CCPA

We maintain administrative, technical and physical safeguards designed to protect personal information against accidental, unlawful or unauthorized destruction, loss, alteration, access, disclosure or use.

WHO THIS PRIVACY NOTICE APPLIES TO
This Privacy Notice applies to you if you are a California resident who has not obtained or sought to obtain a product or service from SPI. This Privacy Notice also applies to you if you are a California resident who has applied for a position with, or been recruited by, SPI. If you do not fall within the categories described above and are a customer of SPI or have sought to obtain a product or service from SPI, our Customer Privacy Policy applies to you. When you visit any SPI websites (“Sites”), our Online Privacy Policy also applies.

SOURCES AND CATEGORIES OF PERSONAL INFORMATION WE COLLECT
When you visit our Sites, we may collect personal information directly from you. The categories of personal information we may collect from you include:

• Contact information you provide, such as name, postal address, email address and telephone number;
• Information you submit in connection with requesting a quote or completing an electronic application on the Sites, including contact information, Social Security Number, date of birth, gender, medical and health information;
• Information you provide to create your online customer service account or producer account, and other account-related information (such as username and password, PIN, security questions and answers, Social Security number, and date of birth).
• Information you submit in connection with electronic payments, such as bank account information;
• Information you submit in connection with a career opportunity at SPI, such as contact information, information in your resume, and details about your current employment; and
• Information contained in content you submit, such as through our “Contact” feature or user experience surveys.

We may also collect personal information directly from you and from other sources through offline means. This includes contact information (such as name, postal address, email address and telephone number), resume information (such as education, professional or employment-related information), commercial information, publicly available information and demographic information, from public sources and third parties (such as data aggregators) who help facilitate our marketing, analytics and recruiting efforts. When appropriate, we may use some of this information to draw inferences about your preferences, so we can better tailor our marketing, advertising and recruiting efforts.

BUSINESS OR COMMERCIAL PURPOSES FOR COLLECTING PERSONAL INFORMATION
We use the personal information you provide to us through our Sites for various business or commercial purposes. Depending on the type of information collected, we may use the information we obtain through the Sites to:

• Personalize your experience on the Sites;
• identify and authenticate you so you may use the Sites;
• create your account;
• process your payments;
• administer our products and services;
• respond to your inquiries and requests;
• conduct user experience surveys;
• connect you with an appropriate dealer;
• provide you information about our products and services;
• manage career opportunities, including for recruitment purposes (such as processing job applications);
• operate, evaluate and improve our business (including developing new products and services; enhancing and improving our products and services; analyzing our products and services; managing our communications; performing data analytics; and performing accounting, auditing and other internal functions);
• protect against, identify and prevent fraud and other unlawful activity, claims and other liabilities; and
• comply with and enforce applicable legal requirements, relevant industry standards, contractual obligations and our policies.
  We may use the information we obtain in other ways for which we provide specific notice at the time of collection.

INFORMATION SHARING
We use the personal information we collect about you to: provide you information about our products and services; conduct marketing and advertising; perform market research; perform data analytics; help enhance or improve our products and services; manage our recruiting efforts and career opportunities; prevent fraud; and perform IT and administrative support functions.

CATEGORIES OF THIRD PARTIES WITH WHOM WE SHARE PERSONAL INFORMATION
We does not and will not sell your personal information. We may disclose your personal information to our subsidiaries, affiliates, and service providers, so we can provide you information about our products and services, as well as perform various business functions, such as data analytics, marketing and advertising, market research, mailings, recruiting and hiring, fraud prevention, and other IT and administrative support functions. The personal information disclosed to them may include your contact information (such as name, postal address, email address and telephone number), and demographic information. We do not authorize our service providers to use or disclose the information except as necessary to perform services or functions on our behalf, or to comply with legal requirements.

We also may share personal information with third parties (1) if we are required to do so by law or legal process (such as a court order or subpoena); (2) in response to requests by government agencies, such as law enforcement authorities; (3) to establish, exercise or defend our legal rights; (4) when we believe disclosure is necessary or appropriate to prevent physical or other harm or financial loss; (5) in connection with an investigation of suspected or actual illegal activity; or (6) in the event we sell or transfer all or a portion of our business or assets (including in the event of a reorganization, dissolution or liquidation).

RIGHTS UNDER THE CCPA AND HOW TO EXERCISE THEM
If you are a California resident whose personal information is covered by the CCPA and this Privacy Notice, you may have certain rights under the CCPA as listed below. We will comply with your request in accordance with, and to the extent permissible under, applicable law.