies and Other Tracking Technologies
- Your Privacy Choices
- Links to Other Websites
- Children’s Privacy
- Changes to this Policy
- Contact Us
- Additional Information for California Residents
1. Personal Information Collected
As further described below, we collect personal information directly from individuals, other sources, and automatically related to the use of our Services or other interactions with us.
Personal Information Collected Directly. The personal information we collect from you depends upon how you use our Services or otherwise interact or engage with us, but generally includes:
- Appointed broker information. We collect personal information for submissions to become an appointed broker with Foresight, such as your name, email address, and phone number.
- Broker submission information. We collect personal information from brokers who submit insurance claims with Foresight. This may include broker contact information and information about employees for workers’ compensation purposes (such as name, date of birth, information regarding their employment, and information regarding an accident or loss).
- Payments. When you make a payment through the Services, our third-party payment providers collect payment information in order to process your payment, and they provide us with limited information related to your transaction, such as reports regarding deposits received and/or payments made for our record-keeping purposes.
- Communications and interactions. When you email, call, or otherwise communicate with us, members of our team, or our chatbots, we collect and maintain a record of your contact details, communications and our responses. We also maintain records of communications and information that you post on our social media channels and information you provide to us related to any customer support requests.
- Events and other requests. We also collect personal information related to your participation in our events as well as other requests that you submit to us related to our Services. For example, if you register for or attend an event that we host or sponsor, we may collect information related to your registration for and participation in such event. When you fill out a ”Contact Us” form, sign up for our mailing lists, or otherwise request information from us, we collect and maintain records of your requests.
Personal Data from Other Sources. We may collect personal information about you from other sources, such as public databases, social media platforms or other entities.
- We receive information from our third-party data providers such as publicly available data, financial information, claim history, benchmark price, and experience modification factor. Our third-party data providers will also conduct Office of Foreign Assets Control searches and provide us reports regarding their findings.
- We may receive lead and prospect information from marketing and advertising entities, about prospective customers that may be interested in our Services. We may also engage with marketing and advertising entities to enhance or update our customer information.
- We may collect personal information from data brokers, such as companies that aggregate, enrich, and cleanse information from a variety of public and proprietary sources for commercial purposes.
- If you post information about us or engage with us on social media or other platforms that are not affiliated with us, we may collect personal information about you from such platform(s). These nonaffiliated platforms and services control the information they collect and share about you. For information about how they may use and disclose your information, including any information you make public, please consult their respective privacy policies.
Personal Information Collected Automatically. We automatically collect personal information related to your use of our Services and interactions with us and others, such as our IT service providers and our marketing and analytics business partners. We may collect this information automatically (e.g., using cookies and pixel tags) or derive information about you and your use of the Services. Such information includes:
- Activities and usage. We also collect activity information related to your use of the Services, such as information about the links clicked, searches, features used, items viewed, and time spent within the Services.
- Location information. We may collect or derive generalized location information about you, such as through your IP address.
2. Purposes of Collection and Processing
Generally, we collect, use, and otherwise process the personal information we collect for the following purposes:
- Conducting our insurance business, including policy and/or claims activities.
- Providing services and support. To provide and operate our Services, communicate with you about your use of the Services, provide troubleshooting and technical support, process your payments, communicate with you, and for similar service and support purposes.
- Responding to inquiries. To respond to your questions, fulfill your orders and requests, and consider your request or application (e.g., if you have submitted a resume or other application information online or by email, we will use it as part of the application review process).
- Analytics and improvement. To better understand how users access and use the Services, and our other services and offerings, and for other research and analytical purposes, such as to evaluate and improve our services and business operations, to develop services and features, and for internal quality control and training purposes.
- Customization and personalization. To tailor content we may send or display on the Services, including to offer location customization and personalized help and instructions, and to otherwise personalize your experiences.
- Marketing and advertising. For marketing and advertising purposes. For example, to send you information about our Services, such as newsletters and other marketing content, including about non-Foresight products and services we think may interest you, as well as any other information that you sign up to receive. We also may use certain information we collect to manage and improve our advertising campaigns so that we can better reach people with relevant content.
- Planning and managing events. For event planning and management, including registration, attendance, connecting you with other event attendees, and contacting you about relevant events and Services.
- Research and surveys.To administer surveys and questionnaires, such as for market research purposes.
- Legal proceedings and obligations. To comply with the law and our legal obligations, to respond to legal process and related to legal proceedings.
- General business and operational support. To consider and implement mergers, acquisitions, reorganizations, bankruptcies, and other business transactions, and related to the administration of our general business, accounting, auditing, compliance, recordkeeping, and legal functions.
