Privacy Notice and Policy for Employees who are California Residents

Effective: January 1, 2026

Intact Insurance Group USA Holdings Inc. (“Intact,” “we,” “us,” “our”) adopts this Privacy Notice and Policy (herein “Privacy Notice”) to comply with the California Consumer Privacy Act of 2018 (CCPA), as amended by the California Privacy Rights Act of 2020 (CPRA) (herein collectively “CCPA”). Any terms defined in the CCPA have the same meaning when used in this Privacy Notice. This Privacy Notice applies solely to personal information of our job applicants, employees, owners, directors, officers and contractors, and their emergency contacts, who are California residents, to the extent the information is subject to the CCPA (these individuals are referred to herein as “Employees”). This Privacy Notice applies to information we collect online and to information we collect offline, including information submitted by telephone and information sent by regular mail or electronic mail.

Personal Information We Collect

We collect 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 (“personal information”). These categories also represent categories of personal information that we have collected over the past twelve months. We may collect the following categories of your personal information for the following business or commercial purpose(s):

Category of Personal Information	Examples	Sources of Personal Information	Business or Commercial Purpose(s) for Which Used
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, or other similar identifiers.	We collect this information directly from you, indirectly from you, from third parties that interact with us in connection with the services we provide, and through tracking technologies when you access our website.	To provide Employees with information that they request from us. To create, maintain, customize, and secure an Employee’s account with us or our business partners. To provide Employees with support and to respond to their inquiries, including to investigate and address concerns, and to monitor and improve our responses. To help maintain the safety, security, and integrity of our technology assets and business. To respond to law enforcement requests and as required by applicable law, court order, or local, state, or federal government regulations. As necessary or appropriate to protect the rights, property, or safety of Intact, our clients, or others. As described to Employees when collecting their personal information or as otherwise set forth in the CCPA. To process registration with any of our services, including verifying an Employee’s information is active ‎and valid. For internal business purposes.
Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).	A name, signature, 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.	We collect this information directly from you, indirectly from you, and from third parties that interact with us in connection with the services we provide.	To provide Employees with information that they request from us. To create, maintain, customize, and secure an Employee’s account with us or our business partners. To provide Employees with support and to respond to their inquiries, including to investigate and address concerns, and to monitor and improve our responses. To help maintain the safety, security, and integrity of our technology assets and business. To respond to law enforcement requests and as required by applicable law, court order, or local, state, or federal government regulations. As necessary or appropriate to protect the rights, property, or safety of Intact, our clients, or others. As described to Employees when collecting their personal information or as otherwise set forth in the CCPA. To process registration with any of our services, including verifying an Employee’s information is active ‎and valid. For internal business purposes.
Protected classification characteristics under California or federal law.	Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information).	We collect this information directly from you, indirectly from you, and from third parties that interact with us in connection with the services we provide.	To respond to law enforcement requests and as required by applicable law, court order, or local, state, or federal government regulations. As described to Employees when collecting their personal information or as otherwise set forth in the CCPA. For diversity and inclusion statistics and analysis.
Biometric information.	Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as, fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data.	We collect this information directly from you, indirectly from you, and from third parties that interact with us in connection with the services we provide.	To provide Employees with information that they request from us. To provide Employees with support and to respond to their inquiries, including to investigate and address concerns, and to monitor and improve our responses. To respond to law enforcement requests and as required by applicable law, court order, or local, state, or federal government regulations. As necessary or appropriate to protect the rights, property, or safety of Intact, our clients, or others. As described to Employees when collecting their personal information or as otherwise set forth in the CCPA. For internal business purposes.
Sensory data.	Audio, electronic, visual, thermal, olfactory, or similar information.	We collect this information directly from you, indirectly from you, and from third parties that interact with us in connection with the services we provide.	To provide Employees with information that they request from us. To create, maintain, customize, and secure an Employee’s account with us or our business partners. To provide Employees with support and to respond to their inquiries, including to investigate and address concerns, and to monitor and improve our responses. To help maintain the safety, security, and integrity of our technology assets and business. To respond to law enforcement requests and as required by applicable law, court order, or local, state, or federal government regulations. As necessary or appropriate to protect the rights, property, or safety of Intact, our clients, or others. As described to Employees when collecting their personal information or as otherwise set forth in the CCPA. To process registration with any of our services, including verifying an Employee’s information is active ‎and valid. For internal business purposes.
Professional or employment-related information.	Current or past job history or performance evaluations.	We collect this information directly from you, indirectly from you, and from third parties that interact with us in connection with the services we provide.	To provide Employees with information that they request from us. To provide Employees with support and to respond to their inquiries, including to investigate and address concerns, and to monitor and improve our responses. To help maintain the safety, security, and integrity of our technology assets and business. To respond to law enforcement requests and as required by applicable law, court order, or local, state, or federal government regulations. As necessary or appropriate to protect the rights, property, or safety of Intact, our clients, or others. As described to Employees when collecting their personal information or as otherwise set forth in the CCPA. For internal business purposes.

