Last Updated: January 1, 2023
We at Woodruff-Sawyer & Co., Woodruff-Sawyer Retirement Plan Services, Inc. and Woodruff-Sawyer Oregon, Inc. (collectively, “Company,” “we,” “us,” or “Woodruff Sawyer”) appreciate the trust you have placed in us as your insurance broker and consultant. In the course of serving you, we are given access to information that is often both sensitive and proprietary. We want you to know that integrity––in the way we operate and the methods by which we conduct business––is a top priority and our most essential core value. As such, we take the responsibility of protecting your company information very seriously.
This policy applies to information we collect:
- On this website at https://woodruffsawyer.com/ (our “Website”), including in email, text and other electronic messages between you and this Website (as a “Visitor”).
- In connection with our role as your insurance broker and consultant while using our Client Access portals, including Woodruff360 and Risk Solution Partners Management Center (as a “User”).
Purpose Of This Notice
In compliance with the Gramm-Leach-Bliley Act (GLBA, a US regulation), General Data Protection Regulation (GDPR, an EU regulation), California Consumer Privacy Act and California Privacy Rights Act (CCPA and CPRA), Virginia Consumer Data Protection Act (VCDPA) and other applicable U.S. State and Federal data protection laws as well as the Fair Credit Reporting Act (FCRA).
The GLBA, which became effective July 1, 2001, and related privacy laws of the various states, generally prohibit us from sharing nonpublic, personal information about you with a third party in a manner not permitted by law. Further, they require us to provide you with this annual notice of our privacy policies and practices. Similarly, the GDPR, as of May 25, 2018, prohibits us from processing any personal data of an individual without authorized grounds. The CCPA takes a similar approach, and provides further additional protections, such as the right to non-discrimination for exercising your rights. This policy and practice notification describes the types of information that we collect about you and the categories of persons or entities to whom that information may be disclosed.
Woodruff Sawyer Privacy Policies And Practices
When you use this Website, as a User of our client portals or simply a Visitor, we collect different types of information, which can include personal data. Personal data means any information relating to an identified or identifiable natural person. The legal bases for the processing of the personal data we collect are primarily that the processing is necessary for us to provide our services and that the processing is in Woodruff Sawyer’s legitimate interests, which is explained in greater detail below. We may also process data on your consent, asking for it as appropriate.
Categories of Non-Public Information We Collect
A. Information We Collect About You and How We Collect It
We collect several types of information from and about Users of our Website, including:
- Information by which you may be personally identified, such as name, postal address, email address, telephone number, Social Security number, and/or driver’s license number – that is, your personal data.
- Information about your transactions with us from the insurance companies we contact to underwrite your insurance.
- Information we receive from the Department of Motor Vehicles (DMV) or other consumer reporting agencies.
- Information contained in medical records or from medical professionals that is related to insurance claims.
- Information about your internet connection, the equipment you use to access our Website, usage details.
- Information about you as an applicant to our Company or a prospect to our Company available from public data sources.
We collect this information:
- Directly from you when you provide it to us.
- From third parties, for example, clients who provide information about their employees or claims, the insurance companies we contact to underwrite your insurance, DMV or other consumer reporting agencies, vendors that aggregate your information as an applicant or prospect from various publicly available data sources, and medical professionals who are providing information in connection to your insurance claim with us.
- Automatically as you navigate through our Website. Information collected automatically may include usage details, IP addresses and information collected through cookies, web beacons and other tracking technologies.
We may collect nonpublic personal data from individuals other than those proposed for coverage.
B. Information You Provide to Us
The information we collect on or through our Website may include:
- Information that you provide to us by filling out applications and other forms, including financial statements, census lists and pro forma business plans.
- Information that you provide to us via our website, including applications and forms, consultation requests, claims forms, accident reports, underwriting worksheets, newsletter subscriptions, and seminar and workshop registration.
- Records and copies of your correspondence (including email addresses), if you contact us.
- Your search queries on our Website.
C. Information We Collect Through Automatic Data Collection Technologies
As you navigate through and interact with our Website, we may use automatic data collection technologies to collect certain information about your equipment, browsing actions and patterns, including:
- Details of your visits to our Website, including traffic data, location data, logs and other communication data and the resources that you access and use on the Website.
- Information about your computer and internet connection, including your IP address, operating system and browser type.
We also may use these technologies to collect information about your online activities over time and across third-party websites or other online services (behavioral tracking). The information we collect automatically helps us to improve our Website and to deliver a better and more personalized service.