3. Disclosures of Personal Information
We disclose the personal information we collect in order to provide our Services to you, respond to and fulfill your requests and insurance claims, as otherwise directed or consented to by you, and for the purposes otherwise described in this Policy. We disclose such personal information to the recipients described in this Policy. These purposes and recipients include:
- Conducting the business of insurance. To validate and analyze insurance claims and facilitate insurance policy requests.
- Services and support. To provide and operate our Services, communicate with you about your use of the Services, provide troubleshooting and technical support, respond to your inquiries, fulfill your requests, process your payments, communicate with you, and for similar service and support purposes.
- Analytics and improvement. To better understand how users access and use the Services, and our other services and offerings, and for other research and analytical purposes, such as to evaluate and improve our services and business operations, to develop services and features, and for internal quality control and training purposes.
- Marketing, advertising, and campaign management. We may disclose certain information that includes personal information to other marketing and analytics providers, who may use this data to improve and measure the effectiveness of our ads and those of such non-Foresight entities. For more information, see Section 4. Cookies and Other Tracking Technologies below.
- In support of business transfers. If we or our affiliates are or may be acquired by, merged with, or invested in by another company, or if any of our assets are or may be transferred to another company, whether as part of a bankruptcy or insolvency proceeding or otherwise, we may transfer the information we have collected from you to the other company. We may also share certain personal information as necessary prior to the completion of such a transfer, such as to lenders, auditors, and agents and advisors, including attorneys and consultants, as part of due diligence or as necessary to plan for the transfer.
- Compliance, governance, and legal requirements. To comply with the legal and compliance obligations, to respond to legal process and related to legal proceedings. For example, we may disclose information in response to subpoenas, court order, and other lawful requests by regulators and law enforcement, including responding to national security or law enforcement disclosure requirements. We may also disclose information, including personal information, related to litigation and other legal claims or proceedings in which we are involved, as well as for our internal accounting, auditing, compliance, recordkeeping, and legal functions. In addition, we may disclose the names of sweepstakes and contests winners, in accordance with applicable law.
We disclose and make available personal information, for the purposes described above, to the following persons and entities:
- Insurance brokers. We may disclose personal information to insurance brokers, professionals who serve as an intermediary between insurance customers and insurance providers. Insurance brokers serve as guides and advocates for insurance customers, helping them to secure the coverage and services they need at a price that fits their budget.
- Carrier partner and claims management entities. We may disclose personal information we collect to carrier partners and other third-party administrators in order to provide the requested service of insurance coverage.
- Vendors and service providers. We may disclose personal information we collect to our service providers and others who perform functions on our behalf. These may include, for example, IT service providers, help desk, payment processors, consultants, auditors, and legal counsel. Our vendors and service providers are subject to contractual terms that place a duty of confidentiality upon them with respect to the information they process on our behalf.
- Our affiliates. We may disclose personal information we collect to our affiliates or subsidiaries, who will use and disclose this personal information in accordance with the principles of this Policy.
- Non-Foresight platforms, providers, and networks. We may disclose or make available personal information to social media, marketing and analytics platforms and providers that we use to provide or make available certain features or portions of the Services, or as necessary to respond to your requests. We may also make certain information (such as browsing information) available to such non-Foresight entities in support of our marketing, advertising and campaign management.
- Regulatory agencies and bureaus. We may disclose personal information to insurance regulators and other governmental bodies, such as those established to set and enforce standards in the private sector to promote fair trade and consumer protection.
Aggregate and de-identified information. To the extent permitted by applicable law, we may receive, use, and disclose aggregate and other non-identifiable information related to our business and Services to provide the Services requested, for quality control, analytics, development, and other purposes. Some of this information may be considered “de-identified” under U.S. privacy laws (i.e., information that it is no longer linked or reasonably linkable to an identified or identifiable consumer). Where we rely on information that has been “de-identified,” as defined by U.S. privacy laws, we will: (i) take reasonable measures to ensure that the de-identified information cannot be associated with an individual, household, or device; (ii) commit to maintain and use the information in de-identified form and not attempt to re-identify the information; and (iii) contractually obligate any further recipient to comply with this provision.
4. Cookies and Other Tracking Technologies
Cookies. Cookies are alphanumeric identifiers that we transfer to your device through your web browser for record-keeping purposes. Some cookies allow us to make it easier for you to navigate our Services, while others are used to support the security and performance of the Services or allow us to track activity and usage data within Service.
