AWP USA Inc. and its subsidiaries, including Jefferson Insurance Company and AGA Service Company d/b/a Allianz Global Assistance are committed to protecting your privacy. By using our products, services or website, you consent to our collection and use of your Personal Data as described in this notice (“Notice”).

Definitions

The below definitions apply to this Notice:

1. “Personal Data” means non-public personal information that identifies a specific identified or identifiable person (“you”). An identifiable person is one who can be identified by reference to an identifier (such as name) or other factors specific to that person. Personal Data does not include publicly available, de-identified, or aggregated data.

2. “Sensitive Data” means Personal Data about a person’s race or ethnicity; political, religious, philosophical, ideological, or trade union memberships, opinions, views or activities; medical or health conditions; genetic or biometric data; financial account information (e.g. bank account number); government-issued ID numbers; sexuality; or social security measures or administrative or criminal proceedings and sanctions that are treated outside pending proceedings. Sensitive Data also includes information we receive from a third party who treats and notes the information as sensitive.

3. “Agent” means a third party that collects or uses Personal Data to perform tasks on our behalf or provide information to us, or our underwriters and reinsurers.

4. “We/Us/Our” means one or more of AWP USA Inc., Jefferson Insurance Company and AGA Service Company.

Privacy Practices

This Notice describes how we collect, use, and maintain Personal Data. It also describes your and our rights.

1. Notice of Collection and Uses/Disclosures

A. Collection of Personal Data

We collect Personal Data from you, or from your agents, representatives, suppliers and providers, cookies, analytics tools, and other tracking technologies, social networks, advertising networks, or other parties from whom you have authorized us to collect it on your behalf. This Personal Data may include:
(i) Identifiers and other identifying personal information (e.g. name, contact information like address, email address, phone number, or other unique personal identifiers, signature, date of birth, insurance policy numbers, education, employment information and history);
(ii) billing or payment information (e.g. bank account or payment card number and billing information);
(iii) information about your trip, event, or enrollment (e.g. agents, suppliers, trip itinerary and plans; tuition and enrollment information);
(iv) information about your transactions or business with us or others (e.g. personal information you provide us for us to generate quotes or to purchase products, quote/purchase history, receipts, insurance EOBs);
(v) financial account information (e.g. account numbers, statements);
(vi) health information (e.g. health insurance information, disability information, medical treatment history, invoices);
(vii) information about or related to any claim you make or other use of our products (e.g. details of your loss, police reports, health/vital records, professional or employment-related information) records of interactions, communications and correspondence between you and us, including audio and electronic information);
(viii) information about your websites and/or mobile application (e.g. browser data, IP address, information about your interaction with a website, application, or advertisement);
(ix) geolocation data (e.g. for location-based website or mobile app customization or services);
(x) biometric information (e.g. fingerprinting required for insurance licenses);
(xi) protected class information (e.g. age, which may be used for purposes of quoting, or disability which may be used in administration of your claim);
(xii) government-issued identification numbers (e.g. social security number, driver’s license number, passport number);
(xiii) job application, education, or employment-related information; or
(xiv) any other information provided to us by you or on your behalf.

We may also collect Personal Data from consumer reporting agencies or fraud databases (e.g. fraud reports). This data may be collected from forms, such as enrollment or claim forms; by phone, website, email, fax, or correspondence; or via cookies or similar technology.

B. Use and Disclosure of Personal Data

We may use the Personal Data we collect from any of the above categories:
(i) to offer, market, sell, underwrite, or make available to you insurance or assistance products or services;
(ii) to provide you with information or services for such products and services;
(iii) to service and administer your insurance, assistance, or other products and services. This may include, for example: providing travel assistance or concierge services, servicing and processing your policy or claims, conducting quality or satisfaction surveys and assessments, keeping electronic or audio records of our interactions and correspondence with you and documents sent and received; and fraud prevention;
(iv) to arrange for the provision of products and services you request, which may include products and/or services provided by a third party;
(v) to review and process job applications and for other employment-related purposes;
(vi) to protect or enforce our legal rights or to respond to lawful requests by public authorities, including to meet national security or law enforcement requirements or as otherwise required by law; or
(vii) for purposes to which you’ve otherwise consented or as you’ve directed, unless revoked.

