WCIRB Privacy Policy

Effective Date: December 29, 2021

The Workers' Compensation Insurance Rating Bureau of California ("WCIRB," "we," "us," or "our") is committed to respecting your privacy. This privacy notice describes how we and some of the companies we work with collect, use, share, and protect information in connection with our websites, portals, mobile apps, and other online applications (collectively, the "Website"), and your choices and rights regarding the collection and use of your information.

This privacy notice applies to any WCIRB Website that displays or links to this privacy notice and to all members, agents, brokers, policyholders, workers, users, and other visitors who access the Website from the United States (collectively, "users"). This privacy notice does not apply to websites, portals, mobile apps, or other online applications that have their own privacy statement or otherwise do not display or link to this privacy notice. In addition, this privacy notice does not apply to information collected offline.

Some of the concepts below are a bit technical, but we tried our best to explain things in a straightforward and transparent way. If you have any questions or comments about this privacy notice, the ways in which we collect and use the information described below, or your choices and rights regarding such use, please do not hesitate to contact us:

Information We Collect
Our Website collects information that either directly identifies you or could reasonably be used in combination with other information to identify you ("personal information"). Examples of personal information include your name, postal address, email address, telephone number, billing and payment information, and any other information provided in combination with such identifiers. Personal information does not include information that has been made anonymous or aggregated so that it can no longer be used to identify a specific person, computer, or device, whether in combination with other information or otherwise.

Our Website may also collect certain technical data and other information that does not directly identify you (for example, by name or contact information), but which may be used to identify a specific computer or device that has accessed our Website, such as your computer's Internet protocol (IP) address or device's unique device identifier.

We collect this personal information when you provide it to us directly through the Website, automatically through your use of the Website, and from our partners and service providers and publicly-available sources.

Information You Provide
You may choose to give us certain personal information in order to use or interact with our Website. This can include your name, postal address, email address, telephone number, billing and payment information, date of birth, employer information and job title, and any other information provided in combination with such identifiers (such as annual income, education, survey responses, inquiry submissions, and Website enrollment information). For example:

• If you create an account (for example, a WCIRB Connect account) or enroll in a service available through the Website (for example, the WCIRB AnalyticsPortal and WCIRB Inquiry services or eSCAD), you may provide your name, company name and address, telephone number, email address, postal address, fax number, California License Number, and any other information necessary to establish and maintain your account or enroll you in the service.



• If you order or request products and services through the Website (for example, by submitting a Policyholder Experience Rating Worksheet Request Form, Coverage Research Service Request, or other product order form), you may provide your name, telephone number, email address, postal address, delivery information, company, payment method and payment card information, the products or services ordered, and any other information necessary to facilitate your particular order. In addition, if you are an injured worker submitting a Coverage Research Service Request, you may provide your name, date of injury, employer information, WCAB Number, insurer information, claim number, email address, telephone number, postal address, and payment method and financial information.



• If you submit a WCIRB Speaker Request Form or otherwise request WCIRB staff to speak at an event, you may provide your name, organization information, telephone number, email address, postal address, and any other information you include with your submission.



• If you submit an inquiry using the Customer Experience online form or otherwise contact us through the Website, you may provide your name, contact information, company name and address, and any other information you include with your inquiry.



• If you sign up to receive information about our products and services or register for our email alerts, you may provide your name, email address, company name, the product, service or alert you are interested in, and postal code.



• If you register for one of our webinars or other events, you may provide your name, email address, telephone number, company name, event you are interested in, and any other information necessary to facilitate your event registration.



• If you apply for a job or submit a resume through the Website, we will collect any personal information included in your application or resume, such as name, phone number, resume information, gender, ethnicity, cover letter content, education and field of study, current title and employer, and referring employee (if applicable).

Information Generated Through Your Use of the Website
Like most websites and other online services, our Website collects certain information that is created and recorded automatically when you use or interact with our Website. This information includes the following:

• Log Data. When you use or interact with the Website, our servers record certain information that is automatically reported by your browser (such as Apple's Safari, Google's Chrome, or Mozilla's Firefox) or device each time you make a request to access the Website or when Website content is downloaded to your browser or device ("log data"). This log data may include your IP address (which may change each time you connect to the Internet—a "dynamic" IP address—or may remain the same—a "static" IP address), browser settings, device information, referring page and URL, the date and time of your request, Website features or pages viewed, app crash data and other system activity, and cookie data. We may also collect similar data from emails sent to our users in order to help us track which emails are opened and which links are clicked by recipients.



