Introduction

Garden Winds values your privacy and is committed to protecting your personal information. This Privacy Policy outlines how we collect, use, and safeguard your data when you interact with our services, including visiting our website at https://gardenwindscanada.com/.

Information We Collect

We may collect the following types of information:

• Personal Information: Name, address, email address, phone number, payment information, and other identifiers.

• Usage Data: Information about how you interact with our website, products, and services.

• Cookies and Tracking Technologies: Data collected through cookies, web beacons, and similar technologies.

How We Use Your Information

Garden Winds uses your information to:

• Provide and improve our products and services.

• Process transactions and send related information.

• Communicate with you about promotions, updates, and other news.

• Analyze usage and trends to enhance user experience.

• Comply with legal obligations and protect our rights.

Sharing Your Information

We may share your information with:

• Service Providers: Third-party vendors who assist in providing our services.

• Legal Obligations: Authorities when required by law or to protect our rights.

• Business Transfers: In connection with mergers, acquisitions, or asset sales.

Your Choices and Rights

You have the right to:

• Access and update your personal information.

• Opt-out of marketing communications.

• Request deletion of your data, subject to legal constraints.

• Disable cookies through your browser settings or Cookie Preference Manager.

Controlling Cookies

You may choose to allow or disable cookies which are not required for our sites via the Cookie Preference Manager, which may be accessed through the banner when first visiting our websites. To set or modify your preferences on subsequent visits or at any time, the Cookie Preference Manager may be accessed via the "Your Privacy Choices" icon in the footer of our websites. To effectively manage cookies via this tool, you must set cookie preferences on all web browsers that you use. If you clear the cookies on your web browser(s) or device(s), you may need to set your cookie preferences again. 

You can also opt out of the collection of your personal information via cookies by enabling a Global Privacy Control ("GPC") signal, which may be accessed by installing a supported web browser or browser extension. Please refer to the help section of your browser or visit the official Global Privacy Control website for more information.

Google's Services

Our websites may use Google Analytics and Google Tag Manager, which are web analytics services provided by Google LLC. These services use cookies to analyze your use of our websites or apps. The information collected by these cookies about your use of our websites or apps is transmitted to and stored on Google servers. Google uses this information to assess your use of our websites or apps and provides reports on data. This data may include how often you visit our websites or apps, what pages you view when you visit the websites or apps, and what other websites you have visited prior to visiting our websites or apps. Google may transfer this information to third parties, if required by law or if third parties process the information on behalf of Google.

You may review Google's data privacy practices for Google Analytics and data privacy practices for Google Tag Manager. You may also review Google's Privacy Policy and Terms of Service for more information. To opt out of being tracked by Google Analytics, you may download and install the Google Analytics Opt-out Browser Add-on. You may also set your preferences in the Cookie Preference Manager on our websites as outlined above in Section 5 of this Policy.

We may use Google reCAPTCHA on our websites or apps, which checks whether our websites or apps are being used by humans or bots. reCAPTCHA analyzes website visitor behavior based on various characteristics, including mouse movements, visit duration, IP address, and other information.

Online Interest-Based Advertising

We work with advertising companies to show you online advertising for our products or services based on your interests. These ads may be based on your interests or activities on our websites or other websites. Garden Winds may use online technologies, such as third-party cookies, beacons, tags, or scripts, to collect information about you. We share this information with our service providers to manage our online advertising. This allows us to render relevant Garden Winds ads to you. This is referred to as online interest- based advertising.

Our third-party partners may also use online technologies for website or app analysis and to manage the effectiveness of our ads placed on other websites or apps. You should also review the privacy practices of those third parties.

Control Online Interest-Based Advertising

You may read more about online interest-based advertising by visiting this Federal Trade Commission website. You can opt out of online interest-based advertising using the Cookie Preference Manager found in the banner on Garden Winds' websites. This Cookie Preference Manager may be accessed anytime to update your selections via the "Do Not Sell or Share My Personal Information" link on our sites. When using our mobile applications, you may set or alter your preferences at any time in the Preferences - Privacy section of your Profile within the mobile application. You can also opt out of online interest-based advertising on your mobile device by using "Limit Ad Tracking," "Opt out of Ads Personalization," or similar feature. Please note that you may continue to see generic or non-targeted ads from these companies after you opt-out. Garden Winds websites or apps do not respond to "Do Not Track" requests.

