Last updated December 5th 2019
3. What Information We Collect
- Quote Information. We collect certain information about you and your pet when you request a quote for pet insurance through our Services, including but not limited to: the name and breed and birth date of your pet, your zip code and location information, your email address, and phone number.
- Policy Application Information. After obtaining your quote, if you choose to apply for an insurance policy for your pet, we will collect and retain further information that can be used to identify you, such as your full name, email address, postal address, phone number, and credit card (or other payment method) information (“Personal Data”). We may also collect your gender, date of birth, age, zip code, and other information that is not considered Personal Data because it cannot be used by itself to identify you. We will also collect further information about your pet, including but not limited to their past and present medical history, and veterinary services providers.
- Information You Voluntarily Provide. You may provide certain information to us when you use the Services, including when you contact us regarding your policy or other inquiries, or provide feedback about the Services. This information may include your name, email address, phone number, address, social security number, bank and bank account information including routing and account numbers, credit card information, billing address, order payment information, and other information that may relate to you or identify you. We will also collect any information you provide to us when you send us emails with queries, feedback, or for any other reason.
- Financial Information. When you apply to obtain an insurance policy for your pet, we will collect financial information such as payment method or credit card information so we can charge you for the policy you requested. We will also collect banking information – such as routing number and account numbers – for the purposes of making direct deposits to you when claims are submitted under the policy.
- Location Information. When you use our Services, we may collect and store information about your location by converting your IP address into a rough geo-location or by accessing your mobile device’s GPS coordinates or coarse location if you enable location services on your device.
- Information Sent by Your Device. We collect certain information that your mobile device, laptop, or other hardware device sends when you use our Services, including but not limited to network and connectivity information, device identifiers, advertising identifiers, language preferences, user settings, software and operating system names and versions, hardware models, and IP address, as well as other information about your use of our Services.
- Third Parties. We also obtain information from third parties, such as affiliates, consumer research agencies, joint marketing partners, and lead providers.
- Information Collected Using Cookies and other Web Technologies. Like many website owners and operators, we (and our partners who assist us with marketing, analytics, user research, advertising, and user support) may utilize automated data collection tools such as Cookies and Web Beacons to collect certain information from users of our Services. These tools are used for a variety of purposes, including but not limited to user authentication, account security, delivery and measuring of advertising, analyzing site traffic and trends, and fraud prevention.
- “Web Beacons” (also known as web bugs, pixel tags, or clear GIFs) are tiny graphics with a unique identifier that may be included on our Services for several purposes, including to deliver or communicate with Cookies, to track and measure the performance of our Services, to monitor how many visitors view our Services, and to monitor the effectiveness of our advertising. Unlike Cookies, which are stored on the device, Web Beacons are typically embedded invisibly on web pages (or in an email).
- “Log Data” means certain information about how a User uses our Services. Log Data may include information such as a User’s Internet Protocol (IP) address, browser type, operating system, the web page that a User was visiting before accessing our Services, the pages or features of our Services to which a User browsed and the time spent on those pages or features, search terms, the links on our Services that a User clicked on and other statistics. We use Log Data to administer the Services and we analyze (and may engage third parties to analyze) Log Data to improve, customize and enhance our Services by expanding their features and functionality and tailoring them to our Users’ needs and preferences. We may use a person’s IP address and other information to generate information about how our Services are used and to detect fraud.
4. How We Use Your Information.
Our primary goals in collecting information are to provide and improve our Services, to administer your use of the Services (including your Account, if you are an Account holder), and to enable you to enjoy and easily navigate our Services. We will use your Personal Data for the following purposes:
- Provide our Services, including quotes and insurance policies, communicate with you, and provide customer support in relation to the Services.
- Resolve disputes, respond to queries, collect fees (if any) and troubleshoot problems.
- Collect payments on the policy you obtain.
- Manage our everyday business needs, such as auditing, administration of the Services, forum management, fulfillment, analytics, fraud prevention, and enforcement of our Terms of Service, or to comply with the law.
