November 30, 2018
Pocket Drive Privacy Notice
We are a mobile Device Service that, together with the Device, provides information on your Vehicle
Assurant, Inc. through its affiliated companies, BroadTech, LLC and The Signal (hereinafter, “We”, “Us”, “Our” or “Company”), respects your concerns about privacy. If you reside in the United States, then the personal information provided to or collected by Our Service is controlled by Assurant, Inc., 28 Liberty Street, New York, NY 10005 U.S.A. This Pocket Drive Privacy Notice (“Notice”) describes how we will collect, access, use, disclose, retain, transfer, otherwise process and protect personal information when you use Our Pocket Drive Device (“Device”) and related Services (the “Service”). The Device and Service are collectively referred to as “Pocket Drive”. The Device refers to the Device that plugs into the OBD II Port of your Vehicle in support of the Services provided by Pocket Drive. The Services may include, but are not limited to:_a) collision and disturbance notifications, b) diagnostic vehicle scan (DTC) reading and notification, c) trip timeline and driving style scoring, d) geofencing, e) maintenance and recall notifications, f) parking locator, g) vehicle locator, h) discount offers, and i) emerigency SOS and roadside assistance j) WiFi hotspot service from a third party service provider, and k) digital glovebox. Services are provided through the use of the Pocket Drive Device and information can be accessed via a mobile app (“Mobile App”). The service will collect personal information from you and your vehicle through the Device and any mobile Devices on which the mobile app is installed. Pocket Drive provides a connected-car service that allows you to gain access to information on the use and operation of your vehicle in order to enhance your driving experience and improve your vehicle performance. The Pocket Drive Solution is enabled by the Pocket Drive Hardware Device which plugs into your vehicle and connects with the Pocket Drive mobile application.
We protect your personal information using industry standard safeguards. We may share information about you with your consent or as required by law, and We will always let you know when We make significant changes to this Privacy Notice.
We adhere to the following principles to protect your privacy:
We protect your personal information and will only provide it to third parties:
(1) with your consent;
(2) where it is necessary to carry out your instructions;
(3) as reasonably necessary in order to provide the Service;
(4) to Our service providers (as described in Section 2.5) in connection with providing the Service or Our associated operations;
(5) when We reasonably believe it is required by law, subpoena or other legal process;
(6) as necessary to enforce Our Terms of Service, to protect the rights of the Company, or to prevent physical harm or financial loss; or
(7) as part of a reorganization or sale of all or part of Our business.
We have implemented safeguards designed to protect your information in accordance with industry standards.
This Notice applies to the Service only and does not necessarily reflect practices with respect to information gathered through other Services We offer or websites We operate or the collection of information through off-line means. To review the privacy practices of those other Services, please refer to the policies provided in association with each.
If you have any concern about providing information to Us or your information being used in any manner permitted by this Privacy Notice and the Terms of Service, you should not download the Mobile App or otherwise use the Service. If you have already downloaded the Mobile App, you may close your account. See Section 3.1 of this Notice to view how to close your account.
Our Privacy Notice applies to any users of the Service. We collect information when users operate Our Service
1. What information We collect
1.1 Account Information & Registration
By using the Pocket Drive Hardware Device, the Pocket Drive Application may collect the following types of information:
To access and use certain features of the Pocket Drive application, you will need to verify your identity and register your Pocket Drive Account (the “Account”) through the available Pocket Drive Mobile Application. During the registration process, you may be asked to provide Us with your mobile telephone number, zipcode, and email address in addition to the personal information previously collected through your dearlership Pocket Drive contract (Ex. vehicle indentifcation number (VIN), make, model, mileage, Pocket Drive hardware Device number (or IMEI), and possibly other Assurant or third party protection contract purchases done through your dealer. You will also need to agree to the Terms of Service and this Privacy Notice. The term "personal information" includes any individually identifiable information about you, such as, your email address, mobile phone number, vehicle identification number (VIN), and IMEI, assigned to your Pocket Drive account.
