Privacy Notice

REVISED: 17 November 2022

Novo Insurance, Inc., its affiliates and subsidiaries (collectively, the "Company", "Novo Insurance", "we" or "us") are a wholly owned subsidiary of Telenav, Inc. (“Telenav”). We own, operate, and provide the website located at https://www.novo.us and any parent or child site (the "Site") and the Novo Insurance mobile application (the "Mobile Application"). We refer herein to the Site and Mobile Application collectively as the "Novo Insurance Platform."

At Novo Insurance we are dedicated to protecting your privacy. We understand that you value your privacy, and that you may have questions about how we use the data collected through our Novo Insurance Platform. This Privacy Notice applies to information we obtain about you in the course of providing access to and use of the Novo Insurance Platform.

By using or accessing the Novo Insurance Platform, you (a) accept how we may collect, use, disclose and otherwise handle your information, as we specifically describe in this Privacy Notice, and (b) represent and warrant that you have the right, authority, and capacity to accept these conditions. By using or accessing the Novo Insurance Platform, you also accept the Terms of Use. You may not access or use the Novo Insurance Platform if you have not reached the age of majority in your state of residence. Specifically, if you are under the age 13, do not access or use the Novo Insurance Platform and do not enter any personally identifiable information about you or anyone under the age of 13 into the Novo Insurance Platform. If you do not agree with all of the conditions of this Privacy Notice or Terms of Use, do not access and/or use the Novo Insurance Platform. If you are accepting on behalf of a company or other third party, you represent and warrant that you have full authority to act for and to bind that company or other party, in which case the term "you" refers to that company or other party.

In connection with the provision of the Novo Insurance Platform, we obtain information about you, such as your name, phone number, address, email address, vehicle information (like vehicle identification number, vehicle license plate), driver's license number, date of birth, Social Security number, marital status, family member information, gender, credit card data and other payment information, policy coverages, insurance policy ID, driving records, claim histories, credit information, credit history, employment history, hobbies, general reputation, education, occupation and payment history. We may also collect data through other sources, such as technology built into or added to your vehicle or a mobile app. Such technology may be supplied by us or another party (collectively, “Third Party Sources”).

We obtain information about you and others when (a) you apply for insurance, (b) you or other users use or access the Novo Insurance Platform, (c) we obtain information from public records, and (d) third parties provide information or services to us to support our provision of the Novo Insurance Platform. Such third parties may include government authorities, consumer reporting agencies, doctors or hospitals, insurance agencies, claims adjusters, actuarial data providers, and business partners who support our business.

If you “opt-in” for the collection of telematics information for driver scoring, we obtain additional information about you and your driving patterns as more fully described in the Telematics Policy. Please note that we work with a third party to provide driver scoring and your data will be shared with the third party for use solely in connection with providing the driver scoring to Novo.

Through the Novo Insurance Platform, we and our third-party marketing partners may also obtain other information relating to you, such as your operating system, your phone carrier, hardware you use, pages you viewed, your IP address, how often you use the Novo Insurance Platform, events that occur within the Novo Insurance Platform during your use, aggregated-usage information, performance data, the site and location from where you downloaded or otherwise accessed the Novo Insurance Platform, your browser type, your Internet service provider, the referring and exit pages, installed fonts, device IDs, language and time zone settings, and other information relating to your use of or access to the Novo Insurance Platform. We and our third-party marketing partners may also use in the Novo Insurance Platform web beacons, clear gifs, pixel tags, local shared objects, and similar technologies to collect information relating to your use of or access to products and services offered through the Novo Insurance Platform. In addition, the Novo Insurance Platform uses remarketing services to advertise on third party websites to previous visitors of the Novo Insurance Platform. For example, we may direct advertising (in the form of an advertisement on a search results page or other website) to a user who previously visited the Novo Insurance Platform, but didn’t complete a task on our site, such as partially completing a contact form. The use of these remarketing services enables Novo to tailor offers to and communicate about our services with individuals who have shown interest in our products. Additionally, third party vendors may use cookies to serve advertisements based on an individual’s past visit to our website.