The technologies we use for this automatic data collection may include:
- Flash Cookies. Certain features of our Website may use local stored objects (or Flash cookies) to collect and store information about your preferences and navigation to, from and on our Website. Flash cookies are not managed by the same browser settings as are used for browser cookies. For information about managing your privacy and security settings for Flash cookies, see http://www.adobe.com/devnet/security.html.
- Web Beacons. Pages of our Website and our emails may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags and single-pixel gifs) that permit us, for example, to count users who have visited those pages or opened an email and for other related website statistics (for example, recording the popularity of certain website content and verifying system and server integrity).
- Do Not Track. Many web browsers support Do Not Track technology. If you enable Do Not Track, we will not use information about your web viewing activities to tailor your online experience.
How We Use Your Information
We use information that we collect about you or that you provide to us, including any personal data in the following ways.
We use this information to (i) provide you with information or services that you request from us and to provide customer service, (ii) carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collection, and (iii) provide you with notices about your account, including expiration and renewal notices.
We use the information to understand and analyze the usage trends and preferences of our Visitors and Users, to improve the services we provide, and to develop new products, services, features, and functionality. Should this purpose require Woodruff Sawyer to process any personal data, then the data will only be used in anonymized or aggregated form.
D. Cookies and Tracking Technologies
We may use automatically collected information, as well as through cookies and similar technologies to: (i) personalize our services, such as remembering a User’s or Visitor’s information so that the User or Visitor will not have to re-enter it during a visit or on subsequent visits; (ii) provide customized content, and information; (iii) monitor and analyze the effectiveness of our services and marketing activities; and (iv) monitor aggregate site usage metrics such as total number of visitors and pages viewed. You can obtain more information about cookies by visiting http://www.allaboutcookies.org.
We take measures to protect the technical information collected by our use of Google Analytics. The data collected will only be used on a need to know basis to resolve technical issues, administer the Website and identify Visitor preferences; but in this case, the data will be in non-identifiable form. We do not use any of this information to identify Visitors or Users.
With your consent, we can also use the information we collect (i) to fulfill any other purpose for which you provide it and (ii) in any other way we may describe when you provide the information.
Categories of Non-Public Information that We May Disclose to Third Parties and the Categories of Third Parties to Whom We May Disclose
Except as described in this policy, we will not intentionally disclose personal data that we collect or store to third parties without the consent of the applicable User, Visitor, or client. We may disclose information to third parties if you consent to us doing so, as well as in the following circumstances.
A. Managing Business On Your Behalf
We may disclose information, such as information from your application or other forms of data or your transactions with us, to a/an (i) affiliated entity to our company; (ii) third party if the disclosure will enable that party to perform a business, professional or insurance function for us, including credit reporting agencies, and our attorney and auditors, (iii) medical care institution or medical professional in order to verify coverage or benefits, or to conduct an audit that would enable us to verify treatment and, (iv) State Insurance Division or Department of Insurance or other insurance regulatory authority, law enforcement, or other governmental authority in order to protect our interest or if we are required by law to divulge the information.
The contractors and other third parties we use to support our business are bound by contractual obligations to keep personal data confidential and use it only for the purposes for which we disclose it to them.
B. Technical Service Providers
We work with third party service providers who provide website, application development, hosting, maintenance, and other services for us. These third parties may have access to, or process personal data or client data as part of providing those services for us. We limit the information provided to these service providers to that which is reasonably necessary for them to perform their functions, and our contracts with them require them to maintain the confidentiality of such information.
C. Non-Personally-Identifiable Information
We may make certain automatically-collected, aggregated, or otherwise non-personally-identifiable information available to third parties for various purposes, including (i) for business or marketing purposes; or (iii) to assist such parties in understanding our clients’, Users’ and Visitors’ interests, habits, and usage patterns for our Website and services.
D. Law Enforcement, Legal Process and Compliance
We may disclose personal data or other information if required to do so by law or in the good-faith belief that such action is necessary to comply with applicable laws, in response to a facially valid court order, judicial or other government subpoena or warrant, or to otherwise cooperate with law enforcement or other governmental agencies.
We may also disclose information to third parties with your consent, within the parameters your provide it.
F. Change of Ownership
Information about Users and Visitors, including personal data, may be disclosed and otherwise transferred to an acquirer, successor or assignee as part of any merger, acquisition, debt financing, sale of assets, or similar transaction, as well as in the event of an insolvency, bankruptcy, or receivership in which information is transferred to one or more third parties as one of our business assets.