Links to Other Websites

We may have links to other companies or organizations on our websites or apps. We may also include social media widgets, such as "Share This" buttons and links to third-party websites, like Facebook and Twitter. These companies and features may collect your information and use cookies or similar technologies to enable these features to function properly. We are not responsible for how these third parties collect, use, disclose, secure, or otherwise process the information that you provide to them. Please read their privacy policies so you can learn how their websites or apps use your information.

Recording Activity on Our Website

We may record or capture your activity on our websites, including where you click and items that you view. We may use these recordings or captured information for security, fraud prevention, marketing and analytics purposes.

Security of Your Information

We implement reasonable security measures to protect your data. However, no method of transmission over the internet is entirely secure, and we cannot guarantee absolute security.

Use of Personal Information 

We generally use your information to provide you with our products or services, to develop or improve our products or services, to communicate with you, to provide you with customer service, to market or advertise our products or services to you, for legal or compliance purposes, or as required or permitted by applicable law. We may use your personal information to comply with our legal obligations, resolve disputes, enforce our agreements or our rights or the rights of third parties, or to comply with government or law enforcement investigations, litigation, discovery, regulatory requirements, corporate investigations, dispute resolution, or others. Please note that additional uses of your personal information may be provided to you at the point of collection, such as by using screen prompts or additional notices.

Retaining Your Personal Information

We generally retain our records that contain your personal information for the time period necessary to fulfill the purpose for which it was collected, in accordance with our records retention schedule. We retain your personal information while your account is active or as needed to provide you services, such as quoting, re-quoting and account management. We also retain your personal information as required or permitted by law, to comply with our legal obligations, resolve disputes, and enforce our agreements.

Securing Your Personal Information

We use reasonable physical and technical safeguards to protect your personal information, both during transmission and storage. When you enter sensitive information on our forms, we encrypt the transmission of that information. No method of transmission over the internet, including by email, or method of electronic storage is 100% secure. So, we cannot guarantee its absolute security.

We limit access to your personal information to those who need it to do their jobs. We maintain physical, electronic, and procedural safeguards that comply with applicable laws to guard your personal information. We require our service providers to use your personal information only for the purposes we outline in our privacy policies and notices.

Children's Privacy

Our services are not directed to individuals under 13. We do not knowingly collect personal information from children under 13.

Dispute Resolution

If you have an unresolved privacy or data use concern that we have not addressed satisfactorily, please contact our U.S.-based third party dispute resolution provider (free of charge) at https://feedback-form.truste.com/watchdog/request.

Changes to This Privacy Policy

We may update this Privacy Policy periodically. Changes will be posted on our website with the updated effective date.

Contact Us

If you have questions or concerns about this Privacy Policy, please contact us at:

Garden Winds
4950 East Second St
Benicia, CA 94510
Phone: (877) 479-4637
Email: customerservice@gardenwinds.com

State Specific Supplemental Privacy Policies

These state specific Supplemental Privacy Policies supplement our Consumer Privacy Policy above and apply to residents of the applicable state. Depending on your relationship with us, one or more of these privacy documents may apply to you.

For California Consumers Only

Supplemental California Consumer Privacy Act Privacy Policy

Last updated: March 2024

This California Consumer Privacy Act Privacy Policy describes how Garden Winds and its affiliates ("we", "us", "our", or "ours") collect, use, and disclose the personal information of California Consumers ("you", "your", or "yours") and the rights prescribed to them in the California Consumer Privacy Act, as amended by the California Privacy Rights Act, and its implementing regulations (collectively, "CCPA"). If you are a California resident, you may have rights under the CCPA. Please review those rights, and methods for exercising them, below.

This policy also serves as a Notice at Collection under the CCPA.

Collection of Personal Information

Over the last 12 months Garden Winds may have collected the following categories of personal information, including sensitive personal information, about you:

1. Identifiers such as name, address, Social Security number, and driver's license number.

2. Protected classifications such as medical conditions, military or veteran status, and race or ethnic origin.

3. Commercial information such as products or services purchased, consumer report information, and information from transactions.

4. Internet, browsing, or other network information such as internet protocol (IP) address, session ID, click or touch stream data, movement activity, scroll activity, and in some cases, keystroke activity.

5. Telematics data (excluding geolocation data) are collected in connection with our telematics discount or usage-based pay-per-mile insurance programs.

