Privacy Policy – PCH Mutual Insurance

Revised and effective: October 4th, 2026

This is the Privacy Policy of PCH Mutual Insurance Company, Inc., a Risk Retention Group (“PCH Mutual,” “us,” “our,” or “we”). We are committed to respecting your privacy. This Privacy Policy (“Privacy Policy”) describes how we collect, process, secure, and share your Personal Data (defined below). We also describe your rights and choices with respect to your Personal Data and other important information regarding our privacy practices. Please read this Privacy Policy carefully.

Scope of this Privacy Policy

PCH Mutual is an insurance company serving our member policyholders (“Members”). This Privacy Policy applies to data relating to identified or identifiable individuals and households (“Personal Data”) that we (or our third-party providers acting on our behalf) collect and process from anyone who accesses our website located at https://pchmutual.com (including all subpages and subdomains, the “Website”) and related services (collectively, the “Services”).

Please Note: The Privacy Policy does not apply to Personal Data processed in connection with insurance policies we may offer or claims made under them. Additionally, our Members may offer their own services, including to residents ( “Residents”). This Privacy Policy does not apply to the processing of data of Residents (e.g. in connection with a claim), or Members (except to the extent the Member uses our Website or other covered Services). Additionally, certain Member benefits accessible through links on our Website are provided on or through third party sites, services, or applications (e.g., our documentation software and resource library provider, certification provider, and other third-party services). This Privacy Policy applies only to how we process Personal Data through our Services. This Privacy Policy does not apply to information processed by third parties, except for third party service providers processing Personal Data on our behalf. Please see the applicable Member’s or other third party’s privacy policy for more information.

HR Privacy: This Privacy Policy does not apply to Personal Data collected in the context of your application for employment or engagement as an employee or contractor for PCH Mutual, or your service as an employee or contractor.

How to Contact Us

If you have any questions about this Privacy Policy or our privacy practices, please contact us at:

Phone: +1 800 673 2558

Email: privacy@pchmutual.com

Categories and Sources of Personal Data

Categories of Personal Data We Process

The categories of Personal Data that we process may include:

Audio/Visual Data:

Audio files and records, such as voicemails, call recordings, and the like.

Contact Data

: Identity Data that that enables us to contact or communicate with you such as email, telephone number, or physical address.

Device / Network Data

: Information regarding your device or interaction with a website, application (e.g., IP address, MAC Address, SSIDs or other device identifiers or persistent identifiers), online user ID, device characteristics (such as browser/OS version), web server logs, application logs, browsing data, first party cookies, third party cookies, web beacons, clear gifs, and pixel tags.

General Location Data

: Non-precise location data, such as general location calculated from your IP address, or other general location data revealed from content you may submit.

Identity Data

: Information such as your name; address; email address; telephone number; date of birth; gender; username, password, or other account-related information.

User Content: Unstructured/free-form data that may include any category of Personal Data, e.g., data that you give us in free text fields such as a contact box.

Sources of Personal Data We Process

We collect Personal Data from various sources, which include:

Data you provide us

We receive your Personal Data when you interact with us, fill out a form, use our Hotline, contact us for more information or customer service, or when you otherwise input information into our Services.

Data we collect automatically

We automatically collect Personal Data about or generated by any device you have used to access our Services.

Service providers

We receive Personal Data from service providers that perform services on our behalf.

Data we create or infer

We, certain partners, and third parties operating on our behalf create and infer Personal Data based on our observations or analysis of other Personal Data processed under this Privacy Policy, and we may correlate this data with other data we process about you.

Data Processing Contexts / Notice at Collection

We process your Personal Data in the following contexts as you access and use the Services. Please note that in addition to these contexts, we may also process your Personal Data generally for our Business Purposes (defined below).

Our Website

Generally

We automatically collect and process Device/Network Data, Identity Data, and General Location Data when you access and use our Website.

We use this Personal Data as necessary to operate our Website, including to deliver pages and content. We also use it to pursue our legitimate interests, including securing the Website and related technology systems; analyzing Website usage; improving the Website and its content; and creating aggregated information regarding users’ content-viewing and usage patterns. We may also use this information for our general Business Purposes.

