Effective: April 24, 2023
Thank you for your interest in our company, products, and services. At Opus Investment Management, Inc. (together referred to as “Opus,” “we,” “our,” “us”), we are committed to protecting the privacy of the personal information that we collect or maintain. We have created this Privacy Policy (the “Privacy Policy” or the “Policy”) to explain how we protect the information that is disclosed to us through our website and other sources as described below.
The applicant and employee privacy notice for California-based applicants and/or employees is available here.
1. Information We Collect and How We Collect It
We collect the following information from you:
We collect this information from the following sources:
2. How We Use Your Information
We may use and disclose your personal information for the following reasons:
We do not sell or share (as defined under the California Consumer Privacy Act, as amended from time to time, and the applicable regulations) for money any personal information about our customers.
3. Personal Information Disclosure
We may disclose your information to the following:
4. Retaining Your Personal Data
Except as otherwise permitted or required by applicable law or regulation, to satisfy any legal or regulatory obligations, or to resolve disputes, we will retain your personal information (including the categories of personal information discussed in the sections above) for as long as necessary to fulfil the purposes for which we collected it. In determining what constitutes an appropriate retention period for personal information, we consider applicable legal requirements, the amount, nature, and sensitivity of the personal information, the potential risk of harm from unauthorized use or disclosure of your personal information, the purposes for which we process your personal information, and whether those purposes can be achieved through other means.
5. Children and Minors
Our website, products, and services are intended for our customers, prospective customers, employees, prospective employees, agents, investors, and business partners, and not intended for children under the age of thirteen (13). We do not intentionally collect personal information from children under the age of thirteen (13) on our website. The Services are not directed to individuals under the age of thirteen (13), and we request that these individuals do not provide Personal Information through the Services. If you believe that we might have any personal information from or about a child, please contact us at privacy@hanover.com.
6. Your California Rights
Under the California Consumer Privacy Act, as amended from time to time, and the applicable regulations (the “CCPA”), Opus is required to notify California consumers about Opus’ collection, use, disclosure, and retention of their personal information. This section applies to Opus’ processing of personal information of California residents to the extent the information is subject to the CCPA. Under the CCPA, you may have the following rights:
Right To Know
You have the right to request that we disclose to you the personal information we collect, use, disclose, sell, or share about you:
You can submit an email request at privacy@hanover.com, fill out and submit the form, or call 800-446-8379 to make a disclosure request. We will respond to your request as soon as we can, and no later than legally required. We will also confirm receipt of your request within 10 business days of receipt. You may make up to two requests in any 12-month period.
Right to Request Deletion
You have the right to request that we delete your personal information. You may make such a request by submitting an email to privacy@hanover.com, fill out and submit the form, or calling 800-446-8379. We will respond to your request as soon as we can, and no later than legally required. We will also confirm receipt of your request within 10 business days of receipt.
You should be aware, however, that California law allows us to retain your personal information under certain conditions, even if you have asked us to delete it, such as when retaining your personal information is necessary for us to complete a transaction with you or provide you with a good or service you have requested. In such circumstances, we will notify you of any denial of your deletion request and the reason for such denial.
Right To Correct Inaccurate Information
If you believe that any of the personal information we maintain about you is inaccurate, you may submit a request for us to correct that information. Upon receipt of a verifiable request to correct inaccurate personal information, we will use commercially reasonable efforts to correct the information as you direct. We will respond to your request as soon as we can, and no later than legally required. We will also confirm receipt of your request within 10 business days of receipt.
Right To Opt-Out
You have the right to opt-out of the sale or sharing of your personal information. To opt-out, please please click here. You may also make such a request by submitting an email to privacy@hanover.com or calling 800-446-8379.
We do not sell or share personal information of children under the age of 18.
Right to Limit the Use of Sensitive Personal Information
We do not collect or use sensitive personal information for any purpose that may fall under the scope of the CCPA.
Non-Discrimination
We will not discriminate against you for exercising your rights under the CCPA. Unless otherwise permitted by the CCPA, we will not:
Verification And Using An Authorized Agent
Only you, or someone legally authorized to act on your behalf, may make a verifiable consumer request to know, delete, or correct as it relates to your personal information. You may also make a verifiable consumer request on behalf of your minor child.
Making a verifiable consumer request does not require you to create an account with us.
To verify the identity of the requestor and authority to make the request, you will be required to provide your name, email address, and other unique information that we may determine is required in order to connect you to the information that we retain.
We will only use personal information provided in a verifiable consumer request to verify the requestor's identity or authority to make the request.
In accordance with the CCPA and in order to safeguard personal information, we cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you.
You may use an authorized agent to submit a request. To use an authorized agent, you will need to (i) provide written instruction to your agent, and verify your identity to us; or (ii) provide a power of attorney pursuant to California Probate Code Sections 4000 to 4465.
To exercise any other rights as described in this Policy, please submit a verifiable request by contacting us using the contact information at the end of this Privacy Policy. Because we take the protection of your information seriously, in order to process this request, your identity must be verified in order to process any requests to know, delete, or correct. We reserve the right to verify your identity in connection with any requests regarding personal information to help ensure that we provide the information we maintain to the individuals to whom it pertains, and allow only those individuals or their authorized representatives to exercise rights with respect to that information. If you are an authorized agent or parent/guardian making a request on behalf of an individual or your minor child, we may require and request additional information to verify that you are authorized to make that request.
We reserve the right to deny your request if we cannot verify your identity. Where we deny your request in whole or in part, we will inform you of the denial, provide an explanation of our actions, and the reason(s) for the denial.
7. California’s “Shine the Light” Law
If you are a California resident, you are entitled, once a year, free of charge, to request information regarding our disclosure, if any, of certain categories of Personal Information to third parties for their direct marketing purposes in the preceding calendar year.
8. Amendments
We reserve the right to amend this Policy at any time. When we do revise this Policy, we will update the “Effective” date at the top of this page so that you can tell if it has changed since your last visit. The effective date of this Policy is the date in which this Policy was last updated.
9. Contact Us
If you have questions about this Privacy Policy, please contact us at:
Phone: 800-446-8379
Email: privacy@hanover.com
Address: Opus Investment Management, Inc. Attn: Chief Privacy Officer 440 Lincoln Street N435 Worcester, MA 01653