Client data may be physically or electronically transferred to an acquirer, or successor or assignee as part of any merger, acquisition, debt financing, sale of assets, or similar transaction, as well as in the event of an insolvency, bankruptcy, or receivership in which information is transferred to one or more third parties as one of our business assets, for the sole purpose of continuing operations.
In connection with the potential sale or transfer of its interests, Woodruff Sawyer and its affiliates will disclose information to a third party only if it (1) concentrates its business in a similar practice, product or service; (2) agrees to be Woodruff Sawyer’s successor in interest with regard to the maintenance and protection of the information collected; and (3) agrees to the obligations of this privacy statement.
G. To Comply with Applicable Laws and the FCRA
We may disclose your information in accordance with requests from law enforcement or court of competent jurisdictions’ decree, order or subpoena. We may also be required to make certain disclosures pursuant to the FCRA to credit agencies or bureaus if initiated, requested or authorized by you in order for Woodruff Sawyer to perform its services.
You have the following rights. You may have the right to access, correct, delete and opt-out of sharing your personal data as detailed below under the GDPR, CCPA, CPRA, FCRA or other applicable data protection regulation. You have the right to non-discrimination. That is, we will not discriminate against you for exercising any of these rights. You have the right to opt-out of the sale of your personal information and to limit what we may do with your highly sensitive information as defined under applicable laws such as the CPRA.
A. Access, Correction, Deletion
We respect your privacy rights and provide you with reasonable access to the personal data that you may have provided through your use of this Website and services. If you wish to access or amend any other personal data we hold about you, or to request that we delete or transfer any information about you that we have obtained, you may contact us as set forth in the sections below. At your request, we will have any reference to you deleted or blocked in our database.
You may update, correct, or delete your account information by contacting us or as provided by our services. Please note that while any changes you make will be reflected in active user databases instantly or within a reasonable period of time, we may retain all information you submit for backups, archiving, prevention of fraud and abuse, analytics, satisfaction of legal obligations, or where we otherwise reasonably believe that we have a legitimate reason to do so.
You may decline to share certain personal data with us, in which case we may not be able to provide to you some of the features and functionality of our Website or services.
At any time, you may object to the processing of your personal data, on legitimate grounds, except if otherwise permitted by applicable law. If you believe your right to privacy granted by applicable data protection laws has been infringed upon, please contact us. You also have a right to lodge a complaint with the appropriate regulatory body.
Your right includes the right to know the source of the information and the identity of the persons, institutions or types of institutions to whom we have disclosed such information within one or two years prior to your request, depending on your jurisdiction. This information can be copied in person, received via email or mail.
To exercise your rights under these data protection regulations, you may contact us at our toll-free number (877) 334-5140, email us at HERE, or fill out our privacy request form.
The request should include the identifying information about yourself and the relevant recorded information at issue. The request should state how you would like to access your information. Upon receipt of your request, we will contact you within ten (10) days confirm your requests and within the appropriate regulatory timeframes to make the relevant arrangements. Where you request that certain information be corrected, amended, or deleted, we will either notify you that we have made the correction, amendment or deletion, or that we refuse to do so and the reasons for the refusal, which you will have the opportunity to challenge.
Please note that to protect your information, we may need to verify your identity before processing your request. In some cases, we may need to collect additional information to verify your identity, such as a government issued ID.
You may exercise these rights yourself or you may designate an authorized agent to make these requests on your behalf. We may request that your authorized agent have written permission from you to make requests on your behalf and may need to verify your authorized agent’s identity.
B. Opting out from Commercial Communications
If you receive marketing emails from us, you may unsubscribe at any time by following the instructions contained within the email or by sending an email to the address provided below. Please be aware that if you opt-out of receiving marketing email from us it may take up to ten (10) business days for us to process your request. Additionally, even after you opt-out from receiving commercial messages from us, you will continue to receive administrative messages from us regarding the use of our services.
Woodruff Sawyer has no direct relationship with a client’s customers or third party whose personal data it may process on behalf of a client. An individual who seeks access, or who seeks to correct, amend, delete inaccurate data or withdraw consent for further contact should direct his or her query to the client they deal with directly. If the client requests we remove the data, we will respond to its request within thirty (30) days. We will delete, amend or block access to any Personal Data that we are storing only if we receive a written request to do so from the client who is responsible for such personal data, unless we have a legal right to retain such personal data. We reserve the right to retain a copy of such data for archiving purposes, or to defend our rights in litigation. Any such request regarding client data should be addressed as indicated in the section below, and include sufficient information for us to identify the client or its customer or third party and the information to delete or amend.