It is important that the personal data we hold about you is accurate and current. Please keep Us informed if your personal data changes during your relationship with Us.
1.2 Hardware Device
We collect and use the information described below about the vehicle in which you installed the Pocket Drive Hardware Device. We receive some of this information via a mobile service provider. See section 3(b) “Mobile Services Providers” for further information on how the Pocket Drive Hardware Device interacts with a mobile network.
1.2.1 Vehicle Operation
We collect information about your vehicle’s operation to provide you with feedback on your driving habits. For example, we collect data on hard braking, hard acceleration, and speed. Using this information, we provide you with insight into your driving style that can help you save on gas and vehicle wear and tear. We require your vehicle type and vehicle identification number so that we can provide you with tailored feedback.
1.2.2 Vehicle Location
We collect information on the location of your vehicle, including your trip route and the parked location of your vehicle. Trip routes allow you to review a particular route that you have driven, the fuel cost associated with that route, and the length of time the particular route takes to drive. If you access the Pocket Drive App by Mobile Device, you may be asked to share your geo-location in order to make use of our geo-location Services. You may also be asked to provide Us with access to your Device’s contact book and phone number in order to use some of the features of the Pocket Drive Mobile App, e.g. to communicate the location of your vehicle to your contacts.
1.3 Payment Information
When you pay for the Pocket Drive in-app Services you will be disclosing your payment information to a third party payment processor who will process and store your personal payment information. We do not have access to any payment processing information or any financial information such as credit card numbers.
1.4 Pocket Drive App Installation & Usage
After you have registered for the Service and the Mobile App has been downloaded, information is collected from the Mobile Device periodically and stored within Our data center or the data center of a service provider to Us. This information varies depending upon the Mobile App features you may be eligible to use and may include: a) collision and disturbance notifications, b) diagnostic vehicle scan (DTC) reading and notification, c) trip timeline and driving style scoring, d) geofencing, e) maintenance and recall notifications, f) parking locator, g) vehicle locator, h) discount offers, and i) emerigency SOS and roadside assistance j) WiFi hotspot service from a third party service provider, and k) digital glovebox Services. We collect this information to provide the Services. You may view certain personal information, and request modification or deletion of your personal information collected by the Mobile App at any time. By disabling certain notifications in the app, such as those noted here, they will no longer receive certain information.
We collect information about your usage of Our Mobile App and may use third party analytics tools to evaluate user actions relative to the Mobile App. For example, when you are logged in on the Mobile App, your usage information will be associated by Us to your account. Even if you are not logged into the Mobile App, we log information about vehicle Devices used to access Our service.
1.5 Aggregated Information
We also collect, use and share aggregated data such as statistical or demographic data for any purpose. Aggregated data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your usage data to calculate the percentage of users accessing a specific Pocket Drive feature. However, if we combine or connect aggregated data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy notice.
1.6 Customer Support
When you contact Our customer support, We may access your personal information contained within the service or your Pocket Drive Device to respond to your request (e.g., Find Your Vehicle). We also use this information to track potential issues and trends and customize Our support responses to better serve you. When Our support representative accesses your Device for troubleshooting purposes, you understand and acknowledge that while the technician is logged in to your account, she or he can access and extract information from the Device. The technician will only access information needed to troubleshoot the Device, and once the session is over, the technician will not retain any of the information on his or her screen. We do not use this information for advertising purposes. You may report any problems or security concerns with the Pocket Drive Device or the Mobile App by contacting customer support at: 1-800-316-4110. Our customer support centers are located within the United States of America and may be operated by Assurant or Our service providers.
1.7 Cookies & In-App Tracking Technologies
We also use in-app tracking technologies to understand how the Pocket Drive Solution function and are used. You can stop all collection of data generated by the use of the Pocket Drive Applications by uninstalling the Pocket Drive Applications.