Additionally, be aware that if you visit other websites, you may be required to accept cookies. Our business partners may also use their own cookies on our website. We do not control use of these cookies and expressly disclaim responsibility for information collected through them. The cookies track link-in and link-out traffic to better understand how other websites may be linking to or referencing the website. We may also track page hits within our Website. We collect and share this information only in aggregated, non-personally identifiable format. For example, we may track how many users viewed a particular website page during a given month.
Pixel tags. Pixel tags (also known as web beacons and clear gifs) are tiny graphics with a unique identifier, similar in function to cookies. In contrast to cookies, which are placed on a user’s device, pixel tags are embedded invisibly on webpages. We may use pixel tags to track information for statistical purposes to improve the services we provide. Our use of pixel tags will not enable other companies to access any of your personally identifiable information.
Additionally, be aware that advertisers and business partners may also use their own pixel tags. We do not control use of these and expressly disclaim responsibility for information collected through them.
Cross-Device Use. Foresight, our service providers, and our business partners may use the information that we collect about you within our Services and on other non-Foresight websites and services to help identify other devices that you use (e.g., a mobile phone, tablet, other computer, etc.). This information may be used as set forth in this section.
Targeted Advertising. To the extent permitted by applicable law, Foresight allows selected entities, including analytics and advertising services and networks, mobile networks, and others (“ad company partners”), to place cookies and pixel tags on our Websites. These ad company partners may collect information about your online activities over time and across other websites. These ad company partners use this information to provide you more relevant ads and content on non-Foresight websites, and to evaluate the success of such ads and content. To review your choices regarding the information we and our ad company partners may collect about you, please see Section 5. Your Privacy Choices below.
Custom Lists and Matching. Unless you have opted out, we may share certain hashed customer list information (such as your name, email address and other contact information) with business parties so that we can better target ads and content to our users, and others with similar interests, within non-Foresight websites, platforms and services. You may opt out of being targeted by us in this manner, as set forth in Section 5. Your Privacy Choices.
You have certain choices regarding the personal information we collect about you. For example, you may:
- Opt out of promotional email communications. You may opt out of promotional emails by clicking on the unsubscribe link in the email, or by emailing us at firstname.lastname@example.org, and identifying or describing the email from which you would like to unsubscribe.
- Opt out of interest-based advertising. We use non-affiliated providers such as Google’s AdSense and AdWords to help us provide advertisements to you that are tailored to you based on interests that you have expressed on our Website or elsewhere (“Interest-Based Ads”). Any advertisements served by Google, Inc., and affiliated companies may be controlled using cookies. These cookies allow Google to display ads based on your visits to this Website. Any tracking done by Google through cookies and other mechanisms is subject to Google’s own privacy policies. You may decide to disable Google cookies by visiting https://myadcenter.google.com/. You can visit Google’s My Ad Center to manage the Google ads you see and opt out of Interest-Based Ads delivered by Google. You also may opt out of receiving Interest-Based Ads from many non-affiliated ad networks, such as those provided by members of the Network Advertising Initiative (“NAI”) and the Digital Advertising Alliance (“DAA”). For more information regarding Interest-Based Ads by NAI members and DAA members, including how to opt out of Interest-Based Ads provided by NAI and DAA members, please visit their respective websites: optout.networkadvertising.org and optout.aboutads.info. Please note that opting out of participating ad networks does not mean that you will not see any advertisements; you will continue to receive advertisements on other websites and from companies that do not participate in the above programs. Even if you opt out of interest-based ads, you may still see ads based on factors such as your general location derived from your IP address, your browser type and recent, previous searches related to your current search.
Please note that even if you opt out of receiving marketing communications from us, we may still send you communications about your account or services you have purchased or received from us, and we will still respond to your inquiries and requests for information.
6. Links to Other Websites
Our Services may contain links to other websites or features not affiliated with Foresight. Any access to and use of those linked websites or features is not governed by this Policy, but instead is governed by the privacy policies of those entities. We are not responsible for the information practices of such nonaffiliated entities, including their collection, use, and disclosure of your personal information.
7. Children’s Privacy
Our Services are not designed for children, and we do not knowingly collect personal information from children under the age of sixteen (16). If we learn that personal information has been collected on the Services from persons under the age of 16, then we will take the appropriate steps to delete this information.
We have implemented reasonable precautions aimed to protect the information we collect from loss, misuse, and unauthorized access, disclosure, alteration, and destruction. Please be aware that despite our efforts, no data security measures can guarantee security. All supplied payment information is transmitted via Secure Socket Layer (SSL) technology and then encrypted into our payment gateway provider(s)’s database so that it is accessible only by those authorized with special access rights to such systems and/or who are required to keep the information confidential.