C. Opting out of Disclosure of Non-Public Information to Third Parties
We do not share your non-public information with third-parties unless we obtain consent or are required to do so in order to perform services that you have requested. You have the right to opt-out of the disclosure of non-public information to non-affiliated third-parties. If we intend to share your non-public information with non-affiliated third-parties then we will provide a clear and conspicuous notice of your rights to opt-out of such disclosure in accordance with the GLBA.
D. Sale of personal data
We do not sell your personal information. However, we support the CCPA and CPRA by allowing California residents to opt out of any future sale of their personal information. If you would like to record your preference that the Company not sell your data in the future, you may contact us at our toll-free number (877) 334-5140, email us at email@example.com, or fill out our privacy request form.
Cookies are text files containing small amounts of information which are downloaded to your device when you visit a website. Cookies are then sent back to the originating website on each subsequent visit, or to another website that recognizes that cookie. Cookies are useful because they allow a website to recognize a user’s device.
Cookies do many different jobs, like letting you navigate between pages efficiently, remembering your preferences, and generally improve the user experience. They can also help to ensure that adverts you see online are more relevant to you and your interests. The cookies used on this website have been categorized based on the categories found in the ICC UK Cookie guide.
A list of all the cookies used on this website by category is set out below.
A. Strictly Necessary cookies
We consider these cookies essential for you to navigate our site and use its features, such as logging into secure, customer only areas of the site. Without these cookies, services you have paid for cannot be provided.
Examples of Strictly Necessary cookies:
- Registered Visitor cookie: Each registered user gets a unique id number, which is used to recognize them during the site visit and also upon their return. (Also applies to Functionality cookies below.)
B. Performance cookies
Aggregated, non-personally identifiable Information is collected about each user on each visit and use of this website. For example: which pages you visit the most often, and if you get error messages from web pages. These cookies don’t collect information that identifies a visitor. All information these cookies collect is anonymous and is only used to improve how this website works.
Examples of Performance Cookies include:
- Referrer URL (internal page): Stores the URL of the previous page visited. Allows us to track how visitors navigate throughout our site.
- Referrer URL (set on external pages, such as clicking on links on Woodruff Sawyer social media pages): Stores the URL which refers a visitor to our site so we may understand which URLs are referring visitors to our site.
- URL history: Stores the pages visited by a user.
- Unregistered Visitor cookie: Allows analysis on how unregistered visitors use our site
- Session Management cookies: Allows us to follow the actions of a user on our website during a browser session. A browser session begins when a user opens the browser window, visits our site, and ends when the visitor leaves the site and closes the browser window. Session Management cookies are created temporarily but deleted once the browser window is closed.
C. Functionality cookies
Allows us to remember choices a user makes (such as a user name, language or the region) in order to provide more enhanced, personal, and persistent features. None of these collect personally identifying information. Each user is counted as an anonymous ID. These cookies cannot track browsing activity on other websites. They don’t gather any information about website visitors that could be used for advertising or remembering where a user has been on the Internet outside our site.
Examples of Functionality Cookies include:
- Registered Visitor cookie: Used to identify a registered user to our site with a unique id, so that we may serve them content and offers based on their profiles. Also used for analysis and marketing purposes. (See also Strictly Necessary cookies above.)
D. Targeting cookies
Used from time to time to: (1) deliver advertisements more relevant to you and your interests; (2) limit the number of times you see an advertisement; (3) help measure the effectiveness of the advertising campaign; and (4) understand people’s behavior after they view an advertisement. They are usually placed on behalf of advertising networks with the site operator’s permission. They remember that you have visited a site and quite often they will be linked to site functionality provided by the other organization. Woodruff Sawyer does not use third-party advertising on our site, so we do not use these particular Targeting cookies for advertising, but we use them for gathering analytics and intelligence about the site.
Examples of Targeting Cookies include:
- Retargeting and re-engagement cookies: Allows us to display advertising to people who have previously visited the website or used our apps, and match the right people with the right message.
- Gathering analytics and intelligence cookies
- Third Party cookies: The Targeting cookies as described above may also be used on third party websites and third parties may use them on our websites as follows:
Woodruff Sawyer advertisements on non-Woodruff Sawyer sites
Cookies may be placed on non-Woodruff Sawyer sites so that when you click on a Woodruff Sawyer advertisement located on these sites, Woodruff Sawyer is provided with this information to enable us to measure and improve the effectiveness of our advertising and to reduce the frequency of ads that are not relevant to each user’s interests. One example of this is Google Marketing Platform. Information about opting out of third party vendor cookies is located here.
