Liberty Mutual Group California Privacy Notice - Commercial Lines

(excluding Workers’ Compensation)

Effective June 2024

Liberty Mutual Group and its affiliates, subsidiaries, and partners (collectively "Liberty Mutual" or "we", "us" and "our") provide insurance to companies and other insurers. This Privacy Notice explains how we gather, use, and share your data. This Privacy Notice applies to you if you are a Liberty Mutual commercial line insured or are a commercial line claimant. It does not apply to covered employees or claimants under Workers’ Compensation policies. If this notice does not apply to you, go to libertymutual.com/privacy to review the applicable Liberty Mutual privacy notice.

What Data Does Liberty Mutual Gather?

The types of personal data we gather and share depend on both the product and your relationship to us. For example, we may gather different data if you are a claimant reporting an injury than if you want a quote for commercial property insurance. The data we gather can include your Social Security Number, income, transaction data such as account balances and payment history, and data from consumer reports. It may also include data gathered in connection with our provision of insurance services, when you apply for such services, or resulting from other contacts with you. It may also include:

  • Identifiers, including a real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, Social Security Number, driver’s license number, or other similar identifiers;

  • Personal information, such as your name, signature, Social Security Number, physical characteristics or description, address, telephone number, driver’s license or state identification card number, insurance policy number, education, employment, employment history, bank account number, financial information, medical information, or health insurance information;

  • Protected classification characteristics, including age, race, color, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, or veteran or military status;

  • Commercial information, including records of personal property, products or services purchased, obtained, or considered, or other purchasing or consumer histories and tendencies;

  • Internet or other similar network activity, including browsing history, search history, information on a consumer’s interaction with a website, application, or advertisement;

  • Professional or employment related information, including current or past job history or performance evaluations;

  • Inferences drawn from other personal information, such as a profile reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes;

  • Risk data, including data about your driving and/or accident history; this may include data from consumer reporting agencies, such as your motor vehicle records, and loss history information, health data, or criminal convictions;

  • Claims data, including data about your previous and current claims, which may include data regarding your health, criminal convictions, third party reports, or other personal data; and

  • Sensitive Data as defined under the California Privacy Rights Act when used to infer characteristics of an individual.

How Do You Gather My Data?

We gather your personal data directly from you.

For example, you provide us with data when you:

We also gather your personal data from other people. For example:

  • ask about, buy insurance, or file a claim
  • your insurance agent or broker
  • pay your policy
  • your employer, association, or business (if you are insured through them)
  • visit our websites, call us, or visit our office
  • our affiliates or other insurance companies about your  transactions with them

 

  • consumer reporting agencies, Motor Vehicle Departments, and inspection services, to gather your credit history, driving record, claims history, or value and condition of your property

 

  • other public directories and sources

 

  • third parties, including other insurers, brokers and insurance support organizations who you have communicated with about your policy or claim, anti-fraud databases, sanctions lists, court judgments and other databases, government agencies, open electoral register, or in the event of a claim, third parties including other parties to the claim witnesses, experts, loss adjusters and claim handlers

 

  • other third parties who take out a policy with us and are required to provide your data such as when you are named as a beneficiary or where a family member has taken out a policy which requires your personal data

Organizations that share data with us may keep it and disclose it to others as permitted by law.

How Does Liberty Mutual Use My Data?

Liberty Mutual uses your data to provide you with our products and services, and as otherwise provided in this Privacy Notice. We may use your data and the data of our former customers for our business and other compatible purposes. Our business purposes include, for example:

Business Purpose

Data Categories

Do We Sell or Share Your Data as Defined by CPRA?

Market, sell and provide insurance.

