Our Commitment To Safeguarding Your Privacy

This Joint Privacy Notice is being provided to you to inform you of our practices and procedures regarding the sharing of nonpublic personal information. Nonpublic personal information is personally identifiable financial information about you, your family, or your household that we may obtain directly from you, that we may obtain as a result of our business dealings with you, or that we may obtain from any other source.

We do not engage in the practice of disclosing your nonpublic personal information to nonaffiliated third parties other than, as necessary, to provide quality insurance services to our customers. For instance, we do not sell your name, address or telephone number to telemarketers or to direct mail solicitors. We do not engage in "list-selling," and we do not offer your personal information to publishing houses, retailers, or coupon companies.

During the continuation of our customer relationship with you, we will also provide you with a copy of this Joint Privacy Notice at least once during each calendar year as part of a regular mailing, such as within a billing or a renewal notice or with a policy and at any time that you request in writing a copy of this Joint Privacy Notice. Further, bec ause Federal and state laws, regulations and business practices can change at any time, we may revise this Joint Privacy Notice accordingly. Once you cease to be a policyholder, we will stop sending you annual privacy notices.

Star Casualty Startrac – Mobile Application Privacy Policy

Star Casualty Insurance Company (we, our, us) are committed to protecting and respecting your privacy. This policy (together with our end user license agreement and any other documents referred to in it) sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us. Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it. By downloading StarTrac app via either Apple’s App Store or the Google Play Store, you are accepting and consenting to the practices described in this policy.

1. WHO ARE WE?

Your personal data, any information which identifies you, or which can be identified as relating to you personally, will be collected and used by Star Casualty Insurance Company.

2. THE DATA WE COLLECT FROM YOU

2.1. Information you give us. When you download and use the App (or contact us in respect of the App), we may collect any or all the following information about you: Personal details (Email address, phone number, name, region, age range & gender).

2.2. Data we collect automatically. When you install and run the App, we may collect any or all the following technical data: Device Identifies the internet protocol address used to connect your device to the internet, your login information, browser type and version, regional settings, operating system, and platform); Data about your use of the App; Information stored on your device; Location information. We use GPS technology to determine your current location; Data about your driving, acceleration, braking, speed, journey times; and Data about when you make and receive phone calls, send, and receive text messages on your device.

2.2.1 If you weren’t the driver for a trip or your phone was used by others in the vehicle during a trip, you may change the trip tag by clicking on the button “I was not driving” which automatically shows up at the end of each trip.

2.3 Right to request deletion off the app.Your written request must include your full name, mailing address, and policy number (if applicable), state that your request is in response to this Privacy Policy, and identify the specific Personal Information you want us to correct, amend, or delete.Please email us at agencysupport@starcasualty.com.

3. COOKIES

3.1. What cookies are and how we use them. Cookies are small data files which we place on your device. We use cookies to distinguish you from other users using the App. This helps us to provide you with a good experience when you use the App and helps us to improve the App.

4. HOW WE USE YOUR PERSONAL DATA

4.1. The purpose of processing your personal data. You have asked us to process your personal data for the purpose of analyzing your driving habits and calculating a driving “score” which may then be used: (i) by you for your own purposes; (ii) by us to determine the results of any prize competitions that you may enter that are run by us; and (iii) by us for improving our services and operations, developing new services and offerings, and other research, data science, analytics and related purposes. None of the data that is collected will be used to calculate insurance premiums, or for any other insurance purpose.

4.2. How your personal data is used. We only ever use your personal data with your consent, or where it is necessary in order to: Enter into, or perform, a contract with you; Comply with a legal duty; Protect your vital interests; Remember your preferences, for example, if you ask not to receive marketing material, we’ll keep a record of this; or For our own or a third party’s lawful interests, provided your rights don’t override these.In any event, we’ll only use your personal data for the purposes for which it was collected, or purposes which are very similar.

4.3. Withdrawing your consent. You can withdraw your consent at any time to our processing of your personal data for any purpose at any time, by contacting us at the email or postal address set out in paragraph 8.

4.4. Re-enrollment. If you have removed your enrollment in the program, and are interested in re-enrolling, please contact your agent who will set up the process to re-enroll you in the program.

4.5. Re-scoring. Once there is a qualified score obtained, the score will be used with every renewal policy term. However, if you like to get a fresh, updated score, you have the option to get re-scored. Please contact your agent to get set up for a re-score.

4.6 How Anonymous Data may be used. For this paragraph 4.6 “Anonymous Data” means data that has been de-identified and/or aggregated with other data to such an extent that you are no longer identified, identifiable or otherwise ascertainable by reference to such data or in combination with other datasets. We will maintain Anonymous Data as part of our own records and information and may share Anonymous Data with third parties. Anonymous Data may be used by us (and shared with third parties) for certain legitimate business purposes including operating and improving our services and operations, developing new services and offerings, and other research, data science, analytics, and related purposes.

