Last Updated: June 17, 2026
We review and update this Policy at least annually and whenever there are material changes to our data practices or applicable law.
Frank Winston Crum Insurance Holdings Corp. and/or its affiliated companies, including Frank Winston Crum Insurance Company, FrankCrum General Agency, Inc., and FrankCrum Insurance Agency, Inc. (collectively “Company,” “we,” “our,” or “us”) respect your privacy and are committed to protecting it through our compliance with this Privacy Policy (“Policy”). This Policy describes how we collect, process, retain, sell/share and disclose personal information when you interact with our websites and other online or offline services that link to or reference this Policy or by using our services. It also describes the privacy rights that may apply to you under applicable law. This Policy also incorporates our California Residents: Notice of Collection and disclosures required under the California Consumer Privacy Act of 2018, as amended by the California Privacy Rights Act (“CCPA”). By using our Site, you acknowledge that you have reviewed this Policy. This Policy may change from time to time (see Section: Changes to Our Privacy Policy).
This Policy applies to individuals who:
Where required by law, additional or different privacy disclosures (including notices provided under applicable insurance or financial privacy laws) may apply to certain products or services. Please refer to the following policies if needed:
Collection of Personal Information and Sensitive Personal Information
Based on your specific transactions and interactions with us or our website, we will or may collect, and we have in the last 12 months collected the following categories of Personal Information (“PI”) about you. For each category of information, the categories of third parties and service providers to whom we have disclosed the information in the last 12 months are referenced below. In jurisdictions where required by law, we limit our collection of Personal Information to what is reasonably necessary and proportionate to provide or maintain the services you have requested or reasonably expect in the context of your relationship with us. The examples provided for each category are not intended to be an exhaustive list or an indication of all specific pieces of information we collect from or about you in each category, but rather the examples are to provide you with a meaningful understanding of the types of information that may be collected within each category.
We use limited analytics tools (such as Google Analytics) solely to understand website performance and navigation. These tools are configured without advertising features, including disabled Google Signals, ad personalization, and remarketing. Analytics data is not sold or shared and is disclosed only to contracted Service Providers for legitimate business purposes. For additional information about Google Analytics, please see Google’s Privacy Policy and Privacy & Terms. Our Site(s) third parties may use first party cookies to support internal content or communications; these cookies are not used for advertising and are not shared with third parties.
| Categories of Personal Information Collected and Source | Business Purpose | Categories of Recipients | Retention Criteria |
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Identifiers. e.g. Contact information including first name, last name, mailing address, phone number, email address, unique personal identifier, online identifier, or Internet Protocol address. Source: Directly from you, automatically when you interact with our Site (limited to online identifiers such as Internet Protocol (IP) address), affiliated entities, insurance and claims related parties, government agencies, regulators, consultants, and professional advisors. |
|
Disclosed:
Sold or Shared:
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Retained for the duration of our relationship and as needed for security, fraud prevention, and recordkeeping. |
|
Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)) ("California Customer Records"). e.g. Name, signature, Social Security number, physical characteristics or description, photograph, address, telephone number, passport number, driver's license or state identification card number, insurance policy number, employment, employment history, membership in professional organizations, professional licenses and certifications, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information. Some personal information included in this category may overlap with other categories. Source: Directly from you, service providers, vendors, business partners, affiliated entities, insurance and claims related parties, government agencies, regulators, consultants, and professional advisors. |
|
Disclosed:
|
Retained for the duration of our relationship and as needed for security, fraud prevention, and recordkeeping. |
|
Protected classification characteristics under California or federal law ("Protected Classes"). e.g. age (40 years or older), Race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation reproductive health decision-making, military and veteran status, or genetic information (including familial genetic information). Source: Directly from you, and where applicable, from insurance and claims-related parties, service providers, and other third parties involved in the handling and administration of claims.
|
|
Disclosed:
Sold or Shared:
|
Comply with applicable laws and regulations; maintain required business, and compliance records; and manage privacy requests and preferences. |
|
Payment and Commercial Information. e.g. First name, last name, billing address, phone number, third party payment service provider-related information, debit or credit card information bank account information, purchase and participation history, or other payment processing information. Source: Directly from you, service providers, vendors, business partners, affiliated entities, insurance and claims related parties, government agencies, regulators, consultants, and professional advisors.
|
|
Disclosed:
Sold or Shared:
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Retained for the life of the account and for a reasonable period thereafter to comply with security and legal obligations. |
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Account Information. e.g. First name, last name, email address, policy number, physical address, and account credentials (such as passwords). Source: Directly from you, service providers, vendors, business partners, affiliated entities, insurance and claims related parties, government agencies, regulators, consultants, and professional advisors.