In connection with your initial insurance application or later renewal of insurance, we may, to the extent permitted by law and with your consent, review your credit report or obtain or use a credit-based insurance score, based on information contained in your credit report. An insurance score uses information from your credit report to help predict how often you are likely to file claims and how expensive those claims will be. We may rely on third parties to develop and provide such insurance scores. Typical items from a credit report that could affect an insurance score – and, thus, the scope or price of insurance we may make available to you - include, but are not limited to, payment history, number of revolving accounts, number of new accounts, the presence of collection accounts, bankruptcies and foreclosures. The information used to develop the insurance score comes from various credit reporting agencies. If we take an adverse action based on information contained in your credit report – such as declining to make insurance available to you or adjusting the scope or price based, in whole or in part, on the insurance score, we will:

• Provide you with the name, address and phone number of the credit reporting agency that supplied the report;

• A statement that the credit reporting agency did not make the adverse decision and cannot explain why the decision was made;

• Inform you of your right to obtain a free copy of the credit reporting agency’s report if requested within sixty (60) days;

• Notify you of your right to dispute the accuracy or completeness of information provided by the credit reporting agency; and

• Inform you of your credit score, if a score was used.

We may use the information we obtain in connection with the following activities (including those provided by our partners):

• For underwriting and rate purposes, including verification of information provided by you or with your consent;

• To calculate your driver score, which, along with other traditional rating factors, determines your insurance quote, the rate you will pay for your current policy or when your policy renews, or pricing for a future policy;

• To understand how to interact with the Novo Insurance Platform, so that we can continue to improve the experience, quality, security and reliability;

• To respond to your customer service requests or the requests of others who may be covered, administer your account, send you service-related correspondence, permit you to add individuals or an account or policy, fulfill an insurance related transaction, process insurance claims, participate in insurance support organizations, underwrite and rate policies and accounts, confirm your identity, communicate with you, and to otherwise provide access to the Novo Insurance Platform;

• To send you newsletters, evaluate marketing campaigns, develop new products and services, market our products and services, analyze how users use the Novo Insurance Platform, send you notifications, and provide a more customized web or mobile experience;

• To facilitate auditing, prevent or investigate fraud, comply with requests from regulatory and law enforcement authorities, protect our rights, protect your safety or the safety of others, comply with applicable law, respond to subpoena or court order, and otherwise investigate, establish, exercise, and defend legal rights;

• To facilitate any other activity in connection with the creation, development, offering, provision, or servicing of our products and services; and

• To conduct any other legitimate business activities not otherwise prohibited by law.

We may share the information we obtain from you with third parties, such as our partners, in connection with the following activities:

• For any purpose to which you expressly consent;

• To facilitate a merger, acquisition, bankruptcy, dissolution, reorganization, sale of some or all of our assets, financing, acquisition of all or a portion of our business, a similar transaction or proceeding, or steps in contemplation of such activities (e.g., due diligence); and

• To conduct any other legitimate business activities not otherwise prohibited by law, or with your consent.

You may limit some of the marketing of our or our affiliates’ products and services to you by contacting us at privacy@novo.us. Your choice will apply to all people listed on your policy.

In addition, we reserve the right to access, read, preserve, and disclose any information as we reasonably believe is necessary to: (i) satisfy any applicable law, regulation, legal process, subpoena or governmental request; (ii) investigate potential violations of your agreement(s) with us; (iii) detect, prevent, or otherwise address fraud, security or technical issues; (iv) cooperate with law enforcement authorities; (v) respond to user support requests; or (vi) protect our, our users' or the public's rights, property or safety.

The third parties with whom we may share information for these purposes include insurance agents, companies that perform payment processing, marketing, driver scoring or other services on our behalf and our business partners, businesses that assist in analyzing and improving websites and mobile applications, other insurance companies that play a role in an insurance transaction with you, those who request information pursuant to a subpoena or court order, government authorities, consumer reporting agencies, doctors, hospitals, insurance agencies, claims adjusters, actuarial data providers, and other business partners. We are not, however, responsible for the content of such third party privacy policies or for ensuring such third parties comply with their policies.

We may include third-party links on the Novo Insurance Platform. We have no control over, and assume no responsibility for, the content, privacy policies or practices of any third-party websites. By including a link to a third-party website, we do not endorse or recommend any products or services offered or information contained at the third-party website. Such third party may have a privacy notice different from that of ours and the third-party website may provide less protection than our website. If you decide to visit a third-party website via a link contained on the Novo Insurance Platform, please ensure that you read their privacy notice, as we are not responsible for these third-party sites.

