Effective Date: 21 Jan 2022
This Privacy Policy describes how Blitz Servicing LLC and its subsidiaries and affiliates, including without limitation, Blitz Insurance Corp. and Blitz Insurance I.I. (collectively, “Blitz,” “we,” “us” and/or “our”) collects, uses, shares and safeguards personal information.
This privacy policy (“Privacy Policy”) applies to personal data that we collect from you as a user of this Site or as a client or customer (“you” or “your” being interpreted accordingly). It provides information on what personal data we collect, why we collect the personal data, how it is used and the lawful basis on which your personal data is processed, and what your rights are under the applicable data protection and privacy laws, including the General Data Protection Regulation (“GDPR”) which became applicable to us and you as of May 2018, and for California residents, under the California Consumer Protection Act (“CCPA”).
Personal data as used in this Privacy Policy means any information that can be used to directly or indirectly identify an individual, and may include your name, address, email address, phone number, contact preferences, and Internet Protocol (“IP”) address. As of the date of this Privacy Policy, we do not collect any personal data through this Site other than your IP address.
This Privacy Policy excludes those websites and online services that have separate privacy policies and that do not incorporate this Privacy Policy by reference or otherwise.
By using our Site or submitting your personal data you are agreeing to accept the terms of this Privacy Policy, so please read it carefully.
The types of information we collect concerning individuals includes:
In connection with a job inquiry or application on our careers pages, you may provide: login credentials; information regarding your work authorization status, education history, current or past job/employment history and professional designations; performance evaluations; and other information about your background and qualifications. In addition, where legally permissible, you may provide information regarding your gender, race/ethnicity, and your veteran and disability status. Blitz will not consider either this information or your choice to decline to provide it in evaluating your qualifications for employment with us. This information will be used only for Equal Employment Opportunity reporting and other legal and compliance purposes.
Depending on the nature of our relationship with you, in the past 12 months we may have collected Personal Data concerning you in the following categories:
Other information
In connection with electronic interactions you have with us or our service providers (including by email, phone or other forms of electronic communication), we may record and monitor details of those interactions, including their content, to the extent permitted or required by applicable law.
We may also collect some information from other sources, including:
When you visit our Sites or open our emails, we may collect certain information by automated means (such as by cookies, web server logs, web beacons and JavaScript). The information we collect in this manner includes your IP address, network location, browser characteristics, device characteristics, operating system, referring URLs, information on actions taken on our Sites, and dates and times of website visits. Cookies are files that websites send to your computer or other Internet-connected device to uniquely identify your browser or to store information or settings on your device. We also may use these and similar technology in emails we send you to collect certain information, such as whether you opened or clicked on links in our email.
Our Sites may use cookies (such as HTTP, HTML5 and Flash cookies) as well as other types of local storage (such as browser-based or plugin-based local storage). Some of these cookies may be placed by third parties such as our service providers. Your browser may tell you how to be notified when you receive certain types of cookies and how to restrict or disable certain cookies. You also may be able to delete your Flash cookies or adjust your Flash cookie settings by visiting the Adobe Flash Website Storage Settings Panel and Global Storage Settings Panel. Please note, however, that without cookies you may not be able to use all of the features of our Sites or other websites and online services.
In conjunction with gathering information through cookies, our web servers may log information such as your device type, operating system type, browser type, domain, and other system settings, as well as the language your system uses and the country and time zone in which your device is located. We also may record information such as the address of the web page that referred you to our Sites and the IP address of the device you used to connect to our Sites. We may log information about your interaction with the Sites, such as which pages you visit. To control which web servers collect information by automated means, we may place tags on our web pages called “web beacons”, which are small files that link web pages to particular web servers and their cookies. We also may send instructions to your device using JavaScript or other computer languages to gather the sorts of information described above and other details about your interactions with the Sites.
We may use third-party web analytics services on our Sites, such as those of Google Analytics. These service providers help us analyze how visitors use the Sites. The information obtained for this purpose (including your IP address and other information collected by automated means) may be disclosed to or collected directly by these service providers. To learn about opting out of Google Analytics, please click here.
The providers of third-party plugins and widgets on our Sites, such as embedded videos and social media sharing tools, may use automated means to collect information regarding your use of the Sites and your interactions with the plugins and widgets. This information is subject to the privacy policies or notices of the providers of the plugins and widgets.
We do not knowingly collect any personal information from children under the age of 13 years. Our products, services, and websites are not intended for use by minors. We do not sell the personal information of minors under 16 years of age without affirmative authorization.
