Privacy Policy

1. SCOPE OF THIS PRIVACY POLICY

This Privacy Policy applies to personal information processed by us, including on our websites, mobile applications, and other online or offline offerings. To make this Privacy Policy easier to read, our websites, mobile applications, and other offerings are collectively called the "Services."

2. PERSONAL INFORMATION WE COLLECT

The categories of personal information we collect depend on how you interact with us, our Services, and the requirements of applicable law. We collect information that you provide to us, information we obtain automatically when you use our Services, and information from other sources such as third-party services and organizations, as described below.

A. Personal Information You Provide to Us Directly

We may collect personal information that you provide to us.

• • Account Creation. We may collect personal information when you create an account, such as email address.
• • Mutuality Program Enrollment: We may collect personal information when you join the Mutuality Program, such as name, phone number, tax ID, driver's license number, and date of birth. Please note that this information is stored encrypted on your local mobile device and our server and we can access it only upon your authorization.
• • Financial and Online Transactional Information. We may collect financial information such as your bank account numbers, bank statements, transaction history, trading data, and credit/debit card numbers. We may collect personal information and details associated with your transactions including, but not limited to, information about the transactions you make using the Services.
• • Your Transactions/Know Your Customer ("KYC") information. If you enroll in the Mutuality Program or conduct other digital financial transactions using our Services, we will record the details of each transaction. In addition, we or our service providers may also collect information to verify your identity and comply with regulatory obligations.
• • Third-Party Administrator ("TPA") Required Information. We facilitate the collection of information needed by TPAs to process any automotive repair claim.
• • Your Communications with Us. We may collect personal information, such as email address, phone number, or mailing address when you request information about our Services, register for our newsletter, request customer or technical support, or otherwise communicate with us.
• • Surveys. We may contact you to participate in surveys. If you decide to participate, we may collect personal information from you in connection with the survey.
• • Interactive Features. We and others who use our Services may collect personal information that you submit or make available through our interactive features. Any information you provide using the public sharing features of the Services will be considered "public."
• • Sweepstakes or Contests. We may collect personal information you provide for any sweepstakes or contests that we offer.
• • Conferences, Trade Shows, and Other Events. We may collect personal information from individuals when we attend or host conferences, trade shows, and other events.
• • Business Development and Strategic Partnerships. We may collect personal information from individuals and third parties to assess and pursue potential business opportunities.

B. Personal Information Collected Automatically

We may collect personal information automatically when you use our Services.

• • Automatic Collection of Personal Information. We may collect certain information automatically when you use our Services, such as your Internet protocol (IP) address, user settings, MAC address, cookie identifiers, mobile carrier, mobile advertising and other unique identifiers, browser or device information, location information, and Internet service provider.
• • Cookie Policy (and Other Technologies). We, as well as third parties that provide content, advertising, or other functionality on our Services, may use cookies, pixel tags, and other technologies ("Technologies") to automatically collect information through your use of our Services.
• • Cookies. Cookies are small text files placed in device browsers that store preferences and facilitate and enhance your experience.
• • Pixel Tags/Web Beacons. A pixel tag (also known as a web beacon) is a piece of code embedded in our Services that collects information about engagement on our Services.

Our uses of these Technologies fall into the following general categories:

• Operationally Necessary
• Performance-Related
• Functionality-Related
• Advertising- or Targeting-Related
• Analytics (including Google Analytics)

3. HOW WE USE YOUR PERSONAL INFORMATION

We use your personal information for a variety of business purposes, including to provide our Services, for administrative purposes, and to market our products and Services, as described below.

A. Provide Our Services

We use your information to fulfill our contract with you and provide you with our Services, such as:

• Managing your information and accounts
• Verify your identity in accordance with applicable know-your-customer, money-laundering and other financial sector legislation
• Facilitating transactions you enter into
• Providing access to certain areas, functionalities, and features of our Services
• Answering requests for customer or technical support
• Communicating with you about your account, activities on our Services, and policy changes
• Processing your financial information and other payment methods
• Allowing you to register for events

B. Administrative Purposes

We use your information for various administrative purposes, such as:

• Pursuing our legitimate interests such as direct marketing, research and development, network and information security, and fraud prevention
• Detecting security incidents and protecting against malicious, deceptive, fraudulent, or illegal activity
• Measuring interest and engagement in our Services
• Improving, upgrading, or enhancing our Services
• Developing new products and services
• Ensuring internal quality control and safety
• Authenticating and verifying individual identities
• Debugging to identify and repair errors
• Auditing relating to interactions, transactions, and compliance activities
• Enforcing our agreements and policies
• Carrying out activities required to comply with our legal obligations

C. Marketing and Advertising

We may use personal information to tailor and provide you with content and advertisements. We may provide you with these materials as permitted by applicable law. Some of the ways we market to you include word-of-mouth networking, direct email campaigns, and custom audience advertising.

