American Express Travel Insurance

Legal Rights & Agreement Rules · Context

Notice covers American Express AMEX Assurance products

This is a privacy notice (a federal-law "FACTS" notice) headed as American Express's description of what it does with your personal information "in connection with the AMEX Assurance products it offers." The saved copy carries the label "Rev. 4/2018". The notice describes how American Express collects, shares and protects personal information and which sharing you can limit.

Supporting quotations

WHAT DOES AMERICAN EXPRESS, IN CONNECTION WITH THE AMEX ASSURANCE PRODUCTS IT OFFERS, DO WITH YOUR PERSONAL INFORMATION?

Federal law also requires us to tell you how we collect, share, and protect your personal information.

Rev. 4/2018

Qualifications & exceptions

• The heading limits the notice to American Express's AMEX Assurance products; the saved text does not say how it applies to other American Express products or services.
• "Rev. 4/2018" is the only revision label in the saved text.

Not stated here

• The source gives no effective date other than the "Rev. 4/2018" label, and does not say whether a newer version exists.
• Which specific AMEX Assurance products are covered is not listed in the saved text.

Data Access & Collection · Company practice

Types of information collected and shared depend on the product

The kinds of personal information American Express collects and shares depend on which product or service you have with it. The notice says this information can include your Social Security number and insurance claim history, and your payment history and transaction history.

Supporting quotations

The types of personal information we collect and share depend on the product or service you have with us. This information can include: ● Social Security number and insurance claim history ● payment history and transaction history

Qualifications & exceptions

• "can include" introduces examples; the list is not stated to be complete.

Not stated here

• Other categories of personal information, if any, are not listed in the saved text.

Data Access & Collection · Company practice

How personal information is collected

American Express says it collects your personal information when you open an account or apply for insurance, give it your contact information or file an insurance claim, and tell it where to send the money. It also collects personal information from others, such as affiliates or other companies.

Supporting quotations

We collect your personal information, for example, when you • open an account or apply for insurance • give us your contact information or file an insurance claim • tell us where to send the money We also collect your personal information from others, such as affiliates or other companies.

Qualifications & exceptions

• The listed occasions are introduced by "for example", so they are not stated to be exhaustive.
• Collection from "affiliates or other companies" is described only in general terms.

Not stated here

• Which other companies provide information about you is not specified.

Sharing & Disclosure · Context

How to read the sharing table

American Express explains that all financial companies need to share customers' personal information to run their everyday business. The notice then lists the reasons financial companies can share, the reasons American Express chooses to share, and whether you can limit that sharing. The table has three columns: the reason, whether American Express shares, and whether you can limit this sharing.

Supporting quotations

All financial companies need to share customers' personal information to run their everyday business. In the section below, we list the reasons financial companies can share their customers' personal information; the reasons American Express chooses to share; and whether you can limit this sharing.

Reasons we can share personal information | Does American Express share? | Can you limit this sharing?

Not stated here

• The table is read as three columns (reason, does American Express share, can you limit) from the column-header row in the saved text.

Sharing & Disclosure · Company practice

Everyday business sharing cannot be limited

American Express shares personal information for its own everyday business purposes, such as processing your transactions, maintaining your accounts, responding to court orders and legal investigations, and reporting to credit bureaus. The table answers "Yes" to "Does American Express share?" and "No" to "Can you limit this sharing?", so this sharing is not one you can opt out of through this notice.

Supporting quotations

For our everyday business purposes – such as to process your transactions, maintain your account(s), respond to court orders and legal investigations, or report to credit bureaus | Yes | No

Qualifications & exceptions

• The listed purposes follow "such as" and are examples.

Not stated here

• The notice does not say which recipients receive information for these purposes.

Sharing & Disclosure · Company practice

Own marketing: shared, no sharing opt-out, but marketing choices exist

American Express shares personal information for its own marketing purposes, to offer its products and services to you. The table answers "Yes" to sharing and "No" to limiting this sharing, with a pointer to the "To limit direct marketing" box for additional privacy choices. That box lets you tell American Express you do not want your personal information used to communicate with you about offers by mail, telephone and/or e-mail.

Supporting quotations

For our marketing purposes – to offer our products and services to you | Yes | No (but please see the "To limit direct marketing" box below for information about additional privacy choices)

To let us know if you do not want us to use your personal information to communicate with you about offers by mail, telephone, and/or e-mail: • Call us at 1-800-228-6855

Qualifications & exceptions

• The "No" in the table is for limiting the sharing; the separate direct-marketing box offers a different choice about being contacted.