Where permitted by law, we may disclose Personal Data we have obtained as described above with our affiliates, business partners, and service providers. This may include disclosing your Personal Data to Agents (such as our business partners or service providers). But, such disclosures are only for the purposes described in this Notice, or for everyday business purposes or as required or allowed by law (e.g. to process transactions, maintain accounts, respond to court orders and legal investigations, or report to credit bureaus). These Agents may be affiliated or nonaffiliated, and may be located both inside and outside of the US. They may be financial services providers (e.g. underwriting insurers). They may also be non-financial companies (e.g. health service providers, travel service providers, the agent/agency through whom you purchased, service providers helping us with marketing or technology).

If you are purchasing insurance on another’s behalf, we and the insurer may require the personal information of the insured to provide and administer the benefits of their plan. By providing the insured’s personal information at the time of purchase, you are confirming that you have obtained the insured’s consent to provide this personal information for this use.

We may also use or disclose Personal Data about you for one or more of the following purposes, to the extent permitted by law:
(i) for public health and safety issues;
(ii) to comply with legal or regulatory requirements;
(iii) to address or comply with workers’ compensation, law enforcement, or other legal, regulatory, or other government mandates, investigations, examinations, or requests;
(iv) to respond to lawsuits or legal or regulatory actions;
(v) for required institutional risk control or for resolving client or consumer complaints or inquiries;
(vi) if we sell or transfer all or a portion of our business assets (for example, further to a merger, acquisition, bankruptcy, reorganization, or other disposition of all or any of our business, or any other business transaction, including negotiations of such transactions);
(vii) to protect, enforce, or defend our or your legal rights, interests, property, or safety;
(viii) to enforce our policies;
(ix) with our consent or at your direction unless revoked; or
(x) other purposes permitted or required by, and in accordance with, applicable law.

Information Collected Automatically, Advertising, and Analytics

We, the vendors advertising networks, and partners we work with, and social networks we connect to, may use various tools and technologies like cookies, pixels, and other tracking technologies or tools to collect certain information automatically about you when you visit our website. This information may include IP addresses, website navigation and Internet usage/network activity data and device/browser-generated data, including regarding your browsing history and your interaction with our and other websites, applications, and advertisements.

Cookies are text files on your computer. When you access our website or use our mobile application, we use cookies and other tracking technologies to collect data about your web usage. We may use third-party technologies, tools, or services such as Meta, Google, Inc.’s Google Analytics and AdWords services, and other similar third-party vendor services.

We use the following Google Analytics Advertising Features:
(i) “Remarketing with Google Analytics” to serve advertisements to you across the Internet based on your visits to our site(s) by leveraging Google Analytics cookies.
(ii) “Demographics and Interest Reporting” to collect information about our site traffic by tracking users across websites and across time via third-party cookies, which generates a report for us to better understand our site users.
(iii) “Display Network Impression Reporting” to gather insights into how our ads are served and viewed across the Google Display Network, including aggregated data on ad impressions and user interactions.
(vi) “Segments” to isolate and analyze subsets of site users by sorting our Google Analytics data.
(v) “Google Ads” to display targeted ads based on user interests and interactions with our website.
(vI) “Google Search Console” to monitor and analyze our website’s visibility and performance in Google search results.

We, along with third-party vendors such as Google, use first-party and third-party cookies to analyze and understand user interactions with our website and serve targeted advertisements based on your prior visits to our site or other websites. Third-party vendors, including Google, use cookies to serve ads based on users’ visits to our website. These cookies enable personalized advertising and may involve the collection of your demographic information, such as age and gender, and interest-based data.

We also may use third party chat and monitoring services on our website provided through Cognigy or other service providers. These services may use JavaScript to provide such services. Information you provide through chat services may be monitored and recorded and used for purposes of providing the services and assistance you request and for other uses related to your policy and claim, as well as for purposes of quality assurance, training, and improvement of products and services. By using the chat service, you agree to such monitoring, recording, and uses, and the processing of your data in accordance with this Privacy Policy.

These services may use technologies to collect and receive data from the website and elsewhere on the Internet and use that data to create a profile of you, measure your interests, detect your device, personalize your content, and provide advertising services to us. These vendors may provide this data to us or store and/or aggregate this data to analyze such usage and create reports for us. We, our affiliates and our Agents use such data and reports for our own business purposes (e.g. to provide customer service, to optimize the content you see from us, traffic and trend analysis, website and user experience improvement, other purposes stated in this Notice, etc.) and Payment Card Industry Data Security Standard (“PCI”) compliance. These vendors may also display our ads on sites across the Internet, and they may use this data to later display ads or other information to you based on your website usage or other information collected as described above. Data from these first- and third-party cookies may be combined or linked together to provide a more comprehensive understanding of user behavior on our sites and across other sites, platforms, and devices. Please note that we or other parties may collect Personal Data about your online activities over time and across different devices and online properties when you use our website. Our websites use functional cookies that are required for the website to operate (including ReCAPTCHA and others). These cookies cannot be disabled. However, you can refuse cookies by disabling them in your browser (this may affect functionality and content available to you).

