Telematics Privacy Notice

Telematics Policy

dated: november 17, 2022

Novo Insurance, LLC ("Novo", "we" or "us") owns and distributes various software applications (the “Application(s)”) for use by end users.

This Telematics Policy sets forth the conditions that govern your use of the Application with respect to our collection and use of telematics data you authorize us to collect. Use of the Application is more broadly governed by the terms contained in the Terms of Use and our general Privacy Policy. By “opting in” to the collection of telematics information, You (a) accept how we collect, use, disclose and otherwise handle telematics information collected from You; and (b) represent and warrant You have the right, authority and capacity to accept these conditions.

If You do not agree with all conditions of this Telematics Policy do not consent to the collection of telematics information and disable location sharing when using the Application.

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.

This Telematics Policy contains important information about the telematics program. Please read this carefully.

DEFINITIONS

The following terms are defined and apply to this Telematics Policy only.

You” and “your” refer to all drivers enrolled in the “Program”.

Program” means the telematics program which provides You with insights about your driving patterns and tips to improve your driving.

01

Overview & Use of Information

The purpose of the Program is to collect and analyse end users’ telematics data for the purpose of providing you with insights which may help you improve your driving; and research and development.

Driving Insights: Novo will provide you with driving insights based on the telematics information provided by you through the Application. These driving insights are provided to inform you of improvements you can make to your driving behavior (e.g., such as making you aware to slow down earlier when approaching a red light to avoid a hard braking event) or be more safety conscience (e.g., not answering a call on your phone while driving).

Research & Development: When used for research and development purposes, telematics information will be used to draw insights and make predictions about driving patterns, safety, and the impact of external factors (such as weather) on accidents and driving events. These research and development activities will inform changes to our existing products as well as new products we and/or our affiliates may develop in the future.

The Program gathers data using theApplication and/or other related devices, such as data directly from the vehicle. Please note that data charges may apply when the Application uploads data from the Application to our secure Novo storage cloud.

02

Participation

Participation in the Program is strictly voluntary. In order to participate in the Program, you must “opt in” to the collection of your telematics data and enable location services and motion permissions for the Application. When You elect to participate in the Program, you agree to (i) enable the Application at the beginning of each driving trip you make; (ii) properly categorize your journey (e.g. by properly selecting if you are the driver or a passenger or if you are traveling by car or bicycle); (iii) not engage in a pattern of disabling the Application to avoid the recordation of driving behavior; and (iv) preserve all driving data if you are in an accident as such data may be subject to a lawful subpoena from the insurance carrier or legal representative, other parties involved in the accident, their insurance carriers and legal representatives.

You will be allowed to correct improperly recorded trips for a limited period of time following completion of a trip within the Application. Please note that if you improperly recategorize too many trips you may be removed from the Program.

03

Program Modifications & Withdrawal

We reserve the right to amend, waive, modify, or supplement the terms of the Program at any time for any reason. If we significantly change the telematics information we collect, we will inform you of such change.

We may terminate your participation in the Program at any time for any reason. You may “opt out” of the Program at any time by changing the Application settings to remove location sharing. If you “opt out” of the Program, Telenav will cease the collection of telematics data from you.

04

Information We Gather

We gather the following information during enrollment and participation in the Program:

A. Your email address

B. Your mobile phone numbers

C. The following data is gathered via the Application and/or other devices including the vehicle, as you drive:

  • GPS location coordinates (latitude, longitude, altitude)

  • Mobile phone state to assess usage while driving

  • Date and time of day

  • GPS Probe data including speed, heading, timestamp

  • Phone permissions

  • User activity (Android only)

  • Motion and fitness (iOS only)

Based on the collection of the above-listed information, Novo derives a risk variable for each of these categories:

  • Hard braking

  • Excessive speed

  • Phone motion (including phone screen tapping)

  • Percentage of time spent on primary, secondary and tertiary roads.

05

Privacy

Protecting your privacy is very important to us. We take our obligation to safeguard and secure your personal information very seriously. Along with our technology partners, we follow strict data security and privacy protocols to protect your information and will not disclose information except as described herein and as described in the Privacy Policy.