January 2023

Freely Privacy Statement

Contents

Freely is a part of the Cover-MoreGroup and Cover-More Holdings USA Inc. group of affiliatedcompanies ("Freely", “we”, "us"or "our"). This Privacy Policy is designed to inform you about how we collect, use and share information about you, including, without limitation, in person, by phone, through mail or email or through our websites https://www.freely.me/us, and any other Freely- operated website, mobile sites, mobile applications or social media accounts (collectively, our "Sites”). By accessing or using our Sites or otherwise disclosing information to Freely, you agree that you are providing freely-given, specific, informed, and unambiguous consent to our collection, use, and sharing of your information in accordance with thisPrivacy Policy. If you do not agree to this Privacy Policy,you must discontinue using our Sites.

Table of contents

  1. What information Do We collect?
  2. How Do We Use Your Information?
  3. Who Do We Share Information With?
  4. Protection of Information
  5. Links to Third Party Sites
  6. Notice to International Users
  7. Children’s Privacy
  8. Disputes
  9. Consumer Privacy Rights
    9(a). Exercising Consumer Rights
    9(b). Disclosure of Personal Information
    9(c). Sale and Sharing of Personal Information and Use of Sensitive PersonalInformation
    9(d).“Shine the Light” Law
  10. Nevada Resident Privacy Rights
  11. Your Choices
  12. Your Rights
  13. Changes to This Privacy Policy
  14. Contact Us
  15. Accessibility

1. What Information Do We Collect?

Information You Provide Directly to Us

We collect information you provide directly to us in order to provide the best service possible. For example, we collect information when you: interact with us in person, by phone or through mail or email, request or purchase a service, register for an account, participate in any interactive features of the Sites, subscribe to a newsletter or email list, participate in a survey, contest, promotion or event, request customer support or otherwise communicate with us. The type of information we collect varies depending on the type of product or service we provide to you. For example, we will collect different information about you if you have a travel insurance policy than if you make a claim on a policy or require assistance when travelling. This information may include information about a permanent or temporary medical condition that you have or health information in general.

Categories of information we may collect from you include:

  • Account Information. When you register or contract for an account on the Sites, you will need to provide us with certain personal information to complete the registration, including information that can be used to contact or identify you, which may include identifiers such as your name, email address, mailing address, username, and phone number. We also collect other information you provide as part of registration process and the administration and personalization of your user experience. We may combine this information with the personal information we collect from you.
  • Transaction Information. If you choose to order products or services from us you will have to provide us with certain information, including personal information such as: your name, mailing and/or e-mail address, contact details, your travel plans, information about your medical history and the medical history of any other person you wish to insure, health information about anyone who requires assistance under the travel insurance policy, medical history of any person with an insurance claim that we must assess, information about claims that you wish to make, partially redacted credit card statements, Driver's License and/or other photographic identification, details contained within identifying documentation, type of medical and non-medical assistance provided by us or our service providers, type of medical and non-medical assistance provided by your medical practitioner, employment and income information, and other information required to administer the productor services you have requested.

    We may also collect other limited payment information from you, such as payment method, and payment card information; however, we do not store full payment card numbers on our servers. Our third-party payment processor collects and processes through tokenization of all payment card information on our behalf.
  • Content You Submit.  We collect the content you submit to theSites. This includes all comments, feedback or materials submitted by you to us, for example, feedback, testimonials, images, reviews, questions, comments, suggestions or ideas (“Feedback”). We will be free to use, display, perform, distribute, copy, adapt, and promote, without compensation to you, the Feedback for any purpose whatsoever.
  • Verification Information. We may collect information to verify and confirm your identity. Thisinformation may include your name, address, date of birth and any otherinformation required by us to complete the verification process.
  • Surveys and Promotions. We may request information from you via surveys or promotions. Participation inthese surveys or promotions, which might include contests or sweepstakes, is voluntary. Examples of requested information may include contact anddemographic information.

