Effective Date: May 1, 2021
Accessibility of this Policy
You can download and print a copy of this Notice here.
What Personal Information Is Collected by Savvy And How Is It Used?
Publicly Available Information. Savvy may obtain information about Users from third-party sources that aggregate public records in order to market and/or provide Savvy’s services.
IP Address. A User’s “IP Address” is identified and logged automatically in our server log files whenever a User visits the Services, along with the time of the visit and the page(s) that were visited. Savvy uses IP Addresses for calculating usage levels of the Services, helping diagnose server problems, and administering the Services.
Third Party Advertising/Re-Targeting Services: When accessing the Site, third party advertising services may place a cookie on your browser, which may be used to target relevant advertisements to you when you visit third party websites. Users may opt-out from receiving targeted advertisements by visiting the (1) Network Advertising Consumer Opt-Out page, (2) Digital Advertising Alliance Opt-Out page, and/or (3) the opt-out provisions pertaining to the applicable advertising services/retargeting provider.
Insurance Rate Comparison:
- By connecting Savvy with your insurance provider, you are requesting and authorizing Savvy to disclose applicable Personal Information contained within your insurance policy, as well as related insurance terms and rates, to third party carriers, insurance agency partners and consumer report services to generate and calculate accurate quotes. Information will be shared with those partners whose quotes you affirmatively select and with insurance marketing partners to the extent permitted by third party carriers and applicable law.
Analytics: Savvy uses the following third party analytics services:
- Amplitude. Amplitude collects User data and information regarding the behavior and usage patterns of Users of the Site.
- Looker. Savvy utilizes Looker, a data analytics platform, that enables Savvy to obtain insights on User behavior on the Site.
- Google Display Network. Savvy utilizes Google Display Network to target advertisements to its Users. Users can manage ad settings on Google Advertising Opt-Out and revisit their privacy preferences on Google’s Privacy Checkup tool.
- Facebook Visitor Action Pixels. Savvy may use “Visitor action pixels” from Facebook on the Site. This allows User behavior to be tracked after they have been redirected to the provider’s website by clicking on a Facebook ad. This enables us to measure the effectiveness of Facebook ads for statistical and market research purposes. Please see the Facebook’s Data Policy for additional information.
SMS Notifications. Savvy utilizes Twilio for SMS notifications between Savvy and Users who have provided their cell phone numbers.
Customer Service and Support. Savvy utilizes Kustomer, Inc. for customer service and support purposes. Processing of Personal Data is subject to the master services agreement and the Kustomer Product Privacy Statement.
Other Potential Disclosures. 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.
Please see Section 5 for additional information regarding a California Consumer’s rights under the CCPA relating to Personal Information collected and processed by Savvy.
Compliance with the Children’s Online Privacy Protection Act, CCPA and Other Privacy Regulations Relating to Minors
Savvy does not knowingly collect Personal Information from anyone under the age of 18. If a parent or guardian becomes aware that his or her minor child as defined by applicable privacy laws has provided Personal Information without their consent, he or she should contact Savvy at firstname.lastname@example.org. We will delete such Personal Data from our files within a commercially reasonable time, but no later than required under the applicable law relating the child’s state and/or country of residence.
Retention of Personal Information
Unless erasure is otherwise required under applicable law, Savvy will retain account and purchase data as long as it is necessary to provide services to our customers. Personal Information obtained from Site visitors will be maintained as long as it is necessary to provide requested communications and information-based services or until a visitor exercises the right to opt-out of requested communications or information-based services. Anonymized and pseudo-anonymized data will be retained as long as Savvy determines such data is commercially necessary for its legitimate business interests.
Your California Privacy Rights
This California Privacy Rights Notice (“Notice”) addresses Savvy’s disclosure obligations under the California Consumer Privacy Act of 2018 (“CCPA”) and the California Civil Code Section 1798.83. For purposes of this section, “Personal Information” has the meaning given in the CCPA but does not include information exempted from the scope of the CCPA. For instance, the CCPA does not apply to personal information collected or disclosed in connection with financial products or services that are used primarily for personal, family, or household purposes.
