Effective Date May 30th, 2023
Section 8.A. is intended to provide the Notice of Collection required under the California Consumer Privacy Act.
1. Personal Information Collected by Savvy
- Non-Public Information. Savvy collects non-public personally identifiable information ("NPI"), which is information that identifies you and is not available to the public.
- Application Information. To obtain offers for you, Savvy may collect your name, address, phone number, email address, social security number, driver’s license, date of birth, and marital status. Savvy will utilize email and/or phone numbers to communicate with you regarding offers, quotes or applications.
- Payment Information. To make payments for the insurance products and services, Savvy may collect debit or credit card account information, email and other information to verify your identity, such as name, address, telephone number, and/or date of birth. Savvy does not itself store debit or credit card information on its servers, but utilizes a secure vault service to benefit the security of your personal payment information.
- Transactional Information. Savvy may receive information about your transactions with us, our affiliates, or others, including your insurance coverage, limits and rates, and payment and claims history. It also includes information that we require for billing and payment.
- Information from Third Parties. Savvy may obtain aggregated public records from third parties, such as data brokers and government agencies, in order to market and/or provide services to our customers. Savvy may receive Personal Information from consumer reporting agencies, which provide us with motor vehicle reports, real property records, claim reports, and/or credit information where permitted by law. Such information is used for prefill of an insurance application, or generation of an estimated premium cost for insurance for marketing purposes and you will have the opportunity to review and correct any incorrect or inaccurate data contained within that application.
- IP Address. A user’s IP address is identified and logged automatically in our server log files whenever you visit the Site, along with the time of the visit, the page(s) that were visited, and the actions taken on those pages. Savvy uses IP addresses for calculating usage levels of the Site, helping diagnose server problems, and administering the Site and Services.
- Web Beacons. Pages of our Site and/or emails from Savvy may contain small electronic files known as web beacons that permit Savvy, for example, to count users who have visited those pages or opened an email and for other related Site statistics.
- How You Can Control Advertising Cookies. Cookies are also utilized to deliver advertising on our site. Among other uses, they allow us to show more relevant advertising to people who visit the site by showing you ads that are based on your browsing patterns and the way you have interacted with our sites. You can find information about how to opt out of the cookies provided by our advertising partners here:
- Google Display Network. Google Display Network targets advertisements to Site Users. Users can manage ad settings on Google Advertising Opt-Out and revisit their privacy preferences on Google’s Privacy Checkup tool.
2. Personal Information Received by Savvy or Disclosed or Shared by Savvy
Personal Information is collected to facilitate the Services offered, for marketing of our Services and products, or for internal analysis relating to product improvements and data security.
Provide Savvy Services. Personal Information is collected to facilitate provision of the Services on the Site to:
- Provide, operate, and improve the Site and Services;
- Process and fulfill your request for products and services, such as insurance offer comparison
- Process payments and complete transactions;
- Communicate with you regarding our products and services;
- Respond to inquiries and provide customer support and feedback;
- Detect, prevent, and investigate security incidents that compromise the availability, authenticity, integrity or confidentiality of stored or transmitted Personal Information;
- Protect against malicious, deceptive, fraudulent or illegal activity directed at Savvy;
- Debug to identify and repair errors that impair existing intended functionality;
- Analyze data to assess, understand and improve the services and personalize user experiences, including creation of anonymized aggregated, statistical and benchmark data. Aggregated data is utilized to help develop and market products or services and present targeted content and advertising;
- Enable functionality of the services to authenticate a user, prevent fraud, and implement security measures;
- Undertake activities to verify or maintain the quality of a service or product that is developed or provided, and to improve, upgrade, or enhance any service or product that is developed or provided by Savvy.
Share with Service Providers. Savvy has engaged with service providers to facilitate the Savvy services and operate our business, including without limitation, database management, hosting, information technology, email/SMS delivery, manual or automated phone calls, customer support, analytics, and data security and compliance services necessary to provide the Savvy services. For each service provider, Savvy will have in place written contracts that describes the purpose of the service and disclosure of Personal Information, and requires the service provider to both keep the Personal Information confidential and not use it for any purpose except performing the services pursuant to such contract.