Information We Collect Automatically

When you accessor use the Sites, information about you is automatically collected in connection with your use of our services, purchase of our products or interaction with the Sites, including the following:

  • Usage Information. We collect information about your usage of, and interaction with the Sites. For example, we may track the number of people who view each page and all of the areas within our Sites you visit.We may also collect and store statistics and other information about the online activities of our users on an aggregated (collective) basis.
  • Device Information. We collect information about the devices used to access the Sites. Such information includes the IP addresses of computers and mobile devices and information about your computers and mobile devices; other device features, including the type of browser, the type of operating system you use, your domain name, access time, referring website addresses and page views; and any information contained within a health or activity tracking device or mobile application including Health Trackers such as Fitbit, Google Fit, Jawbone,MapMyFitness, MapMyRide, MapMyRun, MapMyWalk, Misfit, Moves, Polar Flow, Runkeeper, TomTom Sports, Under Armour Record or Withings (referred to as“Health Trackers”) where you have authorized us to do so.
  • Location Information. With your permission, we may also collect information about the precise geolocation of your device using methods that may include GPS, wireless networks, cell towers, and Wi-Fi access points. For more information about how you can control the collection of location information and/or our access to other applications on your device, please see “YourChoices” below
  • Log Information. When you access or use the Sites, our servers automatically record certain log file information, such as your Internet Protocol (“IP”) address, operating system, browser type and language, referring URLs, access times, pages viewed, links clicked and other information about your activities on theSite.
  • Information Collected by Cookies, Web Beacons and Embedded Scripts. We and our service providers use various tracking technologies, including cookies, web beacons and embedded scripts, to collect information about you when you interact with our Sites, including information about your browsing and purchasing behavior. Cookies are small data files stored on your hard drive or in device memory that help us improve the Sites and your experience, see which areas and features of the Sites are popular, and count visits. Most web browsers are set to accept cookies by default. If you prefer, you can usually choose to set your browser to remove or reject browser cookies. Web beacons are small pieces of data that are embedded in images on the pages of web sites. Web beacons may involve the transmission of information directly to us, to another party on our behalf, or to another party in accordance with its privacy practices. We may use web beacons to bring together information we collect about you and to help us optimize and tailor our Sites for you and other future visitors to our Sites. An embedded script is programming code that is designed to collect information about your interactions with our Sites, such as the links you click on. The code is temporarily downloaded onto your device from our web server or a third party service provider, is active only while you are connected to the Sites, and is deactivated or deleted thereafter.

Please note that if you choose to limit any of the foregoing described automatic information collection tools, including removal or rejection of cookies, this could affect the availability and functionality of the Sites. For more information about how you can control the collection of location information and/or our access to other applications on your device, please see the “Your Choices”section below for information about how to opt-out.

Information We Collect From Third

Parties We may receive information that third parties provide us, which may include information about you. For example, we may collect information about you when you engage third parties to assist in ordering our products or services, when we use third parties to validate or update your information or other third parties who offer services that integrate with the Sites. Additionally, we may collect information about you when you post content to our pages or feeds on third party sites. This Privacy Policy does not apply to information collected through or by any third party. If you have any questions about such third parties' privacy practices, you should review their privacy policies.

We may combine information we collect through each channel of collection together to create your profile.

2. How Do We Use Your Information?

We may use your information for various purposes related to our operations and your use of the Sites. For example, we may use your information:

