Privacy Policy
Who are we?
Cover-America Inc, DBA Smart Citti Agency, company incorporated in the United States of America, 1716 Catherine Court, Suite A1, Auburn, AL 36830 (“Cover-America”) we operate the www.smartcitti.com website and the Smart Citti mobile application (collectively referred as the “Service”).
Cover-America (“we”, “us”, “Smart Citti”) are the Data Controller over any personal data we process about you for the purposes set out in this Privacy Notice. If you have any concerns about our processing of your personal data or you have a general enquiry in relation to data protection, please contact us at enquiries@smartcitti.com
What is personal data?
Personal data: means any information relating to an identified or identifiable natural person (‘data subject’); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.
Personal data is information that identifies you, is not generally available to the public and may include information about your family as well as you personally. We collect the personal data that you provide us so that we may provide you with the Service(s) we offer. If you elect, we may also collect personal data from third-party data providers. You are not obligated to provide us with personal data; however, if you do not provide us with certain information that we request, we may not be able to respond to your requests, process your applications or otherwise conduct the business contemplated between you and us. For example, in order to provide you with insurance quotes, we collect personal data including name, telephone number, mailing address, email address, gender, birthday, marital status, information about your vehicles, residences, etc. and may also collect information about your credit and your existing insurance coverage.
Special Category of Data: means personal data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, and the processing of genetic data, biometric data for the purpose of uniquely identifying a natural person, data concerning health or data concerning a natural person’s sex life or sexual orientation.
When we use the term ‘personal data’ we mean both personal data and special category of data.
What personal data do we collect?
We collect a variety of information that will aid us in quoting and servicing your insurance policy and providing the Service to you.
We are processing the following types of personal data about you:
| Data Type | Description |
|---|---|
| Identity Data | Includes first name, last name, username or similar identifier. |
| Contact Data | Includes email address. |
| Profile Data | Includes your username and password, preferences and feedback. |
| Usage Data | Includes information about how you use our website and our Service. |
| Marketing and Communications Data | Preferences in receiving marketing from and your communication preferences. |
| Technical Data | Including “log data” and “location information” (as described below). |
| Log Data | We collect information that your browser sends whenever you visit our Service (“Log Data”). This Log Data may include information such as your device’s Internet Protocol (“IP”) address, browser type, browser version, the features of our Service that you visit, the time and date of your visit, the time spent on those pages and other statistics. When you access the Service by or through a mobile device, we may collect certain information automatically, including, but not limited to, the type of mobile device you use, your mobile devices IP address of your mobile device, your mobile operating system, the type of mobile Internet browser you use. |
| Location Information | We may use and store information about your location, if you give us permission to do so. We use this information to provide features of our Service, to improve and customize our Service. You can enable or disable location services when you use our Service at any time, through your mobile device settings. |
| Aggregated Data | We also process Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific App feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy notice. |
| Insurance Quote Data | We may collect more detailed personal data should you request an insurance quotation. This data includes: telephone number, mailing address, email address, gender, birthday, marital status, information about your vehicles and drivers and may also collect information about your credit and your existing insurance coverage |
| Driving Activity | Through the use of our Service, if you access our insurance products and services we may collect vehicle miles driven, speed, heading, acceleration, deceleration, altitude, periodic odometer readings, collision and impact, location information, and any information derived from the information. |
| Pet Data | We may collect more detailed data in relation to your Pet’s, such as name, age, medical information. |
| Household Data | We may collect information in relation to your residence and specific belongings (e.g. high value items) should you request a quotation for home insurance. |
| Referral Data | If you choose to refer a friend to our Service, we will ask you for your friend’s name and email address. We will send your friend an invitation email to access the Service. We store this information for the sole purpose of sending the invitation and reminder emails, and for tracking the success of our referral program. |
Where do we obtain your personal data from?
We collect personal data from and about you through:
| Data Source | Description |
|---|---|
| Direct interactions | You may give us your personal data when registering for the App or using the Service. This includes personal data you provide when you:
|
| Automated technologies or interactions | As you interact with our service, we may automatically collect Technical Data about your equipment, app navigation and patterns. We collect this personal data by using cookies and other similar technologies. Please see our Cookie Policy for further details. |
| Third Parties | Some of our products offered through the Service, such as insurance policies and quotations may require us to access personal data via third party data providers (e.g. vehicle registration information). |
How do we use your data?
