Arity Privacy Statement

I.    About Arity

Arity is a technology company focused on making transportation smarter, safer, and more useful for everyone. Arity transforms large amounts of data into actionable insights to help better predict risk and make smarter decisions in real time, and also provides related services. The different types of services offered by Arity are as follows (collectively referred to herein as the “Services”):

• Insurance Client Services: Arity LLC may work with your insurance company to provide services including Arity’s mobile app (Routely), Arity devices installed in vehicles, and other insurance products through which Arity LLC collects driving-related information from users to assist insurance companies in delivering driving-related services (e.g., crash detection, personalized insurance pricing and discounts, and similar driving features, in accordance with device and app settings). The Insurance Client Services offered through the insurance companies’ apps leverage Arity software such as its development kit (“SDK”) to provide the driving-related features described above.
• Business Client Services: Arity 875 provides non-insurance products to entities such as mobile application providers, website publishers, advertisers, and vehicle manufacturers (“Business Clients”). For example, and similar to the services offered to insurance clients by Arity LLC, Arity 875 helps its Business Clients deliver driving-related services to app users (e.g., crash detection and similar driving features) through the use of an Arity SDK, which collects driving information from such users, in accordance with device and app settings. Arity 875 may also provide users with informative insights into their own driving behavior for their own driving education and awareness.
  • Arity 875 furnishing to a consumer reporting agency. Upon a user’s request for an insurance quote or a copy of their driving history and with their consent, Arity 875 may furnish data derived from the driving-related information collected via some of the Business Client Services to Arity Services, LLC in order for Arity Services, LLC to deliver an Arity IQ report to an insurance company for its use in providing you with insurance quotes, rating, and underwriting. Arity Services, LLC is a consumer reporting agency regulated by the Fair Credit Reporting Act (“FCRA”), and the Arity IQ report it provides to insurance companies is an FCRA-regulated consumer report. Please note that this Privacy Statement does not apply to Arity Services, LLC. For information on your rights under FCRA relating to this product provided by Arity Services, LLC, including how to submit a consumer request, visit the Arity Services, LLC Data Support Center.
• Advertising Services: In accordance with your device and app settings and in connection with Business Client Services, Arity 875 also provides services to some Business Clients, as well as to brands wishing to promote their products (“Advertisers”), for their own advertising purposes. For example, Business Clients may incorporate Arity 875 advertising services into their websites and apps, and Advertisers may provide Arity 875 with content/advertising to be served through the Advertising Services on Business Client sites/apps.
• Lead Generation Services: These are lead generation services and websites provided by Arity 875 that link to this Privacy Statement that are designed to help consumers find relevant insurance and loan services.
• Arity Websites: These are Arity-branded websites that link to this Privacy Statement that are designed to provide information about the various Services.

Arity’s role with respect to your data. Please note that depending on the specific Services you use, there are circumstances where Arity acts as a data controller, meaning Arity determines the purposes and means of data processing, and other circumstances where Arity acts a data processor, meaning Arity only processes information on behalf, and at the direction, of another party. For example, Arity is generally a data controller for Arity Websites, Lead Generation Services, and Advertising services. In certain circumstances, Arity acts as a data processor in connection with the Insurance Client Services and Business Client Services. However, Arity may act as a data controller in connection with the Insurance Client Services and Business Client Services depending on factors such as the type of processing at issue and your permission for Arity to collect and process your information for its own purposes as a data controller.

Please also note that as an affiliate of financial institutions offering insurance-related services subject to various financial privacy laws, in some instances, Arity is exempt from the requirements of U.S. state privacy laws, and this Privacy Statement does not apply in those circumstances.