- Customize your experience and otherwise measure and improve our content and Services.
- Send you relevant emails and communications (including keeping you informed about our products, offerings and any promotional offers) that might be of interest to you (If we use your personal information to market to you, you will be able to opt-out of such uses).
- Enforce our agreements, terms, conditions, and policies, and send you notices and alerts.
- Better understand our users’ demographics, interests and behaviors.
We may use your information for any other purpose disclosed to you at the time we collect or receive your information, or otherwise with your consent. Any communication or material you transmit to us via e-mail or otherwise, including any data, questions, comments, chats, phone calls, suggestions or the like, but not including your personal information and any requests, comments or concerns regarding your personal information, will be treated as non-confidential and non-proprietary.
5. Information That We Share With Third Parties.
We will not share any PII that we have collected from or regarding you except as described below:
- Services Providers and Business Partners. We may engage third-party services providers to work with us to administer and provide the Services, including but not limited to our vendors (e.g. fraud detection services, web hosting provides, fulfillment service providers), insurance partners, claims representative, and underwriters. These third-party services providers will have access to your Personal Data only for the purpose of performing services on our behalf. For example, we may share your Personal Data and any necessary payment information, such as credit card number, expiration date and billing address, and bank account information with our payment processing services providers in order to complete transactions that are initiated through the Services. We will also share information about your pet with these third parties, so that they may help us provide the Services to you.
- Your Veterinary Service Providers. We may share information about you, your pet, or our coverage of claims with your veterinary service providers.
- At Your Request. We may share information about you with third parties in the event that you request we do so, for example, with companies offering promotions or offers through our Site our Services, if you are interested in that offer and request that we share your information.
- The General Public. We may share with the general public information that you submit in public forums, for example blogs, social media, comment sections on the website.
- Other Third Parties. We may share anonymized or aggregated data we collect from the use of the Services, such as de-identified demographic information, de-identified location information, information about the computer or device from which you access the Services, market trends, and other analysis that we create based on the information we receive from you and other users.
- Our Subsidiaries and Affiliates. We share information with our corporate subsidiaries and affiliates to help us provide our Services.
- With Your Consent. There may be other circumstances where we will notify you of information that we seek to share with a third party not listed here, and will do so with your consent
- Information Shared with Web Analytics Services Providers. We may use some or all of the following analytics service providers:
- Google. We use Google Analytics, a service provided by Google, Inc. (“Google”), to gather information about how users engage with our Site and Services. For more information about Google Analytics, please visit www.google.com/policies/privacy/partners/. You can opt out of Google’s collection and processing of data generated by your use of the Services by going to http://tools.google.com/dlpage/gaoptout.
- Mixpanel. We use a service provided by Mixpanel, Inc. (“Mixpanel”) to provide us with analytics data regarding users’ interactions with our Site and Services. You may opt-out of Mixpanel’s automatic retention of data that is collected while using the Services by visiting https://mixpanel.com/optout/. To track opt-outs, Mixpanel uses a persistent opt-out cookie placed on your device. Please note that if you get a new computer, install a new browser, erase or otherwise alter the browser’s cookie file (including upgrading certain browsers), you may delete the Mixpanel opt-out cookie.
- Segment. We use a service provided by Segment, Inc. (“Segment”) to provide us with analytics data regarding users’ interactions with our Site and Services. You may opt-out of Segment’s automatic retention of data that is collected while using the Services by visiting https://segment.com/docs/legal/privacy/#tracking-and-targeted-advertising. To track opt-outs, Segment uses a persistent opt-out cookie placed on your device. Please note that if you get a new computer, install a new browser, erase or otherwise alter the browser’s cookie file (including upgrading certain browsers), you may delete the Segment opt-out cookie.
- Information Disclosed in Connection with Business Transactions.