This includes, for example:

  • calculating your premium;
  • determining your eligibility for a quote;
  • confirming your identity and servicing your policy;
  • Identifiers
  • Personal Information
  • Protected Classification Characteristics
  • Commercial Information
  • Internet or other similar network activity
  • Professional or employment related information
  • Inferences drawn from other personal information
  • Risk data
  • Claims data
  • Sensitive Data
  • No

Manage your claim. This includes, for example:

  • managing your claim, if any;
  • conducting claims investigations;
  • conducting medical examinations;
  • conducting inspections, appraisals;
  • providing roadside assistance;
  • providing rental car replacement or repairs;
  • Identifiers
  • Personal Information
  • Protected Classification Characteristics
  • Commercial Information
  • Internet or other similar network activity
  • Professional or employment related information
  • Inferences drawn from other personal information
  • Risk data
  • Claims data
  • No

Day to Day Business and Insurance Operations. This includes, for example:

  • creating, maintaining, customizing, and securing accounts;
  • supporting day-to-day business and insurance related functions;
  • doing internal research for technology and development;
  • marketing, advertising and creating products and services;
  • conducting audits related to a current contact with a consumer and other transactions;
  • as described at or before the point of gathering personal data or with your authorization;
  • Identifiers
  • Personal Information
  • Protected Classification Characteristics
  • Commercial Information
  • Internet or other similar network activity
  • Professional or employment related information
  • Inferences drawn from other personal information
  • Risk data
  • Claims data
  • No

Security and Fraud Detection. This includes, for example:

  • detecting security issues;
  • protecting against fraud or illegal activity, and to comply with regulatory and law enforcement authorities;
  • managing risk and securing our systems, assets, infrastructure, and premises;
  • help to ensure the safety and security of Liberty Mutual staff, assets, and resources, which may include physical and virtual access controls and access rights management;
  • supervisory controls and other monitoring and reviews, as permitted by law; and emergency and business continuity management;
  • Identifiers
  • Personal Information
  • Protected Classification Characteristics
  • Commercial Information
  • Internet or other similar network activity
  • Professional or employment related information
  • Inferences drawn from other personal information
  • Risk data
  • Claims data
  • No

Regulatory and Legal Requirements. This includes for example:

  • controls and access rights management;
  • to evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of Liberty’s Mutual's assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal data held by Liberty Mutual is among the assets transferred;
  • exercising and defending our legal rights and positions;
  • to meet Liberty Mutual contractual obligations;
  • to respond to law enforcement requests as required by applicable law, court order, or governmental regulations;
  • as otherwise permitted by law;
  • Identifiers
  • Personal Information
  • Protected Classification Characteristics
  • Commercial Information
  • Internet or other similar network activity
  • Professional or employment related information
  • Inferences drawn from other personal information
  • Risk data
  • Claims data
  • No

Improve Your Customer Experience and Our Products. This includes, for example:

  • improve your customer experience, our products, and service;
  • to provide support, personalize, and develop our website, products, and services;
  • create and offer new products and services;
  • Identifiers
  • Personal Information
  • Commercial Information
  • Internet or other similar network activity
  • Professional or employment related information
  • Inferences drawn from other personal information
  • Risk data
  • Claims data
  • No

Analytics to identify, understand, and manage our risks and products. This includes, for example:

  • conducting analytics to better identify, understand, and manage risk and our products.

 

  • Identifiers
  • Personal Information
  • Protected Classification Characteristics
  • Commercial Information
  • Internet or other similar network activity
  • Professional or employment related information
  • Inferences drawn from other personal information;
  • Risk data
  • Claims data
  • Sensitive Data
  • No

Customer service and technical support. This includes, for example:

  • answer questions and provide notifications;
  • provide customer and technical support.
  • Identifiers
  • Personal Information
  • Commercial Information
  • Internet or other similar network activity
  • Professional or employment related information
  • Inferences drawn from other personal information
  • Risk data
  • Claims data
  • No

Cross-Context Behavioral Advertising

  • Identifiers
  • IP address
  • Internet or other similar network activity
  • We share this information with service providers such as search engines and social media platforms.

Liberty Mutual will not collect additional categories of personal information or use the personal information we collected for materially unrelated, or incompatible purposes without updating our notice.

How Does Liberty Mutual Share My Data?

Liberty Mutual does not sell your personal data as defined by California law.

