This California Privacy Notice (“Notice”) describes how AXIS Capital Holdings Limited and any of its affiliates (“AXIS” or the “Company” or “we” or “us” or “our”) processes Personal Information of California residents. This Notice supplements our other privacy policies and notices, including our Global Privacy Notice. In the event of a conflict between any other policy, statement, or notice and this Notice, this Notice will prevail as to California residents.
Our California Applicant Privacy Notice covers Personal Information collected from and about our job applicants. Our California Employee Privacy Notice, located on our Intranet, covers Personal Information collected from and about our employees and related workers.
I. PERSONAL INFORMATION WE COLLECT AND WHY WE COLLECT, USE AND DISCLOSE IT
“Personal Information” means information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with you. Personal Information does not include information that is publicly available, de-identified, or aggregated.
We may collect, store, use and disclose your Personal Information consistent with applicable laws. Unless otherwise noted, the disclosures herein cover our activities in the twelve months preceding the Effective Date, as well as current practices. The Personal Information we collect about you may vary depending on the nature of your interactions with us and may not include all of the examples listed below.
| Category of Personal Information | Categories of Sources from which Information was Collected | Purposes for Collection, Use, and Disclosure | Categories of Recipients to which Information was Disclosed |
|---|---|---|---|
| Identifiers,including real name, alias, postal address, unique personal identifier, online identifier, IP address, email address, account name, or other similar identifiers |
| Collection and Use
Disclosure
|
|
| Personal information described in Cal. Civ. Code § 1798.80(e), including name, signature, social security number, physical characteristics or description, address, telephone number, passport number, driver’s license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or other financial information, medical information, or health insurance information |
| Collection and Use
Disclosure
|
|
| Characteristics of protected classifications under California or federal law, including age and date of birth, marital status, race, ancestry, ethnic origin, sex, gender, sexual orientation, gender identity, religion or creed, military or veteran status, medical condition, genetic information, disability, marital status |
| Collection and Use
Disclosure
|
|
| Commercial information, including records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies |
| Collection and Use
Disclosure
|
|
| Internet or other electronic network activity information, including Internet or other similar activity, browsing history, search history, information on a resident's interaction with a website, application logs, device data and registration, social media account information or advertisement |
| Collection and Use
Disclosure
|
|
| Audio, electronic, visual, or similar information |
| Collection and Use
Disclosure
|
|
| Professional or employment-related information |
| Collection and Use
Disclosure
|
|
| Inferences used to create a profile reflecting the resident’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes |
| Collection and Use
Disclosure
|
|
Sensitive Personal Information, including Personal Information collected and analyzed concerning a resident’s health, sex life, or sexual orientation and Personal Information that reveals a resident’s:
|
| Collection and Use
Disclosure
|
|
We also collect some Personal Information that does not directly fit within one of the categories defined by the CCPA. For example, we collect the contents of communications you send to us. Unless otherwise specified, the sources of this Personal Information, the purposes for which we use it, and the categories of persons to which we disclose it are the same as those listed for Identifiers.
In addition to the other purposes for collection, use, and disclosure of Personal Information described herein, we may collect, use, and disclose Personal Information as permitted by law; required by law, regulation or court order; to respond to governmental and/or law enforcement requests; to identify, contact or bring legal action against someone who may be causing injury to or interfering with our or others’ rights or property; to support any actual or threatened claim, defense or declaration in a case or before any jurisdictional and/or administrative authority, arbitration or mediation panel; or in connection with disciplinary actions/investigations. Likewise, we may use and disclose Personal Information to other parties in connection with the sale, assignment, merger, or reorganization.
Personal Information obtained from a report prepared by an insurance-support organization may be retained by the insurance-support organization and disclosed to other persons.
II. HOW LONG WE KEEP YOUR PERSONAL INFORMATION
We keep the categories of Personal Information described above for as long as is necessary for the purposes described in this Notice or otherwise authorized by law. This generally means holding the information for as long as one of the following apply:
- Your Personal Information is reasonably necessary to manage our operations, to manage your relationship with us, or to satisfy another purpose for which we collected the information;
- Your Personal Information is reasonably necessary to carry out a disclosed purpose that is reasonably compatible with the context in which the Personal Information was collected;
- The information is reasonably required to protect or defend our rights or property (which will generally relate to applicable laws that limit actions in a particular case); or
- We are otherwise required or permitted to keep your information by applicable laws or regulations.
Where information is used for more than one purpose, we will retain it until the purpose with the latest period expires. For more information about our retention policies, please contact us using the contact details below.
III. HOW WE SHARE AND SELL PERSONAL INFORMATION
Within the preceding 12 months, we have not sold or shared Personal Information for cross-context behavioral advertising. We do not have actual knowledge that we sell or share the Personal Information of residents under 16 years of age.