Our third party partners may employ images and scripts that help them better manage content on app. We may combine information from third parties with information gathered through the use of the Service for market research, analysis and trending purposes.
You agree that information you provide may be used as described in this Notice and our Terms of Service.
2. How We use and disclose collected information
2.1 Consent to Processing Information about You
By downloading, accessing or otherwise using the Mobile App you indicated that you have read this Notice and expressly and voluntarily accept the terms of Our Terms of Service and freely consent, on your own behalf and on behalf of any family members you have authorized to use the Service, to Our processing of personal information as set forth in this Notice.. You can withdraw or modify your consent to Our collection and processing of information you provide at any time, in accordance with this Notice and the Terms of Service, by closing your account as described in Section 3.1. If you do not consent to the terms of this Notice, do not download, access or otherwise use the Mobile App.
We do not sell or rent any of your personal information.
The personal information We collect through your interaction with the Service is used to provide the Service, to manage your account for the Service, to manage Our business and to improve the Service for yourself and other users of the Service, to develop new products and Services, and for other purposes to which you consented. Examples of the above uses include:
- provide the Pocket Drive Solution to you;
- fix, maintain, enhance and modify the Pocket Drive Solution;
- communicate with you (e.g. in response to your inquiries or comments);
- comply with legal and regulatory requirements;
- promote Our products and Services;
- provide you with offers by Our business partners that might interest you in accordance with your consent; and
- for other purposes in accordance with your consent.
We may also share information related to vehicle mileage, needed repairs and maintenance and collision detection will be shared with the selling dealer in an effort to provide the consumer with an optimal vehicle ownership/leasing experience.
We may communicate with you through email, Our Mobile App and other means available through the Service, including mobile text messaging (e.g., SMS) and push notifications. Examples of these communications include: (1) welcome and registration communications, (2) service communications, and (3) promotional communications. These messages will be sent to you based on your registration information and messaging preferences. You may change your email and contact preferences at any time by signing into your account and changing your email settings.
Please be aware that you cannot opt out of receiving Service-related messages from Us.
2.4 Sharing information with affiliates
The Assurant entity that collects or holds your personal information may share your personal information with Our affiliates (meaning entities controlled by, controlling or under common control with Assurant, Inc.), as reasonably necessary for the purposes stated in this Notice.
2.5 Service providers
We may employ third party companies and individuals to facilitate the Service (e.g. customer support, analysis, Device manufacturing, data plans, audit, application or database hosting, marketing and development). These third parties have limited access to your information only to perform these tasks on Our behalf and are obligated to Us. We do not authorize such third parties to disclose or use it for other purposes. Our service providers are located within and outside of the United States of America. You consent to the transfer of information to service providers located in other jurisdictions that may not provide the same level of legal data protection as the country from which you access and use the Service.
2.6 Mobile Service providers
2.7 Compliance with legal process and other disclosures
We may disclose your personal information, as required by law, such as to comply with a subpoena, or similar legal process; when We believe in good faith that disclosure is necessary to protect Our rights or enforce Our Terms of Service, protect your safety or the safety of others, investigate fraud, or respond to a government request; to any other third party with your prior consent to do so. We may also disclose your personal information, usage information, and other information about you to parties acquiring part or all of Our assets, as well as to attorneys and consultants. Also, if any bankruptcy or reorganization proceeding is brought by or against Us, your information may be considered a company asset that may be sold or transferred to third parties.
3. Your Choices
3.1 Access, correct, delete or limit use of your personal information and Closing your account
You may (1) request access to, modification or correction of, deletion of, or limit or object to the use and disclosure, where required by applicable law, of your personal information controlled by Us or (2) close your account. You can request access to your personal information held by Us, including information that is not viewable through the Mobile App (for example, your IP access logs) through Our customer support center <
> or by sending a written request to Us at the address provided in the “Contact Us” section of this Notice.