Cookies and other tracking technologies

We automatically collect and process Identity Data, Device/Network Data, and General Location Data, in connection with our use of cookies and similar technologies on our Website.

We and authorized third parties may use cookies and similar technologies for the following purposes on our Website:

  • for “essential” purposes necessary for our Website to operate (such as maintaining user sessions, CDNs, and the like); and
  • for “functional” purposes, such as to enable certain features of our Website (for example, to store preferences or selections, such as language or selected products/services).

Please see the Your Rights & Choices section for information regarding opt-out rights for cookies and similar technologies.

CareChron: Resident Care Documentation and Resource Library Services

As a benefit to our Members, we provide free access to a resource library and an online software platform for tracking and documenting resident care through our third-party partner, CareChron. Please note that any information provided to CareChron, including Personal Data, is not shared with PCH Mutual, and any use of CareChron’s services is not subject to this Privacy Policy. For information on CareChron’s privacy practices, please contact CareChron at help@carechron.com.

Contacting Us for Support;

We collect and process Identity Data, Contact Data, and User Content when you contact us, e.g., through the contact us page on the Services, when you call us for support. If you call us via phone, we may collect Audio/Visual Data from any call recordings. This policy does not apply to your communications with third party service providers through the Hotline.

We process this Personal Data to respond to and comply with your request, or to fulfill our legal obligations, and for our other Business Purposes.

Loss Impact Hotline

Our Loss Impact Hotline is operated by third parties (e.g. law firms), and not by PCH. PCH does not receive or have access to any Personal Data that may be collected or disclosed in connection with your use of the Loss Impact Hotline.

Feedback and Surveys

We process Identity Data, Contact Data, and User Content collected in connection with feedback, surveys, or questionnaires.

We process this Personal Data as necessary to respond to concerns and pursue our other legitimate business interests, such as analyzing Member satisfaction; and to allow our partners and service providers to communicate with users. We may also use this Personal Data for our Business Purposes.

We may share feedback and survey data relating to our third-party partners, Members, and service providers, who may use it for their own purposes.

Marketing Communications

We process Device/Network Data, Contact Data, and Identity Data, in connection with marketing emails, and similar communications, and when you open or interact with those communications (“Marketing Communications”). We use Marketing Communications to send you information about products and services we offer in which we believe you may be interested, or to let you know when new briefings in your interest area(s) have been posted to the Services. You may receive marketing communications if you consent and, in some jurisdictions, if you are a representative of a Member or attendee of our events.

We process this Personal Data to contact you about relevant products or services. We may personalize Marketing Communications based on Personal Data we create or infer. If consent is required by law, we will seek your consent. See Your Rights & Choices to limit or opt out of this processing.

Processing Purposes

Business Purposes

We and our Service Providers process Personal Data we hold for numerous business purposes, depending on the context of collection and whether you have exercised Your Rights & Choices. We generally process Personal Data for the following “Business Purposes.”

Service Provision and Contractual Obligations

We process Personal Data as necessary to provide our Services, to authenticate users and their rights to access the Services and as otherwise necessary to fulfill our contractual obligations to you, and provide you with the information, features, and services you request. Similarly, we may use Personal Data as necessary to audit compliance and log or measure aspects of service delivery (e.g., statistics regarding plan enrollment).

Internal Processing and Service Improvement

We may use any Personal Data we process through our Services as necessary to improve the design and functionality of our Services; understand how our Services are used by Members and other users; provide Member services; conduct internal research, technical or feature development, quality assurance, debugging, audits, and similar purposes.

Security and Incident Detection

We may process any Personal Data we collect to ensure that our Services are secure, identify and prevent crime, prevent fraud, and ensure safety. Similarly, we process Personal Data as necessary to detect security incidents, protect against, and respond to malicious, deceptive, fraudulent, or illegal activity. We may analyze network traffic, device patterns and characteristics, maintain and analyze logs and process similar Personal Data in connection with our information security activities.