We may use, disclose or otherwise handle the information described in this Online Privacy Notice for the following purposes to:
In addition, we use information collected through cookies, web beacons, web server logs and other automated means for purposes such as (a) customizing our users’ visits to our Sites, (b) delivering content tailored to our users’ interests and the manner in which our users browse our Sites, and (c) managing our Sites and other aspects of our business.
In many situations we have more than one purpose in collecting and using your information. We may also use the information in other ways for which we provide specific notice at the time of collection.
We will only process your Personal Data as necessary so that we can pursue the purposes described above. Where we process your Personal Data for our legitimate interests as a business or those of a third party, we do so only where we have concluded that our processing does not prejudice you or your privacy in a way that would override our legitimate interest in pursuing those purposes.
When we collect Personal Data from you, unless indicated otherwise, you should assume that, if we ask you for information, we need it for our business or compliance purposes. In limited circumstances, we are required to collect Personal Data to comply with a legal obligation and/or might ask you to provide information that is purely voluntary; in either case, this will be indicated to you.
If you are a former employee, worker, or contractor of Blitz, we will continue to process your Personal Data for a reasonable period following the end of your employment or engagement for our legitimate business and/or our legal compliance purposes and/or for the establishment or defense of a legal claim. Further, in some instances, we may process your data to perform our obligations under the contract between us (e.g. to pay you your final salary payment after your termination date). We only carry out such processing where we have concluded that our processing does not prejudice you or your privacy in a way that would override our legitimate interests in pursuing those purposes. Your data will be retained and deleted in accordance with our retention policies and procedures (as discussed further below).
We and third parties acting on our behalf (such as Facebook, Twitter and LinkedIn) may collect information about your online activities over time and across third-party websites to provide you with advertising about products and services tailored to your interests. Where required by applicable law, we will obtain your consent for the processing of your Personal Data for direct marketing purposes.
You may see our ads on other websites or mobile apps because we participate in advertising networks. Ad networks allow us to target our messaging to users by considering demographic data, users’ inferred interests and browsing context. These networks track users’ online activities over time by collecting information through automated means (such as by cookies, web server logs, web beacons and other similar technologies). The networks use this information to show ads that may be tailored to individuals’ interests, to track users’ browsers or devices across multiple websites or apps, and to build a profile of users’ online browsing activities. The information our ad networks may collect includes data about users’ visits to websites and apps that participate in the relevant ad networks, such as the pages or ads viewed and the actions taken on the websites or apps. This data collection takes place both on the Sites and on third-party websites and apps that participate in the ad networks. This process also helps us track the effectiveness of our marketing efforts. The Sites are not designed to respond to “do not track” signals received from browsers. To learn how to opt out of ad network interest-based advertising, please visit www.aboutads.info/choices, http://www.networkadvertising.org/choices/ or http://www.youronlinechoices.eu/.
We do not disclose Personal Data we obtain about you through the Sites or other channels covered by this Online Privacy Notice, except as described in this Online Privacy Notice. We may share your Personal Data with our affiliates and subsidiaries. Depending on the nature of our relationship with you, we also share Personal Data with service providers who perform services on our behalf, our financial and transaction counterparties, our professional advisors, and your agents and representatives. We do not authorize these persons to use or disclose the information except as necessary for the purposes for which it is provided or to comply with legal requirements.
We also may disclose information about you (1) if we are required to do so by law or legal process, (2) to law enforcement authorities, regulators, or other government entities or other competent authorities based on a lawful disclosure request, or (3) when we believe disclosure is necessary or appropriate to prevent harm or financial loss, or in connection with an investigation of suspected or actual fraudulent or illegal activity. We reserve the right to transfer Personal Data we have about you in the event that we sell or transfer all or a portion of our business or assets (including in the event of a reorganization, spin-off, dissolution or liquidation).
In addition, we may share anonymous/aggregated information with third parties, such as service providers, in order to facilitate our business operations.
Information collected through third-party plug-ins and widgets on the Sites (such as information relating to your use of a social media sharing tool) is collected directly by the providers of the plug-ins and widgets. This information is subject to the privacy policies of the providers of the plug-ins and widgets, and Blitz is not responsible for those providers’ information practices.
For California Residents, in the preceding 12 months, we may have disclosed Personal Data listed in any of the categories in the “Information We Obtain” section above for business purposes (in particular, as described in this section).
We have not sold Personal Data in the 12 months preceding the date of this Online Privacy Notice.