|
|
Disclosed:
Sold or Shared:
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Retained for the life of the account and for a reasonable period thereafter to comply with security and legal obligations. |
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Claim-Related Information. e.g. First name, last name, date of birth, job title, organization name, employment related information, email, phone number, physical address, claim number, policy number, tax ID numbers, social security number, driver’s license number, personnel files, accident reports, incident descriptions, disability-related information, treatment information, and audiovisual material. Source: Directly from you, service providers, vendors, business partners, affiliated entities, insurance and claims related parties, government agencies, regulators, consultants, and professional advisors.
|
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Disclosed:
Sold or Shared:
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For as long as reasonably necessary to investigate, evaluate, and resolve claims; comply with legal and regulatory obligations; respond to audits and examinations; resolve disputes; and protect against fraud and abuse. Retention periods are determined based on the nature of the information, the status of the claim, applicable legal requirements, and our legitimate business needs. |
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Coverage-Specific Information e.g. First name, last name, email address, phone number, physical address, vehicle information, driver’s license number, income, and employment related information. Source: Directly from you, service providers, vendors, business partners, affiliated entities, insurance and claims related parties, government agencies, regulators, consultants, and professional advisors.
|
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Disclosed:
Sold or Shared:
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For as long as reasonably necessary to underwrite policies, administer coverage, pay claims, comply with legal and regulatory obligations, resolve disputes, enforce agreements, and protect against fraud. Retention periods are determined based on the nature of the information, the purpose for which it was collected, and applicable legal requirements. |
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Internet or other similar network activity. Date and time of visits to the Site; pages viewed; links clicked; session identifiers; browser type and general device/browser characteristics; referring URLs; domain name from which the Site was accessed; form interaction information; and cookies or similar technologies. Source: Automatically when you interact with our Site.
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Analytics and service improvement. Business operations and service delivery. Providing and administering products and services. |
Disclosed: Data analytics service providers. Sold or Shared:
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Retained only as necessary for security (e.g., logs), debugging, and analytics controls. |
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Geolocation data. e.g. Physical location or movements, such as your zip code, the time and physical location related to use of our internet website or mobile application, or other information about your location or locations you visited. IP addresses are mapped to inferred geographic attributes. Source: Automatically when you interact with our Site.
|
Analyze and Improve Site. Business operations and service delivery. |
Disclosed: Data analytics service providers.Service providers and vendors.
Sold or Shared:
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Retained only as needed to provide/measure services and analytic controls, consistent with user preferences. |
|
(Not Collected) Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)) ("FERPA Information"). e.g. Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records. Source: None
|
Not Applicable |
Disclosed: No
Sold or Shared:
|
Not Applicable |
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Form and other Electronic Submission Data. e.g. Data submitted through the Site, including Contact Us forms and filing a claim. Source: Directly from you, Service providers, vendors, business partners, affiliated entities, government agencies, regulators, consultants, professional advisors.
|
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Disclosed:
Sold or Shared:
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Retained to fulfill the inquiries and records management. |
Personal information does not include:
Sensitive Personal Information (“SPI”) is a subtype of personal information consisting of the specific information categories listed in the chart below. Importantly, the CCPA only treats this information as SPI when we collect or use it to infer characteristics about a consumer. Of the above categories of Personal Information, the following are categories of SPI we may collect from or about consumers:
|
Sensitive Personal Information Category |
Collected to Infer Characteristics? |
Retention Criteria |
|
Government identifiers. e.g. Social Security number (SSN), driver's license, state identification card, or passport number |
No |
N/A |
|
Complete account access credentials. e.g. Usernames, account logins, account numbers, or card numbers combined with required access/security code or password. |
No |
N/A |
|
Precise geolocation. e.g. GPS data from a consumer's mobile device that can provide its location in a geographic area, with an approximate radius of 1,850 feet. |
No |
N/A |
|
Racial or ethnic origin. |
No |
N/A |
|
Citizenship or immigration status. |
No |
N/A |
|
Religious or philosophical beliefs. |
No |
N/A |
|
Union membership. |
No |
N/A |
|
Mail, email, or text messages not directed to the Company. |
No |
N/A |
|
Genetic data. |
No |
N/A |
|
Neural Data. e.g. Information generated by measuring a consumer's central or peripheral nervous system's activity that is not inferred from nonneural information. |
No |
N/A |
|
Unique identifying biometric information. |
No |
N/A |
|
Health information. |
No |
N/A |
|
Sex life or sexual orientation information. |
No |
N/A |
|
Children's personal information (under age 16). |
No |
N/A |
We process SPI only for the limited purposes permitted under Civil Code §1798.121(a):
If you are a California resident, the CCPA may provide you with the following rights regarding personal information we collect, use, disclose, and retain about you, subject to applicable exceptions and limitations.
