Additional Privacy Information for California Residents
Last updated January 25, 2023
Your privacy is important to us at Enact Holdings, Inc. and its affiliates and subsidiaries (“Enact”) and we are committed to safeguarding, preserving, and respecting your privacy rights. This Privacy Notice (“Notice”) is in accordance with the California Consumer Privacy Act of 2018 (“CCPA”), as amended by the California Privacy Rights Act and implementing regulations. This Notice provides how Enact collects, uses, and discloses personal information about California residents. Personal information is defined by the CCPA to mean information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household. However, please note that not all personal information collected, used or disclosed by Enact is subject to the CCPA, and we reserve the right to limit our response where permitted by applicable law.
California Residents are referred to in this Notice as “you” and “your” and Enact is referred to in this Notice as “we”, “us,” and “our.”
I. Information We Collect
Over the past 12 months, we may have collected the following personal information about you depending on our specific transaction with you:
- Identifiers such as a real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, social security number, driver’s license number, passport number, or other similar identifiers that are capable of being associated with a particular individual.
- Characteristics of protected classifications under California or federal law, such as your race or sex.
- Commercial information, including records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.
- Biometric information, such as voice prints.
- Internet or other electronic network activity information, including, but not limited to, browsing history, search history, and information regarding your interaction with an Internet Web site, application, or advertisement.
- Geolocation data, such as device location.
- Audio, electronic, visual, thermal, olfactory, or similar information, such as call recordings.
- Professional or employment-related information, such as your employment history.
- Education information, such as your school records or degrees earned.
- Inferences drawn from any of the information identified above to create a profile about you reflecting your preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.
Enact may receive this personal information directly from you or indirectly from you through your use of our websites or your other interactions with us. We may also receive this information from our affiliates, subsidiaries, vendors, or service providers. Enact collects this information for the following business or commercial purposes:
- Identifiers such as a real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, social security number, driver’s license number, passport number, or other similar identifiers that are capable of being associated with a particular individual.
- Personal information such as your name, Social Security number, physical characteristics or description, address, telephone number, passport number, driver’s license or state identification card number, insurance policy number, education, employment, employment history, 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.
- Characteristics of protected classifications under California or federal law, such as your race, color, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex, sexual orientation, or veteran or military status.
- Commercial information, including records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.
- Biometric information, such as voice prints.
- Internet or other electronic network activity information, including, but not limited to, browsing history, search history, and information regarding your interaction with a website, application, or advertisement.
- Geolocation data, such as device location.
- Audio, electronic, visual, thermal, olfactory, or similar information, such as call recordings.
- Professional or employment-related information, such as your employment history.
- Education information, such as your school records or degrees earned.
- Inferences drawn from any of the information identified above to create a profile about you reflecting your preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.
- Sensitive personal information that reveals your (a) Social Security number, driver’s license, state identification card, or passport number; (b) account log-in, financial account, debt card, or credit card number in combination with any required security or access code, password, or credential allowing access to an account; (c) precise geolocation; (d) racial or ethnic origin, religious or philosophical beliefs, or union membership; (e) the contents of a consumer’s mail, email, and text messages unless the business is the intended recipient of the communications; or (f) genetic data. Some Sensitive Personal Information included in this category may overlap with other categories.
Enact may receive this personal information directly from you or indirectly from you through your use of our websites, your other interactions with us, or the application for mortgage insurance (along with any supporting documentation) submitted to us by your lender or servicer. We may also receive this information from our affiliates, subsidiaries, vendors, or service providers. Enact collects this information for the following business or commercial purposes:
- The provision of mortgage insurance as requested by you or your lender or servicer.
- Marketing our products and services to you, including responding to your requests for product or service information.
- Researching and analyzing our marketing efforts.
- Responding to legal requests and complying with regulatory requirements.
- Auditing our interactions and concurrent transactions with you, including, but not limited to, counting ad impressions to unique visitors, verifying positioning and quality of ad impressions, and auditing compliance with this specification and other standards.
- Detecting security incidents, protecting against malicious, deceptive, fraudulent, or illegal activity.
- Debugging to identify and repair errors that impair existing intended functionality of our websites and other interactions with you.