II.    Information Processing Through the Services

We collect a variety of information from and about you as you use the Services or otherwise interact with us, and the types of information we collect, how we use it, and how we disclose it may differ depending on the Services you use and how you interact with us. This section of the Privacy Statement explains Arity’s data collection practices.

a.    Sources of Information

We collect information about you from several sources, as follows:

• From you via provision of our direct or indirect Services to you, any related customer service interactions we have with you, or submission of information to us such as through an online form or customer service interaction. Such Services may include, but are not limited to, Arity Websites, Business Client apps, Insurance Client apps, or Arity devices installed in vehicles. We may also collect information directly from you if you choose to participate in a research study or survey that we offer.
• From our Business Clients and insurance clients in connection with services you’ve requested from them. For example, if you are a user of a Business Client app that utilizes the Business Client Services, we will collect information about you from the Business Client in connection with providing these services, in addition to the information we collect on behalf of the Business Clients as discussed below.
• From Business Clients and Advertisers in connection with the Advertising Services we offer. For example, an Advertiser may provide us with an audience of individuals or types of individuals it would like to display online advertising to, and we will match that with information obtained on Business Client websites and apps to deliver such advertising to the intended audience, as well as to measure the effectiveness of such ads.
• From other parties such as our corporate affiliates, service providers, data brokers, and marketing companies to obtain additional demographic and other information about you to supplement the information we obtain as discussed above.

b.    Information We Collect

We collect the following categories of information from and about you in connection with the Services:

Insurance Client Services and Business Client Services. When you use the Insurance Client Services and Business Client Services, we may collect the following information:

• Personal identifiers: Includes name, postal address, phone number, date of birth, vehicle identification number (VIN), unique device or personal identifier, online identifier – such as Mobile Ad ID, internet protocol (IP) address, and email address.
• Internet or other electronic network activity information: Includes app usage history, search history, information regarding your interaction with the apps and advertisements displayed in the apps, links you use, browser type, and internet service provider (ISP). It also includes mobile app and device usage information (e.g., frequency of use, application marketplace from where you downloaded the mobile app, operating system, device model and time zone).
• Location information: This includes general location information derived from your IP address. More precise geolocation information (including geolocation coordinates, e.g., latitude, longitude, and altitude), your direction of travel, Wi-Fi access points, and the time the information was recorded) is collected only when location services are enabled on your device. Other permissions through the operating system of your device may be required for the apps to function properly. Note that precise, GPS-location information is considered “sensitive” under certain laws, and we will only collect and process such information in accordance with applicable legal requirements.
• Driving and device information: Includes phone handling, miles, speed, and if a mobile app detects a collision, information about the collision. We collect this information from your device through sensors, as well as through actions taken on your device (e.g., locking and unlocking, hand movements, incoming calls, etc.).
• Inferences: Inferences drawn from your app usage to create a profile reflecting preferences, characteristics, predispositions, and driving habits and behavior. For example, Arity may derive miles traveled, acceleration, deceleration, braking behavior, cornering, speed, and trip routing from information coming from your mobile device or vehicle, including location data.

Our Websites. When you use our Websites, we collect the following information:

• Personal identifiers: This includes contact information (e.g., name, email address, address, phone number), and Internet Protocol (IP) address. If you are a Business Client visitor to our Websites, we will also collect business contact information (e.g., name of the company where you work, title, role, and business phone number, address, and email address) as well as the log-in information you use to sign into our Business Client portals, if relevant.
• Internet or other electronic network activity information: This includes browsing history, search history, information regarding your interactions with our Websites, links you use, referral pages or web pages you visit while visiting our Websites, browser type, internet service provider (ISP), and other information obtained through Website cookies and similar tracking technologies, as discussed in the “Cookies and Online Advertising” section below.
• Other information. In browsing our Websites, you may also choose to provide us with additional information, such as if you complete a survey or make a request for information from us.

Our Lead Generation Services. When you use our Lead Generation Services to obtain information about third-party insurance and loan services, we collect the following information:

• Personal identifiers: This includes name, postal address, phone number, date of birth, unique device or personal identifier, online identifier – such as internet protocol (IP) address, and email address.
• Personal characteristics: This includes information we collect to help determine insurance and loan offers you may be eligible for from our partners, including your age, marital status, gender, education and occupation, employment status, household income, household size, number of children, and other demographic information.
• Commercial and Transactional Information: This also includes information to help determine eligibility for insurance and loans, and includes information about the make and model of cars you own, insurance policy information, insurance claims data, motor vehicle records and consumer report data, including credit score, home ownership information, and military or veteran status.