We may transfer the Personal Data we collect about you to recipients in countries other than the country in which the information was originally collected. If you are based in the UK, the EU, or another country that imposes data transfer restrictions outside of its territory, this includes transfers outside of the UK and the European Economic Area (“EEA”) or that geographical area, including to those countries in which our affiliates, group members, service providers and business partners operate. Those countries may not have the same data protection laws as the country in which you initially provided the information. Where we transfer Personal Data outside of the UK, the EEA, or other territories subject to data transfer restrictions to other members of Blitz or our service providers, we will ensure that our arrangements with them are governed by data transfer agreements or safeguards, designed to ensure that your Personal Data is protected as required under applicable data protection law (including, where appropriate, under an agreement on terms approved for this purpose by the European Commission or by obtaining your consent).
We intend to keep your Personal Data accurate and up-to-date. We will delete the information that we hold about you when we no longer need it. We retain your Personal Data for as long as it is required by us for our legitimate purposes, to perform our contractual obligations, or where longer, such longer period as is required or permitted by law or regulatory obligations which apply to us.
We will retain your information in line with our retention policies and, in any event, for no longer than is necessary given the purpose for which it was collected, after which it will be deleted or anonymized.
Note that we may retain some limited information about you (even when we know that you have left the organization that you represent) so that we can maintain a continuous relationship with you if and when we are in contact with you again.
We offer you certain choices in connection with the Personal Data we collect from you. To update your preferences or submit a request, please contact us as indicated in the “How to Contact Us” section of this Online Privacy Notice. To the extent provided by the law of your jurisdiction or otherwise applicable to our processing of your information, you may request access to the Personal Data we maintain about you or request that we correct, amend, delete or block the information by contacting us as indicated below. Where provided by law, you may withdraw any consent you previously provided to us or object at any time on legitimate grounds to the processing of your Personal Data, and we will apply your preferences going forward. You can also lodge a complaint about our processing of your Personal Data with the body regulating data protection in your country.
These rights, subject to certain limitations, may include:
Rights of access, correction and deletion. You may have a right of access to the Personal Data that we hold about you, and to some related information, including the purpose for processing the Personal Data, the categories of recipients of that Personal Data to the extent it has been transferred internationally, and, where the Personal Data has not been collated directly from you, the source (the “category information”). You may also have the right to require any inaccurate Personal Data to be corrected or deleted.
Right to object, and portability. You can object to our use of your Personal Data for direct marketing purposes at any time and you may have the right to object to our processing of some or all of your Personal Data (and require it to be deleted) in some other circumstances. In some circumstances, you may also have a “data portability” right to require us to transfer your Personal Data to you or a third party, in a data portable format.
California residents may also request certain information about our disclosure of Personal Data during the prior year, including category information (as defined above).
We review and verify requests to protect your Personal Data, and will action data protection requests fairly and in accordance with applicable data protection laws and principles.
If you wish to exercise any of these rights, please contact us as set out below.
Complaints. You can also lodge a complaint about our processing of your Personal Data with the body regulating data protection in your country.
We maintain administrative, technical and physical safeguards designed to protect Personal Data we obtain through the Sites against accidental, unlawful or unauthorized destruction, loss, alteration, access, disclosure or use. However, no method of transmission over the internet or electronic storage is fully secure. While we use reasonable efforts to protect your personal information from unauthorized access, use, or disclosure, we cannot guarantee the security of such information.
Some of our Sites may permit you to create an account and a password. You are responsible for maintaining the confidentiality of your password, as well as any access to or use of your account by someone that has obtained your password, whether or not you have authorized such access or use. You can notify us of any unauthorized use of your password by contacting us using the contact information below.
Our Sites may provide links to other websites that we think might be of interest to our users (“Linked Sites”). Please note that when you click on one of these links and go to a Linked Site, you may be moving to another provider’s website. Such Linked Sites are not under the control of Blitz, and Blitz is not responsible for the contents or the proper operation of any Linked Site, including without limitation any link contained in a Linked Site, or any changes or updates to a Linked Site. The inclusion of any link does not imply endorsement by Blitz or any association with its operators. Blitz cannot control the activities of any such provider once a user leaves our site. We encourage you to read the terms of use and privacy statements of these Linked Sites as their policies may differ from ours.
If you are based in the European Union (EU) we may need to transfer your personal data to recipients outside of the EU.
This may happen if our servers or our suppliers or service providers are based outside the EU or if you visit our website while traveling to countries outside this area.
We only make these transfers, where the EU has made an “adequacy decision” for the country to which the data will be transferred or where we have put in place the “appropriate safeguards” that the law requires.