6. Sensory data such as audio recordings of your calls to our call centers.

7. Inferences drawn from any of the information identified in this section, such as profiles reflecting preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.

8. Geolocation such as precise physical location (e.g., through use of our websites or mobile apps).

Sources of Personal Information

Over the last 12 months, Garden Winds may have collected your personal information, including sensitive personal information, from the following categories of sources:

1. We may collect identifiers from you directly, your agent, publicly available databases, data aggregators, advertising networks, internet service providers, data analytics providers, government entities, operating systems and platforms, social networks, and data brokers and other third parties from whom we have purchased data.

2. We may collect protected classification information from you directly, medical providers, or our vendors.

3. We may collect commercial information from you directly or from your use of our websites or mobile apps, from your agent, from credit reporting companies, and from consumer reporting companies.

4. We may collect internet, browsing, or other network activity from your use of our websites, mobile apps, or telematics devices.

5. We collect telematics data (excluding geolocation data) from your use of telematics devices.

6. We may collect sensory data, such as such as audio recordings of your calls to our call centers.

7. We may collect professional or employment information from job applications, resumes, or recruiters.

8. We may collect financial account information from you directly.

9. We may collect geolocation from you directly or from your use of our websites 

Purposes of Collection of Personal Information

Over the last 12 months, Garden Winds may have collected and used  your personal information, including sensitive personal information, for our business or commercial purposes.

For all categories of personal information, including sensitive personal information, listed in this policy, our business or commercial purposes include:

1. Auditing;

2. Ensuring the security and integrity of information (such as detecting security incidents and protecting against and prosecuting malicious, deceptive, or illegal activity like fraud);

3. Debugging;

4. Short-term, transient use of personal information;

5. Performing services on behalf of Garden Winds, another business, or a service provider (such as maintaining or servicing accounts or providing customer service);

6. Undertaking internal research; and

7. Verifying or maintaining the quality or safety of a service or device or improving a service or device.

We also use all categories of personal information, including sensitive personal information, listed in this policy to comply with our legal obligations, including to comply with law enforcement or government authority requests, participate in judicial proceedings, and investigate fraudulent activity, resolve disputes, enforce our agreements, provide you with our products or services you have purchased, for everyday servicing purposes, and as otherwise described to you at the point of collection.

For specific categories of personal information, including sensitive personal information, our business or commercial purposes include:

1. Identifiers are used to respond to questions, requests, social media messages, and emails, provide customer service, market, and provide products and services to you, set up, manage and service accounts, conduct website or other surveys, verify your identity, and update our records.

2. Protected classifications (medical conditions or military or veteran status) are used to provide products and services to you, and protected classifications (race or ethnic origin) are used to conduct market research or product research to assist in our ability to serve diverse communities.

3. Internet, browsing, or other network activity is used to conduct website and mobile app analysis, conduct research and analytics, develop and improve our websites and mobile apps, market and provide products or services to you, manage our online advertising and its effectiveness, remember your preferences and interactions, respond to questions and emails, manage and service accounts, conduct website and other surveys, and fraud prevention.

4. Sensory data, such as audio recordings of your calls to our call centers, are used to improve customer service, or for authentication or fraud investigation purposes.

5. Inferences are used to market our products or services to you, improve our products and services, and help predict your future claims.

6. Financial account information is used to provide products and services to you, set up, manage, and service accounts, and update our records.

7. Geolocation data are used to conduct website and mobile app analysis, develop, and improve our websites and mobile apps, secure our websites and mobile apps, and provide products or services to you.

Disclosure of Personal Information

Over the last 12 months, Garden Winds may have disclosed your personal information to the following categories of third parties for the business or commercial purposes listed above and for the following reasons:

1. Identifiers may be disclosed to vendors that provide us with customer service, account setup, account management and servicing, and data verification services.

2. Protected classifications may be disclosed to vendors that assist us in providing products and services to you.

3. Internet, browsing, or other network information may be disclosed to vendors, advertising networks, internet service providers, data analytic providers, or social networks that help us with conducting website and mobile app analysis, conducting research and analytics, developing our websites and mobile apps, collecting information about our website and mobile app usage and email responses, marketing and providing products or services to you, managing our online advertising and its effectiveness, responding to questions and emails, managing and servicing policies and accounts, and helping to offer our telematics or usage- based insurance programs to you.