Surveys and Research. From time to time, Arity may offer individuals the option to participate in voluntary surveys or research studies. If you choose to participate in a voluntary research study or survey, we may collect some demographic information for research purposes.

Advertising Services. For more information about the categories of information we collect in connection with our Advertising Services, see discussion in the section directly below.

III.    Cookies and Online Advertising

a.    Analytics and Advertising on Arity Websites

When you visit our Websites (including, but not limited to, Websites for our Lead Generation Services), we and our third-party marketing and analytics partners may automatically collect information about your use of and access to the Websites using a variety of tracking technologies, including cookies, web beacons (also called “clear GIFs” or pixel tags), embedded scripts, location-identifying technologies, analytics, remarketing and similar technology (collectively, “tracking technologies”).

We and our third-party marketing and analytics providers (such as Google Analytics, Adobe Analytics, Meta, Microsoft and DemandBase) use these tracking technologies to help us provide users with an enhanced and more customized web experience. Additionally, we and our marketing and analytics providers use tracking technologies to monitor visits to our Websites.

The information collected in this manner includes:

• The websites which linked you to, or away from, our Websites, how frequently you visit the Websites, your interaction with emails we send, pages you visit on our Websites, and the ads you view, or your general location when you access our Websites, recordings of mouse clicks, mouse movements, keystrokes, and other communications you make on our Websites;
• Information about the computer, tablet, smartphone or other device you use to access our Websites, such as your IP address, browser type, internet service provider, platform type, device type/model/manufacturer, operating system, date and time stamp, unique device identifiers or advertiser ID, and other similar information, and
• Analytics information collected by us or via third-party analytics tools, to help us measure traffic and usage trends for the Websites and apps and to understand more about the demographics and behaviors of our users.

The information collected through tracking technologies allows us to provide you with an improved, enhanced and personalized customer experience, to monitor and improve our Website and for other business purposes such as to:

• Provide custom, personalized content and information, including targeted content across other mobile applications and websites, communications and advertising,
• Identify and contact you across multiple devices,
• Provide and monitor the effectiveness of our Websites,
• Perform analytics and detect usage patterns on our Websites,
• Diagnose or fix technology problems,
• Detect or prevent fraud or other harmful activities, and
• Otherwise to plan for and enhance our Websites.

Your choices regarding tracking technologies. For our Websites containing cookies or pixels that enable online targeted advertising, you may update your cookie preferences by:

• Visiting the following link: Your Privacy Choices (note that this link is also available in the footer of our Websites).
• Enabling a universal tool on your browser that automatically communicates your opt-out preferences through browser settings called the Global Privacy Control (“GPC”). Note that GPC is only available on certain browsers. Please see your browser instructions for more information.
• Managing cookie settings through your browser or device to disable or block cookies, remove existing cookies, automatically accept cookies or to notify you when you receive a cookie. These settings are browser or device specific, and options available may vary by browser. However, if you disable, modify, or reject cookies, some parts or functionalities of our Websites may be inaccessible or not function properly. For example, disabling cookies may require you to repeatedly enter information to take advantage of services or promotions. Also, if you clear your cookies on your browser or make selections using a different device or browser, you may need to redo your cookie settings.

b. Advertising Services

As explained above, we provide certain services to Business Clients and Advertisers to assist them in their advertising activities. If you use a Business Client website or app that integrates the Arity Advertising services, depending on your browser and device settings, you may see advertising targeted to your interests. We may provide these advertisements to you based on your browsing behavior across different apps and online websites, and we use cookies and other tracking technologies to facilitate this advertising. The Advertising Services generally involve the collection and processing of digital identifiers such as cookie IDs, IP addresses, mobile advertising IDs on your device, inferences derived from location information (which is collected and used in accordance with applicable law), Internet browsing history, and in some instances, your hashed email address.

Arity does not collect or use information from the Insurance Client Services (e.g., the Routely® app and insurance provider apps) or from individuals in certain jurisdictions to serve targeted ads; however, Arity may collect information such as device identifiers, demographic information, or inferences from other non-insurance related Business Clients or other data providers for this purpose.