Right to Know and Data Portability Requests. You have the right to request that we disclose certain information to you about our collection and use of your PI (the "right to know"), including the specific pieces of PI we have collected about you (a "data portability request"). Our response will cover the 12-month period preceding the request, although we will honor requests to cover longer periods that do not extend past January 1, 2022, unless doing so would be impossible or involve disproportionate effort. You may exercise your right to know twice in any 12-month period. Once we receive your request and confirm your identity (see Section: How to Exercise Your Rights), we will disclose to you:
We will confirm receipt of your request within ten business days. If you do not receive confirmation within the ten-day timeframe, please reach out to privacy@frankcrum.com. We endeavor to substantively respond to a verifiable request within 45 days of its receipt. If we require more time (up to another 45 days), we will inform you of the reason and extension period in writing. We will deliver our written response to your verified email address. Our substantive response will tell you whether we have complied with your request. If we cannot comply with your request in whole or in part, we will explain the reason, subject to any legal or regulatory restrictions. Applicable law may allow or require us to refuse to provide you with access to some or all the PI that we hold about you, or we may have destroyed, deleted, or made your PI anonymous in compliance with our record retention policies and obligations.
Any disclosures we provide will cover information for the 12-month period preceding the request receipt date. We will consider requests to provide longer disclosure periods that do not extend past January 1, 2022, unless providing a longer timeframe would be impossible or involves disproportionate effort.
For data portability requests, we will select a format to provide your PI that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance.
We do not charge a fee to process or respond to your verifiable request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.
Notice of Rights to Limit the Use of Your Sensitive Personal Information
We do not use or disclose your SPI for purposes that give rise to a right to limit the use and disclosure of your SPI under CCPA. Because we do not use SPI for purposes that trigger the right to limit under California law, a “Limit the Use of My Sensitive Personal Information” link is not applicable currently. If our practices change, we will provide that link and update this Policy.
We do not sell or share consumer PI, as those terms are defined by CCPA. As a result, consumers do not need to submit requests to opt out of the sale or sharing of PI. Because we do not sell or share consumer PI, we do not disclose such information to third parties for sale or sharing purposes, and there is no downstream opt‑out notification requirement applicable to our service providers or contractors. If our data‑handling practices change in the future in a manner that would trigger opt‑out rights, we will provide notice and any rights required under applicable law at that time.
If you are a California resident, you can authorize someone else as an authorized agent who can submit a request on your behalf. To do so, you must either:
The California Civil Code permits California residents with whom we have an established business relationship to request that we provide you with a list of certain categories of personal information that we have disclosed to third parties for their direct marketing purposes during the preceding calendar year. To make such a request, please send an email to privacy@frankcrum.com or write to us at the address listed below. Please mention that you are making a “California Shine the Light” inquiry.
We will not collect additional categories of personal information or use the personal information we collected for materially different, unrelated, or incompatible purposes without providing you notice. If required by law, we will also seek your consent before using your personal information for a new or unrelated purpose.
We will process privacy requests in accordance with applicable law and within the timeframes required by the laws that apply to your request. We may take steps to verify your identity and authority before fulfilling certain requests, and we may request additional information where necessary to do so.
Where permitted or required by law, we may deny a request in whole or in part, including where an exemption applies or where we are unable to verify the request. If we deny your request, we will explain the basis for the denial to the extent permitted by law.
Where applicable law provides an appeal right, we will describe how to appeal a denial in our response.
We do not use personal information for targeted advertising, and we do not engage in profiling for decisions that have legal or similarly significant effects on you as a consumer. We also do not use automated decision-making to make such significant decisions on this Site. Where required by applicable law, consumers may contact us using the request methods described in this Policy to inquire about rights that may apply to their personal information. If our practices change, we will update this Policy and provide any required notices, rights, or opt-out mechanisms.
To exercise your rights described above, please submit a verifiable request to us by either:
We may collect your personal information from the following sources:
We disclose personal information only to the categories of recipients listed below for business and commercial purposes:
We contractually require service providers, contractors, and other recipients that process personal information on our behalf to keep it confidential and use it only for the limited purposes for which we disclose it to them, unless otherwise permitted or required by law.
We do not sell personal information for monetary or other valuable consideration, and we do not share personal information for cross-context behavioral advertising.
