Privacy Policy

Last Updated: November 09, 2021
‍

1. Scope

Canopy Connect, Inc. (“we” or “us”) is committed to protecting your privacy. This Privacy Policy describes how we collect, store, use and distribute information through our software, website, mobile applications, documentation, and related services (together, the “Services”).

Capitalized terms not defined in this Privacy Policy have the meaning as set forth in the Terms of Service for the Services, which can be found on our Terms page.

Except as set forth in this Privacy Policy, your Personal Information will not be used for any other purpose without your consent. We do not actively collect Personal Information for the purpose of sale of such information in a way that specifically identifies the individual (i.e. we don’t sell customer lists). You may withdraw your consent to our processing of your Personal Information at any time. However, withdrawing consent may result in your inability to continue using some or all of the Services.

You are able to share Personal Information with third parties through use of the Services (including our business customers, or “Innovators”). The privacy policies of these third parties are not under our control and may differ from ours. The use of any information that you may provide to any third parties will be governed by the privacy policy of such third party or by your independent agreement with such third party, as the case may be. If you have any doubts about the privacy of the information you are providing to a third party, we recommend that you contact that third party directly for more information or to review its privacy policy.
‍‍

2. Collection of Information

Information you provide

Our technology makes it easier for you to get value and convenience from your insurance data by making it safer and easier to connect your personal insurance information to software applications created by Innovators that help you do things like verify your active insurance to close on a mortgage or drive a car, save money, cover a home or vehicle, or understand and select coverage options. When you connect your insurance accounts with a Developer application or otherwise connect your insurance accounts through us, we collect login information required by the provider of your account, such as your username and password, answers to challenge questions, or a security token (these are referred to below as your “Login Information”). When providing this information, you give the Developer and us the authority to act on your behalf to access and transmit your information from the relevant insurance institution. Your Login Information, as well as any other information we gather through the Services that may be used to identify, contact, or locate you individually, are collectively referred to herein as your “Personal Information.”

We may collect contact information, such as email address, phone number, or mailing address when you request information about our Services, register for our marketing materials, request customer or technical support, apply for a job, or otherwise communicate with us.

We may post job openings and opportunities on our Services. If you reply to one of these postings by submitting your application, CV and/or cover letter to us, we will collect and use your information to assess your qualifications.

Information collected from your insurance institutions

The information we receive from the insurance institutions that maintain your insurance accounts varies depending on the information made available by those institutions. But, in general, we collect the following types of information from your insurance institutions:

• Account information
• Information about policies, vehicles, and Personal Information related to providing accurate insurance data;
• Information about billing transactions, including amount, date, type, quantity, price, and a description of the transaction.

Information received from your devices

Our technology is generally embedded in our Innovators’ applications. When you use your device to connect to our services through a Developer application, we receive information about that device, including IP address, hardware model, operating system, and other technical information about the device.

We may collect Personal Information automatically when you use our Services:

• Cookies, Pixel Tags/Web Beacons, and Other Technologies. We, as well as third parties that provide content, advertising, or other functionality on our Services, may use cookies, pixel tags, local storage, and other technologies (“Technologies”) to automatically collect information through your use of our Services.
• Cookies. Cookies are small text files placed in device browsers that store preferences and facilitate and enhance your experience.
• Pixel Tags/Web Beacons. A pixel tag (also known as a web beacon) is a piece of code embedded in our Services that collects information about engagement on our Services. The use of a pixel tag allows us to record, for example, that a user has visited a particular web page or clicked on a particular advertisement. We may also include web beacons in e-mails to understand whether messages have been opened, acted on, or forwarded.

Our uses of these Technologies fall into the following general categories:

• Operationally Necessary. This includes Technologies that allow you access to our Services, applications, and tools that are required to identify irregular website behavior, prevent fraudulent activity and improve security or that allow you to make use of our functionality;
• Performance-Related. We may use Technologies to assess the performance of our Services, including as part of our analytic practices to help us understand how individuals use our Services (see Analytics below);
• Functionality-Related. We may use Technologies that allow us to offer you enhanced functionality when accessing or using our Services. This may include identifying you when you sign into our Services or keeping track of your specified preferences, interests, or past items viewed;
• Advertising- or Targeting-Related. We may use first party or third-party Technologies to deliver content, including ads relevant to your interests, on our Services or on third-party websites.
• Analytics. We may use Technologies and other third-party tools to process analytics information on our Services. For example, our analytics partners include
• Google Analytics. For more information, please visit Google Analytics’ Privacy Policy . To learn more about how to opt-out of Google Analytics’ use of your information, please click here .

