We are required by the California Consumer Privacy Act of 2018 (“CCPA”) to provide to California consumers (as defined under CCPA) an explanation of how we collect, use and share their personal information, and of the rights and choices we offer California consumers regarding our handling of the personal information.
Lenox Advisors, Inc. (“we”, “us” or “Lenox”) provides insurance and financial services and products to individuals and employer/corporate clients.
This Privacy Notice (“Notice”) describes how Lenox collects, handles and processes personal information in relation to your access or all of the services, websites and apps we offer (collectively, the “Services”), The Notice is a statement of our practices and of rights regarding your personal information and is not a contractual document, and does not create any rights or obligations on either party, beyond those which already exist under data protection laws. This Notice is intended to meet the requirements of the CCPA as amended. Bolded terms not otherwise defined in this Notice have the same meaning as set forth under the CCPA.
This Notice covers those applicable Services offered by Lenox in California to consumers and their households, however this Notice does not apply, and excludes Services of our companies, as follows:
We collect personal information about California consumers as summarized in the table below.
Examples of PI Collected
Sources of PI
Purposes for PI Collection
Categories of Recipients
Name, postal address, Internet Protocol address, email address, account name, social security number, driver’s license number, passport number
Compliance & operations
Research & development
Quality control & audit
Operating systems and platforms
Business/asset purchasers **
Name, address, telephone number, email address, signature, education, employment, employment history, retirement account number, bank account number, credit card number, debit card number, medical information
Marital/familial status, race, religion, disabilities
Operating systems and platforms
Commercial Information / Purchase Details
Purchase history or tendencies
Genetic, physiological, behavioral, and biological characteristics
Internet Usage Information
Browsing history, search history, information regarding interactions with our website or advertisements
Our companies*Operating systems and platforms
Precise physical location, movements, and travel patterns
Audio recordings of customer service calls, CCTV footage
Professional or Employment Information
Professional, educational, or employment-related information
Inferences from PI Collected
Customer profiles reflecting preferences and predispositions
* We work closely with other businesses and companies that fall under NFP affiliates and subsidiaries, which may or may not be NFP branded.
** We will not sell your personal information to third parties other than to the extent reasonably necessary to proceed with the consideration, negotiation, or completion of a merger, reorganization, or acquisition of our companies’ business, or a sale, liquidation, or transfer of some or all of our companies’ assets. In these situations, we will use reasonable efforts to ensure any such purchaser uses personal information transferred in accordance with this Notice.
Other than as noted above, we do not sell personal information and have not done so since December 31, 2021.
When required by applicable law, when we share personal information with corporate third-parties we will ensure that such third parties maintain a comparable level of protection of the personal information as set out in this Notice by using contractual or other means. To the fullest extent permitted by applicable law, we exclude all liability arising from the use of your personal information by third parties.
We do not knowingly collect online information from children under the age of 13. Our Services are marketed towards corporate entities and adults. If we are notified that we have collected personal information, as defined by the Children’s Online Privacy Protection Act (“COPPA”), of a child under the age of 13, we will delete the information as expeditiously as possible.
California consumers have the following rights. Please note that the CCPA limits these rights by, for example, prohibiting us from providing certain sensitive information in response to an access request and limiting the circumstances in which we must comply with a deletion request. If we deny your request, we will communicate our decision to you.
You also have the right of non-discrimination for access to our Services should you exercise any applicable rights under the CCPA. You also have a right to submit requests for these rights, including through a toll-free number. See HOW TO CONTACT US Section below.
We implement technical, organizational, administrative and physical measures to help ensure a level of security appropriate to the risk to the personal information we collect, use, disclose and process. These measures are aimed at ensuring the on-going integrity and confidentiality of personal information. We evaluate these measures on a regular basis to help ensure the security of the processing. Please be aware that, despite our ongoing efforts, no security measures are perfect or impenetrable. We restrict access to your personal information to those who require access to such information for legitimate, relevant business purposes. We seek contractual commitments of confidentiality, security and proper use from third-party service providers we engage to process personal information.
We will keep your personal information for as long as we have a relationship with you. Once our relationship with you has come to an end, we will retain your personal information for a period that enables us to:
We will delete your personal information when it is no longer required for these purposes. If there is any information that we are unable, for technical reasons, to delete entirely from our systems, we will put in place appropriate measures to prevent any further processing or use of the personal information.
The Lenox subsidiary providing you Services is primarily responsible for the personal information collected in relation to that Service, and your relationship managers at such firms can serve as a contact for your questions or concerns.
The privacy office for Lenox may be contacted as follows:
Address: Lenox Advisors
c/o Privacy Office
1250 Capital of Texas Highway, Suite 600
Austin, TX 78746
Toll-Free Phone: (866) 824-3817
We reserve the right to make changes to this Notice at any time consistent with applicable local laws. Such changes, as long as they do not have a fundamental impact on the nature of our processing of your personal information or otherwise have a substantial impact on you, will be posted on our website. We encourage you to review the website and Notice periodically for any updates or changes.
This Notice is effective as of January 1, 2022.