• Device Information. In addition to log data, we may collect certain information about the device you're using to access the Website ("device information"), such as the device type, operating system and version, device settings, unique device identifier, advertising identifiers, device motion information, mobile network information, and crash data. Whether we collect some or all of this device information often depends on what type of device you're using and its settings. For example, different types of information are available depending on whether you're using a Mac or a PC, or an iPhone or an Android phone. To learn more about what information your device makes available to us, please check the policies of your device manufacturer or software provider.



• Location Information. Depending on the Website features or content and your computer or device permissions, the Website may collect information about your approximate or precise location ("location information"). Various technologies may be used to collect this location information, such as IP address, GPS, and other sensors that may provide information on nearby devices, Wi-Fi access points, and cell towers.



• Transaction Data. When you request, purchase, or use products and services available through the Website, we may collect certain transaction details related to such request, purchase, or use, such as the type of product or service requested, the date and time the product or service was requested and provided, amount charged, payment method, purchase and correspondence history, and other related transaction details ("transaction data").



• Cookie Data. Our Website may use cookies, pixel tags, software development kits, statistical identifiers, and similar technologies (collectively, "cookies and similar technologies") to collect and store certain log data and other information when you visit or interact with our Website in order to identify your browser or device and enable certain features and functionality. These cookies and similar technologies, including their use on the Website and your choices regarding such use, are further described under Use of Cookies and Similar Technologies below.

Information Received from Third Parties
We may receive information about you and your activity on and off the Website from members, insurers, brokers, agents, legal representatives, administrators, service providers, and other third parties. For example:

• If you're an injured worker, we may receive personal information about you from your legal representative or other requesting individual if they submit a Coverage Research Service Request, including your name, date of injury, employer information, WCAB Number, insurer information, and claim number.



• If your organization creates an account (for example, a WCIRB Connect account) or enrolls in a service available through the Website (for example, the WCIRB AnalyticsPortal and WCIRB Inquiry services or eSCAD), the organization may provide personal information relating to its legal contact, member administrator, TPE primary contact, or designated users from the organization who are authorized to use the services or access the organization's account, including name, title, company, telephone number, and email address.



• We may receive information collected by our online partners and providers of analytics tools (including information collected through third-party cookies and similar technologies on the Website), such as Website traffic and usage trend data.



• We may obtain information about you from commercially available sources such as data aggregators, credit agencies, background check firms, marketing providers, and other public databases. This information may include your name, contact information, demographic information, interests and publicly-observed data (such as from social media and shopping behavior), credit information, and professional experience.

Combining Information
Where permitted by law, we may combine the personal information you provide through the Website with information we collect through other WCIRB Websites, WCIRB's offline records, and information provided to us by third parties. Where permitted by law and feasible, we may also combine your personal information with information generated through your use of the Website (such as log data, transaction data, or cookie data), in which case we will treat any information that is combined or associated with your personal information as personal information for as long as it can reasonably be linked with your personal information.

We may use this consolidated information to improve our Website and product and service offerings, enhance our marketing and research activities, communicate information to you, and engage in any other legitimate business activities set forth under Use of Information below or otherwise described in this privacy notice.

Use of Information
We may use the information described above as necessary or useful to provide, support, personalize, and develop our Website, products, and services, including as follows:

• We use the personal information you provide through the Website for the purposes for which such information was provided. For example, if you share your name and contact information with us to submit an inquiry, we will use such information to respond to your inquiry. If you provide your personal information in connection with the purchase of a product or service, we will use the information to process your payment and facilitate delivery (in these situations, we may also save your payment information so that you can use it the next time you want to order a product or service through the Website).



• To create, maintain, customize, and secure your account with us.



• To process your requests, purchases, transactions, and payments and prevent transactional fraud.



• To provide you with customer support and to respond to your inquiries, including to investigate and address your concerns and monitor and improve our responses.



• To personalize your Website experience and to deliver content and product and service offerings relevant to your interests.



• To help maintain the safety, security, and integrity of our Website, products and services, databases and other technology assets, and business.



• For testing, research, analysis, and product development, including to develop and improve our Website, products, and services.



• To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.



• As described to you when collecting your personal information or as otherwise set forth in this privacy notice.

We may also use cookie data (alone or in combination with other information, including personal information) to maintain and improve our Website, verify and authenticate Website users, prevent fraud and secure our Website and databases, process payments, facilitate product and service delivery, remember and analyze user preferences and interests, track and measure Website performance and effectiveness, develop and improve our products and services, deliver ads relevant to user interests or based on user location, demographics or device characteristics, and for any other purpose described under Use of Information or Use of Cookies and Similar Technologies.