By using our website with cookies enabled, you consent to this use of cookies and data for these purposes. You can manage your cookie preferences for each of our websites by clicking the “Do Not Sell or Share My Personal Information” link on that website domain – see “Your Privacy Choices / Opt Our Rights” below for more information.

For more information on how Google Analytics uses data it collects, visit policies.google.com/technologies/partner-sites. To opt out of Google Analytics, visit tools.google.com/dlpage/gaoptout or disable cookies in your browser. To adjust your Google advertising settings, visit: myadcenter.google.com.

You may be able to opt out of certain interest-based advertising using the settings on your browser. To find out more about how these online analytics services manage the privacy of information in conjunction with delivering ads online, and how to opt out of information collection by these networks, please visit: youradchoices.com/appchoices, optout.aboutads.info, or thenai.org.

Other Uses

We may use your geolocation information for generating location-specific product advertisements and offers or to provide and administer the insurance and assistance services as described above. This information may also be used for location-based website or mobile website application services, such as access to local alerts and emergency services numbers and providers, location of healthcare providers or medical services, maps, translation services, and other similar services, or for purposes to which you otherwise consent or as described here.

We may use and disclose the name, email address, or contact information of current and former customers to Agents for marketing administration purposes. For example, we may need to disclose the email address you provided to us to an Agent providing marketing services on our behalf to help ensure that your opt out choices are respected and that you do not receive duplicate communications.

We may employ automation and technology powered by systems which may be considered artificial intelligence systems under certain laws to market, provide, and improve our services.

Upon notification and consent your Personal Data may be used for other reasons. That notice will state the purpose for collecting and using the data, the types of non-Agent third parties to which we disclose the data, and the means we offer you to limit this.

Your Privacy Choices / Opt Out Rights

The law in some jurisdictions allows you the right to choose in some cases to opt out of us sharing your Personal Data with a third party or using it for purposes described or that is materially different from the purposes for which it was originally collected or which you later authorize. You may exercise this right by notifying the Privacy Officer at the information provided below. You may opt out of getting non-essential marketing communications from us by giving notice as described below and either managing your cookie preferences on the website or disabling cookies in your web browser. Except as required or allowed by law (e.g. for fraud prevention), we do not share, sell or otherwise disclose your Personal Data to non-Agent third parties or use it for any purpose other than for which it was originally collected or as you later authorize. If we ever wish to do so, we will give you the opportunity to opt out. If we wish to disclose your Sensitive Data to a non-Agent third party or use such data for a purpose other than for which it was originally collected or as you later authorize, we will only do so with your express consent. We will not unfairly discriminate against you for declining to provide this consent.

To opt out of the sale or sharing of your personal information through tracking technologies such as cookies and pixels, please click the “Do Not Sell or Share My Personal Information” link in the footer of the website domain (e.g. allianztravelinsurance.com) you are using. Please note, we maintain websites on several different domains. If you wish to opt out as described here, you must follow this procedure for each separate website domain that you access/use. If you choose to use an opt-out preference signal such as the Global Privacy Control (GPC), you will be opted out of online, cookie-based sales and sharing of personal information associated with the browser for which you have enabled the signal. If you use multiple browsers or devices, you will need to activate the signal for each one that you use.

To opt out of all other non-essential marketing communications or non-essential unaffiliated third party information selling or sharing, please contact our Chief Privacy Officer as described in “Contact” below with your name, policy number. Please include a statement that says “Opt out” (or something similar). Opt outs will be applied to all products and services we provide. When you opt out or revoke consent, such opt out or revocation will not apply to any action already taken prior to the time of such opt out or revocation. We will not unfairly discriminate against any person who chooses to opt out, or exercise any of their rights as described in this Notice.

Information for Users Outside the U.S.

