Privacy Policy

Categories of Personal Information We Collect
Sources of Personal Information
Purposes for Collecting or Disclosing Personal Information
Disclosure of Personal Information
Retention
Your California Privacy Rights
Marketing Communications and Opt-Out Rights
How to Submit a Request
Personal Information of Children Under the Age of 16
Cookies and Other Tracking Technologies
Sale and Sharing of Personal Information and Right to Opt-Out
Do Not Track and Global Privacy Control Signals
Changes To This Policy
Questions

This Privacy Policy (“Policy”) is adopted by W Insurance Company (“W Insurance”, “we” or “us”) to comply with the California Consumer Privacy Act, as amended by the California Privacy Rights Act (collectively “CCPA”). This Policy describes how we collect, use and disclose personal information, including sensitive personal information, as such terms are defined in the CCPA. This Policy applies to residents of the State of California only.

This Policy applies to personal information of California residents that is subject to the CCPA. Please note that certain information is exempt from the CCPA. For example, personal information collected subject to a federal law called the Gramm-Leach-Bliley Act (GLBA) is exempt. As a result, insurance information may not be disclosed in response to a CCPA request. Other exceptions include medical information and protected health information; personal information used to generate a consumer report; and personal information under the Driver Privacy Protection Act. These exemptions apply to the specific data collected subject to those federal laws, not to all personal information W Insurance may hold about you. For information about our insurance-specific privacy practices, including our practices for collecting, using and disclosing personal information in connection with insurance transactions, please see our separate Insurance Privacy Notice.

If you are a W Insurance employee, job applicant or independent contractor, see our separate Employee Privacy Policy.

For the purposes of this Policy, personal information does not include publicly available information such as information from government records or information made available to the general public or de-identified or aggregated information.

1. Categories of Personal Information We Collect

We have collected the following categories of personal information in the preceding 12 months:

Category of Personal Information Collected	Examples	Disclosed for a Business Purpose
Category of Personal Information Collected Identifiers	Examples Name, postal address, email address, date of birth, telephone number, driver’s license number or state identification card number, credit or debit card number or other similar identifiers	Disclosed for a Business Purpose YES
Category of Personal Information Collected Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e))	Examples Name, signature, physical characteristics or description, address, telephone number, credit or debit card number, driver’s license number or state identification card number, education or employment history	Disclosed for a Business Purpose YES
Category of Personal Information Collected Protected classification characteristics under California or federal law	Examples Age, race, color, ancestry, national origin, citizenship or immigration status, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression), same sex orientation for same sex benefits, veteran or military status	Disclosed for a Business Purpose YES
Category of Personal Information Collected Commercial Information	Examples Records of personal property	Disclosed for a Business Purpose YES
Category of Personal Information Collected Internet or Network Activity	Examples Browser history, search history, IP address, mobile device or information regarding your interaction with our website	Disclosed for a Business Purpose YES
Category of Personal Information Collected Geolocation data	Examples Physical location	Disclosed for a Business Purpose YES
Category of Personal Information Collected Audio, electronic, or visual data	Examples Audio recordings, pictures and videos	Disclosed for a Business Purpose YES
Category of Personal Information Collected Professional or employment-related information	Examples Current job or name of employer	Disclosed for a Business Purpose YES
Category of Personal Information Collected Inferences drawn from other personal information	Examples Profile reflecting a person's preferences, characteristics, behavior, attitudes, intelligence, abilities, and aptitudes	Disclosed for a Business Purpose YES
Category of Personal Information Collected Sensitive Personal Information	Examples Driver’s License, state identification card, social security number, racial or ethnic origin, health information or sexual orientation	Disclosed for a Business Purpose YES

2. Sources of Personal Information

We collect personal information from the following sources:

Your dealings with us in person, over the telephone, through e-mail, mail or our website. We may collect phone numbers, email addresses, and text message content to verify and authenticate the identity of callers requesting policy changes, claims information, or other policy-related services. Telephone calls to and from W Insurance may be recorded for quality assurance, training, and verification purposes;
The forms, documents, and written communications you or your representatives submit to us;
Third parties who assist us in the underwriting and administration of insurance policies or in the investigation, processing, or payment of claims;
Government agencies, public records, insurance support organizations and credit reporting agencies; and
Any other lawful sources.