Use of Cookies and Similar Technologies

Types of Cookies and Similar Technologies
Our Website uses cookies and similar technologies to collect and store certain log data and cookie data when you visit or interact with our Websites in order to identify your browser or device and enable certain features and functionality. These technologies include the following:

• Cookies. Cookies are small text files that are sent to and stored by your browser when you visit or interact with our Website. These cookies are then sent back to the party that served the cookie unchanged each time you visit or interact with the Website in order for the party that served the cookie to recognize your browser or device. Cookies are either first-party cookies or third-party cookies. "First-party cookies" are sent to your browser by the party that operates the site you are visiting (for example, cookies served by WCIRB when you visit the Website). "Third-party cookies" are sent to your browser by any party other than the party that operates the site you are visiting (for example, cookies sent by our online partners, such as Google Analytics, when you visit the Website). Further, when we use cookies, we may use "session" cookies (that last until you close your browser) or "persistent" cookies (that last until you or your browser delete them). Some of the cookies we use on the Website may be associated with your personal information (such as your email address) and other cookies are not.



• Pixel Tags. Pixel tags (also known as web beacons) are small blocks of code installed on our Website which enable our online partners to serve cookies when you visit our Website and are generally used in combination with cookies to track user activity on our Website, receive relevant log data and cookie data, and perform other activities relating to the monitoring and analysis of the use and performance of the Website.



• Statistical Identifiers. Statistical identifiers refers to identifiers created using certain device information and log data. Collectively, this information makes your browser or device sufficiently distinct for a server or similar system to reasonably determine that it is encountering the same browser or device over time. Statistical identifiers enable us and our partners to uniquely identify your browser or device for the same purposes as cookies. Statistical identifiers may be associated with your personal information (such as your email address).

How Cookies and Similar Technologies are Used
Cookies and similar technologies used on our Website (including the information obtained through such use) fall into four categories:

Use of Cookies and Similar Technologies by Our Online Partners
We may use vendors and other online partners to perform some of the Essential, Performance, Analytics, and Advertising activities described above, including to provide audience measurement and analytics services. These online partners may use third-party cookies and similar technologies to collect and store certain device information, log data, cookie data and other information when you visit or interact with our Website in order to identify your browser or device and provide their respective services. Further, these online partners may combine data collected on our Website with information collected on unaffiliated sites or with any other data maintained by these online partners. Their use of data collected on our Website and third-party sites will be subject to their own terms of use and privacy policies.

Your Cookie Choices
Most browsers are set to accept cookies by default. However, browsers typically allow individuals to remove or block browser cookies if they choose. For more information on blocking and removing browser cookies, please review your browser's Settings or Preferences tab. More information can be found here:

For other browsers, please consult the documentation that your browser manufacturer provides.

In addition to removing and blocking browser cookies generally, the following opt-out mechanisms may be available if our Website utilizes the third-party cookies listed below:

• Google Analytics. Our Website may use Google Analytics, a web analytics service provided by Google. Google Analytics utilizes cookies and similar technologies to collect and analyze information about the performance and use of our Website. More information on Google Analytics can be found here. If you would like to opt-out of having your information collected and used as described, please use the Google Analytics opt-out available here.



• Hotjar. Our Website may use Hotjar, a technology service that assists in the optimization of website user experience. Hotjar uses cookies and other technologies to collect data on website users’ behavior and their devices in anonymized form. More information on Hotjar can be found here. If you would like to opt-out of having your information collected and used as described, please use the Hotjar opt-out link here.



• Interest Based Advertising. Our Website may use first- and third-party cookies and similar technologies for targeted advertising based on user interests, demographics, and past browsing activity. If you would like to opt-out of having your information collected and used by us for these purposes, please visit here or here if you're in the United States (if you're in Europe, please visit here; if you're in Canada, please visit here).

The list above identifies some of the third-party cookies we may use on our Website. However, we may use other third-party cookies and similar technologies on our Website that are not listed here. This list is subject to change at any time and without notice.

BY CONTINUING TO VISIT OR INTERACT WITH OUR WEBSITE, YOU CONSENT TO THE USE OF COOKIES AND SIMILAR TECHNOLOGIES AS DESCRIBED IN THIS PRIVACY NOTICE.

Social Plugins
This Website may use social plugins (for example, the Facebook "Like" button or "Share to Twitter" button) to enable you to easily share information with others. When you visit our Website, the operator of the social plugin may be able to place a cookie on your browser or device, enabling that operator to recognize users who have previously visited our Website. If you have previously logged into the associated social media website (for example, Facebook or Twitter) before visiting our Website, the social plugin allows that social media website to receive information about your visit to particular pages on our Website. The social plugin may collect this information for any such users who have logged into social networks, whether or not they specifically interact with the plugin on our Website (for example, by clicking "Like" or "Share"). The social plugin may also allow the social media website to share information about your activities on our Website with other users of their social media website. For further details about the information shared via a particular social media plugin, you should refer to that social media site's privacy policies and terms of use.

