Last Updated: August 19, 2020
intouch Business, Inc., (“intouch”) is committed to protecting the privacy of the individuals we encounter in conducting our business. “Personal Information” is information that identifies and relates to you. Our aim is responsible handling of Personal Information, balancing the benefits of activities like research and data analytics with our other commitments, including transparency and non-discrimination.
Who To Contact About Your Personal Information
If you have any questions about our use of your Personal Information, the rectification of your Personal Information, or would like to request the erasure of your Personal Information, you can email email@example.com or write to:
intouch Business, Inc.,
PO Box 255
Burbank, CA 91503
Attention: Julian Aston, President
Personal Information That We Collect
- Depending on your relationship with us, personal Information collected about you may include:
General identification and contact information
- Your name; address; email and telephone details; gender; marital status; family status; date of birth; educational background; activity records, such as driving records; photos; employment history, skills and experience; professional licenses and affiliations; and relationship to a policyholder, insured or claimant;
- Identification numbers issued by government bodies or agencies
- Social Security number; passport number; tax identification number; military identification number; or driver or another license number.
- Financial information and account details
- Payment card number; bank account or other financial account number and account details; credit history and credit score; assets; income; and other financial information.
- Medical condition and health status
- Current or former physical or mental or medical condition; health status; injury or disability information.
- Information from Other Sources
- We and our service providers may supplement the Personal Information we collect with information from other sources, such as publicly available information, commercially available sources and information from our affiliates or business partners.
How We Use Personal Information
We use this Personal Information to:
- Communicate with you and others as part of our business.
Respond to your requests.
- Send you important information regarding changes to our policies, other terms and conditions, and other administrative information.
- Make decisions about services we offer, and provide services, including insurance, HR and Legal, Safety and compliance, and more.
- Carry out research and analysis, including analysis of our customer base.
- Provide marketing information to you.
- Manage our infrastructure and business operations, and comply with internal policies and procedures, including those relating to auditing; finance and accounting; human resources; benefits administration; billing and collections; IT systems; data and website hosting; data analytics; business continuity; and records, document and print management.
- Resolve complaints, and handle requests for data access or correction.
- Comply with applicable laws and regulatory obligations (including laws that may be outside your country of residence), such as those relating to data protection, anti-money laundering, sanctions and anti-terrorism; comply with legal process; and respond to requests from public and governmental authorities.
- Establish and defend legal rights; protect our operations or those of any of our business partners, our rights, privacy, safety or property, and/or that of you or others; and pursue available remedies or limit our damages.
We use your Personal Information for these purposes where we are satisfied that:
- Our use of your Personal Information is reasonable or necessary to perform a contract, or take steps to enter into a contract with you; or
- Our use of your Personal Information is necessary to comply with a relevant legal or regulatory obligation that we are subject to; or
- You have provided your consent to us using the data; or
- Our use of your Personal Information is necessary to support “legitimate interests” that we have as a business, provided that it is conducted at all times in a way that is proportionate, and that respects your privacy rights.
International Transfer of Personal Information
Sharing of Personal Information
intouch may make Personal Information available to:
- Our service providers
External third-party service providers, such as accountants, auditors, lawyers and other outside professional advisors; IT systems, support and hosting service providers; printing, banks and financial institutions that service our accounts; third-party claim administrators; third-party human resource and benefits administrators; document and records management providers; claim investigators and adjusters; construction consultants; engineers; examiners; and similar third-party vendors and outsourced service providers that assist us in carrying out business activities.
- Governmental authorities and third parties involved in court action
intouch may also share Personal Information with governmental or other public authorities (including, but not limited to, workers’ compensation boards, courts, law enforcement, tax authorities and criminal investigations agencies); and third-party civil legal process participants and their accountants, auditors, lawyers and other advisors and representatives as we believe to be necessary or appropriate: (a) to comply with applicable law, including laws outside your country of residence; (b) to comply with legal process; (c) to respond to requests from public and government authorities including public and government authorities outside your country of residence; (d) to enforce our terms and conditions; (e) to protect our operations; (f) to protect our rights, privacy, safety or property, and/or that of our group companies, you or others; and (g) to allow us to pursue available remedies or limit our damages.
- Should you prefer, we will not disclose confidential personal information about you to non-affiliated third parties. You may opt out of those disclosures; that is, you may direct us not to make those disclosures (other than disclosures required or permitted by law).
Should you wish to opt out of disclosures to nonaffiliated third parties you may contact us by email at firstname.lastname@example.org or by writing to:
intouch Business, Inc.,
PO Box 255
Burbank, CA 91503
Re: Opt Out of Disclosures
intouch will take reasonably appropriate technical, physical, legal and organizational measures, which are consistent with applicable privacy and data security laws. Unfortunately, no data transmission over the Internet or data storage system can be guaranteed to be 100% secure. If you have reason to believe that your interaction with us is no longer secure (for example, if you feel that the security of any Personal Information you might have with us has been compromised), or if you have other data security questions or concerns related to intouch, please immediately notify us. (See the “Who to Contact About Your Personal Information” section above.)
When intouch provides Personal Information to a service provider, the service provider will be selected carefully and required to use measures reasonably designed to protect the confidentiality and security of the Personal Information.
If we believe the security of your Personal Information in our possession or control may have been compromised, we may seek to notify you of that development. If a notification is appropriate, we would endeavor to do so as promptly as possible under the circumstances, and, to the extent we have your email address, we may notify you by email.
Personal Information of Other Individuals
Social Security Numbers
It is the intouch policy to protect customer and employee Social Security Numbers that we collect in the course of our business as confidential. This includes maintaining physical and electronic security procedures to guard against unauthorized access to Social Security Numbers. In addition, we do not disclose Social Security Numbers to third parties, except where required or permitted by law.
Questions and Concerns
Please contact us as set out in the “Who to Contact About Your Personal Information” section above with any such requests or if you have any questions or concerns about how we process
Other Information We Collect Through our Website
“Other Information” is any information that does not reveal your specific identity, such as:
- Browser information;
- Information collected through cookies and other technologies; and
- Contact information provided by you.
How We Collect Other Information
We and our third-party service providers may collect Other Information in a variety of ways, including:
- Through your browser on the intouch website: Certain information is collected by most websites or automatically through your device, such as your IP address (i.e., your computer’s address on the internet), screen resolution, operating system type (Windows or Mac) and version, device manufacturer and model, language, internet browser type and version, time of the visit, and/or page(s) visited.
- You can refuse to accept the cookies we use by adjusting your browser settings. However, if you do not accept these cookies, you may experience some inconvenience in your use of the intouch site and some online products.
Please note that we may use and disclose Other Information for any purpose, except where we are required to do otherwise under applicable law. If we are required to treat Other Information as Personal Information under applicable law, or if we combine Other Information with Personal Information, then, in addition to the uses listed in the “ Other Information We Collect ” section above, we may use and disclose Other Information for all the purposes for which we use and disclose Personal Information.
Third Party Privacy Practices
Please note that we are not responsible for the collection, usage and disclosure policies and practices (including the data security practices) of other organizations, such as Facebook, Apple, Amazon, Google, Microsoft, RIM, Instagram, Twitter, LinkedIn, or any other software application developer or provider, social media platform, operating system or wireless service provider, or device manufacturer, including any Personal Information you disclose to other organizations.