Information that we collect from our Users, including Personal Data, is considered to be a business asset. Thus, if we are acquired by a third party as a result of a transaction such as a merger, acquisition, or asset sale, or if our assets are acquired by a third party in the event we go out of business or enter bankruptcy, some or all of our assets, including your Personal Data, may be disclosed or transferred to a third party acquirer in connection with the transaction..
- Information Disclosed for Our Protection and the Protection of Others.
We cooperate with government and law enforcement officials or private parties to enforce and comply with the law. We may disclose any information about you to government or law enforcement officials or private parties as we, in our sole discretion, believe necessary or appropriate: (i) to respond to claims, legal process (including subpoenas); (ii) to protect our property, rights and safety and the property, rights and safety of a third party or the public in general; and (iii) to stop any activity that we consider illegal, unethical or legally actionable activity.
6. Your Choices
We offer you choices regarding the collection, use and sharing of your Personal Data and we’ll respect the choices you make. Please note that if you decide not to provide us with the Personal Data that we request, you may not be able to access all of the features of the Services.
- Opt-out of Ad Tracking. You can opt out of the collection and use of your information for ad targeting by going to http://www.aboutads.info/choices or http://www.youronlinechoices.eu/ to limit collection through the Site or by configuring the settings on your mobile device to limit ad tracking through the App.
- Modifying Your Information. You can access and modify the Personal Data associated with your Account by sending an email to firstname.lastname@example.org If you want us to delete your Personal Data and your Account, please contact us at email@example.com with your request. We’ll take steps to delete your information as soon as we can, but some information may remain in archived/backup copies for our records or as otherwise required by law.
- Credit Worthiness. We do not currently obtain or share consumer credit worthiness information. However, in the event that the company would begin sharing such information, users will be allowed to opt out of such sharing.
- Non-Affiliate Marketing. We do not currently share user information with third parties seeking to market their own products or services to our users. However, in the event that the company would begin sharing such information for such purpose, users will be allowed to opt out of such sharing.
7. Responding to Do Not Track Signals.
Our Site does not have the capability to respond to “Do Not Track” signals received from various web browsers.
8. The Security of Your Information.
We take reasonable administrative, physical, and electronic measures designed to protect the information that we collect from or about you (including your Personal Data) from unauthorized access, use or disclosure. When you enter sensitive information on our forms, we encrypt this data using SSL or other technologies. Please be aware, however, that no method of transmitting information over the Internet or storing information is completely secure. Accordingly, we cannot guarantee the absolute security of any information.
9. Data Retention.
We need to retain the information you provide us about yourself and your pet in order to provide our Services, and we retain such information for as long as you maintain your policy, at a minimum. We also retain certain relevant information, including transaction, location, device, and usage information, for as long as it is required to do so, in connection with regulatory, tax, insurance, legal, administrative, and other requirements. You may request deletion of your account at any time as provided above. Following such a request, we will delete the information that is not necessary to retain. In certain circumstances, we may be unable to delete your account, such as if there is an outstanding credit on your account or an unresolved claim or dispute. Upon resolution of the issue preventing deletion, we will delete your account as described above. We may also retain certain information if necessary for our legitimate business interests, such as fraud prevention and enhancing users' safety and security. For example, if we shut down a User's account because of security or fraud incidents, we may retain certain information about that Account to prevent that User from opening a new account in the future.
10. Links to Other Sites
11. International Transfer
Your Personal Data may be transferred to, and maintained on, computers located outside of your state, province, country or other governmental jurisdiction where the privacy laws may not be as protective as those in your jurisdiction. If you’re located outside the United States and choose to provide your Personal Data to us, we may transfer your Personal Data to the United States and process it there.
12. Our Policy Toward Children.
Our Services are not directed to children under 13, and we do not knowingly collect Personal Data from children under 13. If we learn that we have collected Personal Data of a child under 13, we will take steps to delete such information from our files as soon as possible.
13. Your California Privacy Rights.
If you’re a California resident, you have certain privacy rights under California law, including the California Consumer Privacy Act of 2018 (“CCPA”). Our California Privacy Notice addresses these rights.