CALIFORNIA CONSUMER PRIVACY NOTICE: INDIVIDUALS, BUSINESSES, AND WEBSITE VISITORS<\/u><\/strong><\/p>\nThis Privacy Notice (\u201cNotice\u201d) describes how Freeway Insurance processes Personal Data that we collect through our websites, social media accounts, online advertisements, and mobile applications (collectively, our \u201cDigital Properties\u201d) and through other online and offline interactions.<\/p>\n
Whenever you interact with us on behalf of another individual or entity, such as by providing or accessing Personal Data about another individual, you need to obtain their consent (or have the legal authority without consent) to share any Personal Data you provide to us.<\/p>\n
Changes:<\/u><\/strong> We may update this Notice from time to time. Any updated Notice will be effective when posted. Please check this Notice periodically for updates. If required by law, we will contact you directly to provide you with an updated Notice.<\/p>\n 1. Sources of Personal Data.<\/div>\n
We collect Personal Data about you from the following sources:<\/p>\n
\n- Directly from you.<\/strong> We may collect Personal Data you provide to us directly, such as when you contact us through our Digital Properties, interact with us in person at tradeshows, sign up for offers or other services, register for an account with us, or otherwise communicate with us.<\/li>\n
- Data collected automatically and through tracking technologies.<\/strong> We may automatically collect information or inferences about you, such as through cookies and other tracking technologies, when you interact with our Digital Properties. This may include information about how you use and interact with our Digital Properties or otherwise interact with us, information about your device, and internet usage information.<\/li>\n
- From third parties.<\/strong> We may collect Personal Data from third parties, such as service and content providers, our affiliated companies and subsidiaries, business partners, data brokers, social media companies or other parties who interact with us, including through referrals.<\/li>\n
- From publicly available sources<\/strong>. We may collect Persona Data about you from publicly available sources, such as public profiles and websites.<\/li>\n<\/ol>\n
We may combine and use information and make inferences from information that we receive from the various sources described in this Privacy Notice, including third party sources. We may also use or disclose the combined information and inferences for the purposes identified below.<\/p>\n
2. Types of Personal Data We Collect.<\/div>\n
We may collect the following types of Personal Data about you:<\/p>\n
\n- Identifiers, <\/strong>such as your name, email address, physical address, telephone number, business contact information, account number, and device identifiers (e.g., cookie IDs and IP address).<\/li>\n
- Records about you<\/strong>, such as signatures; payment and delivery details; the content, timing and method of communications you have with us, such as online chats, calls, and emails; and personal opinions or insights included in any feedback relating to your interactions with us or reviews you submit about our products and services. <\/li>\n
- Commercial information<\/strong>, such as information related to your transactions, products or services purchased, obtained or considered; subscription information; evidence of personal assets and guarantees for potential franchisees;; your marketing preferences;; and legal information relating to your transactions, such as fraud checks or flags raised about your transactions, payment card refusals, complaints and information related to their resolution.<\/li>\n
- Internet or other electronic network activity information<\/strong>, such as your browsing history, search history, preferences (including marketing preferences),and other information regarding your interactions with and use of the Digital Properties. For more information about cookies and other device data, please see Section 5 \u2013 Cookies and Other Tracking Technologies.<\/li>\n
- Non-precise geolocation data<\/strong>, such as your location as derived from your IP address.<\/li>\n
- Audio, electronic, visual, or other sensory information<\/strong>, such as photographs, security camera footage, and audio recordings of your communications with our customer service centers.<\/li>\n
- Professional or employment-related information<\/strong>, such as job title, organization, professional licenses, credentials or affiliations, personality assessments and background check information for potential franchisees; and other professional information.<\/li>\n
- Education information<\/strong>.<\/li>\n
- Inferences<\/strong> drawn from any of the information we collect to assess the level of interest in our products and services based on frequency of visits and contact, evaluate the industries showing interest in our products and services based on IP address (where we can infer your approximate location to improve our communications to you), and determine your preferred frequency for receiving offers.<\/li>\n