Personalization

We process certain Personal Data as necessary to personalize our Services for you and our Members. For example, aspects of the Services may be customized for you so that it displays your name and other appearance or display preferences, to display content that you have interacted with in the past, or to display content that we think may be most relevant to you based on your interactions with our Services and other content.

Compliance, Health, Safety, Public Interest

We may process Personal Data as necessary to comply with our legal obligations, including responding to requests to exercise data-protection rights and lawful requests from government or law-enforcement officials. We may also process Personal Data to establish, exercise, or defend legal claims; meet national-security or law-enforcement requirements; prevent illegal activity; protect individuals’ vital interests; or pursue public-interest purposes, in each case to the extent permitted by applicable law. Please see the How We Disclose and Share Personal Data section for more information about how we disclose Personal Data in extraordinary circumstances.

Aggregated Data

We process Personal Data to create aggregated and anonymized data about our Website users, e.g. feature and service utilization trends, Website performance and satisfaction, and other similar information (“Aggregated Data”). Aggregated Data that does not contain Personal Data is not subject to this Privacy Policy.

Other Business Purposes

If we process Personal Data in connection with our Services in a way not described in this Privacy Policy, this Privacy Policy will still apply generally (e.g., with respect to your rights and choices) unless otherwise stated at collection. We will process such information in accordance with the notice provided at the time of collection or in a manner that is necessary and proportionate to achieve the operational purpose for which the Personal Data was collected or processed or for another operational purpose that is compatible with the context in which the Personal Data was collected.

How We Disclose and Share Personal Data

We may disclose Personal Data to the following categories of third-party recipients for the Business Purposes described above and for the additional purposes described below:

Affiliates

We may share your Personal Data within PCH Mutual and with its current or future parents, subsidiaries, and other affiliated entities of PCH Mutual in order to streamline certain business operations.

Service Providers

We may share your Personal Data with service providers who provide certain services or process Personal Data on our behalf in connection with our general business operations, to improve our products or services, or to enable certain features.

Successors

We may share Personal Data if we go through a business transition, such as a merger, acquisition, liquidation, or sale of all or a portion of our assets. For example, Personal Data may be part of the assets transferred or may be disclosed (subject to confidentiality restrictions) during the due diligence process for a potential transaction.

Lawful Recipients

In limited circumstances, we may, without notice or your consent, access and disclose your Personal Data, any communications sent or received by you, and any other information that we may have about you to the extent we believe such disclosure is legally required, to prevent or respond to a crime, to investigate violations of our Terms of Use, in the vital interests of us or any person (such as where we reasonably believe the use or disclosure is necessary to lessen or prevent a serious threat to the life, health or safety of any individual or to public health or safety) or in such other circumstances as may be required or permitted by law. These disclosures may be made to governments that do not ensure the same degree of protection of your Personal Data as your home jurisdiction. We may, in our sole discretion (but without any obligation), object to the disclosure of your Personal Data to such parties.

International Transfers of Personal Data

If you are located outside the U.S., we may transfer or process your Personal Data in the U.S. and other jurisdictions where PCH Mutual or our service providers operate. Where required by local law, we ensure your data remains protected in connection with any international transfers.

Third-Party Links

The Services may contain links to third party websites and services. Inclusion of third-party links on the Services does not constitute our endorsement of such third parties or their privacy practices. The information practices of such other services, or of social media services that host our branded social media pages, are governed by their privacy policies, which you should review to better understand their privacy practices. Such information practices are not governed by this Privacy Policy.

Your Rights & Choices

You may have certain rights and choices regarding the Personal Data we process. Please note, these rights may vary based on the country or state where you reside, and our obligations under applicable law. See the U.S. State Supplement for more information regarding your rights/choices in certain states.

Verification of Rights Requests

If you submit a request, we may need to verify your identity to ensure that you have the right to make that request, reduce fraud, ensure the security of Personal Data, and comply with applicable law. If an agent is submitting the request on your behalf, we reserve the right to validate the agent’s authority to act on your behalf.

We may require that you match Personal Data we have on file in order to adequately verify your identity. If you have an account, we may require that you log into the account to submit the request as part of the verification process. We may not grant access to certain Personal Data to you if prohibited by law.