Not stated here

• The saved text does not say whether the direct-marketing choice also stops the sharing itself.

Use & Processing · User right or choice

Limiting direct marketing is by phone and per product

American Express says it provides additional privacy choices to customers. To tell it you do not want your personal information used to communicate with you about offers by mail, telephone and/or e-mail, you call 1-800-228-6855. Privacy elections you make for one product or service may not automatically apply to other products and services.

Supporting quotations

We provide additional privacy choices to customers. Privacy elections you make for any one product or service may not automatically be applied to other products and services.

Call us at 1-800-228-6855

Qualifications & exceptions

• The only method stated in the saved text is calling 1-800-228-6855.

Not stated here

• Which other products and services your election would or would not reach is not stated.

Sharing & Disclosure · Company practice

Joint marketing with other financial companies

American Express shares personal information for joint marketing with other financial companies. The table answers "Yes" to sharing and "No" to limiting this sharing. The notice defines joint marketing as a formal agreement between nonaffiliated companies that together market financial products or services to you, and says its joint marketing partners include financial companies.

Supporting quotations

For joint marketing with other financial companies | Yes | No

A formal agreement between nonaffiliated companies that together market financial products or services to you. • Our joint marketing partners include financial companies.

Not stated here

• The partners are not named in the saved text.

Sharing & Disclosure · Company practice

Affiliates' everyday business: transactions and experiences, no opt-out

American Express shares information about your transactions and experiences with its affiliates for the affiliates' everyday business purposes. The table answers "Yes" to sharing and "No" to limiting this sharing. Affiliates are defined as companies related by common ownership or control, financial and nonfinancial, including companies with the American Express name and others such as AMEX Assurance Company.

Supporting quotations

For our affiliates' everyday business purposes – information about your transactions and experiences | Yes | No

Companies related by common ownership or control. They can be financial and nonfinancial companies. • Our affiliates include companies with the American Express name, including financial companies such as American Express Travel Related Services Company, Inc. and nonfinancial companies. Affiliates may also include other companies related by common ownership or control, such as AMEX Assurance Company, a provider of American Express Card-related insurance services.

Qualifications & exceptions

• "Affiliates" includes nonfinancial companies, not only financial ones.

Not stated here

• The affiliates that receive the information are not named beyond the examples given.

Sharing & Disclosure · User right or choice

Creditworthiness information to affiliates: you can limit it

American Express shares information about your creditworthiness with its affiliates for the affiliates' everyday business purposes. The table answers "Yes" to sharing and "Yes" to limiting, so this is a sharing you can limit. Federal law gives you the right to limit only this sharing, affiliates using your information to market to you, and sharing for nonaffiliates to market to you. If your American Express account has a Vermont billing address, American Express says it will automatically treat your account as if you have directed it not to share creditworthiness information with affiliates.

Supporting quotations

For our affiliates' everyday business purposes – information about your creditworthiness | Yes | Yes

Call us at 1-800-228-6855

Vermont: If your American Express account has a Vermont billing address, we will automatically treat your account as if you have directed us not to share information about your creditworthiness with our affiliates.

Qualifications & exceptions

• The Vermont rule applies to accounts with a Vermont billing address.
• The limiting method stated in the "To limit our sharing" row is a phone call.

Not stated here

• Whether the Vermont treatment also covers anything other than creditworthiness information is not stated.

Sharing & Disclosure · User right or choice

Affiliates marketing to you: you can limit it

American Express shares personal information so that its affiliates can market to you. The table answers "Yes" to sharing and "Yes" to limiting, so you can limit this sharing. Federal law gives you the right to limit affiliates from using your information to market to you.

Supporting quotations

For our affiliates to market to you | Yes | Yes

affiliates from using your information to market to you

Not stated here

• The notice does not say how the "Yes" limit for this row differs from the phone-based direct marketing choice, beyond the "To limit our sharing" instructions.

Sharing & Disclosure · Company commitment

Nonaffiliates marketing to you: not shared

American Express answers "No" to sharing personal information for nonaffiliates to market to you, although it says it may share aggregated or de-identified data. For this row the "Can you limit" column reads "We don't share personal information."

Supporting quotations

For nonaffiliates to market to you | No (although we may share aggregated or de-identified data) | We don't share personal information

Qualifications & exceptions

• The commitment is about nonaffiliates marketing to you; sharing with service providers is described separately in the definitions.

Not stated here

• The notice does not define aggregated or de-identified data or say who receives it.

