Effective Date: December 16, 2025
Last Updated: December 16, 2025
This Independent Contractor Privacy Notice (“Notice”) describes how Coterie Applications, Inc. and its subsidiaries and affiliates, including Coterie Insurance Agency, (“Coterie,” “Company,” “our,” “us”) collects and processes Personal Information about Independent Contractors.
Summary
Under the California Consumer Privacy Act of 2018 (CCPA), as amended by the California Privacy Rights Act of 2020 (CPRA), we are required to provide California contractors with a privacy notice that describes our online and offline practices regarding our collection, use, sale, sharing, and retention of their Personal Information, along with a description of the rights they have regarding their Personal Information. This Notice provides the information the CCPA requires, together with other useful information regarding our collection and use of Personal Information. Any terms defined in the CCPA have the same meaning when used in this notice.
This Notice applies to all current and former contractors regardless of their residence.
This Notice is divided into sections based on your status with us: Applicant or Independent Contractor.
“Personal Information” is information that identifies, relates to, describes, references, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular individual or household (“Personal Information”). Personal Information does not include:
- Publicly available information, including from government records, through widely distributed media, or that the individual made publicly available without restricting it to a specific audience.
- Lawfully obtained, truthful information that is a matter of public concern.
- Deidentified or aggregated information.
We collect and use your Personal Information, including sensitive Personal Information, for human resources, health and safety, and business-related and legal compliance purposes, including for the business purposes listed below. We are committed to properly handling the Personal Information collected or processed in connection with your contractural relationship with us.
We will not sell the Personal Information, including any sensitive Personal Information, we collect about our contractors or share it with third parties for cross-context behavioral advertising.
As noted above, this Notice also provides information about contractors rights with respect to their Personal Information, including how to exercise those rights, such as access, portability, deletion, and correction.
You may always choose not to share your Personal Information with us. Please note, however, that if you choose not to share required Personal Information, then, respectively, you may not be able to apply for a job with us and/or become a Coterie contractor. If you have questions about what Personal Information may be required to apply for a job or become an contractor, please contact us at
This Notice does not apply to our collection and use of Personal Information in other contexts.
For more information on our collection and use of Personal Information through our Services or from Claimants, please see
Online Privacy Policy: https://coterieinsurance.com/legal/privacy/.
Coterie Applicant and Employee Privacy Notice: https://coterieinsurance.com/legal/applicant-and-employee/
Biometric Data Privacy Policy: https://coterieinsurance.com/legal/biometric/
If you have any questions about this Notice or need to access this Notice in an alternative format due to a disability, please contact Coterie’s People Operations team at Peopleoperations@coterieinsurance.com or 513-719-6094.
Personal Information Collected: Applicants
Coterie may collect (and may have collected during the 12-month period prior to the Last Updated date of this Notice) the following categories of Personal Information from or about applicants:
- Identifiers. A real name, alias, location (e.g., city and state of residence), Internet Protocol address, email address, phone number.
- Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)). A name, location (e.g., city and state of residence), telephone number, and resume which may include education, employment, employment history, membership in professional organizations, and professional licenses and certifications.
- Protected classifications. Gender identity and/or gender expression (i.e., your preferred pronouns).
- Internet or other similar network activity. All activity on our application system (such as internet browsing history, search history, email communications, application documents submitted, username, and password) and all other activity on Coterie’s communications systems (such as records of phone calls, call logs, voicemails, text messages, chat logs, etc.).
- Geolocation data. Imprecise location information, such as the time and imprecise physical location related to use of our website or application system.
- Professional or employment-related information. Current or past job history or performance evaluations, such as employment application information (work history, academic and professional qualifications, educational records, references, and interview notes.
- Sensitive Personal Information: means non-public personal information that reveals:
- Citizenship or immigration status
Please note that to apply for employment with us, you should only provide information we request. Any additional information you choose to share with us, such as information included on your resume that we have not requested, is shared with us with your consent as governed by this Notice. Therefore, please only share the information we request to process your application for employment.
Personal Information Collected: Independent Contractors
Coterie may collect (and may have collected during the 12-month period prior to the Last Updated date of this Notice) the following categories of Personal Information from contractors:
- Identifiers. 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, emergency contact information, signature, or other similar identifiers.
- Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)). Name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver’s license or state identification card number, membership in professional organizations, professional licenses and certifications, bank account number.
- Protected classifications. Age (40 years or older), citizenship, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), or military and veteran status.
- Biometric information. Biometric data such as fingerprints or faceprints to access Coterie information through Coterie-approved devices.
- Internet or other similar network activity. All activity on our information systems (such as internet browsing history, search history, intranet activity, email communications, social media postings, stored documents and emails, usernames, and passwords) and all activity on Coterie’s communications systems (such as phone calls, call logs, voicemails, text messages, chat logs, app use, mobile browsing and search history, mobile email communications, and other information about contractor’s use of Coterie-issued devices).
- Geolocation data. Physical location or movements, such as the time and physical location related to use of an internet website, application, or device.