5. HOW WE PROTECT YOUR PERSONAL DATA

5.1. Technical and organizational measures. We employ a variety of physical and technical measures to keep your personal data safe and to prevent unauthorized access to, use or disclosure of it. Electronic data and databases are stored on secure computer systems, and we control who has access to them (using both physical and electronic means). Our staff receive data protection training, and we have a set of detailed data protection policies and procedures which personnel are required to follow when handling personal data. We cannot absolutely guarantee the security of the internet or external networks and any online communications, for example, information provided by email or through our website are at your own risk.

5.2. Device security. You are fully responsible for access to your device. You undertake not to allow unauthorized third parties to use your device for any reason whatsoever. You undertake to contact us as soon as possible should you suspect that an authorized person has gained access to your device. We shall not be held liable for any misuse of your device and any resulting consequences for you, your partner, or any third party.

6. WHO CAN ACCESS YOUR PERSONAL DATA

We will not communicate, sell, or transfer your personal data to third parties without obtaining your prior written consent, except where we are required to do so by law. We may share personal data with subcontractors or suppliers who provide us with services. However, these activities will be carried out under a contract which imposes strict requirements on our subcontractors or suppliers to keep your information confidential and secure.

7. STORAGE OF PERSONAL DATA

7.1 Where it is stored. We only store data on servers located within the United States.

7.2. How long it is stored for. The data will be stored and kept for as long as your App remains active. Following deactivation of the App or if you do not use the App for a period of at least six months or as required by the applicable regulations in the state. We continually review the personal data we hold and delete what is no longer required.

8. YOUR RIGHTS

We want to ensure you remain in control of your personal data. Part of this is making sure you understand your legal rights, which are as follows: The right to confirmation as to whether or not we have your personal data and, if we do, to obtain a copy of it, this is known as a subject access request, within one month of our receiving your request; The right to have your data erased, though this will not apply where it is necessary for us to continue to use the data for a lawful reason; The right to have inaccurate data rectified; The right to object to your data being used for marketing or profiling; and Where technically feasible, you have the right to see any personal data you have provided to us which we process automatically on the basis of your consent or the performance of a contract. This information will be provided in a common electronic format. If you would like further information on your rights or wish to exercise them, please write to us at marketing@starcasualty.com

Information We May Collect And Use

During the course of reviewing your application for insurance coverage and deciding whether or not to underwrite the insurance policy for which you have applied, and, if we issue you a policy, during the course of providing services to you as required by the policy, we collect and evaluate information from the following sources:

• Information we receive from you on applications or other forms;
• Information about your transactions with us, our affiliates or others;
• Information we receive from consumer reporting agencies; and
• Information we receive from a state or federal agency.

It is important for us to collect and use this information to properly provide, administer, and perform services on your behalf. We could not provide optimum service to you without collecting and using this information.

Information We May Disclose

We regard all of your personal information as confidential. Therefore, we do not disclose any nonpublic personal information about our customers or former customers to anyone except as permitted by law. In the course of conducting our business dealings, we may disclose to other parties certain information we have about you. These disclosures are only made in accordance with applicable laws, and may include disclosures to reinsurers, administrators, service providers, consultants and regulatory or governmental authorities. Furthermore, certain disclosures of information will be made to your Star Casualty insurance agent and any Star Casualty personnel authorized to have access to your personal information for the purpose of administering your business and providing services to you.

We may disclose the following categories of information to companies that perform services on our behalf or to other financial institutions with which we have joint marketing agreements:

• Information we receive from you on applications or other forms, such as your name, address, social security number or county.
• Information about your transactions with us, our affiliates or others, such as your policy coverage, premium, loss history and payment history; and
• Information we receive from a consumer reporting agency, such as your creditworthiness and credit history.

These entities with which we share personal information are required to maintain the confidentiality of that information. We do not authorize these parties to use or disclose your personal information for any purpose other than for the express purpose of performing work on our behalf or as required or permitted by law.

How We Maintain The Confidentiality And Security Of Your Information

We carefully restrict access to non-public personal information to our employees, our independent contractor insurance agents, our service contract providers, and our affiliates and subsidiaries. The right of our employees, our independent contractor insurance agents, our service contract providers, and our affiliates and subsidiaries to further disclose and use the information is limited by our employee handbook, agent's manual, applicable law, and non-disclosure agreements where appropriate. We maintain physical, electronic, and procedural safeguards that comply with federal and state law to guard your non-public personal information.