Offer Comparison Services. With respect to Savvy’s rate comparison services:
- By connecting Savvy with your insurance provider, you are requesting and authorizing Savvy to disclose NPI within your insurance policy, as well as related terms and rates, to third party insurers, insurance agency partners, and consumer report services to generate and calculate accurate quotes. Information will be shared with those partners you affirmatively select for the specific purpose of facilitating shopping and/or comparison services expressly requested by you, except to the extent a state resident has opted out in accordance with Section 8.B., with insurance marketing partners to the extent permitted by third party carriers and applicable law.
SMS Notifications – Notice & Consent. Savvy utilizes a service provider to enable SMS notifications. You consent to receive recurring text messages relating to the Services at the mobile number associated with your account or otherwise provided to Savvy. You understand and agree that text messages sent to your mobile number may be generated using automated technology. Message frequency varies. Message and data rates may apply. Reply STOP to opt-out or HELP for info. Consent is not a condition of any purchase. Information collected from SMS will not be shared, bought, rented, or exchanged for purposes other than specific to the insurance comparison services you have requested.
Analytics: Savvy uses the following analytics services:
- Google Analytics: Savvy utilizes Google Analytics for data analytics to generate insights and recommendations. Users can manage ad settings on Google Advertising Opt-Out and revisit their privacy preferences on Google’s Privacy Checkup tool.
- Amplitude. User data and information regarding the behavior and usage patterns of Users of the Site. If you wish to opt out of sharing, you may adjust your cookie preferences settings.
- Looker. Savvy utilizes Looker, a data analytics Site, that enables Savvy to obtain insights on User behavior on the Site. Users can manage ad settings on Google Advertising Opt-Out and revisit their privacy preferences on Google’s Privacy Checkup tool.
- Impact Analytics. Savvy utilizes the services of Impact Analytics, Inc. as a method for our affiliates to track a User’s progress through the Savvy Site experience. Personal information is not shared with affiliates, but rather Impact will generate a unique user token to share with Savvy affiliates. Under certain circumstances, affiliates may be able to use the unique user token to corroborate a User’s identity with the affiliate’s own internal records.
Compliance and Protection. Personal Information may be disclosed to serve our legitimate business interests as follows: (1) as required by law, such as to comply with a subpoena, or similar legal process, (2) if Savvy is involved in a merger, acquisition, or sale of all or a portion of its assets, (3) to investigate, prevent, or take action regarding suspected or actual illegal activities or to assist government enforcement agencies; (4) enforce our agreements with you, and/or (5) investigate and defend ourselves against any third-party claims or allegations. We will use commercially reasonable efforts to notify you about law enforcement or court ordered requests for data unless otherwise prohibited by law.
3. Personal Information of Minors
Savvy does not knowingly collect Personal Information on the Site from anyone under the age of 16. If we learn we have collected or received Personal Information from anyone under the age of 16 without verification of parental consent, we will delete that information. If a parent or guardian becomes aware that his or her child under the age of 16 has provided Savvy with Personal Information without their consent, he or she should contact Savvy at firstname.lastname@example.org. Savvy will delete such Personal Information from our files within a commercially reasonable time, but no later than required under the applicable law.
4. Retention and Deletion of Personal Information; De-Identified Data
5. Savvy’s Security Practices
We have implemented reasonable administrative, technical and physical security measures to protect Personal Information against unauthorized access, destruction or alteration. However, although we endeavor to provide reasonable security for Personal Information we process and maintain, no security system can ever be 100% secure.
6. Response To “Do Not Track” Signals
“Do Not Track” is a feature enabled on some browsers that sends a signal to request that a website disable its tracking or cross-website user tracking. The Site will respond to any requests received pursuant to a user-enabled Global Privacy Control.
8. Supplemental U.S. State-Specific Notices
Sections B-K of this Supplemental U.S. State Specific Notice does not apply to NPI collected with respect to Savvy’s offer of insurance products to consumers, which is governed by its obligations pursuant to the Gramm-Leach-Bliley Act (“GLBA”).