3. Purposes for Collecting or Disclosing Personal Information

We collect and disclose personal information for one or more of the following purposes:

To provide, operate and improve our services and our business, including to investigate, evaluate and pay claims and to otherwise facilitate an insurance transaction and to offer or provide products or services available to you;
To determine eligibility for an insurance benefit or payment;
To detect or prevent criminal activity, fraud, material misrepresentation or material non-disclosure in connection with an insurance transaction
To communicate with you, including by sending notices, updates, and support and administrative messages and to notify you or any lienholder or other third party identified as having a legal or beneficial interest in a policy regarding the status of an insurance transaction;
To provide support and respond to your requests and questions;
To communicate with your representatives, such as lawyers or claims agents or other third parties designated by you or where you have instructed us or provided your consent to do so or where doing so is otherwise necessary to provide our services;
To facilitate or complete an actual or prospective business transaction, including, but not limited to, investments in W Insurance, financing of W Insurance, or the sale, transfer or merger of all or part of our business, assets, or shares;
For research and development purposes, including to analyze and improve our business, to develop new products and services and to help us understand user activity on our website and online services;
To comply with applicable laws, lawful requests, and legal process, such as to respond to subpoenas, investigations, or requests from government authorities;
To protect our, your or others’ rights, privacy, safety, or property (including by making and defending legal claims);
To audit or conduct analyses with respect to our internal processes for compliance with legal and contractual requirements or our internal policies;
To enforce the terms and conditions that govern our business; and
To prevent, identify, investigate, and deter fraudulent, harmful, unauthorized, unethical or illegal activity, including cyberattacks and identity theft.

4. Disclosure of Personal Information

We have disclosed personal information to the following categories of third parties in the preceding 12 months:

Our parent company;
Service providers who perform a business, professional or other insurance function for W Insurance including, but not limited to, claims management companies, claims adjusters, repair shops, roadside assistance providers, third parties who assist in determining an individual’s eligibility for an insurance policy, policy benefit or payment or third parties who assist in detecting or preventing criminal activity, fraud, material misrepresentation or material nondisclosure in connection with an insurance transaction;
Your representatives and other third parties designated by you;
Other insurance companies involved in the claims or underwriting process;
Medical care institutions or professionals as necessary to verify coverage or benefits;
Government authorities, regulators, and law enforcement;
Another insured or claimant;
Third parties as necessary for the evaluation or consummation of a proposed or actual sale, acquisition, transfer, merger or consolidation of all or part of our company;
Accountants, auditors, lawyers, insurers, and other professional advisors; and
Other parties not listed above that are identified at or before the point at which we collect personal information along with the purposes for which the information will be shared.

5. Retention

We retain personal information for as long as necessary to fulfil the purposes for which we collected it, including for the purposes of satisfying any legal, accounting, or reporting requirements, to establish or defend legal claims, or for the compliance and protection purposes identified above.

6. Your California Privacy Rights

The CCPA provides California residents with certain rights regarding their personal information. However, these rights are not absolute and are subject to certain exceptions. This section explains those rights.

A. Right to Know About Your Personal Information

You have the right to request that W Insurance provide you with information regarding the personal information W Insurance has collected about you in the preceding (12) months. Once we receive your request and verify your identity, we will disclose to you, subject to any exemptions under the CCPA, the following:

Categories of personal information collected;
Categories of sources from which the personal information is collected;
Business or commercial purpose for collecting, selling, or sharing the personal information;
Categories of third parties to whom W Insurance disclosed the personal information; and
Specific pieces of personal information W Insurance has collected.

B. Right to Delete Your Personal Information

You have the right to request that W Insurance delete your personal information that we have collected from you. However, this right does not apply to any personal information that is exempt under the CCPA. Once we receive your request and verify your identity, we will delete any personal information in our records that is not subject to any of the CCPA exemptions.

C. Right to Correct

You have the right to request that W Insurance correct any inaccurate personal information that W Insurance has about you. Once we receive your request and verify your identity, we will correct any inaccurate personal information that we have collected about you.

D. Right to Limit the Use and Disclosure of Sensitive Personal Information

You have the right to limit the use and disclosure of your sensitive personal information. The CCPA provides this right unless the business uses such information within legally permitted purposes or does not use it to infer characteristics about you. We use sensitive personal information within legally permitted purposes, such as to perform the services or provide the products requested by you, to detect security incidents, to perform services on our behalf, and to verify or maintain the quality of services we provide. Since we use sensitive personal information within these legally permitted purposes and not to infer characteristics about you, we are not required to offer the option to limit the use of such information. If we change our practices in the future, we will notify you by updating this Policy and will offer such an option at that time.

