Arity Privacy Statement Supplement for California Consumers
Effective: July 7, 2020
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 personal and other information about you. Personal information is data that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked (directly or indirectly) with you. Other information does not and cannot reveal an individual’s identity such as information that has been de-identified or aggregated. The information we collect varies based on what products and services you have with us.
We collect information about you in several ways and from several sources. 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 personal 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 personal information directly from you, such as personal information collected during an interview or survey.
The following are the categories of personal information that we have collected and shared for at least the past 12 months, 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- such as mobile advertising identifiers (Mobile Ad ID), internet protocol (IP) address, 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 Arity’s Privacy Statement for additional details about the information automatically collected from your devices.
- Geolocation data: Includes geolocation coordinates, including latitude, longitude, and altitude, your direction of travel, and the time the information was recorded.
- Inferences: Inferences drawn from 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 and not this privacy statement.
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 and other information to:
- analyze, improve, develop or deliver our website using algorithms, analytics software and other similar methods
- 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.
- Provide marketing communications. We may use your personal 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 personal 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 personal 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 personal information about you from other sources, including publicly-available databases or third parties from whom we have purchased data, and combine that personal 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 personal information to update or correct your address information.
We may share personal and other information about you with service providers and other 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 with service providers and other third parties 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 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.
- Marketing and advertising partners: We share personal and other information (including Mobile Ad IDs) with third party online and other marketing and advertising partners to serve interest-based targeted advertising based on driving behaviors. Arity also permits third party online and other 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.
We share the following categories of personal information with the following parties:
- Geolocation Data: Business Clients; Service Providers to Arity; Marketing and Advertising Partners; Law Enforcement or Regulators
- Internet or other electronic network activity information: Business Clients; Service Providers to Arity; Marketing and Advertising Partners; Law Enforcement or Regulators
- Inferences: Business Clients; Service Providers to Arity; Marketing and Advertising Partners; Law Enforcement or Regulators
- Personal identifiers: Business Clients; Service Providers to Arity; Marketing and Advertising Partners; Law Enforcement or Regulators
- Service or product related information: Business Clients; Service Providers to Arity; Law Enforcement or Regulators
When you visit our websites or use our mobile apps, we automatically collect information about your use of and access to 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 and user-enable global privacy controls 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 are unable to verify your identify and 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.
To submit a request, visit arity.consumerprivacyinfo.com or email us at firstname.lastname@example.org. 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. Requests from authorized agents must be submitted via the same online portal or email address.
Right to Access Your Personal Information: You have the right to request that we disclose to you certain information about our collection and use of your personal information over the past twelve months including:
- the categories of personal information collected,
- the specific pieces of personal information we have collected about you,
- the categories of sources from which 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. We will delete your personal information in response to a verifiable request unless needed 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, 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 monetary value. 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 Mobile Ad ID, 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 email@example.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 firstname.lastname@example.org.
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.
If you should have questions or concerns about our privacy partners, please contact us through the below methods.
Please note: When sending inquiries to us, we may need additional information such as the business client you have engaged for which we collected data to better assist you.
Attn: Data Protection Officer
222 W Merchandise Mart Plaza, Suite 875
Chicago, IL 60654
United States of America