  • To personalize the user content and experience.
  • To provide, maintain and improve our Sites and provide you with relevant information and content.
  • To manage and authenticate customer data.
  • To facilitate and administer the provision of the products and services you purchase or request from us, including, but not limited to, verifying   your identity or location, processing payment; administering   a survey, promotion, sweepstakes or contest you participate in; assessing your travel insurance application, including your eligibility for discounted travel insurance; identifying you; arranging and managing your travel insurance with us; assessing and paying a claim; providing you with assistance when travelling; recovering payments due by other insurers; evaluating the emergency care and assistance you require; providing medical and non-medical assistance, including settling costs on your behalf; dealing with inquiries or complaints; or providing you with an analysis of your health and lifestyle based on information from your Health Trackers.
  • To contact you in connection with your account, a particular activity, purchase, or product or service, in person orby recorded message, by e-mail, telephone and/or mobile telephone number, text(SMS) message, or any other means of available communication.
  • To notify you in connection with a survey, promotion, sweepstakes or contest.
  • To provide you with information and offers on our products and services that we believe may be of interest to you.
  • To send you technical notices, updates, security alerts and support and administrative messages.
  • To respond to your comments, questions and requests and provide customer service.
  • To monitor and analyze trends, usage and activities in connection with our Sites.
  • To detect, investigate and prevent fraudulent transactions and other illegal activities.
  • To protect our rights and property and the rights and properties of others.
  • To maintain appropriate records for internal administrative purposes.
  • To perform operational functions in connection with our business, including data analysis, audits, developing and improving products and services, enhancing the Sites and identifying usage trends.
  • To link or combine with information we get from others to help understand your needs and provide you with a better experience.
  • To comply with legal and regulatory requirements (including fraud prevention and anti-money laundering), required disclosures and choices and controls that may be available.
  • To comply with our obligations to third parties in accordance with the terms and conditions of their services being provided on our behalf or directly to you.
  • To carry out market analysis, research, and product pricing analysis and development.
  • Detect, investigate or prevent activity that may be illegal, violate our policies, cause harm to our operations or compromise our security.
  • To carry out accreditation or certification activities.
  • To carry out credit, credit reporting and compliance checks on our authorized representatives and suppliers.
  • To carry out debt-recovery functions.
  • For any purpose that, under thecircumstances, would be reasonably expected by a consumer to be employed.
  • For any purpose that, under the circumstances, would be reasonably expected by a consumer to be employed.
  • To train our staff.
  • For any other purpose with your consent.

We also may use aggregated or de-identified information, which cannot reasonably be used to identify you.Once de-identified and aggregated so that data does not personally identify you(for example, we may aggregate data in order to improve our automation and improve user experience), it is no longer personal information. Such de-identified and/or aggregated information which does not identify individuals is not subject to this Privacy Policy.

  • Automated Decision Making.  'Automated Decision Making' refers to a decision which is taken solely on the basis of automated processing of your personal data. This means processing using, for example, software code or an algorithm, which does not require human intervention.  If you are a prospective plan holder or holder of an insurance plan, we may use automated decision making using your personal information to profile you and calculate insurance premiums (which are often based on age, state of resident, and/or trip cost). By using the Sites, applying for insurance coverage, maintaining insurance coverage, or otherwise communicating consent to automated decision making, you agree that you are providing freely-given, specific, informed, and unambiguous consent to the use of automated decision making and profiling for the provision of our services. If you do not consent to the use of automated decision making and profiling, then we cannot provide our insurance services to you and you must not engage with the Sites or use our insurance services. If you are a current or prospective plan holder and you wish to revoke your consent to the use of automated decision making and profiling, please contact us at freely-privacy@covermore.us or 1 844-246-8480 and we will cancel your insurance policy or application, as applicable.
  • Electronic Promotional Messages. We may send you promotional emails regarding special offers about our or our affiliates’ products and services or products and services on behalf of third party marketing partners who we think can offer products, services or content of interest to you. If you do not wish to receive information from us regarding special promotions or offers you can opt out of receipt of such promotional mailings (please see “Your Choices” below).  Even if you opt out of receiving promotional emails we may continue to send you transactional notifications that are related to your account, orders, or other products or services you have requested.
  • Direct Mail Promotional Offers. We may use your name and mailing address which we obtain from you for us, our affiliates or third party marketing partners to provide marketing offers to you through direct mail. If you prefer not to have your name and mailing address shared with a third party in connection with direct mail promotional messages please see “Your Choices ”below. Please note that even if you opt out of receiving promotional mail wemay continue to send you transactional notifications in the mail that arerelated to your account, orders, or other products or services you haverequested.
  • Third Party Analytics Services. We may work with certain third party service providers to collect, analyze, and use some of the information collected fromyou. For example, we may allow our service providers to set cookies or use web beacons on the Sites or in email communications from us, including Google, Inc.’sGoogle Analytics and AdWords services, Commission Junction LLC, and other similar third-party vendor services. These services use cookies to transmit your IP address and other website navigation and Internet usage and network activity data and device and browser-generated data, including regarding your browsing history and your interaction with our and other websites, applications, and advertisements. These service providers may provide this data to us or store and/or aggregate this data to analyze such usage and create reports for us. These service providers may also display our ads on sites across the Internet, and they may use this data to later display ads or other information to you based on your website usage or other information collected as described above. You may be able to set your browser to remove or reject browser cookies.We do not control these third party service providers’ tracking technologies or how they may be used. If you wish to know who our service providers are and where they are located, you may contact us at freely-privacy@covermore.us.