Notice of Collection: Savvy collects, uses and discloses, and in the preceding 12 months has collected, used and or disclosed, Personal Information as follows:
Categories of Personal Information:
- Identifiers, such as a name, postal address, unique personal identifiers, email address, account username and password, telephone number, insurance policy number, account name, social security number, gender, driver's license number, and other similar identifiers.
- Driving and claims history, including information about any prior accidents or insurance claims.
- Vehicle information, such as a vehicle identification number (VIN), vehicle details, including any customizations, and vehicle photos.
- Real Property records;
- Professional and Employment related information;
- Education-related information;
- Financial identifiers, such as a bank account number, credit card number, debit card number, or other financial information.
- Medical information contained within your insurance policy file.
- Commercial information about consumer transactions and experiences with us and others, such as payment history, claims, coverage and vehicle changes.
- Site usage and device information, such as search and browsing history, online identifier(s), Internet Protocol address, search history, and information regarding how users interact with our Site and online advertisements.
- Geolocation data.
Sources of Collection: Savvy collects each of the above categories from a variety of sources, including, directly from Users (either online, by phone, or by email), from service providers with your consent, data brokers, analytics providers, credit reporting agencies, public records, social networks, advertising and marketing partners, and insurance agents, brokers and providers.
Purpose of Collection and Disclosure: Savvy collects each of the above categories of information for purposes of:
- Performing services, including providing quotes for insurance, processing applications. providing customer service, processing payments, providing advertising or marketing services, providing analytics services, or providing similar services;
- Auditing related to a current interaction with you and concurrent transactions, including, but not limited to, counting ad impressions to unique visitors, verifying positioning and quality of ad impressions, and auditing compliance;
- Communications with you regarding products and services offered by Savvy and its partners.
- To assess and improve our product and service offerings, including the development of new products and services.
- Short-term, transient use, including, but not limited to, the contextual customization of ads shown as part of the same interaction;
- Detecting security incidents, protecting against malicious, deceptive, fraudulent, or illegal activity, and prosecuting those responsible for that activity.
Categories and Purposes of Disclosure: Savvy discloses the above categories of Personal Information to:
- Service providers that assist us in providing insurance-related services;
- Service providers involved in our verification, data-processing, risk-assessment, security and anti-fraud efforts;
- Insurance providers for purposes of offering quotes and information regarding insurance products and services;
- Third party advertising and marketing partners;
- State insurance departments and other governmental and law enforcement authorities to serve our legitimate business interests as follows: (1) as required by law, such as to comply with a subpoena, or similar legal process, (2) to investigate, prevent, or take action regarding suspected or actual illegal activities or to assist government enforcement agencies as required by law; (3) enforce our agreements with you, and/or (4) investigate and defend ourselves against any third-party claims or allegations.
Savvy does not retain a consumer's Personal Information for longer than is reasonably necessary for each disclosed purpose.
Sale of Personal Information; Sharing of Personal Information; Right to Opt-Out
In the last 12 months, Savvy has shared, with your express consent, certain personal information pursuant to a request for a rate comparison for insurance product(s). Savvy may receive a fee for the transfer of that data and/or if the visitor purchases a product or service from Savvy’s insurance partners.
In addition, in the last 12 months, Savvy has shared personal information necessary to provide you with personalized ads. This may be considered a “sale,” under the CCPA even if no money is exchanged.
Savvy may share Personal Information with third parties for cross-context behavioral advertising purposes, exclusively for providing our first-party services.
To the extent Savvy is regarded as “selling” your personal information (as the term “sell” is defined under the CCPA), you have the right to opt-out of that “sale” on a going-forward basis at any time.
Certain state residents have a right to opt-out from the “sale” or “sharing” of your personal information with third parties who are not our service providers (as those terms are defined by applicable laws) and/or to opt out of cross-context behavioral advertising. To exercise this right, click the Do Not Sell or Share My Personal Information link on the bottom of the Site page where your information is being collected or go to your account settings. You can also submit a request to opt-out by emailing us at email@example.com the subject line “Do Not Sell or Share.” Finally, if your browser supports it, you can turn on the Global Privacy Controlto opt-out of the “sale” or “sharing” of your personal information.
Collection of Sensitive Information
Savvy does not collect Sensitive Information for purposes other than as permitted under the CCPA and GLBA.