We have set out below, in a table format, a description of all the ways we use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate. Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data.
| Purpose/Activity | Type of data | Lawful basis for processing including basis of legitimate interest |
|---|---|---|
| To register you as a new customer | (a) Identity (b) Contact | Bring you on board to our platform |
| To manage our relationship with you which will include: (a) Notifying you about changes to our terms or privacy policy (b) Asking you to leave a review or take a survey | (a) Identity (b) Contact (c) Profile (d) Marketing and Communications | (a) Performance of a contract with you (b) Necessary to comply with a legal obligation (c) Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services) |
| To administer and protect our business and this service (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data) | (a) Identity (b) Contact (c) Technical | (a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise) (b) Necessary to comply with a legal obligation |
| To deliver relevant service content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you | (a) Identity (b) Contact (c) Profile (d) Usage (e) Marketing and Communications (f) Technical | Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy) |
| To use data analytics to improve our service, products, marketing, customer relationships and experiences | (a) Technical (b) Usage | Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy) |
| Insurance quotation & policy administration | (a) Identity (b) Contact (c) Profile (d) Marketing and Communications (e) Insurance Quote Data (f) Driving Activity (g) Pet Data (h) Household Data | Necessary to provide insurance quotations and supporting insurance related services (e.g. motor insurance, breakdown assistance, home insurance, pet insurance, etc.) |
If you fail to provide personal data
Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.
Cookies
Cookies are files with small amounts of data, which may include an anonymous unique identifier. Cookies are sent to your browser from a web site and stored on your computer’s hard drive.
We use “cookies” to collect information. Please visit our Cookie Policy for information on what cookies we use and how you can control them.
Where will we keep your personal data?
Your personal data will be stored on systems servers in the United Sates of America. We ensure that our contract has adequate security measures in place to protect your personal data according to the GDPR.
Do we share your personal data with any other organisation/third parties and if so, why and does this involve a transfer out with EEA?
Other than as set out below, we will not share your personal data with a third party except
(i) where we are obliged by law,
(ii) we sell or otherwise transfer the asset(s) of our business to a third party, or
(iii) where we are using a third party supplier to deliver some services to us, in which case we shall take appropriate measures to ensure any such supplier has appropriate security in place to keep your information safe and we shall ensure we have appropriate contractual terms obliging them to keep the information safe.
The suppliers that we currently share your personal data with, include but are not limited to providers of insurance products, home and automotive supply chain services, mail services, data storage and server hosting, analytics, email delivery, surveys, accountancy, secure document storage. Some of these suppliers are based outside of the EEA and where this is the case we ensure that adequate safeguards are put in place to protect your personal data or we otherwise meet the requirements of GDPR for international transfers where appropriate.
By using the Service as part of your request for information about insurance policies and quotations, you authorize us to provide that information to various insurance companies, insurance agents and other related third parties that participate in our insurance quote network. The Insurance Providers may provide your personal data to their insurance carriers, suppliers and other related vendors in order to generate price quotations and information relevant to insurance policies that you have requested, and the Insurance Providers may use the contact information (including telephone number(s)) you have provided to contact you directly with quotations by means of telephone (manually or auto-dialed), fax, email and postal mail, even if you have registered your phone number(s) on local and/or national no-call lists. You further acknowledge and agree that each Insurance Provider that receives your quote request from the Service or from our affiliates may confirm your information with a consumer report, which may include among other things, your driving record and/or credit score. For purposes of faxing, it is understood that Insurance Providers have an established business relationship with each user of this Service, if required to comply with the then current law.
Please be aware that, once you submit a quote request, there is no way for you to access or update the information you have submitted in connection with that request because it is passed onto 3rd parties, and we have no control or access to your personal data. If you make a mistake in a request, you should re-submit your request and information in full. We will retain your information for as long as required to provide you services. We will retain and use your information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements. We use commercially reasonable efforts to ensure that the Insurance Providers are obligated to protect your personal data to at least the degree established in this Policy. Additionally, it is our policy to require Insurance Providers to use commercially reasonable means to secure the receipt and processing of your personal data. You should be aware, however, that after an Insurance Provider contacts you directly, any information you provide directly to the Insurance Provider, which may be the same as or similar to the Personal data you submitted to us through the Service, will no longer be covered by this Policy. Before providing your information directly to an individual Insurance Provider, you should make sure that you have read and understand that Insurance Provider's privacy policies and practices. We have no control over the Insurance Providers and their practices, and we are not and will not be responsible or liable, financially or otherwise, for their respective privacy policies and practices. Also, be aware that the Insurance Providers may use the personal data they acquire from this Service in connection with other information they acquire about you (from other sources that have collected personal data about you such as credit reporting companies, etc.) as well as information you provide them directly. We are not and will not be responsible or liable, financially or otherwise, for any of the personal data that you provide directly to any Insurance Provider or that they acquire from sources other than the Service. In addition, if you no longer want to receive communications from the Insurance Providers regarding insurance quotes, you must contact the respective Insurance Provider(s) directly and request that they no longer contact you. You may not opt out of communications from any Insurance Provider by contacting us. We will share your personal data with third parties only in the ways that are described in this privacy policy.