3. Who Do We Share Information With?

We may share information about you as follows or as otherwise described in this Privacy Policy:

  • With vendors, consultants, business partners, our related entities, and service providers to help us operate our business and the Sites; to administer activities on our behalf; and to assist with services such as data processing and matching, data analysis, data monetization services, information broking, business consulting, and marketing/research.
  • With strategic partners who provide additional features on the Sites. These strategic relationships may include business partners, sponsors and co-branded Site features. The use of your information by these third parties is subject to their own privacy practices and you should check their website for information regarding their privacy policies.
  • By participating in any survey, promotion, sweepstakes or contest, you agree to the official rules that govern that survey, promotion, sweepstakes or contest, including disclosure of your information to third parties or the public in connection with the administration of such survey, promotion, sweepstakes or contest, or as required by law.
  • As may be permitted or required by law (including, but not limited to, court order or subpoena), or to prevent or investigate suspected fraud, violations of our Terms of Use, or activity that appears to us to be illegal or may expose us to legal liability.
  • In response to a request for information if we believe disclosure is in accordance with, or required by, any applicable law, rule, regulation or legal process.
  • To provide you with a more personal experience, such as providing you with products and services that are relevant to you.
  • As determined necessary to protect the physical safety of any person or property or as otherwise appropriate when we believe your conduct on the Sites is inappropriate, is detrimental to us, or is inconsistent with generally accepted norms of behavior.
  • In the event that we, or any of our businesses, are sold or disposed of as a going concern, whether by merger, sale of assets or otherwise, or in the event of an insolvency, bankruptcy or receivership.
  • In connection with a commercial transaction where we or any one of our businesses are seeking financing, investment, support or funding.
  • To enforce any agreement, we may have with you.
  • Between and among us and any current or future parent, subsidiary and/or affiliated company.
  • In sending your information to overseas parties, if required to provide you with medical and non-medical assistance or to progress and assess your claim.
  • With certain entities and parties, such as our Insurer in the U.S., Zurich American Insurance Company; other insurers, including Re-insurers; co-insured/s on any insurance policy, so we may confirm details of the insurance; claims administrators; investigators, in relation to claims; translators, for claims and assistance; goods replacement suppliers to settle your claim; banks and foreign currency providers to settle your claim; transportation and accommodation providers; travel consultants and wholesale travel agencies; any company who we may claim against; medical practitioners and specialists; medical providers such as hospitals; emergency assistance providers; security providers and consultants; family members in the event of a medical emergency; witnesses, when making a claim; record management and storage businesses; companies who perform statistical analysis on our behalf; customer survey businesses and mystery shopping agencies; our professional advisors including lawyers, accountants, tax advisors and auditors; debt collection agencies and other parties that assist with debt-recovery functions; insurance reference bureaus; and printing, mail, and distribution companies.
  • With your consent or at your direction.

Affiliated and non-affiliated third parties that may receive or have access to the personal information in our care are not authorized to use such information for any marketing purposes except as permitted by law or with your consent. They may not copy or disclose personal information to any other party and may use it only for the purpose of performing their responsibilities to us, one of our policy holders and as otherwise permitted or required by law.