4. Sensory data, such as audio recordings of your calls to our call centers, may be disclosed to vendors that provide us with services to improve customer service or for authentication or fraud investigation purposes.

5. Professional or employment information may be disclosed to vendors that assist us with processing job applications or providing offers or denials of employment.

6. Education information may be disclosed to vendors that provide us with human resources, job application, or recruitment services.

7. Inferences may be disclosed to vendors that provide us with services to market our products or services to you.

8. Geolocation data may be disclosed to vendors, advertising networks, internet service providers, data analytic providers, or social networks that help us with conducting website and mobile app analysis, developing our websites, mobile apps, and marketing our products or services to you.

9. Garden Winds does not knowingly "sell" or "share" (as these terms are defined by the CCPA) the personal information of consumers under 16 years of age.

Your California Privacy Rights

The CCPA grants you the privacy rights described in this section, subject to certain limitations and exceptions. Your CCPA rights do not apply to personal information protected by other laws, such as the Fair Credit Reporting Act ("FCRA"), the Gramm Leach Bliley Act ("GLBA"), the Health Insurance Portability and Accountability Act ("HIPAA"), and the Health Information Technology for Economic and Clinical Health Act ("HITECH Act").

• Right to Notice. The right to know how we collect, use, disclose, sell, or share your personal information. This policy is intended to satisfy that right.

• Right to Access. The right to know and access what personal information we have collected about you, including the categories of personal information, the categories of sources from which your personal information is collected, the business or commercial purpose for collecting, selling, or sharing your personal information, the categories of third parties to whom we disclose your personal information, and the specific pieces of personal information that we have collected about you.

• Right to Delete. The right to delete personal information that we have collected from you, subject to certain exceptions.

• Right to Correct. The right to correct inaccurate personal information that we maintain about you.

• Right to Opt Out. The right to opt-out of the sale or sharing of your personal information by us if we sell or share personal information.

• Right to Limit. The right to limit the use or disclosure of your personal information by us to purposes permitted by the CCPA, if we use or disclose sensitive personal information.

• Right to Non-Discrimination. The right not to be discriminated against for exercising any of the privacy rights in this section. We do not use the fact that you have exercised or requested to exercise any CCPA right for any purpose other than facilitating a response to your request.

Exercising Your California Privacy Rights

You or your authorized agent may submit a California privacy rights request using one of the designated methods outlined below. When submitting your request, you must provide us with certain information so that we may locate your personal information in our systems and distinguish it from the personal information of others-for example, individuals who may have similar names or addresses to you. You may need to provide us with your name, email address, address, phone number, driver's license number, Social Security number, or account information, depending on the information you would like to access.

Once we receive your request, we will acknowledge receipt within 10 business days and provide additional information about our verification process and the processing of your request. We will try to process your request within 45 days of receiving it. If we need more time (up to an additional 45 days), we will notify you of our need for additional time and explain the reason why we need more time prior to the end of the initial 45-day period.

We do not generally charge a fee to fulfill any of your requests under CCPA; however, we may charge a reasonable fee or refuse to act on requests that are manifestly unfounded or excessive, including repetitive requests. If we refuse to act on a request, we will notify you of the reason.

You may submit a privacy rights request by calling (877) 479-4637 (7:00 a.m. - 4 p.m. PST, weekdays).

Identity Verification Requirements

Before we fulfill any requests submitted by you, we are required to verify that you are the person that is the subject of the request. Our verification process consists of you answering a series of questions correctly to verify your identity. If you experience technical errors with or are unwilling to verify your identity through our verification process, please contact us at (877) 479-4637 (7:00 a.m. - 4 p.m. PST, weekdays) or customerservice@gardenwinds.com, and we will send to you a notary form that you must sign, notarize, and return to us by mail to the following address:

Garden Winds
4950 East Second Street
Benicia, CA 94510

Garden Winds will reimburse you for any reasonable notarization fees. Failure to verify your identity may result in the rejection of your request.

Authorized Agent Requirements

You may authorize an agent to submit a privacy request on your behalf. Please note, requests submitted by authorized agent also require verification of your identity before processing. Your authorized agent will need to complete the identity verification process explained in the preceding section. Garden Winds may reject a request from an agent that fails to complete the identity verification process. Your authorized agent, on your behalf, may submit a request to access by calling (877) 479-4637 (7:00 a.m. - 4 p.m. PST, weekdays) or email customerservice@gardenwinds.com.