IV. YOUR CALIFORNIA PRIVACY RIGHTS
As a resident of California, you have the right to submit certain requests relating to your Personal Information as described below. To exercise your privacy rights, please submit a request through our California Consumer Rights Request Form or call us at 1 888 914 9661, PIN 292703.
Any privacy rights request you submit to us is subject to an identification and residency verification process (“Verifiable Consumer Request”). We will not fulfill your request unless you have provided sufficient information for us to reasonably verify you are the resident about whom we collected Personal Information. In making a request, you will need to verify that you are the authorized user of the subject email address/account and that you are a current resident of the State of California. Please follow the instructions on our website and promptly respond to any follow-up inquires so that we may confirm your identity. If you request that we provide you with specific pieces of information about you, we will apply heightened verification standards.
An Authorized Agent may submit a request on behalf of a resident if the resident has provided the Authorized Agent with power of attorney in accordance with California law; alternatively, we will (1) require the Authorized Agent to present verifiable written authorization from the resident that the Authorized Agent has the consumer’s permission to submit the request; and (2) independently verify the resident’s own identity with us.
A. California Consumer Privacy Act (“CCPA”) Rights
Right to Opt Out of Sales and Sharing of Personal Information – As stated above, we will not share or sell your Personal Information to third parties. For this reason, we do not treat Personal Information collected by Axis as subject to a Do Not Share or Sell request and, therefore, we do not offer a way for you to submit such a request.
Right to Limit Use and Disclosure of Sensitive Personal Information – We do not use or disclose sensitive Personal Information for purposes to which the right to limit use and disclosure applies under the CCPA. For this reason, we do not offer a way for you to submit such a request.
Right to Know – You have the right to know what Personal Information we have collected about you, which includes:
(1) The categories of Personal Information we have collected about you, including
- The categories of sources from which the Personal Information was collected
- Our business or commercial purposes for collecting Personal Information
- The categories of recipients to which we disclose Personal Information
- The categories of Personal Information that we disclosed for a business purpose, and for each category identified, the categories of third parties to which we disclosed that particular category of Personal Information.
(2) The specific pieces of Personal Information we have collected about you
Right to Delete Your Personal Information – You may request that we delete any Personal Information we have collected directly from you.
Right to Correct Inaccurate Information – If you believe that any Personal Information we maintain about you is inaccurate, you have the right to request that we correct that information.
Rights Related to Automated Decision-Making – You have the right to opt out of automated decision-making, including profiling, if we use your Personal Information to evaluate certain personal aspects relating to your performance at work, economic situation, health, personal preferences, interests, reliability, behavior, location, or movements.
Right to Non-Discrimination for the Exercise of Your Privacy Rights – If you choose to exercise any of your privacy rights under the CCPA, we will not discriminate against you.
B. California Insurance Code Rights
For more information about NPI covered by the Gramm-Leach-Bliley Act (“GLBA”) and your opt out choices, please visit our Financial Privacy Notice here.
“Nonpublic Personal Information” or “NPI” means Personal Information gathered in connection with an insurance transaction from which judgments can be made about an individual's character, habits, avocations, finances, occupation, general reputation, credit, health, or any other personal characteristics.
Right to Request Access. You have the right to request access to the recorded NPI we have collected about you, which includes:
(1) Information about the nature and substance of such recorded NPI;
(2) Copies of such recorded NPI, through in person access or mail;
(3) The recipients to which we disclosed such recorded NPI, up to two years prior to your request;
(4) The source of such recorded NPI where not obtained directly from you;
Rights to Correct, Amend, or Delete Recorded Personal Information. You have the right to request that we correct, amend, or delete any recorded NPI that we hold about you. If we cannot complete your request, we shall notify you of any refusal to make the change and provide you the opportunity to provide a statement supporting your request.
C. California “Shine The Light” Rights
California law permits customers in California to request certain details about how their personal information is shared with third parties and, in some cases, affiliates if that personal information is shared for those third parties’ and affiliates’ own direct marketing purposes. We do not share personal information with third parties or affiliates for those third parties’ or affiliates’ own direct marketing purposes. Californian customers may request such information by contacting us at [email protected] or 10000 Avalon Boulevard, Suite 200, Alpharetta, GA 30009.
To make a request, please provide sufficient information for us to determine if this applies to you, attest to the fact that you are a California resident, and provide your current California address to which we will send our response. Your inquiry must specify “California Privacy Rights Request” in the subject line of the email or the first line of the letter and include your name, street address, city, state, and ZIP code. Please note that we are only required to respond to one request per customer each year.
NOTE: As all of these rights and your CCPA rights exist under different legal regimes, you must exercise your rights under each law separately.
V. CONTACT US
Please address all inquiries, requests, and other communications regarding your personal information or this Privacy Notice to:
Contact: Data Protection Officer Email: [email protected] Address: 10000 Avalon Boulevard, Suite 200, Alpharetta, GA 30009 Phone: 1 888 914 9661, PIN 292703
Last Reviewed: March 2024, v3.1