Depending on the nature and sensitivity of your personal information, your consent to the collection, use and disclosure of personal information may be required. This consent can be express (oral or written) or implied. Your consent may be withdrawn, subject to legal or contractual restrictions. By providing your personal information to us as part of a request that we provide a plan, product, or services, or as a request for employment and employment related benefits, you are implied to have consented to the transfer of your personal information to affiliated and unaffiliated third parties as may be necessary to provide the plan, service, or employment and benefits that you have requested.

4. Protection of Information

We maintain reasonable physical, operational and electronic security measures to protect your information. However, the transmission of information via the Internet, the Sites or email is not completely secure and we cannot guarantee the security of information transmitted to or from us. Your use of the Sites and provision of information to us indicates that you are willing to assume this risk. We maintain administrative, technical, and physical safeguards to protect against the misuse of personal information under our control.

Administrative safeguards:

  • Access to your personal data is limited to authorized personnel who have a legitimate need to know based on their job. In the case of third-party contractors who process personal information on our behalf, similar requirements are imposed. Where an individual employee no longer requires access, that individual's access is revoked.
  • Only allowing access where the individual seeking access has satisfied our identification requirements, such asa security check on the commencement of a call.
  • Confidentiality requirements for our employees and suppliers
  • Secure document storage.
  • Training and education is provided to all group employees in the handling of personal information.

Technical safeguards:

  • Security measures for systems access.
  • Antivirus and anti-malware software, and regularly updated virus definitions.
  • Third parties who we hire to provide services and have access to personal information agree to implement privacy and security practices that we deem adequate.
  • Personal information provided on computer servers is secured in a restricted and controlled network environment.
  • Training and education is provided to all group employees in the handling of personal information.
  • Employing firewalls and intrusion detection systems

Physical safeguards:

  • Third-party contractors who process personal data on our behalf agree to provide reasonable physical safeguards.
  • Employing physical and electronic means such as alarms and cameras to protect against unauthorized access to buildings.
  • Effectively and securely destroying data no longer needed, for example, by shredding or pulping in the case of paper records.
  • Our security procedures and policies are audited on a regular basis to ensure they are updated in accordance with current legal requirements and current levels of security technology.

Record Retention.  We will maintain your information, including any sensitive personal information, for only as long as reasonably necessary to fulfil the purpose for which it was collected, and as long as legally necessary, in accordance with applicable law.  In some circumstances we may retain your personal data for extended periods of time, for instance, where we are required to do so in accordance with legal, regulator, tax or accounting requirements. For example, some insurance related insurance information must be retained for seven (7) years.  Some contracts require a longer retention period.In specific circumstances we may also retain your personal data for extended periods of time so that we have an accurate record of your dealings with us in the event of any complaints or challenges, or if we reasonably believe there is a prospect of litigation relating to your personal data or dealings.

We maintain a data retention policy which we apply to records in our care.Where your personal data is no longer required we will undertake reasonable efforts ensure it is either securely deleted or stored in a way which means it will no longer be used by the business.

5. Links to Third Party Sites

OurSites may link to other websites whose privacy practices may differ from ours.If you submit information to any of those websites, your information is governed by their privacy statements. We do not exercise control over third-party websites and are not responsible for the privacy practices or the content of any such third-party websites. We encourage you to carefully read their privacy statement. The fact that we may link to a third-party website or present a banner ad or other type of advertisement from a third party is not an endorsement, authorization, or representation of any affiliation by us with that third party, nor is it an endorsement of their privacy or information security policies or practices.

6. Notice to International Users

The Sites are hosted in the UnitedStates and are subject to U.S. law. If you are accessing the Sites from outside the United States, please be advised that U.S. law may not offer the same privacy protections as the laws of your jurisdiction. By accessing and using the Sites, you agree that you are providing freely-given, specific, informed, and unambiguous consent to the transfer to and processing of your personal information in the U.S.

7. Children's Privacy

The Sites are intended for general adult audiences and you represent that you are over the age of majority in your jurisdiction of residence. If we have any reason to believe you are not the age of majority or older we may terminate your access to the Sites. In the event that we collect personal information from children under the age of 16 in connection with providing our products or services, we require such personal information to be provided from a parent, guardian or other person with legal authority to provide us with such information. For example, if you purchase a product from us that includes coverage for a child under the age of 16, we may require the child's name and data of birth. We do not share, sell, rent, or transfer children's personal information other than as set forth in this Privacy Policy. If you are aware of any child using the Sites, please contact us at freely-privacy@covermore.us.