We may collect, use, and disclose your personal information for any of the following business and commercial purposes:
The use of information we collect, whether connected to your personal information or not, helps us improve our website and delivers a better and more personalized experience by enabling us to:
Our website may store or retrieve information on your browser, mainly in the form of cookies or similar technologies. Cookies are small text files placed on your device to help website function, remember your preferences, maintain security, and understand how users interact with the Site. We use first-party cookies for website functionality, security, and measurement. We also use limited third-party analytics technologies to help us understand website performance and navigation. We do not use cookies or similar technologies on this Site for cross-context behavioral advertising, retargeting, or targeted advertising.
We use cookies and similar technologies for the following purposes:
Provide and maintain Site functionality and security.
Essential Cookies
Essential cookies are necessary for the website to function properly and cannot be switched off in our systems. They are usually set in response to actions made by a visitor, such as setting privacy preferences, logging in, or filling in forms. You can configure your browser to block or alert you about these cookies, but some parts of the Site may not then work properly.
Non-Essential Cookies
Non-essential cookies are used only for limited analytics, functionality, and measurement purposes on this Site.
Performance cookies help us understand how visitors interact with the Site, such as pages visited, links clicked, general traffic patterns, and traffic sources.
Functional cookies support user preferences and enhanced functionality, such as language settings, display preferences, and secure session management.
Because we do not sell personal information or share personal information for cross-context behavioral advertising, advertising industry opt-out tools are not required for this Site. We nevertheless honor browser settings and user controls that manage cookies at the browser or device level, subject to the limitations of those controls.
You can manage cookies through your browser or device settings. Most browsers allow you to review, block, or delete cookies, and some browsers allow you to set preferences for certain websites. If you choose to block or delete cookies, some features of the Site may not function properly.
Where available, you may also use controls provided by your browser, device, or the Site to manage certain cookie preferences. These tools may not affect all technologies, and their effectiveness depends on the browser, device, and settings you use.
Do Not Track (DNT) is a browser preference some users enable to signal that they do not want online activity tracked. Because there is no consistent industry standard for DNT, our Site does not respond differently to DNT signals. Users may still manage cookies and similar technologies through browser, device, and Site controls where available.
Depending on your state of residence, the nature of your relationship with us, and the type of personal information at issue, you may have certain rights under applicable state privacy laws, subject to exceptions and limitations.
Access and Confirmation. You may have the right to confirm whether we process your PI and to access a copy of the PI we maintain about you, subject to applicable legal exceptions.
Data Portability. You may confirm whether we process your PI and access a copy of the PI we process. To the extent feasible and required by state law, depending on your state, data will be provided in a portable format. Depending on your state, you may have the right to receive additional information, and it will be included in the response to your access request.
Correction. You may request that we correct inaccuracies in your PI that we maintain, considering the information's nature and purpose of processing.
Deletion. You may have the right to request that we delete PI we maintain about you, subject to applicable exceptions, including where retention is required or permitted for compliance or recordkeeping purposes.
Opt‑Out of Certain Processing (Where Applicable). In limited circumstances and only where required by applicable state law, you may have the right to opt out of certain types of PI processing, such as targeted advertising, the sale of personal information, or profiling in furtherance of decisions that produce legal or similarly significant effects. Companies do not sell PI for monetary or other valuable considerations or share for cross-context behavioral advertising.
Appeal. Appeal our decision regarding your privacy rights request (where required by law). Unless otherwise required by state law, your appeal rights apply to any denied request, and we will provide a written outcome within the period required by your state of residence. If we deny your request, you may appeal by emailing privacy@frankcrum.com with the subject line Privacy Rights Appeal.
Important: The scope of these rights varies by state and may not apply in all circumstances. Certain personal information may be exempt from state privacy laws, including information collected, processed, disclosed, or retained pursuant to applicable federal or state financial privacy laws, insurance laws, or related regulations.
To exercise your rights, please submit a verifiable request to us by either:
We maintain retention schedules aligned with legal, regulatory, tax, and contractual requirements and delete or de‑identify data when no longer needed. We keep the categories of personal information described in this Policy for as long as reasonably necessary to fulfill the purposes described or for as otherwise legally permitted or required, such as maintaining the Site, operating our organization, complying with our legal obligations, resolving disputes, and for safety, security, and fraud prevention. This means that we consider our legal and business obligations, potential risks of harm, and nature of the information when deciding how long to retain personal information. At the end of the retention period, personal information will be deleted, destroyed, or deidentified. We align retention to data minimization and reasonable expectations for each purpose, and we honor opt‑outs for at least 12 months before seeking reauthorization.