9. Changes to this Policy
This Policy is current as of the date provided above. We may modify this Policy from time to time, so please be sure to check back periodically. We will post any updates to this Policy here. If we make any changes to this Policy that materially affect our practices regarding our use of personal information that we have previously collected from you, we will endeavor to provide you with notice, such as by posting prominent notice on our Website.
10. Contact Us
If you have any questions or comments about this Policy, the ways in which Foresight collects and uses your information, your choices and rights regarding such use, or wish to exercise your rights, please do not hesitate to contact us at:
548 Market St #92963
San Francisco, CA 94104
11. Additional Information for California Residents
This section of the Policy provides additional information for California residents and describes our information practices as required by the California Consumer Privacy Act, as amended by the California Privacy Rights Act, and its implementing regulations (“CCPA”). Depending on how you interact or engage with us, we may provide you with other privacy notices with additional details about our privacy practices.
Notice at Collection. The following sub-sections below, read together, are intended to comply with our obligations with respect to Notice at Collection under the CCPA: “Categories of Personal Information We Collect and Disclose,” “Retention,” “Purposes of Collection, Use, and Disclosure,” and “Sale and Sharing of Personal Information.”
Scope. This section applies to “personal information” as defined by the CCPA, whether collected online or offline, in our capacity as a business. This section does not address or apply to our handling of personal information that is exempt under the CCPA, such as:
- publicly available information;
- 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), and California Financial Information Privacy Act (FIPA); or
- aggregated or de-identified information.
This California section of the Policy also does not apply to personal information we collect about (i) job applicants, (ii) independent contractors, or (iii) current or former full-time, part-time, and temporary employees or our staff, officers, or directors; different notices apply.
Categories of Personal Information We Collect and Disclose. The following table identifies the categories of personal information we may collect about you (and may have collected in the prior 12 months), as defined by the CCPA, as well as the categories of third parties to whom we may disclose this information for a business or commercial purpose. Depending on how you use the Services, we may collect and disclose the following categories of personal information:
|Category of Personal Information
|Disclosures to Third Parties for Business or Commercial Purposes
|Identifiers, such as a real name, physical address, telephone number, email address, unique personal identifier, online identifier, Internet Protocol (IP) address, or other similar identifiers.
|Personal information categories listed in the California Customer Records statute, such as signature, physical characteristics or description, insurance policy number, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information.
|Protected classification information, such as race or ethnicity, tribal affiliation, religion, sex, gender, national origin or immigration status, disability, medical condition, marital status, military or veteran status, and other characteristics of protected classifications under California or federal law.
|Commercial information, including records of personal property and products or services purchased, obtained, or considered.
|Biometric information, such as imagery of the iris, retina, fingerprint, face, hand, palm, vein patterns, and voice recordings used or intended to be used singly or in combination with identifying data to establish individual identity.
|Internet or other similar electronic network activity, such as browsing history, clickstream data, search history, browser records, device records, marketing and communications preferences, and information regarding interactions with our Website and the Services, advertisements, or emails, including other usage data related to your use of any of our Services or other similar online services.
|Location data, such as general location information about a particular individual or device.
|Sensory data, such as information collected via call recordings if you are interacting with us in a customer service capacity or if you call us on a recorded line, recorded meetings and webinars, videos, and photographs.
|Professional or employment-related information, such as job title, company name, business email, business phone number, brokerage contact information, government-issued brokerage identification numbers, and other similar professional-related information.
|Inferences drawn from other personal information, i.e., those drawn from any of the information identified in this chart to create a profile about a California resident reflecting their preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.
|Sensitive personal information: In limited circumstances, we may collect health information or medical information (for purposes of processing claims).
Sources of Personal Information. In general, we may collect the categories of personal information identified in the table above from the following categories of sources:
- Directly from individuals;
- Our Websites, mobile applications, and Services;
- Government agencies or public records;
- Vendors and service providers;
- Data brokers or business partners;
- Data analytics providers and advertising networks;
- Social media platforms;
- Internet service providers and operating systems & platforms; and
- Business customers and clients.
Purposes of Collection, Use, and Disclosure. In general, we may collect, use, disclose, and otherwise process personal information for the following business or commercial purposes and as otherwise directed or consented to by you:
- Conducting the business of insurance;
- Providing services and support;
- Responding to inquiries;
- Analytics and improvement;
- Customization and personalization;
- Marketing and advertising;
- Planning and managing events;
- Research and surveys;
- Security and protection of rights;
- Legal proceedings and obligations; and
- General business and operational support.