8. Disputes

If you choose to visit or access the Sites or any of our services, any dispute concerning or related to your privacy is subject to this Privacy Policy and our Terms of Use.

9. Consumer Privacy Rights

The law of your jurisdiction may provide you with certain rights regarding our use of your personal information. Subject to any exceptions under applicable law, you may have the following rights with respect to your personal information collected by us:

Data Subject Rights

  • The right to know and access. You may have the right to request that we provide you with (i) a copy of the personal information that we have collected or maintained about you during any specific period of time; (ii) the categories of personal information that we have collected or maintained about you during any specific period of time; (iii) the categories of purposes for which such personal information was disclosed during any specific period of time; (iv) the categories of sources of such personal information that was collected during any specific period of time; and (v) the categories of third parties that such personal information may have been shared with during any specific period of time. If you exercise your right to know or access, we will endeavor to provide you with the information requested for the specific time period requested. If you choose to exercise your right to know or access and do not specify a time period, we will endeavor to provide all of the requested information collected or maintained after January 1, 2022, unless doing so would be impossible or involve a disproportionate effort. In the case that fulfilling a request to know or access proves impossible or involves a disproportionate effort, we will endeavor to provide you the requested categories of information collected or maintained by us in the immediately preceding 12 months from the date of your request. All information provided to you under this right to know and access will be provided in a portable, easily understandable, and to the extent technically feasible, in a structured, commonly used, machine-readable, and readily usable format that will allow you to transmit the relevant information to another entity without hindrance or impediment.
  • The right to deletion. You may have the right to request that we delete the personal information that we or our vendors collected about you. There may be circumstances under which we will be unable to delete your personal information, such as if we need to comply with our legal obligations, complete a transaction for which your personal information was collected, or if such deletion would be impossible or require a disproportionate effort. If we are unable to comply with your request for deletion, we will let you know the reason why.
  • The right to correct inaccurate personal information. You may have the right to request that any of your inaccurate personal information that is maintained by us to be corrected, taking into account the nature of the personal information and the purposes of the processing of the personal information.
  • The right to portability. You may have the right to request that we transmit your personal information to another entity in a portable, easily understandable, and to the extent technically feasible, in a structured, commonly used, machine-readable, and readily usable format.
  • The right to not be subject to certain profiling. You may have the right to opt-out of processing of your information which constitutes profiling in furtherance of decisions that produce legal effects or similarly significant effects concerning you. By using the Sites, applying for insurance coverage, maintaining insurance coverage, or otherwise communicating consent to automated decision making, you agree that you are providing freely-given, specific, informed, and unambiguous consent to the use of automated decision making and profiling for the provision of our services. If you do not consent to the use of automated decision making and profiling, then we cannot provide our insurance services to you and you must not engage with the Sites or use our insurance services. If you are a current or prospective plan holder and you wish to revoke your consent to the use of automated decision making and profiling, please contact us at freely-privacy@covermore.us or 1 844-246-8480 and we will cancel your insurance policy or application, as applicable.
  • The right to appeal. If you submit a request to exercise one of the above rights and we deny such request, you may have the right to appeal our decision.
  • The right to file a complaint. You may have the right to file a complaint with a relevant supervisory authority or your state’s Attorney General. You may contact us freely-privacy@covermore.us, the relevant supervisory authority, or your state’s Attorney General for more information.

9(a). Exercising Consumer Rights

To exercise any of these rights, contact us at freely-privacy@covermore.us or 1844-246-8480.  In connection with submitting a request, you must provide the following information, as applicable: name, email address, phone number, state of residence, and policy number and you must state what type of request you are making.

Only you, or someone legally authorized to act on your behalf, may make a verifiable consumer request related to his or her personal information. In general, we have the right to require you to provide written permission granting authority to your representative and for your agent to verify its identity directly with us, and we may deny a request from your representative who does not submit proof of authorization as we request.