We limit our collection, use, and retention of personal information to what is reasonably necessary and proportionate for the purposes described in this Policy.
Our website contains links to other websites. We are not responsible for the privacy practices or the content of such websites. To help ensure the protection of your privacy, we recommend that you review the Policy of any website you visit via a link from our website. If you access our website through a mobile device, your device or browser may prompt you to grant permission for features such as location, push notifications, or camera access. You can revoke these permissions at any time through your device settings.
When you receive an email from us, we may use tracking technologies to gather certain information about your interaction with the email. Specifically, we may collect whether you open the email; the time and date when you open it; and the Internet Protocol (IP) address of the device used to open the email.
We use this information to help us understand how our emails are received and used, so we can improve content, deliverability, and relevance. This tracking is done automatically using a small, often invisible image (sometimes called a “tracking pixel” or “pixel”) embedded in the email or similar methods.
If you prefer not to have this information tracked, you may disable automatic image loading in your email client or use settings/tools that block tracking pixels. Additionally, unsubscribing from our email list will stop further emails (and thus tracking) from us.
We do not use automated decision‑making systems, including machine learning or AI tools to make decisions that produce legal or similarly significant effects about you. This includes decisions relating to eligibility for, or access to, credit, employment, housing, financial services, essential or federally regulated services, or other outcomes that could meaningfully affect your rights or opportunities. If any automated output could influence how we present content or offer to you on the website, those outputs operate within pre‑defined parameters and are either reviewed or overseen by people or constrained, so they do not produce legal or similarly significant effects.
We do not engage in profiling for decisions that have legal or similarly significant effects on you. If we ever begin using profiling in a way that implies additional rights (for example, under the laws of states that provide opt‑out rights for certain profiling), we will update this Policy and provide any required opt‑out mechanisms.
If we materially change how we use automated decision-making, profiling, or AI, including if future law requires additional disclosures, access, appeal, or opt-out rights for such processing, we will update this Policy and provide any required tools, disclosures, and instructions at or before the time those changes take effect.
We may disclose specific personal and/or sensitive personal information based on a good faith belief that such disclosure is necessary to comply with or conform to the law or that such disclosure is necessary to protect employees or the public.
We use commercially reasonable administrative, physical, and technical measures designed to protect your personal information from accidental loss or destruction and from unauthorized access, use, alteration, and disclosure. However, no website, mobile application, system, electronic storage, or online service is completely secure, and we cannot guarantee the security of your personal information transmitted to, through use, or in connection with the Site. Communications sent to or from the Site may not be secure, and you should carefully decide what information you send to us via such communications channels. Any transmission of personal information is at your own risk. The safety and security of your information also depend on you. You are responsible for taking steps to protect your personal information against unauthorized use, disclosure, and access.
The personal information in your account, including your insurance policies, claims, and payment information, is protected by a unique password you create. To maintain the security of your account, you should not share your password with any third party.
We have not knowingly collected or processed personal information pertaining to children under the age of 16. We do not knowingly collect personal information directly from children under 16 through the Site or our Services without appropriate authorization. In some circumstances, we may receive information about minors from parents, guardians, policyholders, employers, claim representatives, or other authorized persons in connection with insurance products, services, claims, or related activities. If we learn that we have collected personal information directly from a child under 16 through our Site without authorization required by applicable law, we will take appropriate steps to delete or otherwise address that information. If you believe we may have collected personal information from or about a child under 16 inappropriately, please contact us at privacy@frankcrum.com.
Our website is intended only for U.S. audiences; individuals outside the U.S. should not submit personal information.
We may contact you with marketing information that may be of interest to you. You may opt out of receiving any or all these marketing communications from us by following the Your Privacy Choices link or instructions provided in any email we send or by contacting us. Please note that we may still send you transactional, administrative messages, or product updates related to the Service even after you have opted out of receiving marketing communications.
This Policy describes how we handle personal information when you use our Site.
We may update this Policy from time to time, and we will provide notice of any such changes to the Policy as required by law. The date the Policy was last updated is identified at the top of the page. We will notify you of changes to this Policy by updating the "last updated" date and posting the updated Policy on the Site. We may email or otherwise communicate reminders about this Policy, but you should check our Site periodically to see the current Policy and any changes we have made to it.
If you need this Policy in an alternative format, please contact us using the information below.
To exercise your rights or ask questions or comment about this Policy or our privacy practices, contact us at: privacy@frankcrum.com or via our toll-free number: 1-800-393-0815, Option 21.