E. Right to Opt-Out of the Selling or Sharing of Personal Information

You have the right to direct a business that sells or shares personal information to third parties to not sell or share your personal information. W Insurance does not sell personal information for monetary consideration. However, our use of tracking technologies for cross-contextual behavioral advertising purposes may be considered "sharing" of personal information under the CCPA. During the prior 12 months, we may have shared personal information in the categories of Identifiers, Internet or Network Activity, and Geolocation Data for cross-contextual behavioral advertising purposes with digital advertising networks. You may opt out of this sharing as described in Section 10 (Cookies and Other Tracking Technologies) and Section 11 (Do Not Track and Global Privacy Control Signals) of this Policy.

F. Right to Non-Discrimination

You have the right to not receive discriminatory treatment by W Insurance for exercising your CCPA rights.

7. Marketing Communications and Opt-Out Rights

A. Commercial Email Communications

W Insurance may send you marketing emails if you have provided your email address to us. You may opt out of receiving marketing emails at any time by clicking the "unsubscribe" link included in any marketing email we send you. To make this request, you may contact us using the contact information provided in Section 13 below. Please note even if you opt out of marketing emails and telephone calls, we may still send emails or call you for transactional purposes or to fulfill our obligations under your insurance policy.

B. Telemarketing Communications

We will respond to your request within forty-five (45) days. However, in certain circumstances, we may require additional time to process your request, as permitted by the CCPA. We will advise you within forty-five (45) days after receiving your request if an extension is necessary and why it is needed. If we cannot fulfill your request, our response to you will explain the reason why we cannot fulfill your request.

8. How To Submit a Request

If you would like to exercise your CCPA rights identified above, you may submit a request here or by calling us at 800-640-2920 and selecting Option 7.

A. How We Verify Your Identity and Requests

To process your request, we must be able to verify your identity or authority to make the request and confirm the personal information relates to you. This requires that you submit all requests here or by calling us at 800-640-2920 and selecting Option 7. When submitting your request, you must provide your full name, your relationship to W Insurance, if any, your policy or account number if you are a current W Insurance policyholder, your address, your email address, phone number, and any other information pertaining to your request. Submitting your request through one of these channels allows us to verify your identity as required by the CCPA. As such, we cannot accept requests through other channels. We cannot process your request if you do not provide us with sufficient detail to allow us to understand and respond to it. We reserve the right to confirm your current California residency. If we cannot successfully verify your identity, we will inform you of that fact.

B. Responding To Your Requests

We will respond to your request within forty-five (45) days. However, in certain circumstances, we may require additional time to process your request, as permitted by the CCPA. We will advise you within forty-five (45) days after receiving your request if an extension is necessary and why it is needed. If we cannot fulfill your request, our response to you will explain the reason why we cannot fulfill your request.

C. Submitting A Request Through Your Authorized Agent

You have the option to designate an authorized agent to submit a request on your behalf. We may require you and your authorized agent to verify your identity or confirm that the agent has permission to submit a request on your behalf. You are not required to create an account with us to exercise your CCPA rights. We will only use personal information provided in a request to review and comply with your request.

9. Personal Information of Children Under the Age of 16

W Insurance does not seek to, nor do we knowingly collect, information directly from children under the age of 16. We do not sell personal information about consumers under 16 years of age. We do not have actual knowledge of sharing personal information for cross-contextual behavioral advertising purposes for consumers under 16 years of age, although consumers under 16 who use our website could have their personal information shared for cross-contextual behavioral advertising purposes through tracking technologies described in Section 10.

10. Cookies and Other Tracking Technologies

When you visit our website, we and our third-party partners (such as advertising and analytics providers) use cookies, web beacons, pixels, internet tags, and other similar tracking technologies (collectively, "tracking technologies") to gather information about you and your use of our website and email communications. Some tracking technologies help us maintain the security of our website and your account, prevent crashes, fix bugs, note your preferences, and assist with basic site functions. Other tracking technologies provide us with information regarding how visitors interact with our website. Such technologies allow us to understand, for example, how many visitors come to our website, the frequency of such visits, and the number of times a user views a specific page. We use Adobe Analytics for website analytics purposes. Adobe Analytics data is used for website analytics only and is not used for cross-contextual behavioral advertising. To learn more about Adobe Analytics privacy practices or to opt out of cookies set to facilitate reporting, visit the Adobe Privacy Center at www.adobe.com/privacy.html.

