CSAA Insurance Group, a AAA Insurer AAA Insurance with SMARTtrek Program Privacy Notice

Transcription

1 CSAA Insurance Group P.O. Box Oakland, CA CSAA Insurance Group, a AAA Insurer AAA Insurance with SMARTtrek Program Privacy Notice Usage Based Insurance Program and SMARTtrek Program Privacy Notice Supplement Overview Usage Based Insurance Program And SMARTtrek Program Driving Data And Other Information We Collect What Information We Share How We Use The Information Safe Driving Discount Protection Other Users Of Your Vehicle Feedback Regarding Children Changes CSAA Insurance Group SMARTtrek Privacy Policy [Please see the CSAA Insurance Group Usage Based Insurance Program and SMARTtrek Program Privacy Notice Supplement.] Personal Information Privacy Notice (Standard Privacy Notice for All Policyholders) Our Information Practices And Privacy Notice What Personal Information We Collect What Personal Information We Share Protecting Your Personal Information Your Rights [ v3]

2 CSAA Insurance Group, a AAA Insurer Usage Based Insurance Program and SMARTtrek Program Privacy Notice Supplement Overview This Usage Based Insurance Program and SMARTtrek Program Privacy Notice Supplement ( Privacy Notice Supplement ) is provided to you by CSAA Insurance Group consisting 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 related to our policyholders. Our Standard Privacy Notice is provided with your insurance policy and is also 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 Driving Data (as defined below) that we receive in connection with our Usage Based Insurance Program and your participation in the SMARTtrek Program (as defined below). Usage Based Insurance Program And SMARTtrek Program Our usage based insurance program is a voluntary program that may offer one or two types of discounts to the premium for your automobile insurance policy with us ( Usage Based Insurance Program ) relating to your participating vehicle ( Vehicle ). As part of your participation in the Usage Based Insurance Program, you are required to participate in our SMARTtrek program ( SMARTtrek Program ) by enrolling your Vehicle and subscribing to the SMARTtrek services. Your participation in the SMARTtrek Program is at no cost to you during the term of your SMARTtrek Subscription Period as defined in the Smarttrek Program Subscription Terms and Conditions. The SMARTtrek Program involves the collection of information about how, when and where your Vehicle is operated. Using SMARTtrek involves plugging a telematics device (the Device ) into your Vehicle. The Device collects and transmits to us information concerning your Vehicle, such as diagnostic trouble codes, temperature and some battery information, as well as where, when and how the Vehicle is being driven. We provide this service using a number of independent vendors and service providers. Driving Data And Other Information We Collect We will collect, use and share Driving Data as set forth in this Privacy Notice Supplement. Driving Data means information about how, when, and where your Vehicle is operated, and may include other identification or technical data collected from your Vehicle. Driving Data would include, for example, miles driven, vehicle speed, and hard braking events. Driving Data will be captured by a Device that is installed in your Vehicle, and will be transmitted using a cellular data network. In order to participate in the Usage Based Insurance Program, you must plug the Device into your Vehicle as required for participation in the SMARTtrek Program. In addition to Driving Data and other information we collect as part of our insurance relationship with you as described in the Standard Privacy Notice, we may collect, use and store the following types of information about you and your Vehicle: Information that helps us customize our services, such as your use of the Device and various features of SMARTtrek; Other information that you submit through online forms and methods; Information about your Vehicle s operation, including location, technical information like diagnostic trouble codes, fuel economy, odometer readings, and speed data; Information about your driving practices and habits; and Information about collisions involving your Vehicle (including time, location, your vehicle s movement immediately before the collision and the direction from which your Vehicle was hit). AAPNUBI 06 17