Depending on your device settings and applicable law, Arity may also derive insights from geolocation information and driving data to provide you with more relevant ads.

Because most of the Advertising services occur on our Business Clients’ websites and apps and not ours, you generally have to exercise your opt out rights on the Business Clients’ websites and apps, and they will pass your opt out preference to us. However, you can also manage our targeted advertising activities through the Advertising Services by:

• Installing GPC or managing cookie preferences through your device or browser as noted above;
• Install the Digital Advertising Alliance’s (DAA) AppChoices tool on your mobile device. To do this, download the AppChoices app on your mobile device. Then, select “Interest-Based Advertising Choice” followed by “Device ID-Based Choices.” Lastly, select the “Send” option next to Arity’s logo under the “Status” column to complete your opt out submission. Visit the following link for more information about DAA’s AppChoices tool.
• Opting out of our use of your data (including insights derived from geolocation and driving data) for purposes of online advertising by completing our opt-out webform.

IV.    How We Use Information

Arity’s use of your information differs based on the Services, features, and products you use, and your country of origin, as discussed more below. This includes use of information to:

• Create, Deliver, and Facilitate Provision of the Services to You. We use your information to provide you with the various Services discussed above, as well as to provide customer service related thereto.
• Improve, develop and analyze our Services. We use information to analyze, improve, develop or deliver our Services, including to understand how you use our Services to enhance and personalize your experience. To do this, we engage in actuarial studies, model development, and statistical analysis to create and refine our risk, driving behavior, and analytics that allows us to deliver our driving-related services. We also use information to improve or repair our Services, features and products, including addressing bugs or other issues.
• Communicate with you. We may use your information to communicate with you about the Services you use, respond to customer service requests, or to investigate, respond to, and resolve issues or complaints or other inquiries. In accordance with applicable law, communication may be via text, email or other available methods such as push notifications.
• Provide marketing communications. We may use your information to send you promotional communications about our products, services, features, and options we believe may be of interest to you. We may send communications via email or other methods, such as text messages.
• Display Online Advertising. In accordance with your device and app settings and applicable law, we may provide you with offers for products and services that we believe will interest you, as explained more fully in the “Cookies and Online Advertising” section above.
• Comply with legal requirements and protect the safety and security of our business, Services, and Websites. We may use your information to comply with laws, regulations or other legal obligations, to assist in an investigation, to protect and defend our rights and property or the rights of third parties or enforce terms and conditions. We may also use your information to prevent suspected fraud, threats to our network or other illegal activities, prevent misuse or for any other reason permitted by law. We may use your information to protect our company, our affiliates, our customers, our network and our Services.
• Create De-identified and Aggregated Information. We may de-identify information we collect so the information cannot reasonably identify you or your device, or we may collect information that is already in de-identified form. For example, we may create aggregated driving trends and insights and provide those to our Business Clients. Our use and disclosure of de-identified and/or aggregated information is not subject to any restrictions under this Privacy Statement, and we may use and disclose it to others for any purpose, without limitation.

V.    How We Disclose Information

In accordance with applicable law, we disclose information we collect from and about you with the following:

