Great Driver™ Telematics App Privacy Policy
Electric Insurance Company® (“Electric Insurance”, “we”, “our”, “us”) utilizes a third-party vendor to provide the Great Driver™ Telematics Application (“App”), a cloud-based technology that enables us to measure and reward good driving behavior without the need for a plug-in device in the vehicle (the "Platform").
The Platform and the App (together, the "Services") allows insurance carriers to measure the App user’s (“User”) driving skills through a cost-effective, frictionless driver safety scoring and Usage Based Insurance (UBI) solution.
We respect the App Users’ privacy and are committed to making our practices regarding their data transparent. This Privacy Policy describes how we collect, store, use and disclose such personal data. It applies whenever you, the “User” interact with the App or otherwise access or use the Services. Specifically, it describes our practices regarding:
- Data Collection
- Data Uses
- Data Location and Retention
- Data Sharing
- Cookies and Tracking Technologies
- Communications
- Data Security
- Additional Notices
Please read this Privacy Policy carefully and make sure that you fully understand and agree to it. If you do not agree to this Privacy Policy, please do not use the Great Driver App.
You are not legally required to provide us with any Personal Data (defined below), but without it we will not be able to provide you with the full range of Services or with the best user experience when using the Services.
1. Data Collection
Personal Data related to Users of the Great Driver telematics mobile Application (“App” is typically collected and generated through your interaction with the App, through automatic means, or directly from Electric Insurance. Specifically, the following categories of data are collected: (which, if it could be used to identify a specific person, or is linked to such identifying data, will be deemed as "Personal Data")
- Data Automatically Collected or Generated: When you interact with or use the App, it may collect or generate certain technical data about you. Such data is collected or generated either independently or with the help of third-party services (as detailed in Section 4 below), including through the use of "cookies" and other tracking technologies (as further detailed in Section 5 below).
- Such data mainly consists of connectivity, technical and aggregated usage data, such as IP addresses, non-identifying data regarding a device, operating system, browser version, locale and language settings used, the cookies and pixels installed on such device and the activity (clicks and other interactions) of Users in connection with the Services. Such data is mainly used to gain a better understanding on how Users typically use the Services and how their user experience may be improved, as well as the overall performance of the Services.
- User Data Electric Insurance Provides: Electric Insurance may also provide the third-party provider with data concerning its customers, to enroll such Users in the Great Driver Telematics App Program. Such data usually refers to the Users’ surnames, forenames, policy numbers, e-mails, telephone numbers and vehicle details (such as model type and manufacturing year). However, Electric Insurance may provide the third-party vendor with additional data at its discretion.
- Data Received Directly from Users: When Users download the App and use the related Services (usually after they have been enrolled to the Services as detailed above, they may provide Personal Data such as their name and contact details (such as e-mail, phone and address), as well as any other data they choose to provide when they are using the App. In addition, data may be collected that we may also collect data which is primarily related to Users’ driving habits and activities during their driving ("Driving Data"). Such Driving Data includes location, trips’ durations (start and end times), mileage, routes, the occurrence of fast accelerations, hard stops, speeding, mobile device information, non-driving trip information, mobile interaction during trips, and potential auto crashes.
2. Data Uses
We use Personal Data as necessary to determine App Users’ overall driving score and sub-scores, for the performance of the Services; for complying with applicable law; and to support, maintain, and improve the Services and offerings, understanding how the Services are used, optimizing customer service and support operations, and protecting and securing the personal data of our Users, and the Services. Specifically, Personal Data may be used for the following purposes:
- To facilitate, operate, and provide the Services and specifically to create profiles of User's based on their driving behavior to assist in the rating or underwriting of User's auto insurance policy;
- To authenticate the identity of our Users, and to allow them access to the Services;
- To provide our Users with assistance and support;
- To further develop, customize and improve the Services and your user experience, based on common or personal preferences, experiences and difficulties;
- To contact Users with general or personalized service-related messages (such as inquiries about driving schedules, information about the use of the Services etc.);
- To support and enhance data security measures, including for the purposes of preventing and mitigating the risks of fraud, error or any illegal or prohibited activity;
- To create aggregated statistical data, inferred non-personal data or anonymized or pseudonymized data (rendered non-personal), which we or our business partners may use to provide and improve our respective services; and
- To comply with any applicable laws and regulations.
3. Data Location and Retention
Data Location: Personal Data may be maintained, processed, and stored by the third-party vendor and its authorized subsidiaries and Service Providers (defined below) in the United States (US) and other jurisdictions, as necessary for the proper delivery of the Services, or as may be required by law.
Outside the US, the third-party vendor has offices in Israel and the UK, both offer an adequate level of protection for the Personal Data of EU Member State residents.
