Last Modified: July 11, 2017
For important details about how the Application works, and its features and functions, please consult the FAQs available from the Settings menu in the Application, or on the internet, here [add link to terms and conditions]. You also will find important privacy and data related controls in the “family roster” available in the center top of the map view and the menu, available from the top left of the map view.
Collection of Information from or about Users of the Application
As discussed in this Policy, personally identifiable information or “personal information” is data that can be used to identify or contact a single person.
The Application may collect your personal information which may include, but may not be limited to, your e-mail address, name, date of birth, home or work address and telephone number. Additionally, the Application collects non-personal information in the form of driving data from your phone such as driving speed, time of day and GPS-based location data.
Safety and TrueMotion in offering the Application on Safety’s behalf will retain your personal information for the period necessary to fulfill the purposes outlined in this Policy, unless otherwise required or permitted by law.
The Application is intended to collect your driving information, but may inadvertently collect the driving information of third parties with whom you are a passenger. No records will be created that identify any such third parties. If the Application has inadvertently misclassified a trip, you can tap on the trip and edit the trip, and this will help TrueMotion better classify future trips.
As is true of most applications and websites, the Application gathers certain information automatically and stores it in log files. This information may include Device ID, internet protocol (IP) addresses, browser type, internet service provider (ISP), referring/exit pages, operating system, date/time stamp, and clickstream data. To collect this information, when you use the Application, a “cookie” may be set on your device or computer. Cookies contain a small amount of information that allows the web servers associated with the Application to recognize you whenever you visit. The Application stores information that it collects through cookies, log files and/or clear gifs to create a “profile” of your preferences. Safety does not tie your personal information to information in the preferences profile, and does not permit TrueMotion to do so either. Safety and TrueMotion may use this information, which does not identify individual users, to analyze trends, to administer the Application, to track users’ movements with respect to the Application and to gather demographic information about the Application user base as a whole. Safety does not provide this information to outside parties other than as set forth in this Policy, and does not permit TrueMotion to do so either. No personal information is stored in cookies and TrueMotion does not link collected data to personal information.
Use of your Personal Information
The Application uses your personal information to deliver the features and functions of the Application, as they may be modified from time to time.
Safety and TrueMotion (in its role as a service provider to Safety) may use, disclose, or transfer your personal information or the personal information of others you have provided to us in the ordinary course of our business, when:
(1) you expressly authorize them to do so, such as within Families you own or join;
(2) to verify identity, assist with identification or age validation of users, and to determine appropriate services;
(3) to send important notices, such as communications about changes the Application’s terms, conditions, and policies, or to send you other information that may be important to you;
(4) to allow service providers or agents to provide services on behalf of Safety;
(5) to provide Safety’s products or services to you (and contact you when necessary);
(6) to companies with whom Safety has joint marketing agreements;
(7) to protect the confidentiality or security of your records;
(8) subject to applicable contractual or legal restrictions, in connection with a sale of all or substantially all of the assets of Safety or TrueMotion or the merger of Safety or TrueMotion into another entity or any consolidation, share exchange, combination, reorganization, or like transaction in which Safety or TrueMotion is not the survivor;
(9) for internal purposes at Safety or TrueMotion such as auditing, data analysis, and research and to fulfill other standard business purposes including, without limitation, customer care, service quality, business management and operation, risk assessment, security, fraud and crime prevention/detection, monitoring, research and analysis, marketing, customer purchasing preferences and trends and dispute resolution;
(10) to comply with law enforcement, governmental mandate, or other legal requirement, if appropriate, for your protection or in connection with an investigation or prosecution of possible unlawful activity;
(11) to Safety’s or TrueMotion’s attorneys, accountants, regulators, auditors or other advisors;
(12) it is otherwise necessary for Safety, or TrueMotion as its service provider, to disclose it as required or permitted by law;
(13) to protect and defend the rights or property of Safety and/or TrueMotion;
(14) to act under exigent circumstances to protect the personal safety of users of Safety and/or TrueMotion or the public; or
(15) if Safety or TrueMotion determines that for purposes of national security, law enforcement, or other issues of public importance, disclosure is necessary or appropriate.