Do Not Track (DNT)
DNT is a concept that has been promoted by regulatory agencies such as the U.S. Federal Trade Commission (FTC) for the Internet industry to develop and implement a mechanism for allowing Internet users to control the tracking of their online activities across websites by using browser settings. The World Wide Web Consortium (W3C) has been working with industry groups, Internet browsers, technology companies, and regulators to develop a DNT technology standard. While some progress has been made, it has been slow and no standard has been adopted to date. As such, WCIRB does not generally respond to "do not track" signals.

Sharing of Information
We may disclose your personal information to third parties who provide us with various business services, including monitoring and maintaining our Website, processing payments, preparing and delivering products and services, performing Website analytics, and preparing newsletters and mailings. We may also share your information with third parties as necessary to perform the services requested or utilized through the Website.

We may disclose your personal information to third parties in special cases, including to prevent, investigate, or take action regarding illegal activities, suspected fraud, situations involving potential threats to the physical safety of any person, violations of our Terms of Use [https://connect.wcirb.com/STAROnline/Account/ToU.aspx] or any other agreement related to the Website (or products and services available through the Website), or as otherwise necessary or useful to protect the rights and interests of the WCIRB and its members, licensors, and users or as otherwise required by law.

If all or part of WCIRB is merged into another entity, the information we have about you may be transferred to a third party as part of that transaction. The acquiring entity will be required to use the personal information that is transferred only in a manner that is consistent with this privacy notice and applicable law.

Your Choices and Rights

Your Privacy Choices
You can use or generally visit our Website without revealing any personal information about yourself. However, to obtain our products and services, create an account with us, or enroll in a Website service, we will ask you to provide certain personal information (as described above). If you choose not to provide this information, you or your organization may be unable to obtain or use our products and services.

You may "opt-out" of receiving marketing communications from us at any time by emailing us at the address above. In addition, you may unsubscribe from promotional email communications from us by clicking on the "unsubscribe link" provided at the bottom of such communications (when such unsubscribe mechanism is required by law). However, you may not opt out of non-promotional product-, service-, or membership/account-related communications.

Please see Your Cookie Choices above for information on how to delete or refuse cookies and similar technologies. Please note, disabling, removing or blocking cookies may turn off some of the features of our Website that make your experience more efficient, and some Website features may not function properly or be accessible.

Your Rights
You have the right to receive information from us about the categories of personal information we maintain about you and the sources of such information. In addition, you have the right to request rectification of any personal information that is inaccurate or incomplete. However, for record keeping and compliance purposes, we may retain certain information collected from you, even if inaccurate or incomplete.

To exercise any of these rights, please send us an email at the address above. To protect your privacy, we will only respond to email messages sent from the email account you used to contact us initially or otherwise associated with your account/enrollment.

Security
WCIRB implements, maintains, and enforces reasonable and appropriate administrative, organizational, technical, and physical safeguards to protect the integrity, confidentiality, and availability of our Website, databases, personal information, and related assets. However, no method of transmission over the Internet, or method of electronic storage, is 100% secure. Therefore, we cannot guarantee the absolute security of your personal information.

Data Retention
WCIRB implements and maintains reasonable restrictions on the retention of personal information and generally disposes of such personal information once it is no longer necessary or useful for the purposes for which it was collected or further processed. However, we may continue to store archived copies of your personal information for legitimate business purposes and to comply with the law. In addition, we may continue to store anonymous or anonymized information for any legitimate business use described in this privacy notice.

Third-Party Links
This privacy notice only applies to WCIRB Websites that link to this privacy notice. However, our Website may contain links to third-party sites or services. We do not endorse and are not responsible for the content of third-party websites or resources, and our privacy notice does not apply to any sites that are not controlled by the WCIRB, even if you access such sites via a link on our Website. You should review the privacy policies and terms of use of any third-party site before providing any information.

Children
Our Website is not intended for children. We do not knowingly collect any personal information from children under 13-years old. However, if the parent or the guardian of a child under 13 years old believes that the child has provided us with personal information, the parent or guardian of that child should contact us at the address provided above to request the information's deletion. Anyone under 13 years old should seek their parent's or guardian's permission prior to using the Website or disclosing any personal information to WCIRB.

Changes to Our Privacy Notice
WCIRB reserves the right to amend this privacy notice at our discretion and at any time. When changes are made to this privacy notice, the updated notice will be posted on the Website and will be effective as of the date posted. YOUR CONTINUED USE OF OUR WEBSITE FOLLOWING THE POSTING OF CHANGES WILL CONSTITUTE YOUR ACCEPTANCE OF SUCH CHANGES. Material revisions to this privacy notice will not be applied retroactively without your affirmative consent.