Cross-references

• contrast (model-proposed): Nonaffiliates that receive information include service providers — The table says American Express does not share personal information for nonaffiliates to market to you, while the Definitions row says the nonaffiliates it shares with include service providers such as direct marketers performing services on its behalf. The notice does not say how these fit together; the first is about nonaffiliates marketing to you, the second about service providers acting on American Express's behalf.

Sharing & Disclosure · Company practice

Nonaffiliates that receive information include service providers

The notice defines nonaffiliates as companies not related by common ownership or control, which can be financial and nonfinancial. It says the nonaffiliates with which American Express shares personal information include service providers, for example direct marketers, that perform services or functions on its behalf.

Supporting quotations

Companies not related by common ownership or control. They can be financial and nonfinancial companies. • Nonaffiliates with which we share personal information include service providers, including, for example, direct marketers, that perform services or functions on our behalf.

Qualifications & exceptions

• The list of nonaffiliates is introduced by "include" and "for example", so other nonaffiliates may be covered.

Not stated here

• The notice does not say which row of the sharing table covers sharing with these service providers, so how it relates to the "No" for nonaffiliates marketing to you is not stated.

Cross-references

• contrast (model-proposed): Nonaffiliates marketing to you: not shared — The table says American Express does not share personal information for nonaffiliates to market to you, while the Definitions row says the nonaffiliates it shares with include service providers such as direct marketers performing services on its behalf. The notice does not say how these fit together; the first is about nonaffiliates marketing to you, the second about service providers acting on American Express's behalf.

Account & Service Control · User right or choice

How to limit sharing and when sharing can begin

To limit sharing, you call 1-800-228-6855. If you are a new customer, American Express can begin sharing your personal information 30 days from the date it sent the notice. When you are no longer a customer, it continues to share your personal information as described in the notice, but you can contact it at any time to limit its sharing.

Supporting quotations

Call us at 1-800-228-6855 Please note: If you are a new customer, we can begin sharing your personal information 30 days from the date we sent this notice. When you are no longer our customer, we continue to share your personal information as described in this notice. However, you can contact us at any time to limit our sharing.

Qualifications & exceptions

• The right to limit applies to the sharing the table marks "Yes" under "Can you limit this sharing?".

Not stated here

• Whether former customers' limits apply to past sharing is not stated.

Legal Rights & Agreement Rules · User right or choice

Why not all sharing can be limited; state law may add rights

The notice says federal law gives you the right to limit only sharing for affiliates' everyday business purposes involving creditworthiness information, affiliates using your information to market to you, and sharing for nonaffiliates to market to you. State laws and individual companies may give you additional rights to limit sharing. The state notes that follow give California and Vermont accounts specific treatment: for an account with a California billing address American Express says it will not share personal information except to the extent permitted under California law, and for a Vermont billing address it treats the account as having directed no sharing of creditworthiness information with affiliates.

Supporting quotations

Federal law gives you the right to limit only • sharing for affiliates' everyday business purposes - information about your creditworthiness • affiliates from using your information to market to you • sharing for nonaffiliates to market to you State laws and individual companies may give you additional rights to limit sharing. See below for more on your rights under state law.

California: If your American Express account has a California billing address, we will not share your personal information except to the extent permitted under California law.

Vermont: If your American Express account has a Vermont billing address, we will automatically treat your account as if you have directed us not to share information about your creditworthiness with our affiliates.

Qualifications & exceptions

• The state notes apply only to accounts with a California or Vermont billing address.

Not stated here

• What California law permits is not stated in the saved text.
• Rights under other states' laws are not described.

Legal Rights & Agreement Rules · Context

Who is providing the notice

The notice is provided by American Express Travel Related Services Company, Inc. and other American Express affiliates that provide financial products or services, including American Express National Bank and AMEX Assurance Company.

Supporting quotations

American Express Travel Related Services Company, Inc. and other American Express Affiliates that provide financial products or services, including American Express National Bank and AMEX Assurance Company.

Not stated here

• The saved text does not say which entity is responsible for each product.

Security & Safeguards · Company commitment

Security measures

American Express says that to protect your personal information from unauthorized access and use, it uses security measures that comply with federal law, including computer safeguards and secured files and buildings.

Supporting quotations

To protect your personal information from unauthorized access and use, we use security measures that comply with federal law. These measures include computer safeguards and secured files and buildings.

Qualifications & exceptions

• "include" signals the listed measures are not stated to be complete.