Third-Party Vendors & Business Partners

This paragraph contains instructions for all third-party vendors providing services to and third-party business partners of Garden Winds. This paragraph does not apply to individual consumers.

If a California consumer submits a CCPA rights request directly to one of Garden Winds' third-party vendors or business partners, the vendor or partner must instruct the consumer to visit this policy and submit the request through one of the approved methods listed below (webform, email, or toll-free telephone number).

Right to Access

For your security, your request, and our responses to it, will be available for you to access for 30 days, after which they will be deleted. If you would like to access your personal information again, please submit another request.

Please note that the CCPA does not require us to search for personal information if we:

• Do not maintain the personal information in a searchable or reasonably accessible format;

• Maintain the personal information solely for legal or compliance purposes; and

• Do not sell the personal information and do not use it for any commercial purpose.

Right to Delete

Please note that the CCPA does not require us to delete your personal information if it is necessary for Garden Winds to:

1. Complete the transaction for which the personal information was collected, provide a good or service requested by you, conduct activities reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform a contract between Garden Winds and you;

2. Ensure the security and integrity of information (such as detecting security incidents and protecting against and prosecuting malicious, deceptive, or illegal activity like fraud);

3. Debug to identify and repair errors that impair existing intended functionality;

4. Exercise free speech, ensure the right of another consumer to exercise his or her right of free speech, or exercise another right provided for by law;

5. Comply with the California Electronic Communications Privacy Act;

6. Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the businesses' deletion of the information is likely to render impossible or seriously impair the achievement of such research, if you have provided informed consent;

7. Enable solely internal uses that are reasonably aligned with a consumer's expectations based on their relationship with Garden Winds; or

8. Comply with a legal obligation.

Additionally, we may retain your personal information in our backup or archive systems until the retention period of those systems expire, as permitted by the CCPA.

Right to Correct

In order to effectively evaluate your request, we require that you provide us with documentation supporting your request by uploading it to our secure online portal or via postal mail to the following address:

Garden Winds
4950 East Second Street
Benicia, CA 94510

If you provide supporting documentation via postal mail, please do not send us the original; we request that you only send a copy.

We will only use documentation provided by you for the purpose of responding to your request.

Right to Opt-Out of Sale/Sharing

Garden Winds does not sell or share your personal information in exchange for monetary consideration. However, we may allow certain third parties, such as advertising networks, social networks, and data analytics providers, to use cookies and related tracking technologies, such as web beacons, pixel tags, and flash objects (collectively, "Cookie(s)"), to collect information about your visits to our websites or mobile apps and use that information to deliver advertisements relevant to your interests. Information collected about you on our websites or mobile apps by third parties could be combined with other information that you have provided to them or that they have collected from your use of their services. Under the CCPA, these disclosures may constitute a "sale" when the personal information is exchanged for non-monetary consideration (anything of value) or sharing when the personal information is disclosed for cross context behavioral advertising purposes.

Over the last 12 months, the categories of personal information Garden Winds may have shared or sold, as these terms are defined under the CCPA, include: identifiers; internet, browsing, or other network information; inferences; and geolocation.

To opt out of the collection of your personal information using Cookies for advertising or analytics purposes, you can modify your Cookie settings using the Cookie Preference Center, which may be accessed through the banner when first visiting our websites or at any time via the "Privacy Settings" link in the footer of our websites. To effectively manage Cookies via this tool, you must set Cookie preferences on all web browsers that you use. If you clear the Cookies on your web browser(s) or device(s), you may need to set your Cookie preferences again. When using our mobile applications, you may set or alter your preferences at any time in the Preferences section of the Settings within the mobile application. 

You can also opt out of the collection of your personal information via Cookies by enabling a Global Privacy Control ("GPC") signal, which may be accessed by installing a supported web browser or browser extension. Please refer to the help section of your browser or visit the official Global Privacy Control website for more information.

Right to Limit Use/Disclosure

Garden Winds does not use or disclose your sensitive personal information for purposes other than as permitted by the CCPA, so there is no need for you to request to limit the use or disclosure of your sensitive personal information.