We maintain reasonable physical, electronic and procedural safeguards to preserve the integrity and security of the collected information. In the event of a breach, we will notify you in accordance with the laws applicable in the state and/or states where such breach occurred.

You may request to review your personal information in our records by contacting us at any time, as provided in the "Contact Us" section below. If you believe that the information is incomplete or inaccurate, you can request that we correct it. We may not, however, be able to provide information relating to investigations, claims, litigation, or other matters. We will be happy to make corrections whenever possible. We will respond to your requests within a reasonable timeframe.

Please note that some web browsers and devices permit you to broadcast a preference to websites and online services that they "do not track" your online activities. At this time, we do not modify what information we collect or how we use that information based upon whether such a signal is broadcast or received.

You have the ability to accept or decline cookies using your web browser settings. If you choose not to accept cookies from our website, you may not be able to take full advantage of its features or to receive some of the services that it provides. To learn more about cookies and your ability to opt-out of certain advertising cookies, please visit the following websites: http://www.aboutads.info/choices or http://www.networkadvertising.org/choices. To find out how to opt out on a mobile device, please visit the following website: https://www.networkadvertising.org/mobile-choices. On your mobile device you may also select "Limit Ad Tracking" (on iOS devices) or "Opt out of Interest-Based Ads" (on Android).

We do not target the Novo Insurance Platform to anyone under age 13. If you are under age 13, do not enter any personally identifiable information about you or anyone under the age of 13 into the Novo Insurance Platform. If you are a parent or a guardian who has discovered that your child under age 13 has submitted his or her personally identifiable information to us without your permission or consent, we will make reasonable efforts to remove the information from our database, at your written request. To request the removal of your child's information, please contact us as described in the "Contact Us" section below and include in your message your child's name and the email address that your child submitted.

We are a Delaware limited liability company engaged in activities as a licensed insurance agency in various states, although we currently only sell policies in a more limited number of states listed in our FAQs. We sell auto insurance policies which are underwritten by 21st Century Premier Insurance Company. 21st Century Premier Insurance Company is a Delaware domiciled insurance company with offices located in Caledonia, Michigan. Activities such as claims processing, roadside assistance, etc. are handled by 21st Century Premier Insurance Company and/or their services providers and are not provided by Novo Insurance, LLC.

We host the information we collect from the Novo Insurance Platform in the United States. If you are using or accessing the Novo Insurance Platform from outside the United States or any other region with laws or regulations governing personal data collection, use and disclosure that differ from the United States laws, please be advised that through your use of the Novo Insurance Platform, which is governed by U.S. law, you are transferring information to and from the United States and you consent to that transfer.

The laws of the State of Delaware and applicable United States law govern all matters arising out of or relating to this Privacy Notice, including, without limitation, interpretation, construction, performance, and enforcement, without giving effect to such state's conflicts of law principles or rules of construction concerning the drafter hereof. You hereby irrevocably and unconditionally submit to the jurisdiction of the federal and state courts located in New Castle County, Delaware for the purpose of any suit, action, or other proceeding arising out of or based upon this Privacy Notice, your access to or your use of the Novo Insurance Platform, which courts are the exclusive forum for any such suit, action, or other proceeding.

You may not transfer or assign any rights and permissions you grant to us hereunder. However, we may transfer or assign those same rights and permissions without restriction.

If we decide to sell, buy, merge or otherwise reorganize our businesses in certain countries, this may involve us disclosing your information to prospective or actual purchasers and their advisers, or receiving information from sellers and their advisers. In the event of such disclosures of information, we will comply with applicable legal requirements.

We reserve the right at our discretion to change the Privacy Notice at any time. We will post the most current version of the Privacy Notice to our website at https://www.novo.us.

Any changes will be published on our dedicated page on https://www.novo.us and will be effective as of the date of publication (which will also be noted on our website).

Please feel free to contact us if you have any questions regarding this Privacy Policy or our practices. You may contact us using the following information:

Legal Department – Privacy Request

4655 Great America Parkway, Suite 300

Santa Clara, California 95054, United States

privacy@novo.us