Information we receive about you from other sources

We also receive information about you directly from the relevant Developer. For example, our Innovators may provide information about which insurance institution you use, or what information they expect to receive from an insurance institution.
‍

3. Use of Information

We use the information we collect to operate, improve, and protect the services we provide, to market our Services and to develop new services. More specifically, we use your Personal Information:

• To operate, provide, and maintain our Services;
• To verify your identity and manage your account;
• To improve, enhance, modify, add to, and further develop our Services and new products;
• To protect you, our Innovators, our partners, or Canopy Connect from fraud, malicious activity, and other privacy and security-related concerns;
• To provide customer support to you or to our Innovators, including to help respond to your inquiries related to our Service or our Innovators’ applications;
• To pursue our legitimate interests such as direct marketing, research and development (including marketing research), network and information security, and fraud prevention;
• To audit certain interactions, transactions and other compliance activities;
• To enforce our agreements and policies;
• To comply with our legal obligations;
• To investigate any misuse of our service or our Innovators’ applications, including violations of their agreements with us, criminal activity, or other unauthorized access to our Services; and
• For any other purpose described to you when the information was collected, such as registering for events or when applying for employment with us as posted on our site.

We may also use your Personal Information in an aggregated, de-identified, or anonymized manner (that does not identify you personally) for any purpose permitted under applicable law. This includes creating or using aggregated, de-identified, or anonymized data based on the collected information to develop new services and to facilitate research.

We may use Personal Information to tailor and provide you with content and advertisements. We may provide you with these materials as permitted by applicable law.

We may engage in automated decision making, such as for anti-fraud purposes. Canopy’s processing of your Personal Information will not result in a decision based solely on automated processing that significantly affects you unless such a decision is necessary as part of a contract we have with you, we have your consent, or we are permitted by law to engage in such automated decision making. If you have questions about our automated decision making, you may contact us as set forth in “ Contact Us ”
below.

If we plan to use your Personal Information in the future for any other purposes not identified above, we will only do so after informing you by updating this Privacy Policy. See the section entitled “Amendment of this Privacy Policy” below.
‍‍

4. Disclosures & Transfers

We disclose your information to third parties for a variety of business purposes, including to provide our Services, to protect us or others, or in the event of a major business transaction such as a merger, sale, or asset transfer, as described below. We have put in place contractual and other organizational safeguards with our agents to ensure a proper level of protection of your Personal Information (see further “Security” below). In addition to those measures, we will not disclose or transfer your Personal Information to third parties without your permission, except as specified in this Privacy Policy.

• We may share your Personal Information with the Developer of the application you are using and as directed by that Developer (such as with another third party if directed by you).
• We may also share your Personal Information as directed by you, such as with Business Partners to provide you with a product or service you have requested. We may also share your Personal Information to business partners with whom we jointly offer products or services.
• We share your Personal Information with “Service Providers” who have limited access to databases of user information or registered member information solely for the purpose of helping us to provide and/or improve the Services and are subject to contractual restrictions prohibiting them from using the information about our users for any other purpose. Such agents or third parties do not have any rights to use Personal Information beyond what is absolutely necessary to assist us.
• We may disclose your Personal Information to third parties to protect us or others without your consent if we have reason to believe that disclosing this information is necessary to identify, contact or bring legal action against someone who may be causing injury to or interference with (either intentionally or unintentionally) our rights or property, other users of the Services, or anyone else (including the rights or property of anyone else) that could be harmed by such activities. We may disclose Personal Information when we believe in good faith that such disclosure is required by and in accordance with the law.
• We may also disclose your Personal Information in connection with a corporate re-organization, a merger or amalgamation with another entity, a sale of all or a substantial portion of our assets or stock, including any due diligence exercise carried out in relation to the same, provided that the information disclosed continues to be used for the purposes permitted by this Privacy Policy by the entity acquiring the information.