- Sensitive Personal Information<\/strong>, such as Social Security number, driver\u2019s license number, or passport number; account log-in information; and racial or ethnic origin if you choose to provide it.<\/li>\n<\/ol>\n
3. How We Use Personal Data.<\/div>\n
We may use Personal Data for the following purposes:<\/p>\n
\n- To provide you or your company with products and services<\/strong>, such as registering, verifying, and maintaining your account with us; providing and delivering you the products and services you or the company you represent requests and providing customer service; processing or fulfilling orders and transactions, including executing franchise relationships; processing payments; paying referral fees; communicating with you about our products and services; hosting informational webinars; verifying eligibility for certain programs or benefits; soliciting feedback and responding to requests, complaints, and inquiries; and providing similar services or otherwise facilitating your relationship with us.<\/li>\n
- For our internal business purposes<\/strong>, such operating our Digital Properties and customizing the content; maintaining internal business records; document management and similar activities; enforcing our policies and rules; management reporting; auditing; IT administration of our network, Digital Properties, and other technologies; and IT security management and tasks.<\/li>\n
- For our internal research and product improvement purposes<\/strong>, such as verifying or maintaining the quality of our products or services; improving our products or services; designing new products and services; evaluating the effectiveness of our advertising or marketing efforts; and debugging and repairing errors with our systems, networks, and equipment.<\/li>\n
- For legal, safety or security reasons<\/strong>, such as complying with legal and reporting requirements; investigating and responding to claims against the Company and its customers; protecting our, your, our customers\u2019, and other third parties\u2019 safety, property or rights; detecting, preventing, and responding to security incidents; and protecting against malicious, deceptive, fraudulent, or illegal activity.<\/li>\n
- In connection with a corporate transaction<\/strong>, such as if we acquire, or sell or transfer all or a portion of our business or assets, including through a sale in connection with bankruptcy and other forms of corporate change.<\/li>\n
- For marketing and targeted advertising<\/strong>, such as marketing our products or services or those of our affiliates, business partners, or other third parties (for purposes of this paragraph alone, \u201cwe\u201d or \u201cour\u201d includes our affiliates, business partners, or other third parties we may be working with to provide marketing). For example, we may use Personal Data we collect to personalize advertising to you on this website or others, to analyze interactions with our email communications or website areas viewed, to develop product, brand or services audiences (including by identifying you across devices\/sites) to better target our advertising to you, or to send you newsletters, surveys, questionnaires, promotions, or information about events or webinars. You can unsubscribe from our email marketing via the link in the email or by contacting us using the information in the Contact Information <\/em>section below.<\/li>\n<\/ol>\n
We only use Sensitive Personal Information for the following purposes: (i) performing services or providing goods reasonably expected by an average consumer; (ii) detecting security incidents; (iii) resisting malicious, deceptive, or illegal actions; (iv) ensuring the physical safety of individuals; (v) for short-term, transient use, including non-personalized advertising; (vi) performing or providing internal business services; (vii) verifying or maintaining the quality or safety of a service or device; or (viii) for purposes that do not infer characteristics about you.<\/p>\n
We may use anonymized, de-identified, or aggregated information for any purpose permitted by law.<\/p>\n
4. How We Disclose Personal Data.<\/div>\n
We may disclose Personal Data to third parties, including the categories of recipients described below.<\/p>\n
Although we have not “sold” Personal Data for money in the past 12 months, we engage in routine practices with our Digital Properties involving third parties that could be considered a “sale” or \u201csharing\u201d as defined under California law. We do not knowingly sell or share any Personal Data of minors under the age of 16.<\/p>\n
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\n\n\nCategories of Personal Data We Collect<\/em><\/strong><\/th>\nCategories of Third Parties With Whom We Disclose Personal Data for a Business Purpose<\/em><\/strong><\/th>\nCategories of Third Parties to Whom Personal Data is Sold or Shared<\/em><\/strong><\/th>\n<\/tr>\n\nIdentifiers (Section 2.A)<\/strong><\/td>\n\n | | | | |