July 2024

Elroi Privacy Statement

ELROI ONLINE PRIVACY STATEMENT

This Elroi Online Privacy Statement (“Privacy Statement”) describes the privacy practices of Elroi. This privacy statement explains the information we collect, how we collect it, how we use and share it, and the choices you can make regarding your information. Please note that all Elroi affiliates comply with their own policies, as we comply with our own.

INFORMATION WE COLLECT AND HOW WE COLLECT IT

Elroi collects personal information about you. Personal information is information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked (directly or indirectly) with you.We collect personal information about you in two ways. We collect personal information directly from you including when you purchase a service, subscribe to a membership or mailing list, set up an account with us or during the quoting, registering, or application process. We also collect personal information by browsing (e.g. weblaws) which occurs through surfing the web. We collect personal information such as IP address, browsing history and other internet activity information from you when you use our website, or otherwise engage with us through a computer or mobile device.

We collect the following categories of personal information:

PERSONAL INFORMATION CATEGORIES EXAMPLES




PERSONAL IDENTIFIERS
Name, alias, signature, postal address, phone number, fax number, date of birth, unique personal identifier, online identifier, email address, internet protocol (IP) address, state identification card number, insurance policy number, education, employment, credit card number, debit card number,or any other financial information, account name, Social Security number, driver's license number, passport number, physical illness, mental illness, disabilities, or other similar identifiers.

PERSONAL CHARACTERISTICS
Age, race, ancestry, national origin, citizenship, religion, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information) and other descriptions of your physical characteristics (e.g., height).


COMMERCIAL INFORMATION
Service or product related information including account name, account number, personal property,  payment history, records of products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies, account log-in, bank account number, credit or debit card number, or other payment or financial information.

BIOMETRIC AND MULTIMEDIA INFORMATION
Fingerprint, voice print, retinal print, scan of hand or facial geometry, audio, electronic, visual or similar information.

INTERNET OR OTHER ELECTRONIC NETWORK ACTIVITY INFORMATION
Browsing history, search history, information regarding your interaction with our website, application or advertisement, links you use or web pages you visit while visiting our site or applications, browser type, internet service provider (ISP), cookies, and mobile device information including device identifier or other information.


GEOLOCATION DATA
Physical location, movements, or trip tracking information.


PROFESSIONAL OR EMPLOYMENT INFORMATION\
Employment history, union membership, some contents of mail, e-mail and text messages on company devices, applications or communication platforms.


EDUCATION INFORMATION
Education records, grades or transcripts.

INFERENCES

Inferences drawn from any personal information collected to create a profile reflecting preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities and aptitudes.


Sensitive Personal Information: Some personal information we collect is defined under the law as sensitive personal information. Sensitive personal information we collect includes Social Security number, driver’s license number, state identification card number, passport number, customer account log-in, financial account number, debit card number, credit card number in combination with any required security or access code, password, or credentials allowing access to an account, precise geolocation information, racial or ethnic origin, religious beliefs, union membership, genetic data, biometric information used for identification, personal health information and sexual orientation.

USE OF YOUR PERSONAL INFORMATION We use your personal and other information for business purposes including to:
Provide and maintain your services and products. We may use your personal information to provide or maintain your service, products, or membership including to set up a product or service or provide a product or service, maintain your account, handle a claim, complete a transaction, repair a product or respond to customer service requests or other inquiries.

We may also collect information about other parties from you to carry out necessary services and/or requests, including adding another driver to your existing policy. If you provide us personal information about others, or if others give us your personal information, we will only use the information for the specific reason for which it was provided to us.

