Liberty Mutual Group California Privacy Notice - Commercial Lines

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(Excluding Workers’ Compensation)

Effective January 1, 2023

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 residing in California. 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 Personal Data Do We Collect?

    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 data, 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 data, precise geolocation, medical data, or health insurance data;  
    • Protected classification characteristics  described in California Civil Code § 1798.80(e), 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 consuming 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
    • 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.
       

    For information about the types of personal data we have collected in the past twelve (12) months, please see the California Privacy Policy (Consumers).

  • 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 or 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. For data about how we have gathered personal data in the past twelve months, please see the link for the California Privacy Policy (Consumers).

  • How Do We Use Your Personal 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 share or sell your information 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 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 assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal data held by Liberty is among the assets transferred;
    • exercising and defending our legal rights and positions;
    • to meet Liberty contract 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.

  • Do We Disclose Your Personal 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. You have the right to opt-out of this type of sharing and you may learn more about those rights at lmi.co/caprivacychoices.

    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.  How we disclose data to these types of entities is set forth below.

    Liberty Mutual may disclose personal data with affiliated and non-affiliated third parties, including:

    • 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;
    • 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 as needed for business purposes:

    Identifiers Personal data
    Protected Classification Characteristics Commercial data
    Internet or other similar network activity Professional, employment and education data
    Inferences drawn from personal data Risk data
    Claims data   


    For information about how we have shared personal information in the past twelve (12) months, please see the California Privacy Policy (Consumers).

  • 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.

  • How to Contact Us

    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
                                            lmi.co/caprivacychoices

    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.

Last updated: November 2022