Consumer Rights. Consumers may contact Savvy to exercise the following consumer rights:
Request Savvy Disclose At No Charge (“Right to Know”):
- Specific pieces of Personal Information it has collected about you;
- categories of Personal Information collected, used, and/or disclosed about you;
- categories of sources from which Personal Information is collected;
- business and/or commercial purposes for collecting and disclosing your Personal Information;
- categories of third parties with whom your Personal Information has been disclosed/shared; and
Right to Know Requests can be submitted to Savvy by email at firstname.lastname@example.org.
Request Savvy to Delete At No Charge (“Right to Delete”):
Deletion Requests can be submitted to Savvy by email at email@example.com or by mail to Savvy at: Savvy, Inc., Attention: Privacy Request to Delete, 2093 Philadelphia Pike #7288, Claymont DE 19703 or by email at firstname.lastname@example.org.
Request Savvy Correct At No Charge (“Right to Correct”):
Requests that Savvy correct any inaccurate Personal Information collected by Savvy can be submitted by email to email@example.com.
Verified Request Process
Savvy will verify all consumer requests prior to taking any action in response to such request. For consumers that maintain an account with Savvy, it may verify the identity of the consumer making the request by either matching information with the account information on file or through existing account authentication credentials.
Under applicable state law, you may exercise these rights yourself or you may designate an authorized agent to make these requests on your behalf. Authorized agents must demonstrate they have written authorization from you to make requests on your behalf. Savvy may additionally require the consumer to confirm their identity and verify the authorized agent’s permission before complying with any request.
Consumer Request Limitations
Please note that these rights are not absolute and in certain cases are subject to conditions or limitations as specified in the applicable state laws, including, but not limited to:
- Savvy is obligated to disclose/delete only upon a verifiable Consumer request from the consumer or an authorized agent acting on behalf of Consumer.
- Consumers may only make a Personal Information request twice in a 12-month period.
- Deletion is not required if it is necessary for Savvy to maintain the Personal Information to fulfill applicable permissible purposes enumerated pursuant to applicable state law.
Savvy will confirm and respond to all requests within the timeframe required under applicable state law. In responding to any request to disclose/delete, Savvy shall maintain a record of the requests as required under applicable state law.
You have the right not to receive discriminatory treatment for exercising any rights conferred by the CCPA and VCDPA. Savvy shall not discriminate against a consumer for exercising any statutory consumer privacy rights, including, but not limited to, (a) denying goods or services, (b) charging different prices or rates (including discounts/penalties) that is not directly related to the value provided to Savvy for the Personal Information, (c) suggesting Consumer will receive a different rate/price or different level of quality of goods/services, or (d) providing a different level of quality of goods/ services.
Employees, applicants and independent contractors have the right not to be retaliated against for the exercise of their CCPA rights.
Your Virginia Privacy Rights under VCDPA
If Savvy is unable to process requests relating to your Personal Information and denies your request, Virginia residents have the right to appeal by emailing Savvy at firstname.lastname@example.org. Savvy will respond to your appeal request within 60 days of receiving the request to appeal.
Your California Privacy Rights under California Civil Code Section 1798.83 & Business and Professions Code Section 22581
California law permits Consumers to request and obtain from Savvy once a year, free of charge, certain information about their Personally Identifiable Information (“PII”) (as defined by California law) disclosed to third parties for direct marketing purposes in the preceding calendar year (if any). If applicable, this information would include a list of the categories of PII that was shared and the names and addresses of all third parties with which we shared information in the immediately preceding calendar year.
In addition, a business subject to California Business and Professions Code Section 22581 must allow California residents under age 18 who are registered users of online sites, services or applications to request and obtain removal of content or information they have publicly posted. Your request should include a detailed description of the specific content or information to be removed. Please be aware that your request does not guarantee complete or comprehensive removal of content or information posted online and that the law may not permit or require removal in certain circumstances.
Accessibility of this Policy
You can download and print a copy of this Notice as a separate document.
9. Contact Us
If you have any questions regarding your Personal Information or about our privacy practices, please contact us at: Savvy, Inc., Attention: Privacy Department, 2093 Philadelphia Pike #7288, Claymont DE 19703 or by email at email@example.com.