Improve, develop and analyze our Sites, services and products. We use your personal information and other information to:analyze, improve, develop or deliver our Sites, products and services and develop new services, products or features using algorithms, analytics software and other similar methods,conduct actuarial or research studies to maintain, protect and develop our networks, services, and products and protect our customers, andanalyze how visitors use our Sites to improve the Sites and enhance and personalize your experience.We collect some information used for these purposes using analytics software, cookies and other tracking technologies. For more information about the collection and use of this information, see Other Tracking Technologies below

.• Communicate with you about your service or product. We may communicate with you about your product, service, account, policy or membership, provide you transaction confirmations, payment alerts or other service or product related messages via mail, email or other available methods such as push notifications.

Provide marketing communications. We may use your personal information to send you promotional communications about products, services, and features, and options we believe may interest you. We may send communications via email, regular mail or may send push notifications via a mobile device. We may also use your information to serve you ads or customized content online.

Comply with legal requirements and protect the safety and security of our business, services, and Sites. We may use your personal information to comply with laws, regulations or other legal obligations, to assist in an investigation, to protect and defend our rights and property or the rights of third parties or enforce terms and conditions. We may also use your personal information to prevent suspected fraud, threats to our network or other illegal activities, prevent misuse or for any other reason permitted by law.

• Update or correct our records. We may receive personal information about you from other sources, including publicly available databases or third parties from whom we have purchased data,and combine that personal information with other personal information we have about you to update our records. For example, we may obtain change of address information from public sources and use that personal information to update or correct your address.

• Find locations on request. Your location may be obtained from the mobile device or the network using your device’s Global Positioning System (GPS) functionality or directly from you. We may use your location information to search for an agent, searching for a service provider, identifying the location of an breach event you are reporting. We use sensitive personal information only as reasonably necessary to perform or maintain the services or provide goods you requested, to perform services on behalf of the business such as maintaining or servicing accounts, processing payments, to provide analytics services or similar services, to detect security incidents, resist malicious, deceptive, fraudulent, or illegal actions and to prosecute those responsible for those actions, to ensure customers and other peoples’ physical safety, for short- term use such as non-personalized advertising as part of our current interactions, to verify or maintain the quality or safety of service, improve, upgrade or enhance service, or other reasons that do not require an opt-out of this use.We do not market any products or services to children under the age of thirteen or knowingly collect any information from children under the age of thirteen. We do not knowingly sell or share for cross-contect behavioral advertising the personal information of consumers under the age of sixteen. Our website is not intended for children.

SHARING YOUR INFORMATION
We do not sell your personal information. We also do not share personal information for cross-context behavioral advertising as defined under California law. We may share your personal information with our affiliates for business purposes consistent with the uses described in this Privacy Statement. We may also share personal information about you with third parties whenever you consent to or direct such sharing. We strive to work with companies that share our commitment to privacy. We may also share information with others in an aggregated or de-identified form that does not reasonably identify you.

We may also share any of the categories of personal information described above with service providers and other third parties for business purposes or as required or permitted by law including with:

Service providers: Personal information may be shared with service providers who perform services on our behalf for a business purpose including service providers that: help complete transactions, handle a claim, or service your membership, engage in credit reporting or payment processing,provide marketing and advertising, email or other communication services, provide services that support our online activities including providing tracking technologies, web hosting and analytics, provide tax and accounting, legal services, delivery, and data enhancement services,provide technology services and enhance security, privacy and fraud protections, provide data analytics services or conduct research or actuarial studies, and,provide support to our operations.

Marketing and advertising partners: We may share personal and other information with third party online and other marketing and advertising partners or permit these partners to collect personal information from you directly on our Sites to personalize online advertising. We may share personal information with other financial institutions or other companies with whom we have a joint marketing agreement. The Other Tracking Technologies section below has more details about these activities.

Third parties in connection with a business transaction: Personal information may be disclosed to third parties in connection with a corporate transaction, such as a merger, sale of any or all of our company assets or shares, reorganization, financing, change of control or acquisition of all or a portion of our business by an affiliate or third party, or in the event of a bankruptcy or similar proceedings.