3 We collect, information from you and your Vehicle s systems in several different ways, including: From what you provide to us, whether in person, by telephone, or through your use of our website, MyPolicy; From your use of various SMARTtrek features and services; Through the Device, which transmits to us vehicle information collected from the monitoring and recording systems of your Vehicle; Through the Device, which transmits to us location information generated by the Device using the GPS system, as well as information concerning changes in vehicle speed and direction generated by the Device s built-in accelerometer. Information generated by the Device or collected by the Device from your Vehicle s systems is periodically or continuously collected when the Device is installed in your Vehicle. What Information We Share We may share your personal information (including Driving Data) for our everyday business purposes such as to process your transactions, maintain your account(s), respond to court orders and legal or regulatory investigations. Recipients may include, for example, our companies (listed near the end of this notice), claims representatives, service providers, insurance agents, law enforcement, safe driving score service providers, courts and governmental agencies. We may share any of your information with others so that we and they can provide SMARTtrek services to you. We may use, and we may authorize our service providers to use, the Driving Data when it is in aggregated and in anonymous form (i.e., that does not specifically identify you) for any purpose. How We Use The Information We may use Driving Data from your Vehicle in connection with our business, for example: (1) to compute and present to you an insurance renewal offer for a safe driving discount, as explained further below; (2) to compute and present other messages to you about potential insurance price savings; (3) to research and develop new ways to rate or underwrite insurance; (4) to support rate or other insurance related filings with regulatory agencies such as the Department of Insurance; (5) to verify information about how, when, where and how much you drive; (6) to develop insurance pricing and rating models; and (7) in connection with insurance claims as described in our Usage Based Insurance Program Terms and Conditions. We may also use any of the information we collect from the SMARTtrek Device: (1) to provide SMARTtrek 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 SMARTtrek. In addition, we may use information we collect from sources other the Device for any other purposes when the information is used on an aggregate and anonymized basis. Safe Driving Discount If you and your Vehicle have been part of our Usage Based Insurance Program during your first policy term, you may be eligible to receive a safe driving discount, if available, based on actual Driving Data. We plan to use Driving Data collected from your Vehicle to provide you with a renewal offer for insurance that may, depending upon how, when and where your Vehicle was driven, feature a safe driving discount, if available. Driving Data from your Vehicle will not be used to affect your price or qualification during your initial policy period (e.g., either 6 or 12 months). If you received a vehicle-level participation discount during your first policy term under the Usage Based Insurance Program but we were not able to collect sufficient Driving Data during that first term to be able to determine your eligibility for a safe driving discount (if available), we may offer you a vehicle-level participation discount for your second policy term, at no cost to you, conditioned upon the continuation of your SMARTtrek subscription and the continued collection of Driving Data from the Device. AAPNUBI Page 2 of 5

4 Protection The Driving Data and other information we collect will be stored on servers controlled by us or our service providers. The confidentiality, security, and integrity of the Driving Data and such other information will be protected through reasonable physical, administrative and technical safeguards. Because we provide SMARTtrek 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 useof wireless transmission by SMARTtrek. You agree that you will not hold us liable for any damages resulting from any loss of privacy or security occurring in connection with any communications over wireless networks. Other Users of Your Vehicle The information described above is collected by the Device and transmitted to us regardless of who is operating your Vehicle. You should inform anyone you permit to operate your Vehicle that the Device has been installed in it and will collect and transmit to us information concerning the vehicle, its operation and location and that we will collect and record such information. Feedback If you provide feedback to us about SMARTtrek, 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 this Privacy Notice Supplement and our Standard Privacy Notice. Regarding Children We do not intentionally gather personal information about persons who are under the age of 13. If we learn that we have collected the personal information of a child under the age of 13 we will take steps to delete the information as soon as possible. Changes We may update this Privacy Notice Supplement from time to time, and will provide you with notice of any changes applicable to you in accordance with applicable law. CSAA Insurance Group CSAA Insurance Exchange CSAA General Insurance Company CSAA Fire & Casualty Insurance Company CSAA Affinity Insurance Company CSAA Mid-Atlantic Insurance Company CSAA Mid-Atlantic Insurance Company of New Jersey This Privacy Notice Supplement is offered by the insurance company named on the first page in the upper right hand corner, which company is a member of CSAA Insurance Group.The version date of this document is June, AAPNUBI Page 3 of 5

5 CSAA INSURANCE GROUP PERSONAL INFORMATION PRIVACY NOTICE ( Standard Privacy Notice ) Our Information Practices and Privacy Notice Federal and state law requires us to tell you how we collect, share, and protect your Personal Information. This Personal Information Privacy Notice applies to all Personal Information that we collect about you. Please read this notice carefully to understand what we do. Please note that, when you apply for insurance, you may be providing information to us, as well as to your AAA club insurance agency. Your agency may have its own separate privacy notice and data security practices. Please contact your agency if you have any questions about its policies and practices. Definitions Personal Information is information that identifies you as an individual, such as: Name, Postal address, Telephone number and address. We, us, and our refer to your insurance carrier which is named at the top of this page. What Personal Information We Collect The types of Personal Information we collect and share depend on the product or service you have with us. This information can include your name and address, Social Security number, credit history, and insurance claims history. We collect information from you (including from your transactions with us) and outside sources. We collect Personal Information from you, for example, when you request a quote for insurance, apply for insurance, pay insurance premiums, file an insurance claim, or give us your contact information. We also collect Personal Information about you from others, such as affiliates or other companies. We also may obtain information from the American Automobile Association and your AAA club relating to your AAA membership. We also obtain information from consumer reporting agencies. It may include your driving record, claims history with other insurers, credit report information and insurance credit score. A consumer reporting agency that gathers information about you may share this information with others who are authorized to use consumer reports, as allowed by law. What Personal Information We Share All financial companies need to share customers Personal Information to run their everyday business. We may share all of the Personal Information about you that we collect with affiliated and unaffiliated companies, as allowed by law. For example, We may share your Personal Information for our everyday business purposes such as to process your transactions, maintain your account(s), respond to court orders and legal or regulatory investigations, or report to credit bureaus. Recipients may include, for example, our family of insurance companies, claims representatives, service providers, consumer reporting agencies, insurance agents, law enforcement, courts and governmental agencies. We may share your Personal Information for our marketing purposes for example, we may share information with our agents and service providers to offer our products and services to you more effectively. Unless you are a California resident, we also may share your Personal Information for joint marketing with other financial companies. Joint marketing refers to a formal agreement between nonaffiliated financial companies that together market financial products or services to you. AAPNUBI Page 4 of 5

6 In addition, we may share Personal Information about our former customers in the manner described above. Federal and state laws do not allow you to limit the data sharing described above. Protecting Your Personal Information To protect 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. We review the data security practices of companies with whom we share data. We authorize only those personnel who need Personal Information to perform their duties to access such data. Your Rights You can stop unwanted offers of our goods and services. If you do not wish to receive mail or telephone marketing communications from us, please call us at (800) or write us (and include your name, address and your insurance policy number) at: CSAA Insurance Group Privacy c/o Legal Division 3055 Oak Road, MS W280 Walnut Creek, CA 94597; or by at: You have the right to see and, if necessary, correct Personal Information about you. This requires a written request, both to see Personal Information about you and to request correction. We do not have to change our records if we do not agree with your correction, but we will place your statement in our file. If you would like a copy of Personal Information about you, please write us (and include your name, address and one of your insurance policy numbers) at: CSAA Insurance Group Attention: Policyholder Endorsement Department PO Box Oakland, CA This notice is offered by the CSAA Insurance Group. For Nevada Residents Only: We are providing you this notice pursuant to state law. You may be placed on our internal Do Not Call List by calling (800) Nevada law requires that we also provide you with the following contact information: Bureau of Consumer Protection Office of the Nevada Attorney General 555 E. Washington St., Suite 3900 Las Vegas, NV Phone number: (702) BCPINFO@ag.state.nv.us AAPNUBI Page 5 of 5

7 SMARTtrek Privacy Policy Please see the CSAA INSURANCE GROUP, a AAA insurer Usage Based Insurance Program and SMARTtrek Program Privacy Notice Supplement. The version date of this document is June, ACPPNUBI 06 17