You may only make a verifiable consumer request to know or access twice within a 12-month period. The verifiable consumer request must provide sufficient information that allows us to reasonably verify there questor is the person about whom we collected personal information or an authorized representative and describe the request with sufficient detail that allows us to properly understand, evaluate, and respond to it. We cannot respond to a request or provide personal information if we cannot verify the identity or authority to make the request.

We will endeavor to confirm receipt of a request within 10 days following submission and provide information about how we will process the request. We will endeavor to respond to a verifiable consumer request within 45 days of its receipt. If we require more time (up to an additional45 days), we will provide notice in writing explaining the reason for the extended time period.

Making a verifiable consumer request does not require you to create an account with us. We may deliver our written response by mail or electronically, at your option.

If we deny a request, we will provide a response explaining the reasons we cannot comply with a request, if applicable. We may deny your request to exercise any of the rights listed herein if we have a good-faith, reasonable, and documented belief that such request is fraudulent.

9(b). Disclosure of Personal InformationWe may have collected and disclosed the following categories of personal information from a consumer for a business purpose in the preceding 12 months:

  • Various identifiers, including, name, address, online identifier,Internet Protocol (IP) address, email address, account name, or other similar identifiers.
  • Personal information categories listed in the California CustomerRecords statute (Cal. Civ. Code § 1798.80(e)), including, telephone number or financial information.
  • Commercial information, including, records of products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.
  • Biometric information, including, behavioral characteristics, or activity patterns used to extract a template or other identifier or identifying information.
  • The right to equal service. If you have been granted any of the foregoing rights and you choose to exercise any of these rights, we will not discriminate against you in any way. However, if you exercise certain rights, you may be unable to use or access certain features of the Sites.
  • Internet or other similarnetwork activity, including, browsing history, search history, information on aconsumer's interaction with a website, application, or advertisement, includinginternet protocol (IP) addresses, browser type, internet service provider(ISP), referring/exit pages, the files viewed on our Site (e.g., HTML pages,graphics, etc.), operating system, date/time stamp, and/or clickstream data inorder to analyze trends in the aggregate and administer our Site.
  • Geolocation data, including, physical location or movements.
  • Sensory data, including, audio, electronic, visual, or similar information.
  • Professional or employment-related information, including, current or past job history or performance evaluations.
  • Educational information, including, transcript, student records, grades and performance, activities, school name or school ID.
  • Inferences drawn from other personal information, including, profile reflecting a person's preferences, characteristics, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.
  • Protected classification characteristics, including, race, color, national origin, marital status, sex, and veteran or military status.
  • Personal records, such as, power of attorney, family history or power of attorney.
  • Information received from a government entity or other third party.
  • Sensitive personal information, including: (a) a consumer’s Social Security or other state identification number; (b) a consumer’s account log-in, financial account, debit card, or credit card number in combination with any required security or access code, password, or credentials allowing access to an account; (c) consumer’s geolocation; (d) consumer’s racial or ethnic origin, religious or philosophical beliefs, or union membership; (e) the contents of a consumer’s mail, email, or text messages, unless the business is the intended recipient of the communication; and (f) consumer’s genetic data.

We may collect the above categories of personal information directly from you, indirectly as you interact with our Sites, from or through other third party sources, including our customers, or through email or other electronic messages between you and ourSites.

In the prior 12 months, we may have disclosed the categories of personal information set forth above for one or more of the purposes set forth in this Privacy Policy, including disclosure to a service provider or other third party of ours for a business purpose. We will not collect additional categories of personal information or use the personal information we collected for materially different, unrelated, or incompatible purposes without providing you notice.

9(c) Sale and Sharing of Personal Information and Use of Sensitive Personal InformationWe have not, in the preceding 12 months, and do not currently, sell or share your personal information for money or other valuable consideration.