Smart Citti works to promote a safe and reliable Service for all users. We reserve the right to disclose your information that we believe is reasonable, appropriate, or necessary to take precautions against liability; to protect Smart Citti and others from fraudulent, abusive, predatory, or unlawful uses or activity; to investigate and defend ourselves against any third party claims or allegations; to prevent fraud and criminal activity; to assist government enforcement agencies; to protect the security or integrity of the Service; or to protect or vindicate the rights, property, or personal safety of Smart Citti, our users, or others.
Security of your personal data
We work hard to protect your personal data and have adopted appropriate technical and organisational measures to keep it safe from unauthorised disclosure or alteration.
How do you stop us sending you marketing communication?
If you no longer wish to receive communication from us you may opt-out by emailing our Customer Support at enquiries@smartcitti.com
How long do we retain your personal data?
We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.
To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.
Do we make any automated decisions about you that produce legal or significant effects for you?
No
Your rights
We have summarised your rights below. Please contact enquiries@smartcitti.com to exercise these.
- Request access to your personal data. (commonly known as a "data subject access request"). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
- Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
- Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
- Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes.
- Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data's accuracy; (b) where our use of the data is unlawful but you do not want us to erase it, provided it has not already been erased; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
- Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, the personal data you have provided to us in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
- Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
What we may need from you
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
We aim to keep our personal data up to date and accurate. To support this aim, we request that you contact us as soon as possible to advise us of any changes to your personal data.
Our service may, from time to time, contain links to and from the websites of third parties. If you follow a link to any of these websites, please note that these websites and any services that may be accessible through them have their own privacy notices and that we do not accept any responsibility or liability for these notices or for any personal data that may be collected through these websites or services, such as contact and location data. Please check these notices before you submit any personal data to these websites or use these services.
Changes to the Privacy Policy
We reserve the right to amend this privacy policy. However, any changes we may make to our privacy notice in the future will be communicated to you in some manner and will always be posted on our website.
18th Dec 2018
Cookie Policy
About cookies
A cookie is a small text file that a website you visit asks your browser to store on your computer or mobile device.
How we use cookies
We use cookies to understand, secure, operate, and provide our Services. For example, we use cookies:
- to provide the Services, Smart Citti for web and mobile and other services that are web or mobile based, improve your experiences, understand how our Services are being used, and customize our Services;
- to understand which of our FAQs are most popular and to show you relevant content related to our Services;
- to remember your choices, such as your language preferences, and otherwise to customize our Services for you; and
- to rank the FAQs on our website based on popularity, understand mobile versus desktop users of our web-based Services, or understand popularity and effectiveness of some of our web pages.
To limit or block the cookies which are set by Smartcitti, you can amend your browser's privacy settings. The Help function within your web browser will explain how this is done.
How to control cookies
You can follow the instructions provided by your browser or device (usually located under "Settings" or "Preferences") to modify your cookie settings. -Please note that if you set your browser or device to disable cookies, some of our Services may not function properly.
Visit www.aboutcookies.org to find out how to limit or block cookies on an array of different browsers. There are details on how to delete cookies as well as general information about them. For information on how to do this on your mobile phone you will need to refer to the manufacturer's guide.
Blogs / Forums
Our Service offers publicly accessible blogs. You should be aware that any information you provide in these areas may be read, collected, and used by others who access them. To request removal of your personal information from our blog contact us at enquiries@smartcitti.com. In some cases, we may not be able to remove your personal information, in which case we will let you know if we are unable to do so and why.
Happiness / Review’s
One of the social features of the Service allows you to provide feedback, happiness and review data, when using the mobile application. This data can be made public or private. If you choose to make this data public then is will be accessible buy other users of the Service.