- Short-term, transient use, when your personal information is not disclosed to another third party and is not used to build a profile about you or otherwise alter your experience outside the current interaction.
- Maintaining or servicing accounts, providing customer service, processing or fulfilling orders and transactions, verifying customer information, processing payments, providing financing, providing advertising or marketing services, providing analytic services, or providing similar services.
- Undertaking internal research for technological development and demonstration, including the use of session replay services for website maintenance and improvement.
- Undertaking activities to verify or maintain the quality or safety of a service or device that is owned, manufactured, manufactured for, or controlled by us, and to improve, upgrade, or enhance the service or device that is owned, manufactured, manufactured for, or controlled by us.
Enact will retain this information no longer than is reasonably necessary to fulfill the purposes listed above, or as required to comply with applicable law.
II. Information We Share
Over the last twelve (12) months, we may have disclosed your personal information to a third party, such as a vendor or service provider, for a business or commercial purpose. The types of personal information disclosed and the business and commercial purposes are consistent with what is described in Section I of this Notice.
We do not sell your personal information to third parties.
III. Your Rights
a. Right to Request.
You have the right to request that we disclose the personal information we collect, use, and disclose about you to third parties. Specifically, you have a right to request that we provide you with the following:
- The categories of personal information we have collected or shared about you.
- The categories of sources from which the personal information is collected.
- The business or commercial purpose for collecting or sharing personal information.
- The categories of personal information that we have disclosed about you for a business purpose.
- The categories of third parties with whom the business shares personal information.
- The specific pieces of personal information we have collected about you.
You may request this information twice in a 12-month period.
b. Right of Deletion.
You also have the right to request that we delete personal information about you.
c. Right to Opt-Out of the Sale or Sharing of Personal Information.
You have the right to opt-out of the sale or sharing of your personal information by a business subject to certain laws and regulations.
We recognize the Global Privacy Control. Your browser must be able to support the Global Privacy Control for us to recognize your opt-out preference signal.
Please note that opt-out choices may be stored via cookies. If you clear cookies, if your browser blocks cookies, or if you view the page from a different browser or device, your opt-out choice may no longer be logged or recognized.
Please note that we may not be able to honor all requests. The reasons we may not be able to honor your requests include, but are not limited to, the following:
- We may not be able to verify your identity;
- We may not be able to verify you have the authority to request on behalf of someone else;
- The information you request is exempt from the requirements of the CCPA or CPRA or to the CCPA or CPRA requirements of requesting to know or delete; or
- You have requested this information more than twice during a twelve (12) month period.
Further, we are not required to provide you with information about any personal information about you that was collected for a single one-time transaction if, in the ordinary course of business, that information about you is not retained. We are also not required to reidentify or otherwise link any data that, in the ordinary course of business, is not maintained in a manner that would be considered personal information. If we are not able to fully accommodate your request, we will specify the reason during our response to you.
d. Right to Non-Discrimination.
You have the right not to receive discriminatory treatment for exercising the privacy rights conferred by California law. We will not discriminate against you because you exercised any of your privacy rights, including, but not limited to, by: denying goods or services to you; charging different prices or rates for goods or services, including through the use of discounts or other benefits or imposing penalties; providing a different level of quality of goods or services to you; or suggesting that you will receive a different price or rate for goods or services or a different level or quality of goods or services. We will also not retaliate against any employee, applicant for employment, or independent contractor for exercising their rights under the CCPA.
e. Right of Correction.
If we maintain inaccurate personal information about you, then you have the right to request that we correct the inaccurate personal information upon receipt of a verifiable request. Taking into account the nature of the personal information and purposes of processing the personal information, you have the right to request that we correct inaccurate personal information about you, if applicable.
f. Right to Limit Use and Disclosure of Sensitive Personal Information.
If we process Sensitive Personal Information (as defined in Cal. Civ. Code § 1798.140(ae) (effective Jan. 1, 2023)), we do so only for the purposes specifically authorized by California law and in a manner that is necessary and proportionate for those purposes. As such, we do not perform any processing for which a Right to Limit request is available.