D. Other Purposes

• • With Your Consent. We may use personal information for other purposes that are disclosed to you at the time you provide personal information or with your consent.
• • Automated Decision Making. We are developing a mobile application that tracks driving behavior to improve pricing and promote the incentivization mechanism for the Mutuality Program. This information is kept entirely local to your mobile application.
• • De-identified and Aggregated Information. We may use personal information to create de-identified and/or aggregated information.

4. HOW WE DISCLOSE YOUR PERSONAL INFORMATION

We disclose your personal information to third parties for a variety of business purposes, including to provide our Services, to protect us or others, or in the event of a major business transaction such as a merger, sale, or asset transfer.

A. Disclosures to Provide our Services

• Service Providers. We may share your personal information with our third-party service providers and vendors that assist us with the provision of our Services, including IT support, hosting, payment processing, customer service, TPAs, actuarial researchers, auto repair body shops, and related services.
• Business Partners. We may share your personal information with business partners to provide you with a product or service you have requested.
• Affiliates. We may share your personal information with our company affiliates.
• Other Users or Third Parties. Our Services may allow you to share personal information or interact with other users and third parties.
• APIs/SDKs. We may use third-party application program interfaces ("APIs") and software development kits ("SDKs") as part of the functionality of our Services.

B. Disclosures to Protect Us or Others

We may access, preserve, and disclose any information we store associated with you to external parties if we, in good faith, believe doing so is required or appropriate to comply with law enforcement, protect rights and safety, enforce policies, or assist with investigations.

C. Disclosure in Business Transactions

If we are involved in a merger, acquisition, financing due diligence, reorganization, bankruptcy, receivership, purchase or sale of assets, or transition of service to another provider, your information may be sold or transferred as part of such a transaction.

5. YOUR PRIVACY CHOICES AND RIGHTS

Your Privacy Choices

• • Email Communications. You can use the unsubscribe link found at the bottom of emails to opt out of receiving future emails.
• • Text Messages. You may opt out of receiving future text messages by following the instructions in the text message.
• • Mobile Devices. You may opt-out of push notifications by changing the settings on your mobile device.
• • Phone Calls. You may opt out of receiving future phone calls by following the instructions on the call.
• • "Do Not Track." Please note that we do not respond to or honor DNT signals transmitted by web browsers.
• • Cookies and Personalized Advertising. You may stop or restrict the placement of Technologies on your device by adjusting your browser preferences.

Your Privacy Rights

By applicable law, you may have the right to:

• Confirm Whether We Are Processing Your Personal Information
• Access to and Portability of Your Personal Information
• Request Correction of your personal information
• Request Deletion of your personal information
• Request to Opt-Out of Certain Processing Activities
• Request Restriction of or Object to our processing
• Withdraw your Consent to our processing
• Appeal our Decision to decline to process your request

6. INTERNATIONAL DATA TRANSFERS

All information processed by us will be stored and controlled by servers in the United States. If the information processed is transferred, processed, and stored by a partner anywhere in the world that has laws that are different from the laws where you live, we endeavor to safeguard your information consistent with the requirements of applicable laws.

7. RETENTION OF PERSONAL INFORMATION

We store the personal information we collect as described in this Privacy Policy for as long as you use our Services, or as necessary to fulfill the purpose(s) for which it was collected, provide our Services, resolve disputes, establish legal defenses, conduct audits, pursue legitimate business purposes, enforce our agreements, and comply with applicable laws.

In most cases, we immediately delete any personal information collected on our servers once its purpose to collect has been fulfilled. You may have personal information that remains stored on your local device that is encrypted when using the app. You are responsible for keeping it secure.

8. SUPPLEMENTAL NOTICE FOR NEVADA RESIDENTS

If you are a resident of Nevada, you have the right to opt out of the sale of certain personal information to third parties who intend to license or sell that personal information. Please note that we do not currently sell your personal information as sales are defined in Nevada Revised Statutes Chapter 603A.

9. CHILDREN'S INFORMATION

The Services are not directed to children under 18 (or other age as required by local law), and we do not knowingly collect personal information from children.

10. OTHER PROVISIONS

Third-Party Websites/Applications/Services

The Services may contain links to other websites/applications and other websites/applications may reference or link to our Services. These third-party services are not controlled by us. We encourage our users to read the privacy policies of each website and application with which they interact. We do not endorse, screen, or approve, and are not responsible for the third party's actions or omissions.

11. CONTACT US

If you have any questions about this Privacy Policy or our privacy practices, please contact us at: