Effective Date: June 6, 2016
General Information
PLEASE READ THIS PRIVACY STATEMENT AND NOTICE OF PRIVACY PRACTICES CAREFULLY.
This Privacy Statement and Notice of Privacy Practices ("Privacy Policy") sets forth the privacy practices of Asurion Canada, Inc., Asurion, LLC and/or their subsidiaries and affiliates (collectively "Asurion"). This Privacy Policy is applicable to all data collection by Asurion, (excluding mobile applications and related mobile application Services) and shall apply to the user's ("You" or "Your") use of this website, Your use of any affiliated third party websites that may contain a link to this Privacy Policy, or to any pages, facilities, Services, or capabilities accessible on or by any top-level Asurion domain owned by us or any subsite, subdomain, subdirectory, virtual site, or virtual directory thereof (each, a "Site" and collectively the "Sites").
In this Privacy Policy, "personal information" has the same meaning as used in the Personal information Protection and Electronic Documents Act (Canada).
This Privacy Policy shall apply strictly to the personal information of our customers located in Canada. This Privacy Policy describes how Asurion treats Your use of the Sites, including the collection, storage, use, transfer, sharing, disclosure and handling of Your personal information and Your use of our Products and Services which we define below in this Privacy Policy.
This Privacy Policy does not apply to:
- (i) any of our Products or Services that do not display or link to this Privacy Policy or that have their own individual Privacy Policy;
- (ii) information we collect from You or about You in other ways including through emails You may choose to send us; or
- (iii) Your use of our mobile applications or the Services associated with those mobile applications. The Privacy Policy for our Mobile Applications and Service is accessible through Your mobile application.
By using our Products or Services, You acknowledge that You have read this Privacy Policy and consent to Asurion's privacy practices as described in the Privacy Policy, including our collection, use and disclosure of Your personal information for the purposes described below. You further affirm Your consent by submitting content or materials to or through our Services or when You purchase our Products.
We take the privacy of Your personal information seriously. If You have any questions or concerns about this Privacy Policy or Your personal information please contact us directly at privacy@asurion.com or by mail at:
Asurion Canada, Inc.
c/o Office of the General Counsel
648 Grassmere Park
Nashville, Tennessee, USA 37211
This Privacy Policy notifies You of:
PRIVACY POLICY TABLE OF CONTENTS:
- 1. Changes and updates to this privacy policy
- 2. Contact and electronic communication
- 3. Description of our products and services
- 4. Types of information collected and how it is collected
- 4.1. Personal Information we request from you
- 4.2. Other types of information we collect
- 5. Retention and deletion of personal information
- 6. Use of personal information
- 7. Sharing and disclosure of personal information
- 8. Accuracy and completeness of Your information
- 9. Access to and ability to correct or delete Your information
- 10. Third party sites
- 11. Children under 13
- 12. Security of information
- 13. Credit card processing and data security
- 14. Social Media
- 15. International users
- 16. Monitoring and enforcement
1. CHANGES AND UPDATES TO THIS PRIVACY POLICY
Asurion reserves the right to revise or update this Privacy Policy at any time, and You agree to be bound by those revisions or updates. Asurion will notify You of any changes to the Privacy Policy by posting the revised or updated Privacy Policy and its "Last Modified" date on the Sites.
Your use of the Sites thereafter constitutes Your agreement to and acceptance of the Privacy Policy and its revisions or updates. You should periodically read the Privacy Policy to learn of any revisions or updates. In the event we materially change the way in which we use Your personal information, we will provide You with notice and ask You to affirmatively accept the changes to a new Privacy Policy. This Privacy Policy is incorporated as part of the Terms of Service that apply with respect to Your use of the Sites and our Products and Services, which we define below in this Privacy Policy.
If You do not agree to the terms and conditions of this Privacy Policy, including having Your personal information used in any of the ways described in this Privacy Policy please do not provide us with Your information.
If You do not agree to any terms of our Privacy Policy, please do not use the Sites.
2. CONTACT AND ELECTRONIC COMMUNICATION
When purchasing our Products, using our Services or providing Your personal information to us, we will only communicate with You electronically regarding any legal, regulatory, technical, security, privacy, and any administrative or consumer notification obligations that may be related to Your use of the Products and Services. We will comply with all local laws and regulations. If You have any questions about this Privacy Policy or about our Products or Services related to the Privacy Policy, or want to request access to, correction or deletion of Your personal information, You can contact Asurion by e-mail at privacy@asurion.com.
