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ASURION.COM PRIVACY POLICY

Effective Date: August 2015

 

General Information

PLEASE READ THIS PRIVACY STATEMENT AND NOTICE OF PRIVACY PRACTICES CAREFULLY.

This Privacy Statement and Notice of Privacy Practices ("Privacy Policy") sets forth the privacy practices of Asurion, LLC and/or its subsidiaries and affiliates (collectively "Asurion"). This Privacy Policy is intended to be a global enterprise wide privacy policy applicable to all data collection by Asurion, (excluding mobile applications and related mobile application services) and shall apply to the user's ("You or Your") use of this website, Your use of any affiliated third party websites that may contain a link to this Privacy Policy, or to any pages, facilities, services, or capabilities accessible on or by any top-level Asurion domain owned by us or any subsite, subdomain, subdirectory, virtual site, or virtual directory thereof (each, a “Site” and collectively the "Sites").

This Privacy Policy shall apply strictly to customer information collected in the United States. This Privacy Policy describes how Asurion treats Your use of the Sites, including the collection, storage, transfer, sharing, disclosure and handling of Your personally identifiable information ("Personally Identifiable Information" or PII) and Your use of our Products and Services which we define below in this Privacy Policy.

This Privacy Policy does not apply to any of our Products or Services that do not display or link to this Privacy Policy or that do not have their own individual Privacy Policy or to information we collect from You or about You in other ways including through emails You may choose to send us. As indicated above, this Privacy Policy does not apply to Your use of our mobile applications or the services associated with those mobile applications (the Privacy Policy for our Mobile Applications and Service is accessible through your mobile application). By using our Products or Services, You acknowledge that You have read this Privacy Policy and consent to Asurion's privacy practices as described in the Privacy Policy, including our use and disclosure of your PII for the purposes described below. You further affirm your consent by submitting content or materials to or through our Services or when You purchase our Products. This Privacy Policy is not intended to and does not create any contractual or other legal right in or on behalf of any person.


 

CHANGES AND UPDATES TO THIS PRIVACY POLICY:

Asurion reserves the right to revise or update this Privacy Policy at any time, and You agree to be bound by those revisions or updates. Asurion will notify You of any changes to the Privacy Policy by posting the revised or updated Privacy Policy and its "Last Modified" date on the Sites. Your use of the Sites thereafter constitutes Your agreement to and acceptance of the Privacy Policy and its revisions or updates. You should periodically read the Privacy Policy to learn of any revisions or updates. In the event we materially change the way in which we use Your PII, we will provide You with notice and ask You to affirmatively accept the changes to a new Privacy Policy. This Privacy Policy is incorporated as part of the Terms of Service that apply with respect to Your use of the Sites and our Products and Services, which we define below in this Privacy Policy. If You do not agree to the terms and conditions of this Privacy Policy, including having Your PII used in any of the ways described in this Privacy Policy do not provide us with your information. If You do not agree to any terms of the Privacy Policy, please do not use the Sites.


CONTACT AND ELECTRONIC COMMUNICATION:

By purchasing our Products, using our Services or providing Your PII to us, You agree that we can communicate with You electronically regarding any legal, regulatory, technical, security, privacy and any administrative or consumer notification obligations that may be related to Your use of the Products and Services. If You have any questions about this Privacy Policy or about our Products or Services related to the Privacy Policy You can contact Asurion by e-mail at privacy@asurion.com.