Law enforcement, regulators and other parties for legal reasons: Personal information may be disclosed to third parties, as required by law or subpoena, or if we reasonably believe such action is necessary to:comply with the law and the reasonable requests of regulators, law enforcement or other public authorities, protect our or others safety, rights or property, and investigate fraud or to protect the security or integrity of our Sites or any product or services.

HOW LONG WE KEEP YOUR INFORMATION - We retain personal information for the useful life of the product or until you determine you no longer want the data to be retained. Furthermore, we retain personal information in accordance with applicable laws or regulatory requirements and also for as long as necessary to fulfill the purposes for which it was collected and to fulfill the business or commercial purposes that are explained in this Privacy Statement.

OTHER TRACKING TECHNOLOGIES



When you visit our Sites, we and our service providers automatically collect information about your use of and access to these Sites. We collect this information through a variety of tracking technologies, including weblaws, flash objects, web beacons (also called pixel tags), embedded scripts, location-identifying technologies, and similar technology (collectively, “tracking technologies”). Information we collect automatically about you may be combined with other personal information we collect directly. The information collected in this manner includes:The website from where you accessed our Sites, where you went to when you left our Sites, how frequently you visit out Sites, your location when you access our Sites, when and whether you open emails or click the links contained in emails, pages you visit and ads you view on our Sites, recording of mouse clicks, mouse movements, keystrokes, and other communications you make on our Sites,Information about the computer, tablet, smartphone or other device you use such as your IP address, browser type, Internet service provider, platform type, device type/model/manufacturer, operating system, date and time stamp, a unique ID that allows us to uniquely identify your browser, mobile device or your account (including, e.g., a persistent device identifier or an Ad ID), and other similar information,Analytics information collected by us or via third party analytics tools, to help us measure traffic and usage trends for the Sites and to understand more about the demographics and behaviors of our users, andHow often you use a mobile app, from where the app was downloaded, events that occur within the app, aggregated usage, and performance data. The information collected through tracking technologies allows us to provide you with an improved, enhanced, and personalized customer experience, to monitor and improve our Sites and for other internal purposes such as: Remembering information so that you will not have to re-enter it during your visit or the next time you visit our Sites,Provide custom, personalized content and information, including targeted content, communications and advertising, Identify and contact you across multiple devices, Provide and monitor the effectiveness of our Sites, Perform analytics and detect usage patters on our Sites, Diagnose or fix technology problems, Detect or prevent fraud or other harmful activities, and Otherwise to plan for and enhance our Sites.


Targeted online advertising and do not track: We or our marketing and advertising service providers may use information about your activities on our Sites or other websites, to help tailor our advertisements or offers to what may interest you — also called interest-based advertising. The information is collected using the tracking technologies explained above.You may continue to see generic or non-targeted ads about our products and services if you opt-out of interest-based advertising. Although we do our best to honor the privacy preferences of our visitors, we are currently not able to respond to “Do Not Track” signals from your browser.

PRIVACY RIGHTS AND CHOICESVarious federal and state laws provide privacy rights to consumers including the right to know, access, delete, or correct personal information, the right to opt-out of sharing of personal information with affiliates for marketing or the right to opt-out of receiving email marketing. These rights differ by state and also by the type of products and services you have with Allstate. For example, the rights to know, access, delete or correct under the California Consumer Privacy Act (CCPA) do not apply to personal information that is subject to certain federal and state laws governing insurance or health information.