You may also contact us at:
Asurion Canada, Inc.
c/o Office of the General Counsel
648 Grassmere Park
Nashville, Tennessee, USA 37211
3. DESCRIPTION OF OUR PRODUCTS AND SERVICES
We are a technology company. When You call us, You'll talk to people with the patience and experience to genuinely help. We understand what it's like to spill water on a cell phone or a have a hard drive crash on a term paper. We replace. We fix. We find. We solve. We keep You in the game. We are Asurion. Life's Operating System™. Asurion is the industry-defining leader of technology solutions, ensuring 300 million consumers' connected devices and connected appliances stay online and on the job. Asurion offers comprehensive mobile device protection insurance through its various Sites and through its mobile applications to best serve its customers.
Asurion provides its customers with the ability to file warranty claims, register products and locate lost devices through its Sites. Asurion provides delivery and installation of smart appliances, consumer electronics, advanced consumer technologies and other consumer products offering delivery, set up, installation, explanation of user guides and installation materials. These offerings are defined under this Privacy Policy collectively and individually as our ("Products" and "Services").
4. TYPES OF INFORMATION COLLECTED AND HOW IT IS COLLECTED
The types of information we collect from You when You access our Sites or use our Products and Services are listed below. Asurion may share both Your Information with its affiliates, subsidiaries, partners and other third parties, such as third parties who help operate the Sites and its related databases. Asurion requires such organizations to comply with the requirements set out in this Privacy Policy and to keep Your personal information confidential and secure. We collect information directly from You, through use of our Sites, Products, or Services, or from third parties that work with Asurion to deliver our Products and Services.
4.1. PERSONAL INFORMATION WE REQUEST FROM YOU
Certain areas of the Sites (filing claims, registering products, etc.) will require You to provide personal information to Asurion. That personal information may include Your name, phone number, home e-mail address, credit card details, username, password, claim ID, date of log-in, any details provided by You explaining circumstances under which You are requesting assistance or information from Asurion, or similar information.
As part of the claim process, Asurion or its affiliates may require You to provide a copy of Your driver's license, passport, or other personal identification card in order to identify that the claim is valid and to protect You from fraudulent claims.
Additionally, in order to process Your claim and complete Your transaction, Asurion or its affiliates may request Your shipping and billing information, credit card information, or other preferred payment means.
It is Your choice whether to provide the requested personal information but Asurion cannot provide certain Services You request if You do not provide the requested personal information. By submitting this personal information to Asurion, You agree that Asurion may use Your personal information in accordance with this Privacy Policy, for example to register and Service Your warranty, process Your requests, adapt and improve Asurion Services to better suit Your needs, provide benefits entitled to You, and to meet regulatory or contractual requirements relating to the Services provided to You. If You do submit such personal information to Asurion, Asurion may share that personal information with other affiliates in the Asurion corporate family and third parties, in addition to using that personal information for the purposes for which it was submitted by You.
Asurion may also use Your personal information in other ways, such as to provide You with marketing information about Products, Services and offers that may be of interest to You, to seek follow-up from You about Your experiences with Asurion, or as otherwise disclosed to You at the point of collection. Where required, Asurion will seek Your express consent to send such marketing materials.
This marketing consent is sought by Asurion Canada, Inc. and Asurion, LLC and other members of the Asurion corporate family. You may withdraw Your consent to receipt of marketing materials by using the "unsubscribe" link located at the bottom of any electronic messages You receive from Asurion.
Where any messages are sent to You by email, social media, or other type of electronic medium, Asurion will seek Your prior express consent.
Asurion may share Your personal information with its affiliates, subsidiaries, and partners, and with other third parties for similar purposes. Additionally, to the extent required by applicable federal, provincial or local law, Asurion will provide Your personal information to others without seeking Your consent. By submitting personal information to Asurion, You give Asurion permission to receive it, review it, edit it, store it, and use it for the purposes described in this Privacy Policy.
Your personal information will be sent to Asurion entities and third party service providers located in the United States and the Philippines and may be seen by foreign governments or their agencies.