If you are visiting our website from outside of the United States, we may, directly or indirectly, process, store, and transfer the information you provide in or to the United States. By using our website, you acknowledge your Personal Data may be transferred to, and processed in, a jurisdiction outside of your own. Please be aware that the data protection laws and regulations that apply to your Personal Data transferred to the United States or other countries may differ from the laws in your country of residence. Our Binding Corporate Rules related to data transfers may be viewed here: https://www.allianz-partners.com/en_US/allianz-partners—binding-corporate-rules-.html

Security

We take reasonable and appropriate measures to protect your data from loss, misuse, or unauthorized access, disclosure, alteration and destruction. To help maintain the security of your data, we use administrative, physical, and technical safeguards. Nevertheless, transmission via the Internet and online digital storage are not completely secure.

Data Retention

We keep the categories of personal information described above for as long as is necessary for the purposes described in this Privacy Notice or as otherwise authorized or permitted by law. This generally means holding the information for as long as: (i) it is reasonably necessary to manage our operations, to manage your relationship with us, or to satisfy another purpose for which we collected the information; (ii) it is reasonably necessary to carry out a disclosed purpose that is reasonably compatible with the context in which the personal information was collected; (iii) it is reasonably required to protect or defend our rights or property; or (iv) 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 by sending an email to [email protected].

Access

If you discover data we hold about you is inaccurate or incomplete, please contact us. We will grant you reasonable access to the Personal Data we hold about you. We will take reasonable steps to allow you to correct, amend or delete your Personal Data that is inaccurate or incomplete, or has been processed in violation of this Notice, so long as it can be done without undue burden or expense on us, without breaching any legal or professional privilege or obligation, and without violating the rights of others.

Links

Our websites provide links (including social media plugins (“Plugins”)) that connect to third party websites. Clicking such link may establish a connection and transmits data to/from the operator of such website. Clicking a Plugin while logged in to a social media account may cause the social media website’s operator to publish activity to your account. To avoid this, log out of your account before clicking the Plugin link. We are not responsible for and make no representations about the content, security, or privacy practices of any other third-party websites. You should read the privacy notices of the websites you visit to understand their data privacy practices.

Changes to Notice

This Notice reflects our business practices. It is not a contract. However, we are required to and will abide by the terms of this Notice as currently in effect. We may amend this Notice at any time. We will notify you of any updates by posting a revised notice on our website. The revised notice will apply to all information collected by us, including previously collected information. You accept the revised notice by your continued use of our website, products or services following any such amendment. If we revise this Notice in a way that would allow us to disclose your Personal Data to a nonaffiliated third party other than as already described here, we will provide you with a revised notice and give you the opportunity to opt out of any such disclosure. You are responsible to regularly review this Notice. You have the right to a paper copy of this Notice upon request.

Contact

If you have any questions, comments, or complaints about this Notice or the way that we collect or handle your Personal Data, or if you would like a paper copy of this Notice, please contact our Chief Privacy Officer by any of:

Email: [email protected]
Phone: 1-800-284-8300
Mail: Allianz Global Assistance
ATTN: Chief Privacy Officer
9950 Mayland Drive
Richmond, VA 23233

Electronic Notices

Unless you chose to receive them by US mail at the time of purchase, by purchasing your policy, you consent to receive all notices and documents from us electronically. They will be sent to the email address provided at the time of purchase. You may opt to receive notices and documents from us by mail at any time. If you wish to change or update your notice/documents preferences, email us at [email protected]. Please include your name, policy number, and a note that says “Only contact me by mail” (or something similar). You can also let us know by phone at 800-284-8300 or by mail to:

Allianz Global Assistance
ATTN: Customer Service – Only contact me by mail
9950 Mayland Drive
Richmond, VA 23233

If you don’t provide an email address at purchase, you’ll receive notices and documents by mail. You may request paper copies of any electronic information we send, or update your electronic contact information at any time by emailing or mailing us at the above address, or by calling us. Documents sent to you from us will be in either PDF or HTML format. If you can’t receive or read the documents we send you, please contact us so we can assist you.

California Residents

As a supplement to the other information provided throughout this Notice, we provide the following additional information as a notice to residents of California who interact with us as consumers as well as California job applicants, vendors, and business contacts, in accordance with the California Consumer Privacy Act (“CCPA”). Terms defined in the CCPA that are used in this Section shall have the same meaning as in the CCPA. Unless otherwise noted, the disclosures below also describe how we collected and used your personal information within the past twelve (12) months.

Please note, the information provided below only applies to the extent that personal information processed is subject to the CCPA.

