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California Consumer Privacy Act Disclosure

Last Updated: December 22, 2022

The Travelers Companies, Inc. and its affiliates (collectively, “Travelers,” “we,” or “us”) value your privacy. This California Consumer Privacy Act Disclosure explains how Travelers collects, uses, and discloses personal information relating to California residents, pursuant to the California Consumer Privacy Act of 2018, as amended by the California Privacy Rights Act (as amended, the “CCPA”).

This Disclosure does not apply with respect to information about individuals who have purchased or applied for, or been involved in a claim involving, a Travelers personal insurance product or service or who were a participant, beneficiary or claimant of an employee benefit product or workers compensation insurance policy underwritten or issued by Travelers (“Consumer Customers”). For Consumer Customers, please refer to our Privacy Statement for Individual U.S. Personal Insurance Consumers, or to the privacy notice sent to your employer if you are a participant, beneficiary or claimant of an employee benefit product or workers compensation policy, for more information about how Travelers collects, uses, and discloses personal information.

Our collection, use, disclosure, sharing and retention of personal information

Under the CCPA, “Personal Information” is information that identifies, relates to, or could reasonably be linked directly or indirectly with a particular California resident or household. The following describes how we collect, use, and disclose Personal Information relating to California residents based on the types of Personal Information listed in the CCPA.

We collect Personal Information relating to California residents in a variety of contexts, including, for example, collecting Personal Information relating to individuals who request or obtain our products or services, apply for employment with us or are our employees, vendors, contractors or similar personnel, and who visit our locations or facilities. The specific Personal Information that we collect, use, and disclose relating to a California resident will depend on our relationship or interaction with that specific California resident.

We collect the following categories of Personal Information:

  • Identifiers, such as name and government-issued identifier (e.g., Social Security number, driver’s license, state identification card, or passport number), unique personal identifier, and IP address
  • Personal information, as defined in the California disposal of records law, such as contact information, financial information, and medical information
  • Characteristics of protected classifications under California or federal law, such as sex and marital status
  • Commercial information, such as transaction information and purchase history
  • Biometric information, such as fingerprints or facial biometrics, for certain employees
  • Internet or network activity information, such as information regarding interactions with our websites
  • Geolocation Data, such as approximate location based on IP address
  • Audio, electronic, visual, and similar information, such as call recordings and information regarding your use of our websites
  • Professional or employment-related information, such as work history and prior employer
  • Education Information
  • Inferences drawn from any of the Personal Information listed above to create a profile about, for example, an individual’s preferences and characteristics
  • Sensitive Personal Information:
    • Personal Information that reveals an individual’s Social Security, driver’s license, state identification card, or passport number; account log-in, financial account, debit card, or credit card number in combination with any required security or access code, password, or credentials allowing access to an account;
    • Precise geolocation information;
    • Racial or ethnic origin;
    • The contents of mail, email, and text messages unless we are the intended recipient of the communication;
    • Personal Information collected and analyzed concerning an individual’s health;
    • Biometric information used for the purpose of uniquely identifying an individual;
    • Personal information collected and analyzed concerning a consumer’s sex life or sexual orientation

We may disclose all of the categories of Personal Information listed above to the following categories of third parties for our operational business purposes, including within the 12 months preceding the date this Disclosure was last updated: service providers and vendors and third parties where required by law, such as disclosures to government agencies who regulate our business, law enforcement, and third parties who are involved in litigation with us. We also may disclose the following categories of Personal Information to authorized agents and brokers for our operational business purposes, including within the 12 months preceding the date this Disclosure was last updated:

  • Identifiers
  • Personal information, as defined in the California disposal of records law
  • Characteristics of protected classifications under California or federal law
  • Commercial information
  • Internet or network activity information
  • Geolocation Data
  • Audio, electronic, visual, and similar information
  • Professional or employment-related information
  • Education Information
  • Inferences
  • Sensitive Personal Information

We “share” the following categories of Personal Information with marketing and advertising partners for purposes of cross-context behavioral advertising, including within the 12 months preceding the date this Disclosure was last updated:

  • Identifiers
  • Commercial information
  • Internet or network activity information
  • Geolocation Data
  • Audio, electronic, visual, and similar information

We may also disclose Personal Information to a third party in the event of any reorganization, financing transaction, merger, sale, joint venture, partnership, assignment, transfer, or other disposition of all or any portion of our business, assets, or stock (including in connection with any bankruptcy or similar proceedings).

We do not sell Personal Information and have not sold Personal Information in the preceding 12 months. We do not knowingly sell or “share” (for purposes of cross-context behavioral advertising, as defined by the CCPA) the Personal Information of minors under 16 years of age.

Purposes for the collection, use and “sharing” of personal information

The purposes for which we use this Personal Information depend on our relationship or interaction with a specific California resident. We may use this information in order to operate, manage, and maintain our business, provide our products and services, for our employment and vendor management purposes, and to accomplish our business purposes and objectives, including, for example, providing quotes, underwriting and rating policies; responding to inquiries, fulfilling requests, completing transactions and otherwise servicing insurance policies; investigating and processing claims; personalizing or developing products and services; marketing; research and data analysis; risk and security control; fraud detection and prevention; identity verification; determining eligibility for an employment or other relationship with us; paying compensation and administering benefits; managing performance and other aspects of your relationship with us; accounting, audit, and other internal functions, such as internal investigations; maintaining our facilities and infrastructure; compliance with law, legal process, and internal policies; record keeping; and exercising and defending legal claims.