When you visit our Sites, we and our service providers automatically collect information about your use of and access to these Sites. We collect this information through a variety of tracking technologies, including weblaws, flash objects, web beacons (also called pixel tags), embedded scripts, location-identifying technologies, and similar technology (collectively, “tracking technologies”). Information we collect automatically about you may be combined with other personal information we collect directly. The information collected in this manner includes:The website from where you accessed our Sites, where you went to when you left our Sites, how frequently you visit out Sites, your location when you access our Sites, when and whether you open emails or click the links contained in emails, pages you visit and ads you view on our Sites, recording of mouse clicks, mouse movements, keystrokes, and other communications you make on our Sites,Information about the computer, tablet, smartphone or other device you use such as your IP address, browser type, Internet service provider, platform type, device type/model/manufacturer, operating system, date and time stamp, a unique ID that allows us to uniquely identify your browser, mobile device or your account (including, e.g., a persistent device identifier or an Ad ID), and other similar information,Analytics information collected by us or via third party analytics tools, to help us measure traffic and usage trends for the Sites and to understand more about the demographics and behaviors of our users, andHow often you use a mobile app, from where the app was downloaded, events that occur within the app, aggregated usage, and performance data. The information collected through tracking technologies allows us to provide you with an improved, enhanced, and personalized customer experience, to monitor and improve our Sites and for other internal purposes such as: Remembering information so that you will not have to re-enter it during your visit or the next time you visit our Sites,Provide custom, personalized content and information, including targeted content, communications and advertising, Identify and contact you across multiple devices, Provide and monitor the effectiveness of our Sites, Perform analytics and detect usage patters on our Sites, Diagnose or fix technology problems, Detect or prevent fraud or other harmful activities, and Otherwise to plan for and enhance our Sites. Targeted online advertising and do not track: We or our marketing and advertising service providers may use information about your activities on our Sites or other websites, to help tailor our advertisements or offers to what may interest you — also called interest-based advertising. The information is collected using the tracking technologies explained above.You may continue to see generic or non-targeted ads about our products and services if you opt-out of interest-based advertising. Although we do our best to honor the privacy preferences of our visitors, we are currently not able to respond to “Do Not Track” signals from your browser.

PRIVACY RIGHTS AND CHOICESVarious federal and state laws provide privacy rights to consumers including the right to know, access, delete, or correct personal information, the right to opt-out of sharing of personal information with affiliates for marketing or the right to opt-out of receiving email marketing. These rights differ by state and also by the type of products and services you have with Allstate. For example, the rights to know, access, delete or correct under the California Consumer Privacy Act (CCPA) do not apply to personal information that is subject to certain federal and state laws governing insurance or health information.

Email Marketing Choices and Other Notifications:
We may send you email marketing communications about products, features and services that may be of interest to you. To opt out from receiving marketing and promotional emails from us, please send us a request by email at @Elroi.com or click the unsubscribe link located at the bottom of each communication. If you opt out from receiving marketing emails, we may still send you non-marketing emails such as emails about your products or services, responses to your requests and inquiries, or notices of updates to terms and conditions or our privacy practices.

ELROI CUSTOMER’S RIGHTS AND CHOICES Elroi customer’s right to access, review and correct personal information: Elroi customers can request to see or access their recorded personal information at any time. To do this, please email us at team@Elroi.com. When sending your initial email, include only your name, state of resident, and the nature of your request; do not send any additional personal information. Proper identification may be required to fulfill the request. If you believe our information is incomplete or inaccurate, you can request that we correct it and we will make corrections if possible. Please note we may not be able to provide information relating to investigations, claims, litigation, and other matters. We will respond to all such requests within a reasonable time. We can’t change information provided to us by other companies like consumer reporting agencies. You will have to contact them directly.You may also update, delete or modify your account profile information at any time by logging into your online account and making updates, or you may call us or contact your agent to correct the information.

Personal Information Sharing Preferences: We would like to share your personal information with one or more Elroi affiliates in order to make you aware of different products,services and offers they can provide. However, please note that while we appreciate participating in our affiliate communities, we are a solo legal entity and therefore do not share the same privacy policy as them. For more information about Elroi’s affiliates, see the Afficilates section at the end of this Privacy Statement. To request that we not allow other Elroi affiliates to use your personal information to market their products and services, please contact us at team@Elroi.com. Please keep in mind that it may take up to four weeks to process your request. If you previously contacted us and asked us not to allow other Elroi affiliates to use your personal information, your previous choice still applies, and you do not need to contact us again. If you would like to change your previous choice, please call the number above at any time.