Personal Information Collected and Disclosed:
Savvy’s practices regarding the collection, use and/or disclosure of Personal Information currently and during the past twelve months are as follows:
Personal Information Collected, Used and/or Disclosed in Preceding 12 Months CCPA Category Source of Collection Business Purpose Disclosed or Shared for Business Purpose? Identifiers (such as name/alias, email, address, cell or telephone number, IP address, unique online ID) You; service providers, devices Respond to requests for information, provide services, auditing, analytics, marketing Yes;
insurance marketing partners
Civil Code Section 1798.140 information (such as name, address, cell or telephone number, driver’s license or state identification card number, insurance policy number, financial information, medical information) You; service providers, devices Respond to requests for information and provide services; marketing Yes;
insurance Marketing partners
Commercial information (such as products/services purchased, obtained or considered) Devices Analytics; marketing Yes;
service providers; insurance marketing partners
Online identifiers (such as IP address or other unique online ID, browsing history, interaction with our website and advertisements) You, service providers, devices Respond to requests for information, provide services, analytics, marketing and tracking website usage Yes;
insurance Marketing partners
Medical information You; service providers Respond to requests for information and provide services Yes;
Geolocation data You; service providers Analytics Yes;
Other Potential Third Party Disclosures: Personal Information may also be disclosed as described in the “Other Potential Disclosures” section above.
Sale of Personal Information
In the last 12 months, Savvy has shared, with your express consent, certain Personal Information listed in Section 5.A above 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 partner.
California law may classify our use of the third party advertising services described above as a “sale” of your Personal Information to the companies that provide the services. This is because we allow them to collect information from our Users (e.g., online identifiers and browsing activity) so they can help serve ads on other online services more likely to interest you.
See below for information on opting out of sales of your personal information
Your Rights Under CCPA
California residents may exercise the following CCPA rights:
Request for Information:
You can request the following information about our practices during the past 12 months:
- The categories of Personal Information that we have collected.
- The categories of sources from which we collected Personal Information.
- The business or commercial purpose for collecting and/or selling Personal Information.
- The categories of third parties with whom we share Personal Information.
- The categories of Personal Information that we sold or disclosed for a business purpose, and if so, the categories of Personal Information received by each category of third-party recipient.
Request to Access:
You can request a copy of the Personal Information that we have collected about you during the past 12 months.
Request to Delete:
You can ask us to delete the Personal Information that we have collected from you.
Right to Opt-Out - Do Not Sell My Personal Information
You have the right to opt out of the “sale” of Personal Information as that term is defined by the CCPA. You may do so through either of the following methods:
- Submit a request through our Web Form.
- Email email@example.com with a subject heading “Do Not Sell My Personal Information”
You have the right to choose whether or not to accept cookies. However, since cookies can be an important part of how our Services work, if you remove or reject cookies, this could affect the availability and functionality of our Services.
Below are some options to control or limit how cookies are used on our Services:
- Although most browsers and devices accept cookies by default, you can usually manage settings to remove or reject browser cookies manually within your browser’s configuration settings. Please note that if you remove or reject cookies some of the features of our website may not function properly.
- To prevent your data from being used by Google Analytics, you can install Google’s opt-out browser add-on.
- For information on how our advertising partners may allow you to opt out of receiving ads based on your web browsing history, please visit http://optout.aboutads.info/.
How to Exercise Your Rights to Know, Access and Delete:
You can request to exercise your information, access and deletion rights by emailing firstname.lastname@example.org.
We will need to verify your identity to process your information, access and deletion requests and reserve the right to confirm your California residency. To verify your identity, we may require you to provide government identification, give a declaration as to your identity under penalty of perjury and/or provide additional information.
Under the CCPA, you may exercise these rights yourself or you may designate an authorized agent to make these requests on your behalf. Your authorized agent may make a request on your behalf upon our verification of the agent’s identity and our receipt of a copy of valid power of attorney given to your authorized agent pursuant to California Probate Code Sections 4000-4465. If you have not provided your agent with such a power of attorney, you must provide your agent signed permission to exercise your CCPA rights on your behalf, provide the information we request to verify your identity, and provide us with written confirmation that you have given the authorized agent permission to submit the request.
You are entitled to exercise the rights described above free from discriminatory treatment as prohibited by the CCPA.
Your Rights Under California’s Shine the Light Law
Under California’s Shine the Light law, you may also ask companies with whom you have formed a business relationship primarily for personal, family or household purposes to provide the names of third parties to which they have disclosed certain personal information (as defined under the Shine the Light law) during the preceding calendar year for their own direct marketing purposes and the categories of personal information disclosed. You may send us requests for this information to email@example.com. In your request, you must include the statement “Shine the Light Request,” and provide your first and last name and mailing address and certify that you are a California resident. We reserve the right to require additional information to confirm your California residency.
The security of your personal information is important to us. We employ a number of organizational, technical and physical safeguards designed to protect the personal information we collect. However, security risk is inherent in all internet and information technologies and we cannot guarantee the security of your personal information.
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. At present, the Site does not respond to or alter its practices when a Do Not Track signal is received.
If you have any questions regarding your Personal Information or about our privacy practices, please contact us at: Savvy, Attention: Privacy Department at firstname.lastname@example.org