You may also contact us at:
Asurion
Attn: Office of the General Counsel
648 Grassmere Park
Nashville, TN 37211


DESCRIPTION OF OUR PRODUCTS AND SERVICES:

We’re a technology company. When you call us, you’ll talk to people with the patience and experience to genuinely help. We understand what it’s like to spill water on a cell phone or a have a hard drive crash on a term paper. We replace. We fix. We find. We solve. We keep you in the game. We are Asurion. Life's Operating System™. Asurion is the industry-defining leader of technology solutions, ensuring 280 million consumers’ connected devices and connected appliances stay online and on the job. Asurion offers comprehensive mobile device protection insurance through its various Sites and through its mobile applications to best serve its customers. Asurion provides its customers with the ability to file warranty claims, register products and locate lost devices through its Sites. Asurion provides delivery and installation of smart appliances, consumer electronics, advanced consumer technologies and other consumer products offering delivery, set up, installation, explanation of user guides and installation materials. These offerings are defined under this Privacy Policy collectively and individually as our ("Products" and "Services").


SUMMARY OF PRIVACY POLICY:

This Privacy Policy notifies you of:

  • what types of Non-personally identifiable information ("Non-PII") is collected from you when you use our Sites;

  • what PII of yours is collected from you through the Sites and when you engage with our third party service providers;

  • how your PII is used by Asurion;

  • with whom the PII may be shared;

  • what choices are available to you regarding collection, use and distribution of your PII;

  • the kind of procedures Asurion employs in an effort to hinder the unauthorized access, deletion, alteration, use or disclosure of information you provide to Asurion or by using the Sites; and

  • how you can correct any inaccuracies in the PII you provide to us by using the Sites.


INFORMATION COLLECTION:

We collect two types of information from you when You use our Products and Services. We collect PII and Non-PII which we describe below. Asurion may share both your PII and Non-PII with its affiliates, subsidiaries, partners and other third parties, such as third parties who help operate the Sites and its related databases. Asurion requires such organizations to comply with the requirements set out in this Privacy Policy.


NON-PERSONALLY IDENTIFIABLE INFORMATION:

Asurion gathers certain broad, Non-PII about use of the Sites, including the number of unique visitors to the Sites, the frequency with which they visit the Sites and the services preferred by those visitors on the Sites. Asurion looks at the data regarding use of the Sites in summary form, rather than on an individual basis. Asurion gathers this Non-PII data so it can learn, for example, which pages of the Sites are the most and least viewed by visitors and which third-party websites are referring visitors to the Sites. The Non-PII data helps Asurion determine the extent to which visitors use certain parts of the Sites and allows Asurion to tailor the Sites in the future. In connection with these activities, Asurion may use the following standard technologies to collect information:

  • LOG INFORMATION:

When you use our Products and Services or view content provided by Asurion on the Sites, we automatically collect and store certain information in our server logs. This type of information includes details of how you used our Products or Services, IP address information described below, web pages which have been viewed by a visitor, data and time, domain type, device event information such as crashes, system activity, hardware, settings, browser type, browser language, the date and time of your request and referral URL.

  • COOKIES:

A cookie is a small, removable data file that is stored by your web browser on your computer. Asurion uses cookies to, among other things, identify your computer during a particular visit to the Sites and analyze your behavior during a particular visit. Asurion does not store personal or sensitive information in cookies. Most web browsers provide you with the ability to accept or decline cookies, as well as to be warned each time a cookie is being sent. If you choose to decline cookies, however, you may not be able to take advantage of all aspects of the Sites.

  • PIXEL TAGS:

Pixel tags, also known as beacons or clear GIFs, help Asurion better manage content on the Sites by informing it of what content is effective. Pixel tags are tiny graphics with a unique identifier, similar in function to cookies, and are used to track the online movements of web users. In contrast to cookies, which are stored on a user's computer hard drive, pixel tags are embedded invisibly on web pages.

  • IP ADDRESSES:

Asurion collects and analyzes traffic on the Sites by keeping track of the IP addresses of its visitors. An IP address is the unique numeric identifier assigned to each computer browser accessing the Internet. An IP address, by itself, cannot identify you personally. However, when combined with other information provided by your Internet service provider, your IP address can be used to identify the computer originating a message.


PERSONALLY IDENTIFIABLE INFORMATION:

Certain areas of the Sites require You to provide PII to Asurion. The PII that Asurion collects may include Your name, phone number, e-mail address, username, password, claim ID, date of log-in, any details provided by You explaining circumstances under which You are requesting assistance or information from Asurion, or similar information. As part of the claim process, Asurion or its affiliates may require You to provide a copy of Your driver’s license, passport, military ID, or other personal identification card. Additionally, in order to process Your claim and complete your transaction, Asurion or its affiliates may request Your shipping and billing information, credit card information or other preferred payment means. By submitting PII to Asurion, You agree that Asurion may use the information in accordance with this Privacy Policy, for example to register and service Your warranty, process your requests, adapt and improve Asurion services to better suit Your needs, provide benefits entitled to You, and to meet regulatory or contractual requirements relating to the services provided to You. If You do submit PII to Asurion, Asurion may share that information with third parties, in addition to using that information for the purposes for which it was submitted by You.

Asurion may also use Your PII in other ways, such as to provide You with information about Products, Services and offers that may be of interest to You, to seek follow-up from You about Your experiences with Asurion or as otherwise disclosed to you at the point of collection. Where required, Asurion will seek your express consent to send such messages, including when sent by email or other type of commercial electronic message. This consent is sought by Asurion, LLC, 648 Grassmere Park, Nashville, TN 37211. You may withdraw your consent by using the "unsubscribe" link located at the bottom of such messages you receive from Asurion, or by contacting Asurion at the phone number listed in your applicable Terms of Service.

Asurion may share Your PII with its affiliates, subsidiaries and partners and with other third parties for similar purposes. Additionally, to the extent required by applicable federal or state law, Asurion will provide your PII to others. By submitting PII to Asurion, You give Asurion permission to receive it, review it, edit it, store it and use it in appropriate ways and settings.


RETENTION AND STORAGE OF PII:

Asurion will retain Your PII for as long as necessary to fulfill the purpose(s) for which it was collected and to comply with applicable laws, and Your consent to such purposes(s) remains valid with respect to claims data and to file claims related to insurance coverage after termination of Asurion's relationship with You.


USE OF PII AND NON-PII:

In addition to any of the previously mentioned uses of PII and non-PII, Asurion may use Your information collected on the Sites for such purposes as:

  • helping to establish and verify Your identity;

  • activating and maintaining Your account;

  • to the extent that Your telecommunications carrier does not provide such services, billing and resolving billing disputes;

  • contacting You to offer Product or Service updates and notices, promotional notices and other information about Products and Services or other services available from Asurion or its affiliates (You may choose not to allow Asurion to use or disclose Your PII for marketing and promotional purposes by contacting Asurion as outlined in the Contact and Electronic Communications section of this Privacy Policy);

  • providing You with products or services or carrying out the transaction(s) You have requested or authorized;

  • responding to Your questions, inquiries, comments and instructions;

  • improving the Sites by solving technical problems, calculating overall usage statistics, internal marketing and promotional purposes, product development and content improvement;

  • taking good faith steps to enforce terms and conditions; and

  • maintaining the security and integrity of the Sites and Asurion's systems.


SHARING AND DISCLOSURE OF PII AND NON-PII:

Personally Identifiable Information. Primarily, we may share or disclose Your PII in the following instances:

  • To fulfill a service to You.

For example, if You email us a question, we may use Your email address to process your request and respond to your question.

  • To offer You products from our affiliates, strategic partners, agents, or from third-party marketers and other unaffiliated parties that we believe may be of interest to You, or to assist such parties for research, administrative, and/or business purposes.

These parties may contact You with an offer or advertisement related to a product or service, or they may use such information for their own research, administration or business purposes.

  • To unaffiliated third-party service providers, agents, or independent contractors who help us maintain our services and provide us with other administrative services (including, but not limited to, order processing and fulfillment, providing customer service, maintaining and analyzing data, sending customer communications on our behalf, and entry collection, winner selection and prize fulfillment for contests, sweepstakes, and other promotions). Asurion requires these service-related companies to comply with the principles set out in the Privacy Policy, and require them to use such information only for the purposes for which it was provided to them

  • To complete Your purchase.

If You choose to make a purchase of one of our Products or on or through our Services, we may ask You for Your credit card number, billing address, and other information in connection with completing such purchase, and we may use such information to fulfill Your purchase. We may also provide such information, or other personally identifiable information provided by You, to unaffiliated third-parties to complete Your purchase (for example, to process Your credit card).

  • To comply with law, or in the good faith belief that such action is necessary to conform to the requirements of law, or comply with legal process served on us, and to protect and defend our rights or property, including our rights and property and our services, or act in urgent circumstances to protect the personal safety of You and our other visitors.

  • To third parties as part of a corporate reorganization process including, but not limited to, mergers, acquisitions, and sales of all or substantially all of our assets.

  • To track and analyze non-identifying, aggregate usage and volume statistical information from our visitors and customers and provide such information to third parties.

  • To protect against fraud and potential fraud.

We may verify the information you provide to obtain our Products and Services through third parties. In the course of such verification, we may receive additional PII about You from such services. In particular, if You use a credit card or debit card to purchase services with us, we may use card authorization and fraud screening services to verify that Your card information and address match the information You supplied to us, and that the card has not been reported as lost or stolen.

Non-personally identifiable information. We may share and disclose Your Non-PII for the purposes described in this statement or where it is collected, or any other legal purpose, including, when and where applicable, sharing and disclosing non-personally identifiable information combined with personally identifiable information.

Legal Disclosure. We may disclose information about You and Your use of the services if we believe that such disclosure is reasonably necessary to:

(i) Comply with the law and/or legal process where a formal request has been made (e.g. request from an administrative oversight agency, civil suit, subpoena, court order or judicial or administrative proceeding);

(ii) Protect or defend our rights and/or property or the rights and property of others;

(iii) Enforce our Terms of Service and/or this Privacy Policy; and

(iv) Respond to claims that the content(s) of a communication violates the rights of another.

Also, circumstances may arise where, for business reasons, we may decide to reorganize, or divest all or part of our business through sale, assignment, merger or acquisition, or we may acquire a new business. In these circumstances, PII may be shared with the actual or prospective purchasers or assignees, or with the newly acquired business. In such an event, we shall provide notice of any material change to this Privacy Policy, or our Products and Services, in the manner described in this Privacy Policy.


ACCESS TO AND ABILITY TO CORRECT OR DELETE YOUR INFORMATION:

Upon request via postal mail, e-mail, or telephone, Asurion will provide You a summary of Your PII retained by Asurion. As allowed by law and consistent with our applicable partner agreements, You may modify, correct, change, or request Asurion to delete or update and PII that Asurion has collected through the Sites by contacting Asurion via postal mail, e-mail, or telephone, as provided in the Contact and Electronic Communication section of this Privacy Policy.


THIRD PARTY SITES:

The Sites may contain links to other websites, including websites operated by non-affiliated or independent third parties. Please be aware that those sites may collect PII from or about You and Non-PII about Your visit. These sites have not necessarily been reviewed by Asurion and are maintained by third parties over which Asurion exercises no control. Accordingly, Asurion expressly disclaims any responsibility for the privacy policies, information collection practices, content, accuracy of the information, and/or quality of products or services provided by or advertised on these third-party websites. Moreover, these links do not imply an endorsement with respect to any third party or any website or the products or services provided by any third party. You should review the privacy policies that are posted on any website that You visit, before using the website and providing PII to the website. Asurion is not responsible for the privacy policies or practices of any websites that may be mentioned on, or accessible from, the Sites.


CHILDREN UNDER 13:

The Services provided by Asurion are not directed to persons under 13. Asurion does not knowingly collect PII from children under 13. If You become aware that your child is accessing the Services and PII without Your consent, please contact us by using the information provided in the Contact and Electronic Communications section of this Privacy Policy. Asurion will take steps to remove PII from Asurion Storage Systems and terminate the account should Asurion determine that a child under 13 has accessed the Services.


SECURITY OF INFORMATION

Information submitted via the Internet, including through a web page or e-mail is subject to interception or incorrect routing, and the Internet is not a fully secure communications channel. Please consider this prior to submitting any information to Asurion via the Sites. While Asurion follows generally accepted industry standards to protect the information submitted to us, no method of transmission over the Internet, or method of electronic storage, is 100 percent secure. Therefore, while Asurion strives to use commercially acceptable means to protect Your personal information, Asurion cannot guarantee its absolute security. For information specific to application and mobile device security and credit card processing security please review these specific sections under this Privacy Policy.


CREDIT CARD PROCESSING AND DATA SECURITY:

Asurion does not receive funds directly from You when You utilize the Sites. Asurion utilizes a third party payment processing gateway who provides the infrastructure and security necessary to provide secure transmission of your credit card transaction data. Asurion can only accept credit cards from processing through our secured payment processing gateway. To explain simply, our credit card processor manages the routing of credit card transaction in the same fashion as a traditional credit card swipe machine you find in the physical retail world; however, they use the Internet instead of a phone line. Although we do not control the security environment for them and cannot make any guarantees regarding the secure processing of your credit card transaction data, we want to inform you that our credit card processor is compliant with the Payment Card Industry Data Security Standard (“PCI DSS”) as a Level 1 service provider. We demand that our credit card processors are compliant with PCI DSS before we selected them. PCI DSS is the bankcard industry’s most stringent security standard. Examples of our credit card processor’s security measures include: physical, electronic, and procedural safeguards; sophisticated security monitoring tools; documented security policies; use of strong encryption for transmissions of order information to and from our customers; restricting access to personally identifiable information; and periodic security audits by third party security experts. For more detailed information about how we utilize this third party payment processing gateway company and more information about the secure processing of your credit card transaction data, please see the below links:


CALIFORNIA PRIVACY RIGHTS:

This notification is required under California law. Under California law, California residents may opt-out of Asurion disclosing personal information about them to third parties for their marketing purposes. If You are a California resident and do not want Asurion to disclose Your PII to other companies for their marketing purposes, please contact Asurion by any of the ways described in the Contact and Electronic Communications Section above. Pursuant to Section 1798.83 of the California Civil Code, residents of California have the right to request from a business, with whom the California resident has an established business relationship, certain information with respect to the types of PII the business shares with third parties for direct marketing purposes by such third party and the identities of the third parties with whom the business has shared such information during the immediately preceding calendar year. To request a copy of such information, please contact Asurion by any of the ways described in the Contact and Electronic Communications section above, and Asurion will respond within 30 days as required by law.

California law also requires Asurion to disclose how it responds to Your Web browser “do not track” signals or other mechanisms that provide You the ability to exercise choice regarding the collection of PII about your online activities over time and across third-party websites or online services. Asurion is also required to disclose whether other parties may collect personally identifiable information about Your online activities over time and across different websites when You use the Sites.


DO NOT TRACK AND THIRD PARTY ADVERTISING COOKIES:

Do-Not-Track is a public-private initiative, http://www.w3.org/2011/tracking-protection/, that has developed a technical “flag” or signal that an end-user may be able to activate within their browser software to notify websites that they do not wish to be “tracked” by third parties as defined by the initiative. The initiative, however, has not reached a consensus as to exactly what technical or other actions those parties receiving the signal should take. As a result, Do-Not-Track has not yet been standardized and most websites, including Asurion, do not alter their behavior or change their services when they receive a “do-not-track” flag or signal. You can, however, make decisions about your privacy and the advertisements You receive. Asurion may utilize online behavioral advertising on the Sites in the future. Once enabled on this Site, You can control whether companies serve you behaviorally-based advertising by visiting the Digital Advertising Alliance (“DAA”) Web page and using the DAA's opt-out: http://www.aboutads.info/choices/.

As an alternative to the DAA opt-out, You can also elect to block all cookies from first parties (such as Asurion) and from third parties (such as entities involved in advertising) by using the cookie blocking options built into Your browser software. Please note, however, that if You do decide to block cookies, some parts of Asurion’s website may not function correctly. For more specific information on Do-Not-Track and the exercise of consumer choice regarding the collection of PII about your online activities over time and across third party websites or online services, please review Asurion’s Cookie Policy.

Although Asurion currently does/does not utilize third party advertising cookies on the Sites, at some time in the future, Asurion may elect to work with a variety of advertisers, advertising networks, or advertising servers. These advertisers, advertising networks, advertising servers, and analytics companies use various technologies, and technologies from third party companies, to collect data in order to display (or serve) relevant ads to users. These technologies may include the placement of cookies or web beacons, the use of HTML5 LocalStorage, the use of unique or non-unique non-personal identifiers, or the use of other technologies on the Sites or Asurion application, and these technologies may be used to track user behavior, to track how the Site or Asurion applications are being used, and possibly to serve you more relevant ads. Asurion currently utilizes analytics companies to collect information about use of the Site which enables Asurion to improve the way it works and help prevent fraud. Analytic cookies collect information about how You use the Site, for instance, which pages You go to most. The information allows Asurion to see the overall patterns of usage on the Sites, helps Asurion record any difficulties You have with the Sites, and shows Asurion whether its advertising is effective or not. While many of these technologies do not store or maintain PII, they do collect and use information that may include location and service provider information garnered via the IP address used to access the mobile Internet or other means, device identifiers, the type of phone or other mobile device used (e.g., iPhone, Blackberry 8800, etc.), the date and time of a user’s mobile internet session, whether one of the mobile ads that a third party facilitated was delivered and, if applicable, a record if that ad was “clicked.” These targeted advertisements may appear on the Sites or other services that You visit.


SOCIAL MEDIA:

Any information, communications, or material of any type or nature that You submit to the Sites or through Asurion Services (including, but not limited to any Asurion Sites contained on a social media platform or website such as Facebook, Instagram or Twitter) by email, posting, messaging, uploading, downloading, or otherwise (collectively, a “Submission”), is done at Your own risk and without any expectation of privacy. Asurion cannot control the actions of other users of any social media platform or website and Asurion is therefore not responsible for any content or Submissions contained on such sites and platforms. By visiting any Asurion Sites that is contained on a social media platform or website, You are representing and warranting to Asurion that You have reviewed the applicable Privacy Policy and terms of use of such platform or website and that You will abide by all such provisions contained therein. Additionally, in the event that Asurion offers a message board or any other interactive or social-type feature on the Sites, please be aware that these areas may allow You to publicly post, and share with other users, certain messages, content, or other information (e.g., stories, pictures, ingredients, tips, etc.). Although Asurion may take certain precautions to protect those who use these areas of the Sites, Asurion encourages You to be wary of giving out any PII in such public forums. The information You post can be collected and used by people You don't know. Asurion cannot guarantee the privacy and safety of these areas and is therefore not responsible for any information You choose to post. Your use of these features is fully at Your own risk.


INTERNATIONAL USERS:

FOR NON US RESIDENTS: We may transfer information that we collect about You, including Your PII , to subsidiary and affiliated entities, or to other third parties across borders and from Your country or jurisdiction to other countries or jurisdictions around the world. If You are visiting from the European Union or other regions with laws governing data collection and use that may differ from U.S. law, please note that You are transferring information about You, including PII, to a country and jurisdiction that does not have the same data protection laws as the European Union, and You consent to the transfer of information about You, including Your PII, to the U.S.; and the use and disclosure of information about You, including Your PII, as described in this Privacy Policy.