Retention of Information

We may retain your personal information for the period necessary to fulfill the purposes described in our privacy policies or any notice provided at the time of collection, 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 agreements with us or claims relating to your products or services. We will delete your information once the legal obligation expires or after the period of time specified in our records retention policies.

Additionally, we may retain the information relating to your CCPA request in accordance with our legal obligations and records retention policies. We may retain the information about your request to track and fulfill your request. Please note that we will maintain a record of your request and all correspondence for at least 24 months. We collect, store, or process your information in compliance with our privacy policies.

Revisions

Garden Winds may revise this policy from time to time as permitted by law. Garden Winds will provide you the revised policy on this website, on a website that replaces this website, in person, via email, or using other methods. Changes are effective on the date they are posted.

Contact Us

You may contact us at customerservice@gardenwinds.com if you have any questions or concerns about this policy or your privacy rights under the CCPA.

For Oregon Consumers Only

Supplemental Oregon Consumer Privacy Act Privacy Policy

This Oregon Consumer Privacy Act Privacy Policy describes how Garden Winds and its affiliates ("we", "us", "our", or "ours") collect, use, and disclose the personal data of Oregon Consumers ("you", "your", or "yours") and the rights prescribed to them in the Oregon Consumer Privacy Act. If you are an Oregon resident, you may have rights under the OCPA. Please review those rights, and methods for exercising them, below.

Processing of Personal Data

Garden Winds may process the following categories of personal data, including sensitive personal data, about you: 

1. Identifiers such as name, address, Social Security number, and driver's license number. 

2. Protected classifications such as medical conditions, military or veteran status, and race or ethnic origin. 

3. Commercial information such as products or services purchased, consumer report information, and information from transactions. 

4. Internet, browsing, or other network information such as internet protocol (IP) address, session ID, click or touch stream data, movement activity, scroll activity, and in some cases, keystroke activity. 

5. Audio, electronic, photo, visual, or similar Information, such as photos or video recordings. 

6. Sensory data such as audio recordings of your calls to our call centers. 

7. Professional or employment-related information such as professional licenses or designations, and employment history (e.g., in connection with an application for employment with Garden Winds). 

8. Education information such as transcripts (e.g., in connection with an application for employment with Garden Winds). 

9. Inferences drawn from any of the information identified in this section, such as profiles reflecting preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes. 

10. Financial account information such as account log-in information, financial account number, and debit card or credit card number. 

11. Geolocation such as precise physical location (e.g., through use of our websites or mobile apps). 

Purposes for Processing Personal Data

Garden Winds may process your personal data, including sensitive personal data for the following purposes:

1. Identifiers are used to respond to questions, requests, social media messages, and emails, track insurance applications, provide customer service, market, and provide products and services to you, set up, manage and service accounts, conduct website or other surveys, verify your identity, and update our records.

2. Protected classifications (medical conditions or military or veteran status) are used to provide products and services to you, and protected classifications (race or ethnic origin) are used to conduct market research or product research to assist in our ability to serve diverse communities.

3. Internet, browsing, or other network activity is used to conduct website and mobile app analysis, conduct research and analytics, develop and improve our websites and mobile apps, market and provide products or services to you, manage our online advertising and its effectiveness, remember your preferences and interactions, respond to questions and emails, manage and service and accounts, conduct website and other surveys, fraud prevention, and offer our telematics or usage-based insurance programs to you.

4. Telematics data (excluding geolocation data) are used to offer our telematics discount or usage based pay-per-mile insurance programs, and the telematics data collected in connection with these programs are only used for determining actual miles driven.

5. Sensory data, such as audio recordings of your calls to our call centers, are used to improve customer service, or for authentication or fraud investigation purposes.

6. Professional or employment information is used to process job applications and to provide offers or denials of employment.

7. Education information is used to process and evaluate your job application and related materials.

8. Inferences are used to market our products or services to you, improve our products and services, and help predict your future claims.

9. Financial account information is used to provide products and services to you, set up, manage, and service accounts, and update our records. 

10. Geolocation data are used to conduct website and mobile app analysis, develop, and improve our websites and mobile apps, secure our websites and mobile apps, and provide products or services to you. 

11. We also use all categories of personal data, including sensitive personal data, listed in this policy to comply with our legal obligations, including to comply with law enforcement or government authority requests, participate in judicial proceedings, and investigate fraudulent activity, resolve disputes, enforce our agreements, provide you with our products or services you have purchased, for everyday servicing purposes, and as otherwise described to you at the point of collection.