4.2. OTHER TYPES OF INFORMATION WE COLLECT
Asurion also gathers certain information about the use of Asurion's Sites, including the number of unique visitors, the frequency of visits, how users interact with the Sites, user experience preferences, IP address, and other information that may help Asurion improve customer experience, mitigate fraudulent activity, and comply with legal requirements. Such information may include, but is not limited to the following:
Log Information
When You visit Asurion's Sites we automatically collect and store certain information in our server logs. This type of information includes details of how You interacted with our Sites, Services, or applications. It may include information such as: IP address, Unique Device Identifier, or Caller ID / ANI (Automatic Number Identification) information, content of web pages, transaction with APIs (Application Program Interface), transactions with IVR (Interactive Voice Response) systems, activity and content of visitor interaction with call center representatives; application usage activity, hardware information, hardware and system settings, browser type, browser language, the date and time of Your request, referral URL, etc.
Cookie
A cookie is a small, data file that is managed by Your web browser or other application and stored on Your local system. Asurion uses session and persistent cookies to, among other things, identify Your computer during a particular interaction and analyze Your behavior during a particular visit. Most web browsers provide You with the ability to accept or decline cookies, as well as to be warned each time a cookie is being sent. If You choose to decline cookies, You may not be able to fully use Asurion's Sites, services, or applications.
Pixel Tags
Pixel tags, also known as web beacons, help Asurion better manage user experience and content tracking. Pixel tags are tiny graphics with a unique identifier, which provide a similar function to cookies and are used to track user interaction with content provided by Asurion or an affiliate organization. In contrast to cookies, which are stored on a user's computer hard drive, pixel tags are embedded invisibly within content. The small size and transparency of pixel tags are not intended to deceive content recipients, but minimize distraction.
Third Party Data Sources
Asurion may leverage external data sources in order to provide context and background on the users of its sites, services, or applications in order to improve customer experience, mitigate fraud or malicious activity, or comply with internal company and external regulatory requirements.
Do Not Track and Third Party Advertising Cookies
Do-Not-Track is a public-private initiative, http://www.w3.org/2011/tracking-protection/, that has developed a technical "flag" or signal that an end-user may be able to activate within their browser software to notify websites that they do not wish to be “tracked” by third parties as defined by the initiative. The initiative, however, has not reached a consensus as to exactly what technical or other actions those parties receiving the signal should take. As a result, Do-Not-Track has not yet been standardized and most websites, including Asurion, do not alter their behavior or change their services when they receive a "do-not-track" flag or signal. You can, however, make decisions about Your privacy and the advertisements You receive. Asurion may utilize online behavioral advertising on the Sites in the future.
As an alternative to the DAA opt-out, You can also elect to block all cookies from first parties (such as Asurion) and from third parties (such as entities involved in advertising) by using the cookie blocking options built into Your browser software. Please note, however, that if You do decide to block cookies, some parts of Asurion's Sites may not function correctly.
5. RETENTION AND DELETION OF PERSONAL INFORMATION
Asurion will retain Your personal information for as long as necessary to fulfill the purpose(s) for which it was collected and to comply with applicable laws, and Your consent to such purposes(s) remains valid with respect to claims data and to file claims related to insurance coverage after termination of Asurion's relationship with You. When personal information is no longer needed or legally required, it will be permanently deleted or de-identified so that it can no longer be associated with a specific individual.
6. USE OF PERSONAL INFORMATION
In addition to any of the previously mentioned uses of personal information, Asurion may use Your information collected on the Sites for such purposes as:
- helping to establish and verify Your identity;
- activating and maintaining Your account;
- to the extent that Your telecommunications carrier does not provide such services, billing and resolving billing disputes;
- contacting You to offer Product or Service updates and notices, promotional notices and other information about Products and Services or other Services available from Asurion or its affiliates);
- providing You with products or Services or carrying out the transaction(s) You have requested or authorized;
- responding to Your questions, inquiries, comments and instructions;
- improving the Sites by solving technical problems, calculating overall usage statistics, internal marketing and promotional purposes, product development and content improvement;
- taking good faith steps to enforce terms and conditions; and
- maintaining the security and integrity of the Sites and Asurion's systems.
7. SHARING AND DISCLOSURE OF PERSONAL INFORMATION
Primarily, we may share or disclose Your personal information in the following instances:
- To fulfill a Service to You.
For example, if You email us a question, we may use Your email address to process Your request and respond to Your question.
- To offer You products from our affiliates, strategic partners, agents, or from third-party marketers and other unaffiliated parties that we believe may be of interest to You, or to assist such parties for research, administrative, and/or business purposes.