Third Parties to Whom Personal Information is Disclosed

Category of Personal Information	Third Parties
All Categories	Our affiliates or pursuant to a business transfer Government agencies or to protect the rights of our company or others Pursuant to a legal request or subpoena Third parties who assist with any of the above Other third parties at your direction
All Categories except Biometric	Our service providers
Identifiers	When you interact with third-party content on our website

Sales of Personal Information

We do not sell Employees’ personal information.

Retention

We retain your personal information for as long as is reasonable or necessary to fulfill the purposes for which the data was collected, to meet our business requirements, and to comply with applicable laws and regulations.

Your Rights and Choices

The CCPA provides California residents with specific rights regarding their personal information. This section describes your CCPA rights and explains how to exercise those rights via a request to Intact (a “consumer request”).

Access to Specific Information and Data Portability Rights

You have the right to request that Intact disclose certain information to you about our collection and use of your personal information over the past 12 months. Once we receive and confirm your verifiable consumer request (see Exercising Access, Data Portability, Correction and Deletion Rights), we will disclose to you the specific pieces of personal information we collect, use, or disclose about you.

Correction Request Rights

You have the right to request that Intact correct any of your inaccurate personal information that we collected from or about you and retained. Once we receive and confirm your verifiable consumer request (see Exercising Access, Data Portability, Correction and Deletion Rights), we will correct (and direct our service providers and contractors that maintain the personal information at issue pursuant to their written contract with us to correct) your personal information from our records, unless an exception applies.

Deletion Request Rights

You have the right to request that Intact delete any of your personal information that we collected from or about you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request (see Exercising Access, Data Portability, Correction and Deletion Rights), we will delete (and direct our service providers and contractors that collected your personal information pursuant to their written contract with us to delete) your personal information from our records, unless an exception applies.

Exercising Access, Data Portability, Correction and Deletion Rights

To exercise the access, data portability, correction and deletion rights described above, please submit a verifiable consumer request to us by either:

Calling us toll-free at 1-877-624-7775
Visiting California Consumer Privacy Inquiries

Only you, or someone legally authorized to act on your behalf, may make a verifiable consumer request related to your personal information.

You may only make a verifiable consumer request for access or data portability twice within a 12-month period.

Verifiable consumer requests must:

Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative.
Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

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 that the personal information relates to you.

Making a verifiable consumer request does not require you to create an account with us.

We will only use personal information provided in a verifiable consumer request to verify the requestor's identity or authority to make the request. We require a consumer making a verifiable consumer request to provide information about themselves that will allow us to authenticate them.

Using an Authorized Agent

You may use an authorized agent to submit a request to for access or data portability, request to correct or request to delete. 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.

Non-Discrimination

We will not discriminate against you for exercising any of your CCPA rights.

Changes to Our Privacy Notice

Intact reserves the right to amend this Privacy Notice at our discretion and at any time. When we make changes to this Privacy Notice, we will post the updated notice on our website and update the notice's effective date.

Contact Information

If you have any questions or comments about this Privacy Notice, the ways in which Intact collects and uses your personal information described above and in the Website Privacy Policy, or your choices and rights regarding such use, or if you wish to exercise your rights under California law, please do not hesitate to contact us at:

Phone (Toll-Free): 1-877-624-7775
Website: California Consumer Privacy Inquiries
Email: privacycoordinator@intactinsurance.com

Postal Address:

Intact Insurance Specialty Solutions
Attn: General Counsel
605 Highway 169 North
Plymouth, MN 55416

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Intact Insurance Specialty Solutions is the marketing brand for the insurance company subsidiaries of Intact Insurance Group USA LLC. Coverages may be underwritten by one of the following insurance companies: Atlantic Specialty Insurance Company, a New York insurer; Homeland Insurance Company of New York, a New York insurer; Homeland Insurance Company of Delaware, a Delaware insurer; OBI America Insurance Company, a Pennsylvania insurer; or OBI National Insurance Company, a Pennsylvania insurer. Each of these insurers maintains its principal place of business at 605 Highway 169 N, Plymouth, MN 55441. This material is intended as a general description of certain types of insurance coverages and services. Coverages and availability vary by state; exclusions and deductibles may apply. Please refer to your insurance policy or consult with your independent insurance advisor for information about coverages, terms and conditions. Some coverage may be written by a surplus lines insurer through a licensed surplus lines broker. Surplus lines insurers do not generally participate in state guaranty funds and insureds are therefore not protected by such funds.

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