We collect data elements within the following categories of personal information from consumers from the sources and for the purposes as described in this Notice: identifiers, personal information, characteristics of protected classifications, commercial information, biometric information, internet or other electronic network activity information, geolocation data, audio/electronic/visual information, and professional or employment-related information, inferences drawn from the foregoing, and sensitive personal information. We use these categories of data for purposes as described in Section 1 of this Notice.

For examples of the specific types of personal information we may collect about California consumers, please see the “Collection of Personal Data” section above. For additional information about the business and commercial purposes for the collection of personal information, please see the “Use and Disclosure of Personal Data” section above.

We may collect personal information directly from you when you provide us information in person, online, or through electronic forms; through our customer service number; automatically through our website via cookies, analytics tools, and other tracking technologies; advertising networks, and social networks; and from our service providers, vendors and suppliers, our affiliates, business partners, or other individuals and businesses.

Some of the ways in which we share or use personal information for advertising may be considered “sales” or “sharing” for targeted or cross-context behavioral advertising under the CCPA. We have “sold” and/or “shared” data elements within the following categories of personal information: identifiers, personal records, commercial information, internet or other electronic network activity information; and geolocation data. This personal information was “sold” or “shared” to companies providing: marketing, analytics, or advertising services; other online third-party branded tools or functionality (such as maps or video players); and social networks, for the purpose of providing analytics and advertising assistance and services for us and other functionality and services through our digital properties We do not have actual knowledge that we “sell” or “share” the personal information of anyone under 16 years of age. For these purposes, “sold” or “sale” does not include the transfer of Personal Data as an asset that is part of a merger, acquisition, bankruptcy, or other disposition of all or any portion of our business.

Additionally, we have disclosed data elements within the following categories of personal information for a business purpose: identifiers, personal records, characteristics of protected classifications, commercial information, biometric information, Internet or other electronic network activity information, geolocation data, audio/electronic/visual information, professional or employment-related information, inferences drawn from the foregoing, and sensitive information. We disclosed each category to our affiliated companies, business partners, underwriters, reinsurers, agents, service providers, government entities, and other third parties as described in the “Use and Disclosure of Personal Data” section above for the purposes as described in this Notice.

Your California Privacy Rights

You may in some cases have certain rights under California law. However, these rights are not available in all cases, and they are subject to applicable exceptions, exemptions, and limitations as provided by law (including without limitation with respect to personal information collected pursuant to the Gramm-Leach-Bliley Act). You can submit a request to exercise these rights by emailing us at [email protected] or calling us at 1-800-284-8300. These rights may include the following, subject to certain exceptions: (1) Right to Know – you have the right to request that we disclose to you the categories of personal information we have collected about you, as well as the sources of such personal information, the purpose, and the categories of third parties with whom such personal information is shared; (2) Right to Correct – you have the right to request we correct personal information we maintain about you that you believe is inaccurate; (3) Right to Delete – you have the right to request that we delete personal information we have collected about you; (4) Right to Limit Use of Sensitive Personal – you have the right to limit the use of your “sensitive personal information” to only limited purposes, such as providing you with the services you request; (5) Right to Opt Out of Sales and Sharing – you have the right to opt out of the “selling” and/or “sharing” of your personal information with “third parties” (see “Your Privacy Choices / Opt Out Rights” section above for how to opt out); (6) Non-discrimination rights – you have the right that we will not discriminate against you for exercising any of these rights, including without limitation by denying goods or services to you; charging a different price or rates for goods or services, including through the use of discounts or other benefits or imposing penalties; providing a different level or quality of goods or services to you; or suggesting that you will receive a different price or rate for, or a different level of quality of, goods or services.

Please note that, if you submit privacy rights requests, we may ask you for specific information to help us confirm your identity prior to processing your request. Please follow any instructions provided and promptly respond to any follow-up inquiries so that we may confirm your identity and respond to your request. If you ask that we give you specific pieces of personal information or that we delete or correct certain types of personal information, we may apply heightened verification standards, which require additional proof of your identity.

Upon verification of your request, we will respond to your request. If we decline to fulfill your privacy rights request, we will tell you why, unless we are not legally permitted to do so. Only you, or someone you authorize to act for you, may make a request related to your personal information. If you designate an authorized agent to make a request for you, you may still need to verify your identity directly with us before your request can be processed.

Effective Date

This Notice was last revised on, and is effective as of, April 7, 2025.