Some content or applications, including advertisements, on the Sites are served by third-party service providers, including advertisers, ad networks and application providers. These third party service providers may use cookies alone or in conjunction with web beacons or other tracking technologies to collect information about you when you use our Sites.  The information they collect may be associated with your personal information or they may collect information, including personal information, about your online activities over time and across different websites and other online services. They may use this information to provide you with interest-based (behavioral) advertising or other targeted content. The use of behavioral remarketing does not constitute a “sale” of personal information as defined under the applicable law.

Refer to the Section above entitled “Third Party Analytics Services” to review how to opt-out of receiving behavioral or targeted advertising.

We do not use your sensitive personal information for the purpose of inferring characteristics about you.

9(d) "Shine the Light" Law

California’s "Shine the Light" law,Civil Code section 1798.83, requires certain businesses to respond to requestsfrom California consumers asking about the business' practices related todisclosing personal information to third parties for the third parties’ directmarketing purposes. To make such a request, please send an email to freely-privacy@covermore.us.

How We Respond to “Do Not Track” Signals

Our Sites do not respond to DO NOT Track signals.  Third parties cannot collect any other personally identifiable information from our Sites unless you provide it to them directly.

10. Nevada Resident Privacy Rights

Nevada residents may have certain rights to opt-out of sales of their personal information under Nevada Revised StatutesChapter 603A. However, please know we do not currently sell data triggering this Nevada statute's opt-out requirements. If you have questions with respect to this right, please contact freely-privacy@covermore.us.

11. Your Choices

  • Location Information. With your consent, we may collect information about your actual location when you use our mobile applications and when you request or purchase products or services. You may stop the collection of this information at any time by changing the settings on your mobile device but note that some features of our mobile applications may no longer function if you do so.
  • Native Applications on Mobile Device. Some features of our mobile applications may require access to certain native applications on your mobile device, such as the camera, photo album and the address book applications. If you decide to use these features, we will ask you for your consent prior to accessing the applications and collecting associated information. Note that you can revoke your consent at any time by changing the settings on your device.
  • Cookies. Most web browsers are set to accept cookies by default. If you prefer, you can usually choose to set your browser to remove or reject browser cookies. Please note that if you choose to remove or reject cookies, this could affect the availability and functionality of the Sites.
  • Push Notifications. With your consent, we may send promotional and non-promotional push notifications or alerts to your mobile device. You can deactivate these messages at any time by changing the notification settings on your mobile device or within our mobile applications.
  • Direct Mail Marketing. To request to opt out of receiving unsolicited commercial direct mail please contact free-privacy@covermore.us. Please note we  will still need to send you essential information about your insurance, travel alerts, policy and claim documentation.
  • Email Marketing. You can choose to opt out of receiving promotional emails from us at any time. Emails will include an unsubscribe link that will remove you from future emails. You may also submit a request to freely-privacy@covermore.us. Please note we will still need to send you essential information about your insurance, travel alerts, policy and claim documentation.

12. Changes To This Privacy Policy

We may change this Privacy Policy from time to time. The most recent version of the Privacy Policy will always be posted on our Sites, with a posted "EffectiveDate". By using our Sites or otherwise providing us with your information after the Effective Date you are deemed to consent to our then-current privacy policy. This Privacy Policy will be reviewed at least annually to ensure it remains up to date and may be amended from time to time by posting the amended version on our website.

13. Contact Us

If, at any time, you would like to access, change, or request deletion of your data (please specify the kind of information you are seeking), you have questions, concerns, complaints, or comments about our Privacy Policy, please feel free to contact our privacy manager at free-privacy@covermore.us or write to us at:

The Privacy Manager

Cover-MoreInc.

810N. 96th Street, Suite 300 Omaha, NE 68114

Email: freely-privacy@covermore.us

If you have a complaint or concern about how we use your personal data, please contact us in the first instance and we will attempt to resolve the issue as soon as possible. If applicable, you also have a right to lodge a complaint with your national data protection supervisory authority at any time.

14. Accessibility

We are committed to facilitating the accessibility of our Sites for all people with disabilities. To access this Privacy Policy in an alternative format, please contact us at freely-privacy@covermore.us or 1-844-246-8480.