Please note that if you are using the Services at the request or as part of an organization, your organization’s account administrator may be able to view certain activity and content associated with your use of the Services, including, but not limited to, elements of your Personal Information.
‍

5. International Transfers

The Services are hosted in the United States and are intended primarily for visitors located within the United States. If you choose to use the Services from other regions of the world with laws governing data collection and use that may differ from U.S. law, then please note that you may be transferring your Personal Information outside of those regions to the United States for storage and processing. We endeavor to safeguard your information consistent with the requirements of applicable laws. By providing your Personal Information through the Services, you consent to the extent allowed by law to such transfer, storage, and processing.

The files containing your information will be on our servers and those of our service providers and will be accessible to persons that require it for the purposes of their duties. Information may be accessible to the courts and the law enforcement and national security authorities of the United States. To obtain more information about our policies and practices with respect to service providers outside of your country, please contact us as set forth below. If you are located in the European Economic Area, Switzerland, the United Kingdom or Brazil, you have the right to lodge a complaint with a supervisory authority if you believe our processing of your Personal Information violates applicable law.
‍‍

6. Security

The security of your Personal Information is important to us. We use commercially reasonable efforts to store and maintain your Personal Information in a secure environment. We take technical, contractual, administrative, and physical security steps designed to protect Personal Information that you provide to us. We have implemented procedures designed to limit the dissemination of your Personal Information to only such designated staff as are reasonably necessary to carry out the stated purposes we have communicated to you. The files and records containing your Personal Information will be kept in our offices and/or on our servers or those of our service providers and only those employees that require it for the purposes of their duties will have access to this file. To the fullest extent permitted by applicable law, we do not accept liability for unauthorized disclosure.
‍‍

7. Retention

We will keep your Personal Information for as long as it remains necessary for the identified purpose or as required by law, which may extend beyond the termination of our relationship with you. We may retain certain data as necessary to prevent fraud or future abuse, or for legitimate business purposes, such as analysis of aggregated, non-personally-identifiable data, account recovery, or if required by law. All retained Personal Information will remain subject to the terms of this Privacy Policy. Please note that if you request that your Personal Information be removed from our databases, it may not be possible to completely delete all of your Personal Information due to technological and legal constraints.
‍

8. Your Privacy Choices and Rights

The privacy choices you may have about your Personal Information are determined by applicable law and are described below.

• Email and Telephone Communications. If you receive an unwanted email from us, you can use the unsubscribe link found at the bottom of the email to opt out of receiving future emails. Note that you will continue to receive transaction-related emails regarding products or Services you have requested. We may also send you certain non-promotional communications regarding us and our Services, and you will not be able to opt out of those communications (e.g., communications regarding our Services or updates to our Terms or this Privacy Policy).

We process requests to be placed on do-not-mail, do-not-phone, and do-not-contact lists as required by
applicable law.

• Text Messages. You may opt out of receiving text messages from us by following the instructions in the text message you have received from us or by otherwise contacting us.
• Mobile Devices. We may send you push notifications through our mobile application. You may opt out from receiving these push notifications by changing the settings on your mobile device. With your consent, we may also collect precise location-based information via our mobile application. You may opt out of this collection by changing the settings on your mobile device.]
• “Do Not Track.” Do Not Track (“DNT”) is a privacy preference that users can set in certain web browsers. Please note that we do not respond to or honor DNT signals or similar mechanisms transmitted by web browsers.
• Cookies and Interest-Based Advertising. You may stop or restrict the placement of Technologies on your device or remove them by adjusting your preferences as your browser or device permits. However, if you adjust your preferences, our Services may not work properly. Please note that cookie-based opt-outs are not effective on mobile applications. However, you may
  opt-out of personalized advertisements on some mobile applications by following the instructions for Android , iOS and others.

The online advertising industry also provides websites from which you may opt out of receiving targeted ads from data partners and other advertising partners that participate in self-regulatory programs. You can access these and learn more about targeted advertising and consumer choice and privacy by visiting the Network Advertising Initiative , the Digital Advertising Alliance , the European Digital Advertising Alliance , and the Digital Advertising Alliance of Canada . Please note you must separately opt out in each browser and on each device.

