Effective Date: August 2015
PLEASE READ THIS PRIVACY STATEMENT AND NOTICE OF PRIVACY PRACTICES CAREFULLY.
CONTACT AND ELECTRONIC COMMUNICATION:
You may also contact us at:
Attn: Office of the General Counsel
648 Grassmere Park
Nashville, TN 37211
DESCRIPTION OF OUR PRODUCTS AND SERVICES:
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.
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:
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.
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.
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:
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;
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 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;
(iv) Respond to claims that the content(s) of a communication violates the rights of another.
ACCESS TO AND ABILITY TO CORRECT OR DELETE YOUR INFORMATION:
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:
SECURITY OF INFORMATION
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/.
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.