Your Choices

Marketing Communications

You can withdraw your consent to receive marketing communications by clicking on the ‘Unsubscribe’ link in an email. You can also withdraw your consent to receive marketing communications or any other consent you have previously provided to us by contacting us. To opt out of the collection of information relating to email opens, configure your email so that it does not load images in our emails.

Withdrawing Your Consent/Opt-Out

You may withdraw any consent you have provided at any time. The consequence of withdrawing consent might be that we cannot perform certain services for you that are conditioned on your consent.

Cookies and Similar Technologies

General

If you do not want information collected through the use of cookies, you can manage/deny non-necessary cookies (and certain technologies) using your browser’s settings menu. You may need to opt out of third-party services directly via the third party.

Do-Not-Track

Our Services do not respond to your browser’s do-not-track request.

Data Security

We implement and maintain commercially reasonable security measures to secure your Personal Data from unauthorized processing. While we endeavor to protect our Services and your Personal Data from unauthorized access, use, modification, and disclosure, we cannot guarantee that any information, during transmission or while stored on our systems, will be absolutely safe from intrusion by others.

Children

Our Services are neither directed at nor intended for use by persons under the age of 18. We do not knowingly collect Personal Data from such individuals. If we learn that we have inadvertently done so, we will promptly delete such Personal Data if required by law. Do not access or use the Services if you are not of the age of majority in your jurisdiction.

Data Retention

We retain Personal Data for so long as it is reasonably necessary to achieve the relevant processing purposes described in this Privacy Policy, or for so long as required by law. What is necessary may vary depending on the context and purpose of processing. In determining retention periods, we generally consider (without limitation):

  • Retention periods established under applicable law;
  • Industry best practices;
  • Whether the purpose of processing is reasonably likely to justify further processing;
  • Risks to individual privacy in continued processing;
  • Applicable data protection impact assessments;
  • IT systems design considerations/limitations; and
  • The costs associated with continued processing, retention, and deletion.

We will review retention periods periodically and may pseudonymize or anonymize data held for longer periods.

Changes to Our Privacy Policy

We may change this Privacy Policy from time to time. We will post changes on this page. We will notify you of any material changes, if required, via email or notices on our Services. Your continued use of our Services constitutes your acknowledgment of any revised Privacy Policy.

U.S. State Supplement

Applicable U.S. State Privacy Rights & Choices

Under applicable U.S. state consumer privacy laws, residents of certain U.S. states may have the following rights, subject to regional requirements, exceptions, and limitations:

–              Confirm/Access

  • : Right to confirm whether we process your Personal Data and to access such data.

–              Portability

  • : Right to request that we provide certain Personal Data in a common, portable format.

–              Deletion

  • : Right to delete certain Personal Data that we hold about you.

–              Correction

  • : Right to correct certain Personal Data that we hold about you.
  • Opt-Out: (sales, targeted advertising, profiling).
    • You may have the right to opt out of the following:
    • If we engage in sales of data (as defined by applicable law), you may direct us to stop selling Personal Data.
    • If we engage in targeted advertising, you may opt out of such processing.
    • If we engage in certain forms of “profiling” (e.g. profiling that has legal or similarly significant effects), you may opt out of such processing.

Submission of Requests

You may submit requests by emailing us at privacy@pchmutual.com. Before submitting a request, please review our verification requirements in the Your Rights & Choices section of this Privacy Policy. Except as otherwise described below, you may only make a U.S. state consumer privacy rights request on your own behalf. Certain laws allow authorized agents to submit requests to exercise the right to opt out on your behalf. Where allowed by law, we reserve the right to verify the identity of the agent and the agent’s authority to act on your behalf. Parents and legal guardians may make requests on behalf of their child.

Please note that our processing of Personal Data may be subject to exceptions, and we may not be able to fulfill your request. If we deny your request, we will respond with a detailed explanation. If you have any questions or wish to appeal any refusal to take action in response to a U.S. state consumer privacy rights request, contact us at privacy@pchmutual.com.

We will respond to your rights requests, including any appeals, within the period required by law.