If you close your account(s), your information, including information that has been backed up from your mobile Device, will generally be removed from the Service within 24 hours. We typically delete logs and other backup information through the deletion process within 90 days of account closure, except as noted in Section 3.2 <
>. You may close your account by visiting and clicking on the “Close Account” link. The information available on this link will guide you through the account closure process.
If you think that any personal information We have collected about you is inaccurate, or if you would like to limit the use and disclosure of such information, you may send a reasonable written request for review to Us at the address provided below in the “Contact Us” section of this Notice. We will investigate your request and make appropriate changes or deletions if warranted. We will respond to any reasonable requests for access to personal information in 45 days or as permitted under applicable law.
In certain situations and subject to applicable laws, we may not be able to provide access to all of the personal information that We hold about you. For example, We may not provide access to information if doing so:
- would likely reveal personal information about a third party;
- could reasonably be expected to threaten the life or security of another individual;
- would reveal Our or third party confidential information;
- includes information that is protected by solicitor or attorney client privilege; or
- includes information that was processed in relation to the investigation of a breach of an agreement or a contravention of a law.
In order to safeguard your personal information from unauthorized access, We may ask that you provide sufficient information to identify yourself prior to providing access to your personal information. We will respond to your request in accordance with applicabe law.
Depending on the circumstances and applicable laws, We may refuse to process certain access requests.
3.2 Data retention
We retain personal information you provide while your account is active or as needed to provide the Service. We may retain your personal information even after you have closed your account if retention is reasonably necessary to comply with Our legal obligations, meet regulatory requirements, resolve disputes, prevent fraud and abuse, or enforce this Privacy Notice and Our Terms of Service. We may retain personal information, for a limited period of time, if requested by law enforcement. Our customer support may retain information for as long as is necessary to provide support-related reporting and trend analysis only, but we generally delete or de-personalize closed account data consistent with this Notice. Once personal information is anonymized, We may retain such information as long as We need it for business purposes. Additionally, We maintain logs and backups for security, debugging, and site stability purposes for up to 90 days after your account has been closed
4. Important Information
4.1 Minimum age
We do not knowingly collect personal information from anyone under the age of 13 or such equivalent minimum age in the relevant jurisdiction. You must be at least the legal driving age, or the equivalent minimum age in the relevant jurisdiction, to use the Service.
4.2 Changes to this Privacy Notice
We may update this Notice from time to time. If We make any material changes to Our Notice, We will notify you by email or by means of a notice through Service, or by other means prior to the change becoming effective, so that you may review the changes before you continue to use the Service. If you object to any changes contained in the Notice, you may close your account. Continuing to use Our Services after We publish, or communicate with you about, any changes to this Notice means that you are consenting to the changes. As We may make changes to this Notice, We suggest that you review this Notice each time you access and use the Service. Please review changes carefully. If you agree to the changes, simply continue to use the Service. If you object to any of the changes to Our terms and you no longer wish to use Our Service, you may close your account(s) as described in Section 3.1. Unless stated otherwise, Our current Notice applies to all information that We have about you and your account. Using Our Services after a notice of changes has been communicated to you or published on Our Service shall constitute consent to the changed terms or practices. If any changes are made to this Privacy Notice, We will revise the Effective Date that is indicated on the Privacy Notice
4.3 Security Procedures
We have measures in place to restrict access to information to those employees and individuals whom We know have a valid business purpose to have access to such data. We maintain physical, electronic and procedural safeguards. We follow generally accepted standards designed to protect the personal information submitted to Us, both during transmission and once we receive it. We require those who provide Services for Us and to whom We provide information collected through the Service to keep such information safeguarded and confidential. However, no method of transmission over the Internet or method of electronic storage is totally secure. Therefore, We cannot guarantee its absolute security.
4.4 Contact Us
We welcome your questions or comments regarding this Privacy Notice. Please write to the Privacy Officer, Assurant Privacy Office, at email@example.com .
Effective date: November 30, 2018