Liberty Mutual shares your personal data as disclosed above. The California privacy law defines sharing as "communicating orally, in writing, or by electronic or other means, a consumers personal information, to a third party for cross-context behavioral advertising, whether or not for monetary or other valuable consideration". This occurs when you visit the Liberty Mutual website. Cookies or pixels are deployed that then allow us to show you targeted advertisements when you visit other websites or social media platforms.

This type of sharing is different from disclosing personal information to other entities to perform a service related to providing insurance or processing your claim. Liberty Mutual may disclose personal data with the following categories of affiliated and non-affiliated third parties:

  • Liberty Mutual affiliates;

  • Service Providers (such as auto repair facilities, towing companies, property inspectors, and independent adjusters);

  • Insurance support organizations;

  • Brokers and agents;

  • Public entities (e.g. regulatory, quasi-regulatory, tax or other authorities, law enforcement agencies, courts, arbitrational bodies, and fraud prevention agencies);

  • Consumer reporting agencies;

  • Professional advisors including law firms, accountants, auditors, and tax advisors;

  • Insurers, re-insurers, policy holders, and claimants;

  • Group policyholders (for reporting claims data or an audit);

  • A person, organization, affiliates or service providers conducting actuarial or research studies; and

  • As permitted by law.

We may also disclose data with other companies that provide marketing services on our behalf or as part of a joint marketing agreement for products offered by Liberty Mutual. We will not disclose your personal data with others for their own marketing purposes.

We may also disclose data about our transactions (such as payment history) and experiences (such as claims made) with you to our affiliates.

Liberty Mutual may disclose the following categories of personal data to service providers for business purposes:

Identifiers

Personal Data

Protected Classification Characteristics

Commercial Information

Internet or other similar network activity

Claims Data

Inferences drawn from personal data

Risk Data

Professional, employment, and education information

 

How Do We Keep Your Personal Data Safe?

We maintain physical, electronic, and procedural safeguards to protect your non-public personal information. These safeguards comply with applicable laws. Our employees and agents are authorized to access your data only for legitimate business purposes.

How Long Does Liberty Mutual Retain Each Category of Personal Data?

We retain your information in accordance with our legal obligations, our records retention policies, or as otherwise permitted by law. For example, we may have a legal obligation to retain information relating to your policies or claims with us. We will delete your data once the legal obligation expires or after the period of time specified in our records retention policies. The period of retention is subject to our review and alteration.

Children's Privacy

We do not direct our services to individuals under the age of 13 and we request that these individuals do not provide personal data through our services.

What Rights Do I Have to Learn More About My Personal Data?

Individuals may request access to a copy of their personal information. We will honor requests for access after we have verified your identity. We will grant two requests per year after. A request may be made to us by contacting us as described below.

You may have additional rights if you are a resident of California. For information about our data practices in the last 12 months, including the types of personal data we have collected, from whom we gathered that data, and with whom we disclosed the data, please go to Lmi.co/caprivacynotices and click on the link for the California Privacy Policy (Consumers). As a California resident, you also have the right to opt-out of cross-context behavioral advertising. You can learn more about those rights at lmi.co/caprivacychoices. To learn more about these and other privacy rights you may have as a California resident, please see the California Privacy Policy (Consumers). If you cannot access the link, please contact us.

Will Liberty Mutual Update This Privacy Notice?

We reserve the right to make changes to this notice at any time and for any reason. The updated version of this notice will be effective once it is posted online at https://www.libertymutual.com/. You are responsible for reviewing this notice to stay informed of any changes or updates.

Who Do I Contact Regarding Privacy?

You can submit requests, seek additional information, or obtain a copy of our Privacy Notice in an alternative format by either:

Calling:                        800-344-0197
Email:                          Privacy@libertymutual.com
Online:                         Libertymutualgroup.com/privacy-policy/data-request
Postal Address:         Liberty Mutual Insurance Company
                                     175 Berkeley St., 6th Floor
                                     Boston, MA 02116
                                     Attn: Privacy Office

 

To download a copy of this document, please click here.