PRIVACY POLICY – MotionSmart^SM Mobile App

Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it. By registering to use the App, clicking the relevant tick boxes prior to installing the App and then using the App or Services, you agree to the practices described in this Privacy Policy.

MAPFRE Insurance and CMT have always made it a priority to protect your personal and privileged information. We do not sell your information. We limit access to your personal and privileged information to those persons who need to know it to perform their jobs and to provide service to you, and as required or permitted by law. We maintain physical and electronic safeguards to protect such information from unauthorized use or disclosure.

• MAPFRE Insurance and CMT only collect and maintain the minimum amount of data necessary to provide the Services.
• MAPFRE Insurance and CMT do not sell your customer information.
• MAPFRE Insurance and CMT do not share customer information with third parties except as expressly set forth in this Privacy Policy, under Information We May Share or, otherwise, is necessary to provide Services to you or is required by law. MAPFRE Insurance and CMT handle all collected data in the same uniform fashion – for prospective, current or former customers.
• MAPFRE Insurance and CMT maintain physical, procedural and technological controls to protect customer information and to comply with applicable privacy laws and regulations.

We collect information that we believe is necessary to serve you effectively and to permit us to meet your needs, such as information that we receive from your insurance application collected over the telephone, through electronic devices such as laptops, phones, and tablets, and through written correspondence and communications from you.

The types of information we collect about you and the sources from which we collect the information include: your name, address, telephone number; information about your transactions with us; information that you provide to us on our Website; information from your insurance agent or broker (if applicable); information that we receive from consumer reporting agencies; information from website usage (or traffic) including information automatically collected through technology such as cookies, pixels, and tags; information from customer lists provided by other organizations and marketing data providers; information from governmental agencies and insurance-support organizations; location information on certain applications including usage based insurance programs; and information relating to insurance claims, which may include medical information.

When you use the App or Services, we will collect information about your driving style and habits, such as location, speed, acceleration, braking and cornering and combine this with weather, traffic, time of day and other contextual data. Such use is based upon you giving explicit consent to this profiling when registering to use the App or Services.

Apple, iPhone Users:  Information about the App’s privacy practices are required for the Apple App Store to assist users in understanding an app’s privacy practices before they download the App on any Apple platform.  In addition to the above, we may also collect the following information that is linked to your identity.  This information is not used for tracking* purposes:

• Contact Information – email: Users can authenticate their access to the App via email address.
• Health & Fitness – Fitness (Motion): The App uses motion activity to detect phone use while driving
• Location – precise: This enables more accurate delineating of trips.
• User Content – Photos or Videos: User can upload a photo for their profile.
• Identifiers – User ID and Device ID.
• Usage Data – Product Interaction: User engagement analytics help us to improve user interface design.
• Diagnostics – Crash Data: Data on possible collisions is used in aggregate analytics to understand the impact of driving behaviors.
• Other Data

* Tracking is defined as linking data collected about a user or device with a third-party data for advertising, advertising measurement purposes, or sharing data about a user or device with a data broker.

Sensitive Data: MAPFRE Insurance and CMT do not collect personal data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, and do not engage in the processing of genetic data, biometric data for the purpose of uniquely identifying a natural person, or data concerning health or medical condition.

We use information that we believe is necessary to serve you effectively and to permit us for one or more of the following purposes:

• To fulfill or satisfy the purpose for which you provided the information to us including but not limited to: underwriting, rating, claims, billing, policy servicing, marketing and advertising purposes,
• To provide, support, personalize, and develop our website/mobile/electronic capabilities, products, and services,
• To create, maintain, customize, and secure your account with us,
• To process your requests, purchases, transactions, and payments and prevent transactional fraud,
• To provide you with support and to respond to your inquiries, including to investigate and address your concerns and monitor and improve our responses,
• To provide services through various applications including administering usage based insurance programs that we may operate independently or with our vendors,
• To help maintain the safety, security, and integrity of our Website, products and services, databases and other technology assets, and business,
• For testing, research, business & statistical analysis building statistical models, and product development, including to develop and improve our Website, products, and services,
• To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations,
• To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by us about our [Website users/consumers] is among the assets transferred,
• To the extent that we collect protected classification information, we collect such information to comply with federal and state law and/or, to deliver employee benefits & services,
• To respond to your inquiries, questions or comments if you access our Website or if you send us an email with questions or comments. We may save your questions or comments or your e-mail address for future reference,
• To notify you about your account, products, and services with us and notify you of any changes to products and services we offer or provide to you.

In addition, the information may also assist us with managing our business including but not limited to:  maintaining business continuity plans, conducting internal audits, building actuarial and statistical models, and fulfilling various legal requirements, or to perform obligations under an existing contract with you.