We seek to use reasonable organizational, technical and administrative measures to protect personal data. Unfortunately, no data transmission or storage system can be guaranteed to be 100% secure. If you have reason to believe that your interaction with us is no longer secure (for example, if you feel that the security of your account has been compromised), please immediately notify us in accordance with the “Contact Us” section below.
We will keep your personal data only for as long as is reasonably necessary for the purposes outlined in this Privacy Policy, or for the duration required by any legal, regulatory, accounting or reporting requirements, whichever is longer. Upon expiration of the applicable retention period we will destroy your personal data in accordance with applicable laws and regulations. In some circumstances we may anonymize your personal data so that it can no longer be associated with you, in which case it is no longer personal data.
If the GDPR applies to personal data, it gives individuals resident in the EU certain rights that they can exercise free of charge. These include the:
If you would like to assert one or more of these rights, please email or write to us at the address set out in the “Contact Us” section of the Privacy Policy. We will respond to your requests within all applicable timeframes.
You may also unsubscribe from receiving our email marketing communications at any time by following the “unsubscribe” instructions included in our communication.
California defines the “sale” of data very broadly, including the sharing of Personal Information with third parties. California defines a “sale” as “selling, renting, releasing, disclosing, disseminating, making available, transferring, or otherwise communicating orally, in writing, or by electronic or other means, a consumer’s Personal Information by the business to another business or a third party for monetary or other valuable consideration.”
As explained above, certain sharing of your Personal Information is necessary for us to complete any transaction that you enter into with Blitz. If you choose to enter into certain transactions with Blitz, a certain amount of sharing of your Personal Information is required to perform our transactional obligations, to run our business and provide any services to you as a customer. We do not otherwise sell California residents’ Personal Information.
California residents have rights under the California Civil Code Section 1798.100, et seq. These rights are as follows:
If you are a California resident, you may request that we:
We do not “sell” the Personal Information of individuals under the age of 16.
We may from time to time elect to share certain information about you collected by us on the Site with third parties for those third parties’ direct marketing purposes. California Civil Code Section 1798.83 permits California residents who have supplied Personal Information, as defined in the statute, to us, under certain circumstances, to request and obtain certain information regarding our disclosure, if any, of Personal Information to third parties for their direct marketing purposes. If this applies, you may obtain the categories of Personal Information shared and the names and addresses of all third parties that received Personal Information for their direct marketing purposes during the immediately prior calendar year (e.g., requests made in 2021 will receive information about 2020 sharing activities).
To make such a request, please provide sufficient information for us to determine if this applies to you, attest to the fact that you are a California resident and provide a current California address for our response. To make such a request (limit one request per year), please submit a written request to us using the “Contact Us” method below (limit one request per year).
Please note that if we are unable to verify your identity to a degree of certainty as required by the CCPA through any reasonable method, we will state that we are unable to verify in a written response to you along with a reason as to why there is no reasonable method by which we can verify your identity. We will evaluate our methods for verifying the identity of all consumers who request to know or delete Personal Information on a yearly basis.
If all the consumers of a household jointly request access to specific pieces of information for the consumers of the household or deletion of the household’s Personal Information, we will comply with the request if we can verify the identity of all members of the household pursuant to our procedures for identity verification mentioned above.
As a California resident, you may designate an authorized agent to act on your behalf to make a request under the CCPA, such as requesting disclosure of any Personal Information we have sold or collected; or requesting deletion of such Personal Information. If you should use an authorized agent to exercise your various rights under the CCPA, we may require that you provide your authorized agent with written permission to exercise your various rights and to verify your own identity with us through the processes laid out in the section titled Exercising California Residents’ Privacy Rights, above. If your authorized agent does not submit proof that they have been authorized by you to submit verified requests for disclosure and deletion, we reserve the right to deny such a request that we have received and will explain to your authorized agent why we have denied such request.
Please contact us to access this Privacy Policy through alternative means if you are visually impaired.
This Online Privacy Notice may be updated periodically and without prior notice to you to reflect changes in our Personal Data practices. We will post the updated version on the Sites and indicate at the top of the Notice when it was most recently updated. Your continued use of our website following the posting of an updated Privacy Policy constitutes your consent to such new privacy policy. Please check for any updates regularly.
If you have any questions or comments about this Privacy Notice, or if you would like us to update information we have about you or your preferences, please email us at privacy@lightstonegroup.com.
You also may write to:
Blitz Servicing LLC
Attn: General Counsel
1985 Cedar Bridge Avenue, Suite 1
Lakewood, NJ 08701
Copyright 2022 by Blitz Servicing LLC