Your Privacy Rights

Exercising Your Privacy Rights
OCPA provides individuals with certain rights relating to their personal data. To exercise any of these rights, you or your authorized agent may submit a privacy rights request using one of the designated methods outlined in this section. When submitting your request, you must provide us with certain information so that we may locate your personal data in our systems and distinguish it from the personal data of others-for example, individuals who may have similar names or addresses to you. You may need to provide us with your name, email address, address, phone number, driver's license number, Social Security number, or account information, depending on the information you would like to access. Once we receive your request, we will provide additional information about our verification process and the processing of your request. You may submit a privacy rights request by calling (877) 479-4637 (7:00 a.m. - 4 p.m. PST, weekdays) or email customerservice@gardenwinds.com.

We do not generally charge a fee to fulfill your privacy requests; however, we may charge a reasonable fee or deny requests that are manifestly unfounded or excessive, including repetitive requests. If we deny your request, we will notify you of the reason and you may appeal the denial by emailing us at customerservice@gardenwinds.com.

Identity Verification Requirements
Before we fulfill any requests submitted by you, we are required to verify that you are the person that is the subject of the request. Our verification process consists of you answering a series of questions correctly to verify your identity. If you experience technical errors with or are unwilling to verify your identity through our verification process, please contact us at (877) 479-4637 (7:00 a.m. - 4 p.m. PST, weekdays) or customerservice@gardenwinds.com, and we will send to you a notary form that you must sign, notarize, and return to us by mail to the following address:

Garden Winds
4950 East Second Street
Benicia, CA 94510

Garden Winds will reimburse you for any reasonable notarization fees. Failure to verify your identity may result in the rejection of your request.

Authorized Agent Requests
You may authorize an agent to submit a privacy request on your behalf. Please note, requests submitted by authorized agent also require verification of your identity before processing. Your authorized agent will need to complete the identity verification process explained in the preceding section. Garden Winds may reject a request from an agent that fails to complete the identity verification process. Your authorized agent, on your behalf, may submit a request to access using the by calling (877) 479-4637 (7:00 a.m. - 4 p.m. PST, weekdays) or email customerservice@gardenwinds.com.

Disclosure of Personal data

Garden Winds may have disclosed your personal data to the following categories of third parties for the business or commercial purposes listed above and for the following reasons:

1. Identifiers may be disclosed to vendors that provide us with customer service, account setup, account management and servicing, and data verification services.

2. Protected classifications may be disclosed to vendors that assist us in providing products and services to you.

3. Commercial information may be disclosed to vendors, advertising networks, or data analytics providers that help market our products or services to you.

4. Internet, browsing, or other network information may be disclosed to vendors, advertising networks, internet service providers, data analytic providers, or social networks that help us with conducting website and mobile app analysis, conducting research and analytics, developing our websites and mobile apps, collecting information about our website and mobile app usage and email responses, marketing and providing products or services to you, managing our online advertising and its effectiveness, responding to questions and emails, managing and servicing policies and accounts, and helping to offer our telematics or usage- based insurance programs to you.

5. Sensory data, such as audio recordings of your calls to our call centers, may be disclosed to vendors that provide us with services to improve customer service or for authentication or fraud investigation purposes.

6. Professional or employment information may be disclosed to vendors that assist us with processing job applications or providing offers or denials of employment.

7. Education information may be disclosed to vendors that provide us with human resources, job application, or recruitment services.

8. Inferences may be disclosed to vendors that provide us with services to market our products or services to you and help predict your future claims.

9. Financial account information may be disclosed to vendors that help us provide our products or services to you.

10. Geolocation data may be disclosed to vendors, advertising networks, internet service providers, data analytic providers, or social networks that help us with conducting website and mobile app analysis, developing our websites, mobile apps, or insurance programs, and marketing our products or services to you.

11. Garden Winds may also disclose all categories of personal data as part of corporate transactions, such as mergers, acquisitions, or divestitures, as well as with our affiliates and subsidiaries. We may be required to disclose all categories of personal data with law enforcement, regulatory agencies, or litigants based on legally enforceable requests for this information.

Contact Us

You may contact us at customerservice@gardenwinds.com if you have any questions or concerns about this policy or the use of your personal data.