We may permit third parties to use tracking technologies on our website for analytics and advertising, including helping to manage and display advertisements and to tailor advertisements to your interests. These third parties use their technology to provide advertising about products and services tailored to your interests which may appear either on our website or on other websites. We use the Google Marketing Platform and its service partners to deliver and measure online advertising. Google and its service partners may collect information about your use of our website, including device identifiers, IP address, and browsing activity, and may use this information for cross-contextual behavioral advertising purposes. This use constitutes "sharing" of personal information under the CCPA.

For more information about how Google may use your data, click here: “How Google Uses Data When You Use Our Partners’ sites or apps”. We may also use other advertising and analytics service providers from time to time. When we do, the privacy practices of those providers will be governed by their own privacy policies.

If you wish to restrict or block cookies set on our website, you can do this through your computer or device's browser settings. Restricting cookies may limit your ability to use some features on the website.

We may use the following types of tracking technologies on our website:

Cookie Type	Description
Cookie Type Essential Cookies	Description Essential cookies are cookies that our website needs in order to function and that enable you to move around and use the website and features. Without these essential cookies, the website will not perform as smoothly for you as we would like it to, and we may not be able to provide the website or certain services or features you request. Examples of where these cookies are used include to determine when you are signed in, to determine when your account has been inactive, and for other troubleshooting and security purposes.
Cookie Type Analytics Cookies	Description Analytics cookies provide us with information regarding how visitors navigate and interact with our website. Such cookies allow us to understand, for example, more about how many visitors we have to our website, how many times they visit us, and how many times a user viewed specific pages within our website. We use Adobe Analytics cookies for these purposes. Adobe Analytics data is used for website analytics only and is not used for cross-contextual behavioral advertising. To learn more about Adobe Analytics privacy practices, visit www.adobe.com/privacy.html.
Cookie Type Ad-tracking cookies	Description Ad-tracking cookies are placed by third-party advertising partners, including Google Marketing Platform and its service partners, to deliver and measure online advertising. These cookies collect information such as device identifiers, IP address, and browsing activity to tailor advertisements to your interests, which may appear on our website or on other websites. Our use of these cookies for cross-contextual behavioral advertising purposes may constitute “sharing” of personal information under the CCPA. To opt-out from this practice see Section 11 below.

11. Sale and Sharing of Personal Information and Right to Opt-Out

You may opt-out of being tracked by third party tracking technologies for cross-context behavioral advertising purposes on our website by:

Click here to set your cookie preferences; or
Broadcasting the Global Privacy Control (GPC) for those browsers and browser extensions that support such a signal. This is an opt-out at the browser and device level. For example, if you turn on GPC on your iPad or laptop, you have opted out for information while this device, but not if you visit our website on your mobile phone. You will need to turn on GPC for each device. Click here to learn how to turn on GPC. If you turn on GPC, your opt-out of sharing is accepted automatically.

Your request to opt-out of sale/sharing will be linked to your browser identifier only specific to the device you are currently using.

If you would like to completely opt-out of cross-context behavior advertising, you will need to proceed with a request to opt-out through our CCPA Application that requires authentication. Click here to make a request.

12. Do Not Track and Global Privacy Control Signals

Certain web browsers may provide a do-not-track (DNT) option. You may be able to ask your browser to inform websites that you do not wish your activities to be tracked, either with cookies or other persistent identifiers, commonly called “DNT signals.” The W Insurance website currently does not respond to DNT signals. As noted above, the GPC is a browser-based signal that communicates a consumer's preference to opt-out of the sale or sharing of personal information for cross-contextual behavioral advertising purposes. The W Insurance website recognizes the GPC signal received from your browser as a valid request to opt out of the sharing of your personal information. To learn how to enable GPC, visit To learn how to enable GPC, visit globalprivacycontrol.org.

13. Changes To This Policy

We reserve the right to change this Policy at any time. The “Effective Date” listed at the bottom of this Policy indicates when it was last revised. All updated policies will be posted on our website.

14. Questions

If you have any questions about this Policy, you may contact us at:

By Mail:
W Insurance Company
c/o ACE Privacy Office, Corporate Legal
3333 Fairview Road, A451
Costa Mesa, CA 92626

By E-mail:
legal@w-insurance.com

The Effective Date and date of the last update of this Policy is August 10, 2026.