SMARTtrek®Mobile App Driving Program
Privacy Notice Supplement
CSAA Insurance Group, a AAA Insurer
(Version August 1, 2021)
Overview
This Privacy Notice Supplement (“Privacy Notice Supplement”) is for the SMARTtrek mobile application driving program (the “Program”) sponsored by CSAA Insurance Group. The CSAA Insurance Group consists of CSAA Insurance Exchange, CSAA General Insurance Company, CSAA Fire & Casualty Insurance Company, CSAA Affinity Insurance Company CSAA Mid-Atlantic Insurance Company and CSAA Mid-Atlantic Insurance Company of New Jersey (the “Company,” “we,” “our,” and “us”).
Our Personal Information Privacy Notice (“Standard Privacy Notice”) describes our general collection, sharing, and use practices for personal information and is reproduced at the end of this Privacy Notice Supplement. This Privacy Notice Supplement amends the Standard Privacy Notice to explain our practices relating to our use of App Data (as defined below) that we receive in connection with your participation in the Program. This Privacy Notice Supplement together with the Standard Privacy Notice is referred to as the “Privacy Policy.”
SMARTtrek Program Overview
The Program is a voluntary mobile app driving program that tracks how safely you drive and is governed by the SMARTtrek Mobile App Driving Program Terms and Conditions (“Terms and Conditions”). You must be invited to participate in the Program. If you accept the invitation, you will be asked to install the SMARTtrek mobile app (the “App”) and register. You will then receive a unique activation code to activate the App. Once the App is activated, you can begin driving and receive feedback on your trips through the App.
App Data and Other Information We Collect
While the App is installed on your smartphone and active, we will collect, use and share App Data as set forth in the Privacy Policy. “App Data” means information about trips that you take with your smartphone including when you are driving a vehicle, riding in a vehicle as a passenger, taking other transportation such as public transportation, riding a bike or even walking (if walking quickly). The App Data would include, for example, the start and end times of each trip, trip distance in miles, speed, hard braking/smooth driving events, GPS/location information, and accelerometer data. The App Data also includes the smartphone’s mobile phone number, cellular call state and mobile device information including the battery level, International Mobile Equipment Identity (IMEI for short) and operating system, and information about when your smartphone is used for a phone call (whether using a hands-free “blue tooth” type device or not) during a trip and when you interact with your smartphone during a trip by touching or swiping it. The App Data will be used to derive information about your Program activity, and trips including, smooth driving, phone habits, speed, trip duration and time and day of trips, presenting information about your trips to you through the App. We may also use the App Data and the information we derive from the App Data for pricing insurance where you are the purchaser of the policy or are a rated driver under a Company policy.
In addition to App Data, we also collect your name, email address, age, state of residence, gender (if provided) and other Personal Information we collect as part of our relationship with you as described in the Privacy Policy. We may collect, use and store the following types of information about you and your trips:
If you receive a quote for an insurance policy from us, purchase an insurance policy from us or are a named insured on a Company policy, in addition to the types of information described in the Standard Privacy Notice, we may also collect:
Information Collection and Tracking Technology
We will collect the App Data and use it to derive a safety score for you. The technologies we use for automatic information collection may include various analytics tools to collect aggregated statistics of user behavior in the App. The analytics tools may record all screens and user interactions by default. We may also use the App Data and Personal Information to model and help model our automobile insurance policies and to help us develop products, services and systems.
Other Trips
When enabled, the App will collect information and auto-detect the type of trip (driving, passenger, walking, cycling, boat, train or plane) and will collect information for all of these types of trips when the smartphone is present. If the App auto-detects the trip as being in a vehicle, it will assume that you are driving the vehicle and categorize it as “Driving.” You will have a limited time after the end of a trip to confirm or edit the trip type. For example, if the App auto-detected the type of trip as “Driving” but you were actually a passenger in a vehicle being driven by someone else, you should change the trip to be “Passenger” to show that you were not driving. If you modify the trip to be “Passenger,” the App will associate the trip information with you as a passenger. Only trips tagged as “Driving” (which means you were driving) will be evaluated and scored under the App.