We neither rent nor sell your personal data to any third party. We will share your personal data only in a manner consistent with the purposes set forth below or, otherwise, with your consent.  You will have had to review and agree to the sharing and terms of use prior to utilization of the application.

Specifically, we may share information that we collect:

• with industry regulators, law enforcement agencies or other governmental authorities, and anti-fraud organizations or as otherwise required or permitted by law;
• with attorneys or other authorized persons in connection with legal matters, as required by subpoenas and court rules and orders; including our attorneys, reinsurers, accountants, and auditors; and such other parties as permitted or required by law;
• with companies within the MAPFRE Insurance group and affiliates of MAPFRE U.S.A., Inc.;
• with your insurance agent or broker (if applicable);
• with parties to conduct research and analyze data to improve our products and services;
• with third parties that perform services for us such as processing transactions authorized by you, providing consumer reports, building statistical models, and conducting claims investigation, medical examinations, inspections, and appraisals;
• with third parties including banks, credit unions, affinity groups, and various intermediaries with which we have joint marketing agreements to market our products;
  • to enforce or apply our MAPFRE MotionSmart program Terms and Conditions/ Disclosure Notice and other agreements, including for billing and collection purposes;
• if we believe disclosure is necessary or appropriate to protect the rights, property, or safety of MAPFRE Insurance group and affiliates of MAPFRE U.S.A. Inc., our customers, or others. This includes exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction.

In addition, MAPFRE Insurance and CMT may provide anonymous application or website usage data to analytics and search engine providers that assist us in the improvement and optimization of our website and applications. We may also share your information for any other purpose disclosed by us when you provide the information, or otherwise with your consent.

We use “cookies” to enhance your access to our web site. A cookie is a small amount of data that is sent to your browser from a web server and stored on the hard drive of your computer or mobile communications device. Cookies do not store personal information about you, unless you knowingly provide it. Cookies can store non-personal information, such as what web site pages or advertisements your browser has accessed. We use cookies to store information and personalize your experience with our web site. For example, cookies allow our web site to recognize you as a previous visitor, and thus save and remember any preferences that may have been set while you were previously browsing our web site. You do have some control over cookies. Many browsers can be set to notify you when a cookie is being placed on your computer. Many browsers can also be set to refuse to accept cookies, although this may affect your internet experience. You can also erase cookies that are already on your computer. For more information about working with cookies, you should consult your user manual, FAQ, or “help” function of your specific browser and operating system software.

WE DO NOT SELL YOUR INFORMATION TO TELEMARKETERS OR OTHER MASS MARKETING BUSINESSES.

We have implemented measures designed to secure your personal information from accidental loss and from unauthorized access, use, alteration, and disclosure. We limit access to your information to those persons who need to know it to perform their jobs and to provide service to you, and as required or permitted by law. We maintain physical, electronic, and procedural safeguards to protect such information from unauthorized use or disclosure.

You may have additional concerns about the privacy and security of information collected through our Website. We are committed to protecting the online privacy of visitors to our Website. We maintain physical, electronic, and procedural safeguards to secure your personal information. However, “perfect security” does not exist on the internet, and there is always some risk in transmitting information electronically. We use security measures consistent with industry standards, such as firewalls and encryption technology, to protect your information. Information we share with third parties are also subject to appropriate security evaluations and confidentiality provisions to limit the purposes for which information shared may be used.

Our Website may contain links to other websites. We have no control over the privacy practices or the content of any of our business partners, advertisers, sponsors, or other websites we provide links to from our Website. You should check the applicable privacy policy of the website sponsor when linking to other websites.

The safety and security of your information also depends on you. Where we have given you (or where you have chosen) a password for access to certain parts of our website or an account with us, you are responsible for keeping this password confidential. We ask you not to share your password with anyone.

MAPFRE Insurance^® is a brand and service mark of MAPFRE U.S.A. Corp. and its affiliates, American Commerce Insurance Company^SM, Citation Insurance Company^SM; The Commerce Insurance Company^SM; Commerce West Insurance Company^SM (Cal. COA. 06715), MAPFRE Insurance Company^SM (Cal. COA 18643), and MAPFRE Insurance Company of Florida^SM (Miami, FL).

If you are a resident of Arizona, Connecticut, Georgia, Illinois, Maine, Minnesota, Montana, Nevada, New Jersey, North Carolina, Oregon or Virginia, you have the right to access and correct the personal information that we have collected about you. Upon the request of residents of other states, we will take reasonable steps to verify the accuracy of the personal information in our records.

Like you, we are concerned with protecting your privacy. To request a copy of our Privacy Policy or to verify the accuracy of information we have about you, you may email us at MotionSmart@mapfreusa.com, or call us at (833) 915-3859.