• Affiliates. We disclose information with our affiliates under common ownership and/or control in connection with providing our Services to you.
• Service providers to Arity: We may disclose information to our service providers who perform services on our behalf for a business purpose including service providers that provide:
  • marketing and advertising, email or other communication services;
  • services that support our Website activities, including providing tracking technologies, web hosting and analytics;
  • tax and accounting, legal services, delivery, and data enhancement services;
  • technology services and enhance security, privacy and fraud protections;
  • analytics services or conduct research or actuarial studies; and
  • support to our operations.
• De-identified/Aggregate Information. We may create de-identified and/or aggregated information that can no longer identify you or your device and disclose such information with Business Clients and others for their own purposes. Where we disclose de-identified/aggregated information, we will contractually require the receiving party not to take steps to attempt to re-identify it.
• Website Online Advertising Partners: Arity permits third party advertising partners to collect information from you from our Websites to facilitate our online advertising activities. See the “Cookies and Online Advertising” section above for more details about these activities.
• Business Clients and Insurance Provider Clients. We disclose your information to Business Clients and/or insurance providers in connection with the Insurance Client Services and Business Client Services. For example, when using an insurance provider’s mobile app or a Business Client’s mobile app that has an Arity SDK embedded, information is disclosed to the insurance provider (via the insurance app) or the Business Client (via the non-insurance app) for purposes of servicing the product or service you have requested from that business client. If you are using our Routely® mobile app or other mobile app with Arity software (e.g., an Arity SDK) as an employee-tester for your employer, then Arity, LLC may share your driving data with your employer. We may also disclose the contact information you provided via our websites with our Business Clients so that they may contact you to offer their products and services. We also disclose information to our Business Clients, including Advertisers, in connection with the Arity Advertising Services discussed above.
• Third parties in connection with a business transaction: Information may be disclosed to third parties in connection with (or during due diligence in connection with) a corporate transaction, such as a merger, sale of any or all of our company assets or shares, reorganization, financing, change of control or acquisition of all or a portion of our business by an affiliate or third party, or in the event of a bankruptcy or related or similar proceedings.
• Law enforcement, regulators and other parties for legal reasons: Information may be disclosed to third parties, as required by law or subpoena, or if we in good faith reasonably believe such action is necessary to:
  • comply with the law and the reasonable requests of regulators, law enforcement or other public authorities;
  • protect our or others safety, rights or property; and
  • investigate fraud or to protect the security or integrity of our websites and mobile apps or any product or services.

VI.    U.S. Privacy Rights and Choices

If you are a U.S. resident, you have rights under certain U.S. state privacy laws with respect to information that identifies, relates to, or could reasonably be linked to you (“personal information”). These rights differ by state and by the type of Services you use. For example, rights under certain state laws do not apply to personal information and/or the processing of personal information that is regulated by insurance laws and the Fair Credit Reporting Act. However, regardless of your state of residence, Arity provides the following privacy rights to all U.S. residents:

• Right to know and access your personal information: You have the right to request the specific pieces of personal information we have collected about you and the right to know:
  • the categories of personal information collected;
  • the categories of sources from which personal information was collected;
  • the business purpose for collecting the personal information; and
  • the categories of third parties with whom we disclose personal information.
• Right to deletion of personal information: You have the right to request we delete the personal information collected about you, subject to certain exceptions under applicable law.
• Right to correct personal information: You have the right to request we correct any inaccurate information we have about you.
• Right to opt out of automated processing: You have the right to opt out of the processing your personal information for purposes of profiling in furtherance of decisions that produce legal or similarly significant effects, if applicable.

In addition, Oregon and Minnesota residents can request a list of the specific third parties, other than natural persons, to which we have disclosed personal information.

We won’t discriminate against you if you exercise any of the privacy rights described in this Privacy Statement.

Please note that certain personal information may be exempt from such requests under applicable law. For example, we need certain information in order to provide the Services to you or comply with applicable law. We may take reasonable steps to verify your identity before responding to a request, which may include, at a minimum, depending on the sensitivity of the information you are requesting and the type of request you are making, verifying your name and email address. If we are unable to verify your identity, we may be unable to respond to your requests. You may be able to designate an authorized agent to make requests on your behalf. In order for an authorized agent to be verified, you must provide the authorized agent with signed, written permission to make such requests or a power of attorney.

Submitting a request: To submit a request, visit our online webform or call us at 1-800-654-1412. Please note that it may take some time, in accordance with applicable laws, to fulfill your request. If we require an extension and such extension is permissible under applicable law, we will let you know.

Appeal rights: If we are unable to fulfill your request to access, review, delete or correct your personal information, we will respond to you explaining why. If you would like to appeal for additional review of our inability to fulfill your request, visit our appeals webform.

Sale or Sharing/Processing of personal information for targeted advertising purposes: We do not sell personal information for monetary value. However, as noted in the “Cookies and Online Advertising” section above, we do engage in certain targeted advertising activities for which you have a right to opt out. Please see the “Cookies and Online Advertising” section above for the various ways you can exercise choice with respect to these activities.

