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Arity Privacy Statement Supplement for California Consumers

Effective: 12/27/2019

Your privacy is very important to us. This Privacy Statement Supplement (“Privacy Supplement”) explains your rights as a California consumer regarding personal information that is subject to the California Consumer Privacy Act (“CCPA”) and supplements the information about Arity’s (“Arity”, “we”, “our” or “us”) privacy practices in the Arity Privacy Statement.  This Privacy Supplement is intended for California consumers only and should be read in conjunction with the Arity Privacy Statement.

Use the Table of Contents to link directly to a specific section of the Privacy Supplement.

Information We Collect and How We Collect It

We collect information about you in several different ways. We collect geolocation information and related driving behavior information about you through either (i) a mobile application you have installed that includes Arity’s driver behavior tracking technology or (ii) through a device installed in your vehicle. When we reference “mobile apps” below, we are referring both to a mobile app we provide and a mobile app that includes our driving behavior tracking technology. We collect information about you from other parties including our corporate affiliates, our business clients (businesses that use Arity’s technology with which you engage to receive a product or service), data brokers and service providers. We may collect information directly from you, such as information collected during an interview or survey.

The following are the categories of personal information that we may have collected about you and examples of the information that may be considered personal information under California law that fall into those categories:

  • Personal identifiers: Includes name, alias, postal address, unique personal identifier, online identifier, and email address.
  • Internet or other electronic network activity information: Includes browsing history, search history, information regarding your interaction with our website, mobile apps, and advertisements we facilitate, links you use, referral pages or web pages you visit while visiting our websites, browser type, internet service provider (ISP), and cookies. It also includes mobile app and device usage information (e.g., frequency of use, application marketplace from where you downloaded the mobile app, operating system and time zone) and driving behavior (e.g., phone handling, miles, speed, and if a mobile app detects a collision, information about the collision). See the Arity Privacy Statement for full information on the information Arity collects.
  • Geolocation data: Includes geolocation coordinates, including latitude, longitude, and altitude, your direction of travel, and the time the information was recorded.
  • Multimedia information: Includes audio, electronic, visual or similar information for purposes of conducting surveys or interviews.
  • Inferences: Inferences drawn from any personal information collected to create a profile reflecting preferences, characteristics, psychological trends, predispositions, driving habits and behavior, attitudes, abilities and aptitudes.

Arity often acts as a service provider to its business clients and collects certain additional personal information in connection with performing services on behalf of those business clients. The use of this information is subject to the privacy practices of those business clients. The personal information Arity collects as a service provider falls under the following categories of personal information:

  • Personal identifiers such as account name, social security number, driver’s license number, or other similar identifiers.
  • Other identifying information such as signature, phone number, state identification card number, insurance policy number, date of birth or family member information.
  • Characteristics of a protected class such as age, marital status, gender, gender identify or gender expression.
  • Commercial information such as policy coverage information, premiums, and payment history, driving or motor vehicle record, claims history, and credit information.

Use of Your Information

We use your personal and other information for business purposes including to:

  • Provide and maintain your services and products. We may use information to provide or maintain your service or products or provide services to our business clients to enable them to provide a product or service to you, including to set up a service or provide a product, or maintain your service, respond to customer service requests, or to investigate, respond to, and resolve issues or complaints or other inquiries.
  • Conduct Analytics and Research: We use personal and other information to perform actuarial studies, model development, and statistical analysis to refine our risk modeling and analytics and to create, deliver or improve our products and services including providing services to our business clients. For example, we use geolocation data to create insights on driving behavior and provide the geolocation data and those insights back to our business clients for purposes of the business client providing you a service or product. Where possible, we use anonymized or de-identified information for model development and analytics and have implemented practices to limit the use of personal information for analytics purposes.
  • Improve, develop and analyze our websites, services and products. We use personal information within algorithms, analytics software and other similar methods to analyze, improve, develop or deliver our website. We also use your information to analyze how visitors use our website to improve the website and enhance and personalize your experience. We collect some information used for these purposes using analytics software, cookies and other tracking technologies. For more information about the collection and use of this information, see Arity’s Cookie Statement.
  • Targeted advertising: We use advertising identifiers associated with your mobile device (commonly known as a Mobile Ad ID) to serve third-party interest-based advertising based on your driving habits. We serve these ads to you directly and through third-party advertising platforms.
  • Communicate with you about your service or product. We may communicate with you about your product or service, provide you confirmations or other service or product related messages via text, email or other available methods such as push notifications.
  • Send marketing communications. We may use your information to send you promotional communications about products, services, features, and options we believe may be of interest to you. We may send communications via e-mail or may send push notifications via a mobile device. Push notification preferences are controlled in your device. We may also use your information to serve you ads or customized content online.
  • Comply with legal requirements and protect the safety and security of our business, services, and Sites. We may use your information to comply with laws, regulations or other legal obligations, to assist in an investigation, to protect and defend our rights and property or the rights of third parties or enforce terms and conditions. We may also use your information to prevent suspected fraud, threats to our network or other illegal activities, prevent misuse or for any other reason permitted by law. We may use your personal information to protect our company, our affiliates, our customers, our network and our websites and mobile apps.
  • Update or correct our records. We may receive information about you from other sources, including publicly-available databases or third parties from whom we have purchased data, and combine that information with other information we have about you to update our records. For example, we may obtain change of address information from public sources and use that information to update or correct your address information.

Sharing Your Information

We may share personal and other information about you with third parties whenever you consent to or direct such sharing. We may also share your personal information with our affiliates for business purposes consistent with the uses described in this Privacy Supplement.  We strive to work with companies that share our commitment to privacy. We may also share information with others in an aggregated or de-identified form that does not reasonably identify you.

We may also share your personal or other information for business purposes or as required or permitted by law with:

  • Business clients: We share your personal information with our business clients that play a role in providing you a product or service, such as providing you with a mobile application.
  • Service providers to Arity: Personal information may be shared with service providers to Arity who perform services on our behalf for a business purpose including service providers that:
    • provide marketing and advertising, email or other communication services,
    • provide services that support our online activities including providing tracking technologies, web hosting and analytics,
    • provide tax and accounting, legal services, delivery, and data enhancement services,
    • provide technology services and enhance security, privacy and fraud protections,
    • provide analytics services or conduct research or actuarial studies, and
    • provide support to our operations.
  • Online marketing and advertising partners: We share personal and other information (including Mobile Ad Ids) with third party online marketing and advertising partners to serve interest-based targeted advertising based on driving behaviors. Arity also permits third party online marketing and advertising partners to collect information from you directly on our websites and mobile apps to facilitate online advertising. Arity’s Cookie Statement has more details about these activities.
  • Third parties in connection with a business transaction: Personal information may be disclosed to third parties in connection with a corporate transaction, such as a merger, sale of any or all of our company assets or shares, reorganization, financing, change of control or acquisition of all or a portion of our business by an affiliate or third party, or in the event of a bankruptcy or related or similar proceedings.
  • Law enforcement, regulators and other parties for legal reasons: Personal information may be disclosed to third parties, as required by law or subpoena, or if we reasonably believe such action is necessary to:
    • comply with the law and the reasonable requests of regulators, law enforcement or other public authorities,
    • protect our or others safety, rights or property, and
    • investigate fraud or to protect the security or integrity of our websites and mobile apps or any product or services.

Cookies and Other Tracking Technologies and Settings

When you visit our websites or use our mobile apps, we automatically collect information about your use and access of these websites and mobile apps using a variety of tracking technologies, including cookies, Flash objects, web beacons (also called pixel tags), embedded scripts, location-identifying technologies, and similar technology (collectively, “tracking technologies”). For details about these practices, including how to not accept cookies, see the Arity’s Cookie Statement. Although we do our best to honor the privacy preferences of our visitors, we are not able to respond to “Do Not Track” signals from your browser at this time.

If you are using a mobile app and disable the GPS functionality on your mobile device, location information may not be collected, and your service may be impacted.

Your California Privacy Rights and Choices

California residents have certain rights to access and delete their personal information as well as other rights described below.

To enhance user privacy, Arity maintains data in a way that cannot be reasonably associated with any individual. Therefore, in most cases, we will be unable to return specific pieces of information to you. However, you may be able to request information that Arity collects through one of our business clients who provide you with a product or service. To better protect you and your personal information, we will only respond to access or deletion requests that Arity has been able to properly verify through an authentication process. To verify your identity, you will be asked to provide certain information, which we will only use to verify your identity.   

To submit a request, visit arity.consumerprivacyinfo.com or email us at consumerrequests@arity.com. Responses to a verified request may take up to 45 calendar days, or longer depending on the nature of the request. If additional time is needed, we will notify you of the additional time. We may only respond to two access requests within a 12-month period.

Right to Access Your Personal Information: You have the right to request that we disclose certain information about our collection and use of your personal information over the past twelve months including:

  • the categories of personal information collected about consumers,
  • the specific pieces of personal information we have about you,
  • the categories of sources from where personal information was collected,
  • the business purpose for collecting the personal information, and
  • the categories of third parties with whom we share personal information.

 

Right to Deletion of Personal Information: You have the right to request we delete the personal information we collected, with certain exceptions. We will delete your personal information in response to a verifiable request unless needed for the following:

  • To complete a transaction for which we collected the personal information, provide a good or service you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you,
  • Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities,
  • Debug products to identify or repair errors that impair functionality,
  • Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law,
  • Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us,
  • Comply with a legal obligation, including compliance with the California Electronic Communications Privacy Act, or
  • Otherwise use your persona information, internally, in a lawful manner that is compatible with the context in which you provided the information.

 

Sale of Personal Information

We do not sell personal information for money. To facilitate the delivery of targeted advertising, we share unique advertising identifiers with advertising publishers. Under California law, sharing these unique advertising identifiers for online advertising may be considered a “sale” of information. Except for this kind of sharing, Arity does not sell any other information. To make a request for Arity to not share your unique advertising identifier, please click here.

 

Non-Discrimination Rights: We will not discriminate against you for exercising any of your rights.

 

Other Rights under California Law

California Civil Code section 1798.83 (Shine the Light Law): If you are a California resident, you can opt-out of our sharing of your personal information with third parties for the third parties’ direct marketing purposes by emailing info@arity.com. To find out more about your opt-out rights, please review this Privacy Supplement or contact us at Arity 222 W. Merchandise Mart Plaza Suite 875, Chicago IL 60654 or via email at info@arity.com.

Social Media, Links, and External Sites

Links to other company’s websites may be provided on the Arity website as a convenience to you. If you choose to go to these external websites, you will be subject to the privacy practices of those external websites; Arity is not responsible for the privacy practices of those websites. We encourage you to be aware when you leave our website to read the privacy policies or statements of every website you visit, as those privacy policies or statements may differ from ours.

Our website includes Social Media Features, such as the Facebook Like button and Widgets, the Share this button or interactive mini-programs that run on our website. These features may collect your IP address, which page you are visiting on our website, and may set a cookie to enable the feature to function properly. Social media features and widgets are either hosted by a third party or hosted directly on our website. Your interactions with these features are governed by the privacy policy of the company providing it.