Not stated here

• The notice gives no detail on specific technical or organizational controls.

Account & Service Control · Company practice

No joint accounts

Asked what happens when you limit sharing for an account held jointly with someone else, the notice answers that American Express does not offer joint accounts.

Supporting quotations

We don’t offer joint accounts.

Not stated here

• The notice does not say how limits work if more than one person is covered under a policy or product.

Account & Service Control · Procedure

Where to ask questions

For questions about the notice, you can call 1-800-228-6855 or go to www.americanexpress.com/contact.

Supporting quotations

Call 1-800-228-6855 or go to www.americanexpress.com/contact.

Not stated here

• The linked contact page is not part of the saved text.

Use & Processing · Company practice

Personal information may be transferred to other countries

American Express says it may transfer personal information to other countries, for example for customer service or to process transactions.

Supporting quotations

We may transfer personal information to other countries, for example, for customer service or to process transactions.

Qualifications & exceptions

• "may" states a possibility, and the purposes are introduced by "for example" so they are not stated to be exhaustive.

Not stated here

• The countries and any safeguards for such transfers are not stated in the saved text.

Account & Service Control · User right or choice

AMEX Assurance customers: possible right to access and correct

For AMEX Assurance Company customers, the notice says you may have the right to access and correct recorded personal information. It also says state law may be more protective than federal law. This paragraph sits under the notice's heading about the AMEX Assurance products.

Supporting quotations

AMEX Assurance Company customers: You may have the right to access and correct recorded personal information.

State law may be more protective than federal law.

WHAT DOES AMERICAN EXPRESS, IN CONNECTION WITH THE AMEX ASSURANCE PRODUCTS IT OFFERS, DO WITH YOUR PERSONAL INFORMATION?

Qualifications & exceptions

• The right is stated as "may have", not as a guarantee, and no condition for having it is given.

Not stated here

• The saved text does not say how to make an access or correction request or what law creates the right.

Sharing & Disclosure · Permission or license

AMEX Assurance customers: when information may be disclosed

For AMEX Assurance Company customers, personal information may be disclosed by American Express to detect fraud or misrepresentation, to verify insurance coverage, to an insurance regulatory authority, to law enforcement or other governmental authority pursuant to law, or to a group policyholder for purposes of reporting claims experience or conducting an audit.

Supporting quotations

Personal information may be disclosed by us to detect fraud or misrepresentation, to verify insurance coverage, to an insurance regulatory authority, law enforcement or other governmental authority pursuant to law, or to a group policyholder for purposes of reporting claims experience or conducting an audit.

Qualifications & exceptions

• Disclosure to government authorities is "pursuant to law"; disclosure to a group policyholder is for reporting claims experience or conducting an audit.

Not stated here

• Whether these disclosures can be limited is not stated; the sharing table does not mention them separately.

Retention & Deletion · Company practice

Insurance-support organization may retain claim information

Personal information related to insurance claim activity, obtained from a report prepared by an insurance-support organization on American Express's behalf, may be retained by that organization and disclosed as required by law.

Supporting quotations

Personal information related to insurance claim activity obtained from a report prepared by an insurance-support organization on our behalf may be retained by such organization and disclosed as required by law.

Qualifications & exceptions

• Disclosure by the organization is "as required by law".

Not stated here

• How long the organization may retain the information is not stated.

Sharing & Disclosure · Company commitment

California billing address: sharing limited to what California law permits

If your American Express account has a California billing address, American Express says it will not share your personal information except to the extent permitted under California law.

Supporting quotations

California: If your American Express account has a California billing address, we will not share your personal information except to the extent permitted under California law.

State laws and individual companies may give you additional rights to limit sharing.

Qualifications & exceptions

• Applies by billing address on the account, not by residence.

Not stated here

• What California law permits is not stated in the saved text, so what remains shareable is unknown.

Sharing & Disclosure · Company commitment

Vermont billing address: creditworthiness not shared with affiliates

If your American Express account has a Vermont billing address, American Express says it will automatically treat your account as if you have directed it not to share information about your creditworthiness with its affiliates. Affiliates are companies related by common ownership or control.

Supporting quotations

Vermont: If your American Express account has a Vermont billing address, we will automatically treat your account as if you have directed us not to share information about your creditworthiness with our affiliates.

Companies related by common ownership or control. They can be financial and nonfinancial companies.

Qualifications & exceptions

• Automatic; no request by you is described as needed.

Not stated here

• Other affiliate sharing for Vermont accounts is not addressed in this paragraph.