- Sensory data. Audio, electronic, and visual information, such as telephone recordings, meeting recordings, and photograph.
- Professional or employment-related information. Current job history or performance evaluations, performance and disciplinary records, compensation data, leave of absence information, emergency contact information.
- Sensitive Personal Information: means non-public personal information that reveals:
- Government identifiers, such as your Social Security number (SSN), state identification card, or passport number.
- Complete account access credentials, such as usernames, account logins, or account numbers.
- Precise geolocation, such as physical access to a Coterie office location
- Religious or philosophical beliefs, only if related to a religious reasonable accommodation request.
- Citizenship or immigration status.
- Mail, email, or text messages not directed to Coterie but sent on Coterie devices and/or over the Coterie network.
- Unique identifying biometric information.
- Health information.
Sensitive Personal Information and Consent: Applicants and Independent Contractors
Sensitive Personal Information is a subtype of Personal Information consisting of the specific information categories noted above. While we collect information that falls within the Sensitive Personal Information categories listed above, the CCPA does not treat this information as sensitive because we do not collect or use it to infer characteristics about a person. Further, Coterie does not use or disclose Sensitive Personal Information for purposes other than the purposes described below.
Where your consent is not required, and the Sensitive Personal Information is not necessary for a legal business purpose as described below, you have the right to withdraw your consent at any time. This can be done by changing your Privacy Settings.
The withdrawal of consent will not affect the lawfulness of the collection, use, and/or disclosure of your Sensitive Personal Information based on your consent before it was withdrawn. Further, Coterie will not retaliate against any applicants or contractors for the withdrawal of their consent.
Sources of Personal Information: Applicants
We obtain the categories of Personal Information listed above about applicants from the following categories of sources:
- Directly from you;
- Your devices used to access our application system or website;
- Service providers, contractors, and other vendors who provide services on our behalf, such as our application system;
- Previous employers that provide information about you, such as when they provide a reference or confirm dates of employment; and
- Operator systems and platforms, such as our application system.
- Government entities; and
- Credit reporting service providers and background check services
Sources of Personal Information: Contractors
- Directly from you;
- Your Coterie-issued devices and activities on the Coterie information systems;
- Our affiliates and subsidiaries;
- Service providers, contractors, and other vendors who provide services on our behalf;
- Clients or business partners who provide information about you, such as when they provide feedback;
- Internet service providers;
- Operator systems and platforms;
- Government entities; and
- Credit reporting service providers and background check services.
How We Use Personal Information: Applicants and Contractors
Coterie does not sell or share for cross-context behavioral advertising purposes applicants or contractors Personal Information.
Coterie may use (and may have used during the 12-month period prior to the Last Updated date of this Notice), the Personal Information and Sensitive Personal Information from applicants and contractors for the following purposes:
- Recruit and process employment applications, including verifying eligibility for contractual employment and conducting background, reference, and related checks.
- Conduct contractor onboarding.
- Create, maintain, and secure your online applicant account and other Coterie accounts.
- Maintain and administer payroll.
- Maintain contractor personnel records and comply with record retention requirements.
- Provide contractors with human resources management services and data maintenance and support services.
- Communicate with contractors, and their emergency contacts.
- Comply with applicable state and federal labor, contractual employment, tax benefits, workplace safety, and related laws.
- Prevent unauthorized access to or use of the Coterie property, including information systems, electronic devices, and data.
- Ensure productivity and adherence to Coterie policies.
- Conduct internal audits and investigate complaints, grievances, and suspected violations of Coterie policy.
- Respond to law enforcement requests and as required by applicable law or court order.
- Exercise or defend our legal rights and its employees, affiliates, customers, and agents.
- Perform workforce analytics and data analytics.
- Facilitate the efficient and secure use of Coterie information systems and devices.
- Ensure compliance with Coterie information systems policies and procedures.
- Prevent unauthorized access to, use, or disclosure or removal of Coterie property, records, data, and information, including customer and claimant information.
- Improve efficiency and logistics.
- Improve customer service.
- Assess and provide necessary reasonably accommodations, including religious and disability-related accommodations.
- Evaluate and provide feedback about job performance, facilitate working relationships, and for professional development.
- Evaluate an individual contractors appropriateness for current or future position, discipline, or termination.
- Identity management and access controls.
- Comply with all applicable laws and regulations.
- Ensure business continuity.
- Provide technical support.
- Allocating and managing company assets and human resources.
- Strategic planning and project management.
- Maintaining records relating to business activities, budgeting, and financial management.
- Managing mergers, acquisitions, sales, reorganizations or disposals and integration with business partners.
- Performing services, including maintaining or servicing client accounts, providing client service, processing client transactions, verifying client information, or processing payments.
To the extent we process deidentified information, we will maintain and use the information in deidentified form and will not attempt to reidentify the information unless permitted by applicable law.