These parties are obligated by contract to only use the information they are provided for the purposes specified by Asurion.
- To unaffiliated third-party service providers, agents, or independent contractors who help us maintain our Services and provide us with other administrative services (including, but not limited to, order processing and fulfillment, providing customer service, maintaining and analyzing data, sending customer communications on our behalf, and entry collection, winner selection and prize fulfillment for contests, sweepstakes, and other promotions).
Asurion requires these service-related companies to contractually comply with the principles set out in the Privacy Policy, and require them to use such information only for the purposes for which it was provided to them.
- To complete Your purchase.
If You choose to make a purchase of one of our Products or on or through our Services, we may ask You for Your credit card number, billing address, and other information in connection with completing such purchase, and we may use such information to fulfill Your purchase. We may also provide such information, or other personally identifiable information provided by You, to unaffiliated third-parties to complete Your purchase (for example, to process Your credit card). These third-parties are contractually bound to use the information provided only for the purposes specified by Asurion.
- To comply with law, or in the good faith belief that such action is necessary to conform to the requirements of law, or comply with legal process served on us, and to protect and defend our rights or property, including our rights and property and our Services, or act in urgent circumstances to protect the personal safety of You and our other visitors.
- To third parties as part of a corporate reorganization process including, but not limited to, mergers, acquisitions, and sales of all or substantially all of our assets.
- To track and analyze non-identifying, aggregate usage and volume statistical information from our visitors and customers and provide such information to third parties.
- To protect against fraud and potential fraud.
We may verify the information You provide to obtain our Products and Services through third parties who are contractually prohibited from using any information we provide to them for any purpose not specified by Asurion. In the course of such verification, we may receive additional personal information about You from such services. In particular, if You use a credit card or debit card to purchase Services with us, we may use card authorization and fraud screening services to verify that Your card information and address match the information You supplied to us, and that the card has not been reported as lost or stolen.
- To notify You of any known breach of personal information.
7.1. LEGAL DISCLOSURE
We may disclose information about You and Your use of the Services if we believe that such disclosure is reasonably necessary to:
- (i) comply with the law and/or legal process where a formal request has been made (e.g. request from an administrative oversight agency, civil suit, subpoena, court order or judicial or administrative proceeding);
- (ii) protect or defend our rights and/or property or the rights and property of others;
- (iii) enforce our Terms of Service and/or this Privacy Policy; and
- (iv) respond to claims that the content(s) of a communication violates the rights of another.
Also, circumstances may arise where, for business reasons, we may decide to reorganize, or divest all or part of our business through sale, assignment, merger or acquisition, or we may acquire a new business. In these circumstances, personal information may be shared with the actual or prospective purchasers or assignees, or with the newly acquired business. In such an event, we shall provide notice of any material change to this Privacy Policy, or our Products and Services, in the manner described in this Privacy Policy.
8. ACCURACY AND COMPLETENESS OF YOUR INFORMATION
Asurion takes various steps to reasonably ensure the accuracy and completeness of personal information. However, Asurion relies on our client partners to provide accurate and complete enrollment data about You that they directly collect from You and provide to Asurion. Asurion also relies on You to provide accurate and complete information when submitting a claim or interacting with Asurion for any other purposes.
9. ACCESS TO AND ABILITY TO CORRECT OR DELETE YOUR INFORMATION
Upon request via postal mail or-mail, Asurion will provide You a summary of Your personal information retained by Asurion. As allowed by law and consistent with our applicable partner agreements, You may modify, correct, change, or request Asurion to delete or update and personal information that Asurion has collected through the Sites by contacting Asurion via postal mail or e-mail as provided in the Contact and Electronic Communication section of this Privacy Policy.
10. THIRD PARTY SITES
The Sites may contain links to other websites, including websites operated by non-affiliated or independent third parties. Please be aware that those sites may collect personal information from or about You and Your visit. These sites have not necessarily been reviewed by Asurion and are maintained by third parties over which Asurion exercises no control. Accordingly, Asurion expressly disclaims any responsibility for the privacy policies, information collection practices, content, accuracy of the information, and/or quality of products or services provided by or advertised on these third-party websites. Moreover, these links do not imply an endorsement with respect to any third party or any website or the products or services provided by any third party. You should review the privacy policies that are posted on any website that You visit, before using the website and providing personal information to the website. Asurion is not responsible for the privacy policies or practices of any websites that may be mentioned on, or accessible from, the Sites.