For additional details regarding how we use your personal information, please see Section 2. Purposes of Collection and Processing.
Retention. We retain the personal information we collect only as reasonably necessary for the purposes described above or otherwise disclosed to you at the time of collection. For example, we will retain your purchase information as necessary to comply with our tax, accounting and recordkeeping obligations, to provide you with the services you have requested, as well as an additional period of time as necessary to protect, defend or establish our rights, defend against potential claims, and comply with our legal obligations. In some cases, rather than delete your personal information, we may de-identify or aggregate it and use this information in compliance with the CCPA.
Sales and Sharing of Personal Information. The CCPA defines “sale” as disclosing or making available personal information to a third party in exchange for monetary or other valuable consideration, and “sharing” includes disclosing or making available personal information to a third party for purposes of cross-context behavioral advertising. While we do not disclose personal information to third parties in exchange for monetary compensation, we may “sell” or “share” the following categories of personal information: identifiers, commercial information, and internet and network activity information. We may disclose these categories to third-party advertising networks and analytics providers for purposes of marketing and advertising and to improve and measure our ad campaigns. We do not sell or share sensitive personal information, nor do we sell or share personal information about individuals we know are under age sixteen (16).
Sensitive Personal Information. Notwithstanding the above, we only use and disclose sensitive personal information as reasonably necessary (i) to perform our services requested by you, (ii) to help ensure security and integrity, including to prevent, detect, and investigate security incidents, (iii) to detect, prevent, and respond to malicious, fraudulent, deceptive, or illegal conduct, (iv) to verify or maintain the quality and safety of our services, (v) for compliance with our legal obligations, (vi) to our service providers who perform services on our behalf, and (vii) for purposes that are not for inferring characteristics about you. We do not use or disclose your sensitive personal information other than as authorized by the CCPA (pursuant to Cal. Civil Code § 1798.121 and § 7027(m) of the CCPA regulations).
California Residents’ Rights. The CCPA provides California residents with specific rights regarding personal information. Subject to certain conditions and exceptions, California residents have the following rights with respect to their personal information:
- Right to Know. You have the right to request: (i) the categories or personal information we collected about you; (ii) the categories of sources from which the personal information is collected; (iii) our business or commercial purposes for collecting, selling, or sharing personal information; (iv) the categories of third parties to whom we have disclosed personal information; and (v) a copy of the specific pieces of personal information we have collected about you.
- Right to Delete. You have the right to request that we delete personal information we have collected from you.
- Right to Correct. You have the right to request that we correct inaccuracies in your personal information.
- Right to Opt Out of Sales and Sharing. You have the right to opt out of “sales” and “sharing” of your personal information, as those terms are defined under the CCPA.
- Right to Limit Use of Sensitive Personal Information. You have the right to limit use and disclosure of your sensitive personal information. We do not use or disclose sensitive personal information beyond the purposes authorized by the CCPA; thus, this right is not available to California residents.
- Right to Non-Discrimination. You have the right not to be subjected to discriminatory treatment for exercising any of the rights described in this section.
Submitting CCPA Requests. California residents may exercise their CCPA privacy rights as set forth below:
- Right to Know, Delete, and Correct. California residents may submit CCPA requests to access/know, delete, and correct their personal information by:
When you submit a request, we will take steps to verify your identity and request by matching the information provided by you with the information we have in our records. In some cases, we may request additional information in order to verify your identity, or where necessary to process your request. If we are unable to verify your identity after a good faith attempt, we may deny the request and, if so, will explain the basis for the denial.
You may also designate someone as an authorized agent to submit requests and act on your behalf. Authorized agents will be required to provide proof of their authorization in their first communication with us, and we may also require that the relevant consumer directly verify their identity and the authority of the authorized agent.
- Right to Opt Out of Sales and Sharing. To exercise your right to opt out of the “sale” or “sharing” of your personal information, you may do so via our cookie preference manager. We will apply your opt out based upon the personal information in our records that is linked or reasonably linkable to the information provided in your request. You may also click the “Do Not Sell or Share My Personal Information” link at the bottom of our Website.
In addition, if we detect that your browser or device is transmitting an opt-out preference signal, such as the “global privacy control” or “GPC” signal, we will opt that browser or device out of cookies that result in a “sale” or “sharing” of your personal information. If you come to our Website or use our Services from a different device or from a different browser on the same device, you will need to opt out, or use an opt-out preference signal, for that browser and/or device as well. More information about GPC is available at: https://globalprivacycontrol.org/.
For more information about our privacy practices, you may contact us as laid out in Contact Us, above.