The third-party vendor may be required to transfer Personal Data to countries other than the country in which the data originated. Any such transfers shall be done in compliance with all applicable laws. While privacy laws may vary between jurisdictions, the third-party vendor, its affiliates and Service Providers (as defined below) are each committed to protect Personal Data in accordance with this Privacy Policy and customary industry standards, regardless of any lesser legal requirements that may apply in their jurisdiction.
Data Retention: The third-party vendor retains User's Personal Data for as long as Electric Insurance’s agreement with it is in effect, or for as long as their account is active, or as long as the App is still active, and the third party vendor has not been notified otherwise, or as long as it is considered necessary for the purposes described herein. Notwithstanding the above, User's Personal Data collected during Services testing, may be deleted following completion of the test, unless otherwise is requested in writing by the Users.
Users’ Personal Data is maintained as long as reasonably necessary to provide the Services.
Personal Data is retained for as long as it is required to comply with our legal and contractual obligations, or to address any potential disputes (i.e. as required by laws applicable to records and bookkeeping, as necessary for allowing the Users to meet their own obligations or legitimate needs, and in order to have proof and evidence concerning our relationship, should any legal issues arise following discontinuance of use), in accordance with our data retention policy.
Please note that except as required by applicable law, there is no obligation to retain Personal Data for any particular period, and it may be securely deleted for any reason and at any time, with or without notice to User. If you have any questions about our data retention policy, please contact us by email at [email protected].
4. Data Sharing
Legal Compliance: Personal Information may be disclosed or government and law enforcement officials may be allowed access to Personal Data, in response to a subpoena, search warrant or court order (or similar requirement), or in compliance with applicable laws and regulations. Such disclosure or access may occur if it is believed in good faith that we are legally compelled to do so, or that disclosure is appropriate in connection with efforts to investigate, prevent, or take action regarding actual or suspected illegal activity, fraud, or other wrongdoing.
Service Providers: Third parties may be engaged to perform services complementary to the Services (e.g., hosting services, data analytics services, marketing and advertising services, data and cyber security services, user engagement services, e-mail distribution and monitoring services, session recording, and our business, legal and financial advisors) (collectively, "Service Providers"). These Service Providers may have access to your Personal Data, depending on each of their specific roles and purposes in facilitating and enhancing the Services, and may only use it for such purposes.
Sharing Users Personal Data with Electric Insurance: Personal Data of Users may be shared with Electric Insurance (including data and communications concerning the Services user account). In such cases, sharing such data means that other individuals from Electric Insurance may receive it, and will be able to monitor, process and analyze your Personal Data and associated content.
Protecting Rights and Safety: Personal Data with others if it is believed in good faith that this will help protect the rights, property or personal safety of Users.
The third-party vendor Subsidiaries: The third party vendor may share Personal Data internally within its group for the purposes described in this Privacy Policy. In addition, should the third-party vendor or any of its subsidiaries undergo any change in control, including by means of merger, acquisition or purchase of substantially all of its assets, Personal Data may be shared with the parties involved in such event. If such change in control might materially affect your Personal Data stored with us, we will notify you at a time permitted under the terms of this event and the choices you may have via e-mail or prominent notice on the Services. For the avoidance of doubt, the third-party vendor may share your Personal Data in additional manners, pursuant to your explicit approval, or if it is legally obligated to do so, or if it has successfully rendered such data non-personal and anonymous. The third-party vendor may transfer, share or otherwise use non-personal data at its sole discretion and without the need for further approval.
5. Cookies and Tracking Technologies
The Services and some of our Service Providers utilize "cookies", anonymous identifiers and other tracking technologies which help us provide, secure and improve the Services, personalize your experience and monitor the performance of our activities.
6. Communications Service
Communications: Users may be contacted with important information regarding the Services. For example, we may notify you (through any of the means available to us) of changes or updates to the Services, service changes, password-retrieval notices, etc. The third-party vendor or Electric Insurance may also send you notifications, messages and other updates.
7. Data Security
In order to protect your Personal Data held with us and the Service Providers, we are using industry-standard physical, procedural and electronic security measures, including encryption as appropriate. However, please be aware that regardless of any security measures used, we cannot and do not guarantee the absolute protection and security of any Personal Data stored with us or with any third parties as described in Section 4 above.
8. Additional Notices Updates and Amendments
This Privacy Policy may be updated from time to time by posting an amended version on App. The amended version will be effective as of the date it is so published. External Links: While the Services may contain links to other websites or services, we are not responsible for their privacy practices, and encourage you to pay attention when you leave the Services for the website or application of such third parties and to read the privacy policies of each and every website and service you visit. This Privacy Policy applies only to the Services.
How to Contact Us
If you have any questions or comments about this Privacy Policy or if you would like us to update information we have about you or your preferences, please contact us at at [email protected] , or by writing to us at: Attn: Chief Compliance Officer Electric Insurance Company, 75 Sam Fonzo Drive, Beverly, MA 01915. We can also be reached at 800.227.2757.