If you are a California resident, please see our California Notice at Collection for additional information about your rights under California law.

VII.    Retention of Information

We retain information in accordance with applicable laws or regulatory requirements and also for as long as necessary to fulfill the purposes for which it was collected and to fulfill the business or commercial purposes that are explained in this Privacy Statement. Refining and developing statistical models relies on information collected over a period of time. We store this information until it is no longer needed to improve, develop or provide you the services. Where possible, we keep this information in a pseudonymized format. When no longer needed, we delete or deidentify the personal information. We review our data retention policies periodically and comply with local legal requirements.

VIII.    Links to Third Party Sites and Services

Links to other companies’ websites may be provided on the Services as a convenience to you. If you choose to go to these external websites, you will be subject to the privacy practices of those external websites; Arity is not responsible for the privacy practices of those websites. We encourage you to be aware when you leave our Services to read the privacy policies or statements of every website you visit, as those privacy policies or statements may differ from ours.

Our Websites include Social Media Features, such as the Facebook “Like” button and Widgets, the Share This button or interactive mini-programs that run on our website. These features may collect your IP address, which page you are visiting on our website, and may set a cookie to enable the feature to function properly. Social media features and widgets are either hosted by a third party or hosted directly on our website. Your interactions with these features are governed by the privacy policy of the company providing it.

IX.    Security

We recognize the importance of keeping your information secure. We use a combination of reasonable technical, administrative, and physical safeguards to protect your information. However, no website, mobile application, database or system is completely secure or “hacker proof.” So, we cannot guarantee its absolute security. You are also responsible for taking reasonable steps to protect your information against unauthorized disclosure or misuse.

X.    Children’s Information

We do not knowingly gather personal information or market products or services to children under the age of sixteen. If we become aware that we have collected personal information from a child without the required parental consent, we will make reasonable efforts to delete such data from our records.

XI.    Changes to this Privacy Statement

We may periodically update or revise this Privacy Statement. The effective date at the top of the document shows when this Privacy Statement was last revised. We will let you know when we update the Privacy Statement by changing the date or other appropriate means.

XII.    Information for International Users

Our Services are provided from the United States and other jurisdictions, and we store, and/or process your personal information in the United States and other jurisdictions for the purposes described in this Privacy Statement. Please note that the laws in the United States regarding the processing of your personal information may differ from the laws in your jurisdiction of residence. Wherever your personal information is transferred, stored or processed by us, we take reasonable steps to protect your information in accordance with this Privacy Statement and applicable laws.

Please note that our legal bases for the collection and processing of your personal information are as follows:

• Where use of your personal information is necessary to perform our obligations under a contract or commitment to you. For example, to provide the Services you’ve requested from us, or to comply with our legal terms.
• Where use of your personal information furthers our legitimate interests or the legitimate interests of others. For example, to provide security for our Services, operate our business and our Services, make and receive payments, defend our legal rights, and prevent fraud.
• Where we use your personal information to comply with applicable legal obligations. For example, keeping track of purchases for tax and auditing purposes.
• Where you have consented to our processing of your personal information for a particular purpose.

XIII.    Contact Information

If you should have questions or concerns about our privacy practices, please contact us through the below methods.

Please note: When sending inquiries to us, we may need additional information such as the business client you have engaged for which we collected data to better assist you.

Email: privacy@arity.com

Mail: Arity
Attn: Data Protection Officer
PO Box 227238
Dallas, TX 75222-7238
United States of America

To request that you no longer receive business-related promotional e-mails from Arity, please email us at info@arity.com.

If you wish to no longer receive promotional emails marketed to consumers regarding insurance quotes or other consumer products, visit Unsubscribe Email & Phone. This Unsubscribe will only apply to marketing emails sent through or in relation to our lead generation websites.

If you opt out from receiving marketing emails, we may still send you transactional, non-marketing emails such as emails about your products or services, responses to your requests and inquiries, or notices of updates to terms and conditions or our privacy practices.