STATE SPECIFIC PRIVACY RIGHTS AND CHOICES

California, Virginia and Connecticut Residents: California residents have certain rights under California Consumer Privacy Act (CCPA) to access, correct and delete personal information, and other rights described below. Similar rights exist for Virginia and Connecticut residents for some of the personal information we collect. While these rights apply only to some of the personal information we collect, for transparency and for your convenience, you can submit a request no matter where you live.

Right to Know and Access Your Personal Information: You have the right to request the specific pieces of personal information we have collected about you and the right to know: The categories of personal information we’ve collected, The categories of sources from which personal information was collected, The business or commercial purposes for collecting the personal information, and The categories of third parties with whom we disclose or share personal information.

Right to Deletion of Personal Information: You have  the right to request deletion of personal information collected from you, subject to certain exceptions including that we need the personal information to: Complete a transaction or provide a good or service you requested, service your account, or take actions reasonably anticipated within the context of our ongoing business relationship. Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities,Comply with a legal obligation, orOtherwise use your personal information, internally, in a lawful manner that is compatible with the context in which you provided the information.

Right to Correct Personal Information: You have the right to request we correct any inaccurate information we have about you. We may request that you provide documentation to support your request and we will correct your information unless we determine that the personal information is more than likely accurate.

Non-Discrimination Rights: We don’t discriminate against you if you exercise any of the privacy rights described in this privacy statement.

Verified Requests: To protect you and your personal information, we will only respond to access or deletion requests that we have been able to properly verify through our authentication processes. To verify your identity, you will be asked to provide several pieces of personal information, such as name and demographic information, which we only use to verify your identity or authority to make the request.

Submitting a Request:
To submit an access or deletion request, please email team@Elroi.com to submit an online request. To submit a correction request, please email team@Elroi.com to submit an online request. Responses to a verified request may take up to 45 calendar days, or longer depending on the nature of the request. If additional time is needed, we will notify you of the additional time. We may only respond to two access requests within a 12-month period. Requests from authorized agents must be submitted via the same email but to protect your privacy, consumers will be required to verify their identity directly with us via email.


You have the right to correct inaccuracies in any personal data provided to us, the right to opt out of your data being used for targeted advertising, sold, or specific profiling purposes, the right to confirm whether we are processing your personal data, to access that data, and to request the deletion of personal data collected or provided to us.

SOCIAL MEDIA, LINKS AND EXTERNAL SITESLinks to other company’s websites may be provided on the Elroi Sites as a convenience to you. If you choose to go to these external websites, you will be subject to the privacy practices of those external websites; Elroi is not responsible for the privacy practices of those websites. We encourage you to be aware when you leave our Site to read the privacy policies or statements of every website you visit, as those privacy policies or statements may differ from ours. Our Privacy Statement applies solely to the Sites where this Privacy Statement appears.

INTERNAL SITES Please note that all internal sites built by Elroi will reflect these privacy rights. These include our dashboards and other internal sites not directly linked to our Elroi website.

SECURITY
Protecting your personal information is important to us. We use a combination of reasonable technical, administrative, and physical safeguards to protect your personal information. However, no website, mobile application, database or system is completely secure or “hacker proof.” So, we cannot guarantee its absolute security. You are also responsible for taking reasonable steps to protect your personal information against unauthorized disclosure or misuse.We limit access to your personal information to those who need it to do their jobs. We comply with all applicable federal and state data security laws.CONTACT USIf you should have questions or concerns about our privacy practices, please contact us at team@Elroi.com.

CHANGES TO OUR PRIVACY STATEMENT
We may periodically update or revise this Privacy Statement. The effective date at the top of the document shows when this Privacy Statement was last revised. We will let you know when we update the Privacy Statement by changing the date or other appropriate means.

ELROI AFFILIATES This Privacy Statement describes the privacy practices of Elroi. This Privacy Statement does not apply to any of Elroi’s Affiliates. Elroi’s Affiliates are: (please list).