Safety authorizes TrueMotion (which offers the Application on Safety’s behalf) to use various web site or mobile application analytics tools and technologies regarding activities in the Application. The overall aim of these tools is to aid in making the Application easy to use and to proactively identify and correct error conditions.
Disclosure of Information about Users within Families
Drivers in the Application may be organized into Families, which are groups of users (within a family relationship, or simply friends or others who agree to share certain information within their Family group). Members of a Family can optionally see each other’s locations, trips and driving scores. Any Family member can tap on themselves to leave the Family.
Disclosure of Information about Users to Third Parties
Safety authorizes TrueMotion (which offers the Application on Safety’s behalf) to share information collected from or about registered Application users or their devices with trusted partners to help perform statistical analysis. All such third parties are contractually prohibited from using personal information provided by the Application, except to provide these services to the Application, and they are required to maintain the confidentiality of your information with equal or greater protections than those provided by the Application.
Third Party Sites and Services
The Application may contain links to third-party websites, products, and services. Information collected by third parties, which may include such things as location data or contact details, is governed by such third-party privacy practices. We encourage you to learn about the privacy practices of those third parties.
Security of your Personal Information
To make sure your personal information is secure, Safety requires TrueMotion (which offers the Application on Safety’s behalf) to maintain reasonable safeguards on data collected from and about Safety’s insureds, including by communicating privacy and security guidelines to employees and strictly enforcing safeguards around the confidentiality, integrity, and availability of data collected from Safety’s insureds within TrueMotion’s environment. The Application secures your personal information, and the personal information of others on computer servers in a controlled, secure environment, protected from unauthorized access, use or disclosure. However, no data transmission over the Internet can be guaranteed as 100% secure. As a result, while Safety and TrueMotion strive to protect your information, neither Safety nor TrueMotion can ensure or warrant the security of any information you transmit to Safety and TrueMotion or you receive from Safety and TrueMotion.
Access to Personal Information
You can help ensure that your contact information and preferences are accurate, complete, and up to date by logging in to your account. Access, correction, or deletion requests should be directed to Safety, per the Contract Information section below.
Collection and Use of Non-Personal Information
The Application also collects data in a form that does not, on its own, permit direct association with any specific individual. Safety or TrueMotion may collect, use, transfer, and disclose non-personal information for any legitimate purpose. The following are some examples of non-personal information that Safety or TrueMotion collects and how it may be used:
- The Application may collect information such as zip code, area code, unique device identifier, referrer URL, location, and the time zone where the Application is used so that Safety or TrueMotion can better understand customer behavior and improve their products and services. If Safety or TrueMotion associates this information with Device ID, or your personal information, Safety and TrueMotion, and each of them, will treat the information as personal information, as described in this Policy.
- The Application records information about your digital actions. This information is aggregated and used to provide more useful information to customers or partners, in the aggregate, and to understand the popularity or utilization of Safety’s or TrueMotion’s product offerings. Aggregated data is considered non-personal information for the purposes of this Policy.
Using the Application from Outside the United States
If you are using the Application from outside of the United States, please be aware that your information, including any personal information to which Safety or TrueMotion may be given access, may be transferred to, stored, or processed in the United States. The data protection and other laws of the United States and other countries may not be as comprehensive as those in your country. By using the Application, you understand that your personal information may be transferred to Safety’s and/or TrueMotion’s facilities located in the United States and to those third parties with whom Safety or TrueMotion shares such information as specified in this Policy.
No Information Collected from Children under 13
The Application targets legally licensed or permitted drivers only. Accordingly, the Application does not knowingly collect, use or disclose personal information from children under 13, or equivalent minimum age in the relevant jurisdiction. If Safety learns that the Application has collected the personal information of a child under 13, or equivalent minimum age depending on jurisdiction, without first receiving verifiable parental consent, Safety will take steps to delete the information as soon as possible.
Changes to this Policy
This Policy may change at any time and from time to time. The most recent version of the Policy is reflected by the version date located at the bottom of this Policy. Safety and TrueMotion encourage all users to periodically review this Policy for the latest information on its privacy practices.
If you have any questions about this Policy, please contact Safety at email@example.com or (800) 951-2100 x6429.