11. CHILDREN UNDER 13
The Services provided by Asurion are not directed to persons under 13 years of age. Asurion does not knowingly collect personal information from children under 13. If You become aware that Your child is accessing the Services and personal information without Your consent, please contact us by using the information provided in the Contact and Electronic Communications section of this Privacy Policy. Asurion will take steps to remove personal information from Asurion Storage Systems and terminate the account should Asurion determine that a child under 13 has accessed the Services.
12. SECURITY OF INFORMATION
Information submitted via the internet, including through a web page or e-mail is subject to interception or incorrect routing, and the internet is not a fully secure communications channel. Please consider this prior to submitting any information to Asurion via the Sites. While Asurion follows generally accepted industry standards to protect the information submitted to us, no method of transmission over the internet, or method of electronic storage, is 100 percent secure. Therefore, while Asurion strives to use commercially reasonable means to protect Your personal information, Asurion cannot guarantee its absolute security. For information specific to application and mobile device security and credit card processing security please review these specific sections under this Privacy Policy.
13. CREDIT CARD PROCESSING AND DATA SECURITY
Asurion does not receive funds directly from You when You utilize the Sites. Asurion utilizes a third party payment processing gateway who provides the infrastructure and security necessary to provide secure transmission of Your credit card transaction data. Asurion can only accept credit cards from processing through our secured payment processing gateway.
To explain simply, our credit card processor manages the routing of credit card transactions in the same fashion as a traditional credit card swipe machine You find in the physical retail world; however, they use the internet instead of a phone line. Although we do not control the security environment for them and cannot make any guarantees regarding the secure processing of Your credit card transaction data, we want to inform You that our credit card processor is compliant with the Payment Card Industry Data Security Standard ("PCI DSS") as a Level 1 service provider.
We demand that our credit card processors are compliant with PCI DSS before we select them. PCI DSS is the bankcard industry's most stringent security standard. Examples of our credit card processor's security measures include: physical, electronic, and procedural safeguards; sophisticated security monitoring tools; documented security policies; use of strong encryption for transmissions of order information to and from our customers; restricting access to personal information; and periodic security audits by third party security experts.
14. SOCIAL MEDIA
Any information, communications, or material of any type or nature that You submit to the Sites or through Asurion Services (including, but not limited to any Asurion Sites contained on a social media platform or website such as Facebook, Instagram or Twitter) by email, posting, messaging, uploading, downloading, or otherwise (collectively, a "Submission"), is done at Your own risk and without any expectation of privacy.
Asurion cannot control the actions of other users of any social media platform or website and Asurion is therefore not responsible for any content or Submissions contained on such sites and platforms.
By visiting any Asurion Site that is contained on a social media platform or website, You are representing and warranting to Asurion that You have reviewed the applicable Privacy Policy and terms of use of such platform or website and that You will abide by all such provisions contained therein. Additionally, in the event that Asurion offers a message board or any other interactive or social-type feature on the Site, please be aware that these areas may allow You to publicly post, and share with other users, certain messages, content, or other information (e.g., stories, pictures, tips, etc.). Although Asurion may take certain precautions to protect those who use these areas of the Sites, Asurion encourages You to be wary of giving out any personal information in such public forums. The information You Submit can be collected and used by people You don't know. Asurion does not guarantee the privacy and safety of these areas and is therefore not responsible for any information You choose to Submit.
Your use of these features is fully at Your own risk.
15. INTERNATIONAL USERS
We may transfer information that we collect about You, including Your personal information, to Asurion subsidiary and affiliated entities, or to other third party service providers outside of Canada and from Canada to other countries or jurisdictions around the world.
If You are visiting from the European Union or other jurisdictions with laws governing data collection and use that may differ from Canadian and United States law, please note that You are transferring information about You, including personal information, to one or more countries and jurisdictions that do not have the same data protection laws as the European Union or other jurisdictions, and You consent to the transfer of information about You, including Your personal information, to Canada and the United States and other countries; and the use and disclosure of information about You, including Your personal information, as described in this Privacy Policy.
16. MONITORING AND ENFORCEMENT
Asurion has implemented various measures to monitor compliance with and enforce the elements in this Privacy Policy. If You have a privacy related inquiry, complaint or dispute, please contact us at the email or postal address listed in the first section of this Privacy Policy.