Disclosure of Personal Information
During the 12-month period prior to the last updated date of this Notice, Coterie may have disclosed the following categories of Personal Information for a business purpose to the following categories of service providers, contractors, or third parties:
| Categories of Personal Information | Categories of Third Parties |
| Identifiers |
|
| Additional Data Subject to Cal. Civ Code § 1798.80 |
|
| Protected Classifications |
|
| Biometric Information (only with your consent) |
|
| Online Activity |
|
| Geolocation Data |
|
| Sensory Information (such as audio and video recordings, photographs). |
|
| Employment Information |
|
| Education Information |
|
Retention of Personal Information
We will retain and use your Personal information for the period necessary for the purposes for which we collect it and as permitted or required by law. Following the expiration of the retention period, Personal Information will be deleted. Therefore, any data subject rights you may have cannot be exercised after the expiration of the retention period.
California Applicants’ and Contractors’ Rights and Choices
If you are a California applicant or contractor, you have the following rights under the California Consumer Privacy Act of 2018 (CCPA), as amended by the California Privacy Rights Act of 2020 (CPRA), regarding your Personal Information:
Right to Know and Data Portability
You have the right to request that we disclose certain information to you about our collection and use of your Personal Information (the “right to know”), including the specific pieces of Personal Information we have collected about you (a “data portability request”). Our response will cover the 12-month period preceding the request, and any other data range you specify going back to January 1, 2022, unless doing so would be impossible or involves disproportionate effort. You may make two right to know and data portability requests in any 12-month period. Once we receive your request and confirm your identity (see How to Exercise Your Rights), we will disclose to you:
- The categories of:
- Personal Information we collected about you; and
- sources from which we collected your Personal Information.
- The business or commercial purpose for collecting your Personal Information and, if applicable, selling or sharing your personal information.
- If applicable, the categories of persons, including third parties, to whom we disclosed your Personal Information, including separate disclosures identifying the categories of your Personal Information that we:
- disclosed for a business purpose to each category of persons; and
- sold or shared to each category of third parties.
- When specifically requested, a copy of your Personal Information subject to any permitted redactions.
Right to Delete
You have the right to request that we delete any of your Personal Information that we collected from you and retained, subject to certain exceptions and limitations (the “right to delete”).
Right to Correct
You have the right to request correction of Personal Information we maintain about you that you believe is inaccurate. We may require you to provide documentation, if needed, to support your claim that the information is inaccurate. Unless an exception applies, we will correct Personal Information that our review determines is inaccurate and direct our service providers to take similar action. For more information, see Exercising the Rights to Know, Delete, or Correct.
Right to Non-Discrimination
You have the right to exercise these rights without discrimination or retaliation for exercising any of your privacy rights under the CCPA.
How to Exercise Your Rights
Exercising the Rights to Know, Delete, or Correct
To exercise the right to know, data portability, delete, or correct described above, please submit a verifiable request to us by:
- Emailing us at privacy@coterieinsurance.com
You or your authorized agent may only submit a request to know or for data portability twice within a 12-month period.
Verification Process and Authorized Agents
Only you, or someone legally authorized to act on your behalf, may make a request to know, delete, or correct related to your Personal Information.
If you use an authorized agent to submit a request on behalf, the authorized agent must submit the request as described above and include a copy of the written, signed permission indicating that they are permitted to act on your behalf.
To help protect your privacy and maintain security, we will take steps to verify your identity for a verifiable request before granting you or your authorized agent access to your Personal Information or complying with your request. We may verify your identity by requiring you to sign into your company account. If you do not have a company account and you request access to, correction of, or deletion of your Personal Information, we may require you to authenticate your e-mail address and provide information about your employment dates with Coterie, prior payments from Coterie, prior correspondence with Coterie, or other details about your work with or relationship to Coterie. In addition, if you do not have a company account and you or your authorized agent ask us to provide specific pieces of Personal Information, we may require you or your authorized agent to sign a declaration under penalty of perjury that you are the contractor whose Personal Information is the subject of the request.
Responding to Your Requests to Know, Delete, or Correct
We will confirm receipt of your request within ten business days. If you do not receive confirmation within the ten-day timeframe, please contact Coterie Chief Information Security Officer at privacy@coterieinsurance.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 Coterie email address or other confirmed email address related to your request. Our substantive response will tell you whether or not 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 of the Personal Information that we hold about you, or we may have destroyed, deleted, or made your Personal Information anonymous in compliance with our record retention policies and obligations.
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.
Nothing in this Notice forms a contract for employment or alters your at-will employment relationship with Coterie. Coterie may update this Notice from time to time. We will notify you of the most recent version of the Notice or obtain your consent if (a) there are material changes to the Notice and (b) we are required to do so by law.
- Summary
- Personal Info Collected: Applicants
- Personal Inform Collected: Contractors
- Sensitive Personal Information and Consent
- Sources of Personal Info: Applicants
- Sources of Personal Info: Contractors
- How We Use Personal Information
- Disclosure of Personal Information
- Retention of Personal Information
- California Rights and Choices
- Right to Know and Data Portability
- Right to Delete
- Right to Correct
- Right to Non-Discrimination
- How to Exercise Your Rights
- Exercising the Rights to Know, Delete, or Correct
- Verification Process and Authorized Agents
- Responding to Your Requests