What Information We Share and Who We Share It With
We may share your Personal Information and the App Data, without prior authorization, (1) for our everyday business purposes — such as to process your transactions, determine eligibility for incentives, maintain your account; (2) to respond to court orders and legal or regulatory investigations; (3) to report to credit bureaus; (4) to facilitate an audit; (5) to prevent or defect fraud and criminal activity; and (6) to determine pricing an insurance policy. Recipients may include, for example, our companies (i.e., members of CSAA Insurance Group), service providers (including The Floow), insurance agents, your local AAA club, law enforcement, safe driving score service providers, courts and governmental agencies medical-care institutions, actuarial/research entities, and insurance regulatory authorities. We may share any of your information with others so that we and they can provide the Program and the App services to you. We may use, and we may authorize our service providers to use, the App Data when it is in aggregated and in anonymous form (i.e., that does not specifically identify you) for any purpose.
We also may share certain categories of your Personal Information without prior authorization for joint marketing with nonaffiliated financial companies, such as your local AAA club. These categories of shared Personal Information may include name, email address, mobile phone number, and state of residence. “Joint marketing” refers to a formal agreement between nonaffiliated financial companies (e.g., us and your local AAA club) that together market financial products or services to you.
How We Use The Information
We may use the App Data and Personal Information in connection with our business, for example: (1) to compute and present to you an insurance quote or offer containing a discount or a surcharge; (2) to use to determine whether to include a discount or surcharge for a policy you purchase or on which you are a named insured; (3) to underwrite a policy on which you are insured; (4) to research and develop new ways to rate or underwrite insurance; (5) to support rate or other insurance related filings with regulatory agencies such as a Department of Insurance; (6) to verify information about how, when, where and how much you drive; (7) to develop insurance pricing and rating models; (8) to determine whether to provide you with a quote or other messages to you about insurance; and (9) in connection with eligibility for incentives.
We may also use the App Data and Personal Information: (1) to provide the App and its features to you; (2) to communicate with you about your account; (3) for troubleshooting; (4) for analysis and research; (5) as required by law; (6) to protect our rights or property; and (7) to prevent fraud or misuse of the App account and the Program.
MyPolicy
After you enroll in the Program and become a policyholder, you will receive an email containing a link to the Company’s MyPolicy web portal (“MyPolicy”). You may view your available App Data online through MyPolicy until 15 days after your policy renews or earlier if you cancel your participation in the Program. We reserve the right to change the presentation of trip information on MyPolicy or to not display trip information on MyPolicy at all. Please note that any named insured may view your App Data on MyPolicy.
Protection
The App Data and Personal Information will be stored on servers controlled by us or our service providers (including The Floow). The confidentiality, security, and integrity of the App Data, Personal Information and such other information will be protected through reasonable physical, administrative and technical safeguards. Because the App transmits information through wireless networks, your communications may be intercepted by others. We cannot and do not guaranty (and we expressly disclaim) the security and privacy of wireless transmissions, and we will not be liable for any lack of security relating to the use of wireless transmission from your smartphone. You agree that you will not hold us or our service providers (e.g., The Floow) liable for any damages resulting from any loss of privacy or security occurring in connection with any communications over wireless networks.
You have the right to request the deletion of your SMARTtrek account or data collected through the app by submitting an email request to aaahelp@smarttrek.com. Please state in the subject line “SMARTtrek deletion request” and include the following information with the email submission: The full name, email address, and phone number associated with your SMARTtrek account. Please specify if the email if your request is to delete your SMARTtrek account or data deleted.
We may determine that the data related to your request may need to be retained in accordance with federal and state laws that apply to insurance companies.
In addition, we may not be required to delete data collected through the app under certain circumstances, including when it is necessary for us to maintain it in order to:
If you provide feedback to us about the App and/or the Program, you agree that we may use and disclose such feedback for any purpose, provided we will not associate such feedback with your Personal Information. We may collect any information contained in such communication and will treat the Personal Information in such communication in accordance with the Privacy Policy.
Changes
We may modify or update the Privacy Policy from time to time, and will provide you with notice of any changes applicable to you in accordance with applicable law and will obtain your consent, if required by applicable law. The Privacy Policy, and the effective date of any updates, is viewable through the App. Therefore, we ask you to check the Privacy Policy link in the App occasionally for updates to be sure that you are aware of these changes.
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