IV. How to Make a Request to Know, to Delete, or to Correct Personal Information
If you would like to make a request to know the personal information we have collected or maintained about you or if you would like to request we delete your personal information, please submit your request using our Online Form or please call the ActionCenter at 800 444.5664 Monday through Friday 8:00 AM to 8:00 PM ET. If using the contact form, please put “CCPA Request” in the comment section along with details of your specific request. You will also need to indicate whether you are acting on another’s behalf and indicate in what capacity you are acting. For example, if you are acting as attorney-in-fact pursuant to a power of attorney, we will require you to provide us with a copy of the power of attorney. If not acting as an attorney-in-fact or in a manner ordered by a court, you will need to provide us with notarized written permission from the individual. If submitting an online request, you will not need to submit these documents in the initial request. We will reach out to you separately with instructions.
Based on the information you provide us in the contact form or over the phone, we may need additional information to verify your identity. If we have questions regarding your identity after we receive your request, we will contact you for additional information.
You may also choose a person or a business registered with the California Secretary of State that you authorize to act on your behalf to submit your requests (“Authorized Agent”). If you choose to use an Authorized Agent, we require that you provide the Authorized Agent with written permission to allow them to submit your request and that you verify your identity directly with us. Failure to do so may result in Enact denying your request.
V. Specific Rights for Employees and Contractors
As a job applicant, employee, or contractor of Enact, you have certain rights under the CCPA. Among those rights include knowing the categories of information we collect about you and the purpose(s) for which we will use your personal information. Also, we cannot collect additional categories of personal information about you or use your personal information for additional purposes without providing you with an additional notice. Please see below for the categories of personal information Enact collects as well as the purposes for which we collect that information.
The categories of information we collect about job applicants, employees, and contractors may include the following:
- Identifiers such as a real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, social security number, driver’s license number, passport number, or other similar identifiers that are capable of being associated with a particular individual.
- Personal Information, such as your name, Social Security number, physical characteristics or description, address, telephone number, passport number, driver’s license or state identification card number, insurance policy number, education, employment, employment history, 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.
- Characteristics of protected classifications under California or federal law, such as your race, color, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender identity), sexual orientation, or veteran or military status.
- Commercial information, including records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.
- Biometric information, such as voice prints.
- Internet or other electronic network activity information, including, but not limited to, browsing history, search history, and information regarding your interaction with a web site, application, or advertisement.
- Geolocation data, such as device location.
- Audio, electronic, visual, thermal, olfactory, or similar information, such as call recordings.
- Professional or employment-related information, such as your employment history.
- Education information, such as your school records or degrees earned.
- Inferences drawn from any of the information identified above to create a profile about you reflecting your preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.
- Sensitive personal information that reveals your (a) Social Security number, driver’s license, state identification card, or passport number; (b) account log-in, financial account, debt card, or credit card number in combination with any required security or access code, password, or credential allowing access to an account; (c) precise geolocation; (d) racial or ethnic origin, religious or philosophical beliefs, or union membership; (e) the contents of a consumer’s mail, email, and text messages unless the business is the intended recipient of the communications; or (f) genetic data. Some Sensitive Personal Information included in this category may overlap with other categories.
The purposes for which we collect the above categories of personal information include:
- To properly review and assess your job application or contract.
- To review and manage your role and performance as an employee or contractor, including any correspondence between you and Enact.
- To manage and administer your pay and applicable benefits, such as your health insurance and 401(k).
- To support Enact’s efforts in maintaining a safe and supportive work environment.
- To research, analyze and develop business or product plans.
- To conduct investigative criminal background checks or obtain consumer reports containing information as to your character, general reputation, personal characteristics, and mode of living.
- To prevent, detect, and address any and all security incidents and illegal activity.
- To meet any legal, regulatory, or court-ordered requirements associated with your job application, employment, or contract.
VI. We Do Not Sell Your Data
We do not sell your personal information to third parties, including the personal information of minors under 16 years of age.
VII. Changes to the Notice
We reserve the right to amend this Notice at any time. Please check the “last updated” date at the top of this Notice to see when the Notice was last updated.
VIII. Questions or Concerns
If you have any questions or concerns about what has been provided in this Notice, please send your question or concern to the following address or contact the ActionCenter at 800 444.5664:
- Enact Mortgage Insurance
- Attention: Chief Compliance Officer
- 8325 Six Forks Road
- Raleigh, NC 27615