Third Party Services
The Website may contain features or links to websites and services provided by third parties. Any information you provide on third-party sites or services is provided directly to the operators of such services and is subject to those operators’ policies, if any, governing privacy and security, even if accessed through us. We are not responsible for the content or privacy and security practices and policies of third-party sites or services to which links or access are provided through our Website. We encourage you to learn about third parties’ privacy and security policies before providing them with information.
Additional Rights of California Residents
Information Confidentiality and Security
We follow generally accepted industry standards to protect the information submitted to us, both during transmission and once we receive it. This notice is also to inform you that we maintain appropriate administrative, technical and physical safeguards to protect non-public information in compliance with Federal Trade Commission (FTC) regulations in order to protect against accidental or unlawful destruction, accidental loss, unauthorized alteration, unauthorized disclosure or access, misuse, and any other unlawful form of processing of the personal data in our possession. This includes, for example, firewalls, password protection and other access and authentication controls.
In addition to the foregoing, in accordance with existing and new regulations under the GLBA, we also have developed, implemented and maintained comprehensive written information security program that include:
- Designating a qualified individual for coordination of the information security program;
- A risk assessment evaluation;
- Specific administrative safeguards to address and identify information security risks;
- Specific technical safeguards to address identified information security risks;
- Specific physical safeguards to address identified information security risks;
- An identity-theft prevention program for consumer accounts;
- Internal policies and procedures that govern data breach situations and management; and
- Service provider management due diligence, contract management and monitoring.
However, no method of transmission over the Internet, or method of electronic storage, is 100% secure. We cannot ensure or warrant the security of any information you transmit to us or store with us, and you do so at your own risk. We also cannot guarantee that such information may not be accessed, disclosed, altered, or destroyed by breach of any of our physical, technical, or managerial safeguards. If you believe your Personal Data has been compromised, please contact us as set forth in the “Contact Us” section.
If we learn of a security systems breach, we will inform you and the authorities of the occurrence of the breach in accordance with applicable law.
We restrict access to your nonpublic, personal data to employees on a “need to know” basis. If the employee is not involved with your account, he or she does not need access to your information. We maintain physical, electronic, and procedural safeguards that comply with Federal and State regulations to guard your nonpublic personal data. We will continue to protect and treat your information as confidential.
Woodruff Sawyer is a business associate within the scope of the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and its implementing regulations. As a business associate, we restrict the use and disclosure of protected health information (PHI) on behalf of our clients. We also provide for the security of electronic protected health information (ePHI) on behalf of clients. All of our Privacy and Security policies and procedures ensure compliance with HIPAA’s privacy and security requirements.
We only retain personal data for as long as the purposes for which we have initially collected it. Where we collect that information through the consent provide by an individual (not client), but that individual withdraws consent, we will delete that information within a reasonable time. Where that information is retained and necessary for us to comply with our legal obligations, resolve disputes, enforce our agreements, or comply with insurance regulations, we will retain that information for the period of time required for that purpose or ten (10) years from that date.
Our services are hosted in the United States. If you choose to use our services from the European Union or other regions of the world with laws governing data collection and use that may differ from U.S. law, then please note that you may be transferring your client data and personal data outside of those regions to the United States for storage and processing by our service providers.
We will comply with GDPR requirements providing adequate protection for the transfer of personal information from Europe to the U.S. Also, we may transfer your data to the U.S., the EEA, or other countries or regions deemed by the European Commission to provide adequate protection of personal data in connection with storage and processing of data, fulfilling your requests, and operating our services. We may also transfer your personal data to the other countries or regions not in the EEA or U.S., but will do so only with your consent or where we have agreements in place on such restricted data transfers with the relevant third party.
Data Controller and Data Processor
The client or the user is the data controller under the GDPR for any client data containing personal data, meaning that such party controls the manner such personal data is collected and used as well as the determination of the purposes and means of the processing of such personal data.
Where we collect information on our own behalf, and not to effectuate our services for a client, we are a data controller for purposes of the GDPR as to personal data of data subjects. For example, where we collect personal data for marketing purposes, we are a data controller. Where Woodruff Sawyer is a data controller under the GDPR, we will comply with the requirements to provide adequate data privacy and protection of the personal data that we control.