We use and disclose Sensitive Personal Information only for the purposes specified under the CCPA, which include performing services for our business, providing our products and services, and ensuring the security and integrity of our business, infrastructure, and the individuals we interact with. This includes short-term transient use, such as displaying first party, non-personalized advertising, order processing and fulfillment, servicing accounts, establishing and maintaining employment relationships, providing customer service, verifying customer information, processing payments, and activities relating to quality and safety control or product improvement.

Retention of personal information

As an insurance company, the length of time we retain Personal Information we collect is regulated by state law. The legally required retention periods vary depending on, among other things, the type of information at issue and the purpose for which it was collected. Other criteria that we use to determine our retention periods include:

  • The length of time we have an ongoing relationship with you and the length of time thereafter during which we may have a legitimate need to reference your Personal Information to address issues that may arise;
  • For employees, the duration of your employment and the length of time we have an ongoing relationship with you or your dependents/beneficiaries;
  • For job applicants, the duration of the job application process, whether your job application is approved, and whether you want to be notified of future job opportunities; and
  • Whether retention is advisable in light of our legal position (such as in regard to applicable statutes of limitations, litigation, or regulatory investigations).

Right to opt-out of “sharing” of personal information

You have the right to opt out of any future “sharing” of your Personal Information for purposes of cross-context behavioral advertising. When you visit our websites, we use cookies and similar tools to automatically make certain data available to third-party marketing and advertising partners who help us improve and deliver advertising, as listed in the chart above. Under the CCPA, this activity constitutes “sharing.”

You can opt out of “sharing” in a frictionless manner by broadcasting an Opt-Out Preference Signal, such as the Global Privacy Control (GPC), or Do Not Track (on the browsers and browser extensions that support such signals). You can also opt out by clicking “Cookie Settings” at the bottom of our website and following the instructions in the menu to opt out of advertising cookies.

Sources of personal information

We collect Personal Information directly from you, and from third parties, including from:

  • Agents and brokers;
  • Service providers and vendors;
  • Other individuals, such as witnesses, and individuals involved in litigation with us;
  • Your employer or other businesses that you have a relationship with;
  • Publicly available sources;
  • Consumer reporting agencies and insurance support organizations;
  • References you provide when you apply for a job with us;
  • Other businesses, such as other insurance companies, and businesses involved in litigation with us; and
  • Government agencies.

Access, deletion, correction and “sharing” requests

If you are a California resident, you have the following rights:

You may request that we disclose to you:

  1. the categories of Personal Information we collected about you and the categories of sources from which we collected such Personal Information;
  2. the business or commercial purpose for collecting or “sharing” Personal Information about you;
  3. the categories of Personal Information about you that we disclosed to third parties for a business purpose and the categories of third parties to whom we disclosed the Personal Information;
  4. the categories of Personal Information about you that we “shared” (for cross-context behavioral advertising, as defined by the CCPA) and the categories of third parties with which we “shared” such Personal Information; and
  5. the specific pieces of Personal Information we collected about you, including a copy of your Personal Information in a portable format.
  • You may request that we delete Personal Information we collected from you (if applicable).
  • You may request that we correct inaccuracies in the Personal Information we maintain about you.
  • You may request to opt out of any future “sharing” of your Personal Information for purposes of cross-context behavioral advertising.

In some instances, we may not be required to honor your request where a CCPA exception applies, such as where the disclosure of Personal Information would adversely affect the rights and freedoms of other individuals, or if you are a Consumer Customer.

You have the right to be free from unlawful discrimination for exercising your rights under the CCPA, including, if applicable, your right as an employee, applicant, or independent contractor not to be retaliated against for exercising your CCPA rights.

How to submit access, deletion and correction requests

If you are a California resident, you may make a request described above yourself, or you may have an authorized agent submit a request on your behalf. You or your authorized agent may use either of the following methods to submit a request:

When making a request, you will need to provide certain identifying information, such as your name, address, and email address to allow us to verify the request and locate your information. We will verify and respond to your request consistent with applicable law, taking into account the type and sensitivity of the Personal Information subject to the request. If an authorized agent submits a request on your behalf, we may request that the agent provide, as applicable, proof concerning their status as an authorized agent. In addition, we may require that you verify your identity or confirm that you provided the agent permission to submit the request.

How to submit a request to opt out of sharing

You can opt out of “sharing” in a frictionless manner by broadcasting an Opt-Out Preference Signal, such as the Global Privacy Control (GPC), or Do Not Track (on the browsers and browser extensions that support such signals). You can also opt out by clicking “Cookie Settings” at the bottom of our website and following the instructions in the menu to opt out of advertising cookies.

Deidentified information

Where we maintain or use deidentified information, we will continue to maintain and use the deidentified information only in a deidentified fashion and will not attempt to re-identify the information.

Changes to this California Consumer Privacy Act Disclosure

We may change or update this Disclosure from time to time. When we do, we will post the revised Disclosure on this page with a new “Last Updated” date.

Questions or concerns

If you have any questions or concerns about our privacy policies or practices, please write to: Travelers, One Tower Square, Hartford, CT 06183, Attn: Privacy Office.