In accordance with applicable law, you may have the right to:

• Access Personal Information about you, including: (i) confirming whether we are processing your Personal Information; (ii) obtaining access to or a copy of your Personal Information, in a structured, commonly used, and machine readable format; and (iii) receiving an electronic copy of Personal Information that you have provided to us, or asking us to send that information
  to another company in a structured, commonly used, and machine readable format (the “right of data portability”);
• Request Correction of your Personal Information where it is inaccurate or incomplete. In some cases, we may provide self-service tools that enable you to update your Personal Information;
• Request Deletion of your Personal Information;
• Request Restriction of or Object to our processing of your Personal Information; and
• Withdraw your Consent to our processing of your Personal Information.

If you would like to exercise any of these rights, please contact us as set forth below. We will process such requests in accordance with applicable laws.
‍

9. Notice to California Consumers

Under California Civil Code Sections 1798.83-1798.84, California residents are entitled to ask us for a notice identifying the categories of Personal Information which we share with our affiliates and/or third parties for marketing purposes, and providing contact information for such affiliates and/or third parties. We do not share your Personal Information with third parties for the third parties’ direct marketing purposes unless you provide us with your express consent to do so.

Pursuant to the California Consumer Privacy Act of 2018 (“CCPA”), natural persons who are California residents have certain rights concerning their Personal Information held by us, as described below.

Personal Information Collection, Use, and Disclosure: The following table describes (i) the categories of Personal Information (as defined in the CCPA) we may collect about you; (ii) the sources from which that information is collected; (iii) the business and/or commercial purposes for collecting that information; and (iv) the categories of third parties to whom that information is disclosed.

FOR PURPOSES OF THE CALIFORNIA CONSUMER PRIVACY ACT, WE DO NOT AND WILL NOT SELL YOUR PERSONAL INFORMATION.
California Privacy Rights: To the extent provided for by law and subject to applicable exceptions, California residents have the following privacy rights in relation to the Personal Information we collect:

• The right to know what Personal Information we have collected and how we have used and disclosed that personal information;
• The right to request deletion of your Personal Information; and
• The right to be free from discrimination relating to the exercise of the foregoing privacy rights.

Exercising Your Rights: California residents can exercise the above privacy rights by emailing us at hello@usecanopy.com or calling us at 707-789-1110.

Verification: in order to protect your Personal Information from unauthorized access or deletion, we may require you to verify your login credentials before you can submit a request to know or delete Personal Information. If you do not have an account with us, or if we suspect fraudulent or malicious activity, we may ask you to provide additional Personal Information for verification. If we cannot verify your identity, we will not provide or delete your Personal Information.

Authorized Agents: you may submit a request to know or a request to delete your Personal Information through an authorized agent. If you do so, the agent must present signed written permission to act on your behalf and you may also be required to independently verify your identity with us.

10. Supplemental Notice for Nevada Residents

If you are a resident of Nevada, you have the right to opt-out of the sale of certain Personal Information to third parties who intend to license or sell that Personal Information. Please note that we do not currently sell your Personal Information as sales are defined in Nevada Revised Statutes Chapter 603A. For any questions, or to request that we do not sell your information in the future, please contact us as set forth below.

11. Children's Information

The Services are not directed to children under 13 (or other age as required by local law), and we do not knowingly collect Personal Information from children. If you are a parent or guardian and believe your child has uploaded Personal Information to our site without your consent, you may contact us as described below. If we become aware that a child has provided us with Personal Information in violation of applicable law, we will delete any Personal Information we have collected, unless we have a legal
obligation to keep it.

12. Amendment of this Privacy Policy

We reserve the right to change this Privacy Policy at any time. If we decide to change this Privacy Policy in the future, we will post or provide appropriate notice. The date on which the latest update was made is indicated at the top of this document. We recommend that you print a copy of this Privacy Policy for your reference and revisit this policy from time to time to ensure you are aware of any changes. Your continued use of the Services signifies your acceptance of any changes.

13. Contact Us

You can help by keeping us informed of any changes such as a change of email address or telephone number. If you would like to access your information, if you have any questions, comments or suggestions, if you find any errors in our information about you, or if you have a complaint concerning our compliance with applicable privacy laws, please contact us at hello@usecanopy.com or by mail at: Canopy Connect, Inc., 9450 SW Gemini Dr, PMB 37656, Beaverton, Oregon 97008 USA.

‍