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Privacy Policy
Opus Investment Management, Inc.

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:

  • Identifiers, including personal information, such as a real name, alias, postal address, online identifier, Internet Protocol address, email address, signature, telephone number, or other similar identifiers.
  • Internet or other electronic network activity information, including, but not limited to, browser details, device information, visitor type (e.g. first time or returning), browsing history, search history, and information regarding a consumer’s interaction with an internet website application, or advertisement.
  • Geolocation data.
  • Inferences drawn from any of the information identified in this subdivision to create a profile about a consumer reflecting the consumer’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.

We collect this information from the following sources:

  • Directly from you when you provide us information in person, online, through electronic forms, or when you reach out to our customer service.
  • Automatically through our website via cookies and other tracking technologies.

2. How We Use Your Information

We may use and disclose your personal information for the following reasons:

  • Debugging to identify and repair errors that impair existing intended functionality.
  • Short-term, transient use, including, but not limited to, nonpersonalized advertising shown as part of a consumer’s current interaction with the business, provided that the consumer’s personal information is not disclosed to another third party and is not used to build a profile about the consumer or otherwise alter the consumer’s experience outside the current interaction with the business.
  • Providing products and services.
  • We may use your contact information to reach out to you as needed including responding to inquiries or to provide you with information about our products and services.
  • Undertaking internal research for the improvement of our products and services.
  • To detect data security incidents or protect against malicious, deceptive, fraudulent or illegal activity.

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:

  • Affiliated Entities. We may disclose your personal information to our subsidiaries, corporate affiliates, and entities with common branding. These companies may use your information consistent with this Policy.
  • Service Providers. We may disclose personal information with service providers that we hire to assist with running our everyday business, such as account maintenance, data analysis, online advertising, infrastructure provision, IT services, customer service, email delivery services, mobile application store providers, and other similar services.
    • Cookies And Online Tracking Technologies
    • We, and the entities we partner with, may track some of the web pages you visit through online tracking technologies. These technologies are intended to collect information about you to help us to monitor and analyze user activity on our site, to aid your website experience and make improvements to serve you better, and for our marketing purposes.
    • Opus uses analytics services, including, but not necessarily limited to, Google Analytics. These service providers may track details about your online activities over time and across different websites. We engage these service providers to help us improve our website and services. These services may also allow us to provide you with targeted advertisements or other content that you may be interested in based on your online activities. To opt-out of being tracked by Google Analytics across all websites you visit where Google Analytics may be used, visit https://tools.google.com/dlpage/gaoptout.
  • Business Transfers or Assignments. In the event of any reorganization, merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of our business, assets or stock (including without limitation in connection with any bankruptcy or similar proceedings), we may transfer any and all information that we collect from site users or offline to the entity with whom any of the aforementioned dispositions is occurring.
  • Law Enforcement; Emergencies; Compliance. We may disclose personal information about you to others as we believe to be appropriate: (i) under applicable law including laws outside your country of residence; (ii) to comply with legal process (iii) to respond to requests from public and government authorities including public and government authorities outside your country of residence; (iv) to enforce our terms and conditions; (v) to protect our operations and property interest; (vi) to protect the rights, privacy, safety or property of Opus, our employees, users of our services, you, or others; and (vii) to permit us to pursue available remedies or limit the damages that we may sustain. We have no obligation to notify you of such disclosures, except as required by applicable law.
  • At your direction. We may use and disclose your personal information as you otherwise consent.

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:

  • To know the categories and/or specific pieces of personal information collected about you, including the source of your personal information, whether your personal information is sold or disclosed and the purpose, and with whom your personal information was disclosed;
  • To request deletion of personal information, if permissible by law;
  • To correct inaccurate personal information we retain about you;
  • To opt-out of “sale” and/or “share” of your personal information;
  • To limit the use of your sensitive personal information; and
  • To non-discrimination based on the exercise of a consumer’s privacy 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:

  1. The categories of personal information we have collected from consumers
  2. The categories of sources from which the personal information was collected
  3. Our business or commercial purposes for collecting, selling, or sharing personal information
  4. The categories of third parties (recipients) to which we disclose personal information
  5. The specific pieces of personal information we have collected about you
  6. A list of all third parties to which we have disclosed personal information, as defined under California Civil Code Section 1798.83(e) (a/k/a the “Shine the Light Law”), during the preceding year for third-party direct marketing purposes, if applicable

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.


We will not discriminate against you for exercising your rights under the CCPA. Unless otherwise permitted by the CCPA, we will not:

  • Deny you goods or services;
  • Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties;
  • Provide a different level or quality of goods or services;
  • Suggest that you will receive a different price or rate for goods or services or a different level or quality of goods or services.

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