Novo Telematics Policy

Novo Insurance, LLC ("Novo", "we" or "us") owns and distributes various software applications as mobile phone applications and in-car embedded 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. Additionally, the latest version of the Telematic Policy is available here: https://novo.us/telematics-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. The use of Telematics functionalities is a voluntary, usage-based insurance program that collects and analyzes driving data to determine participants’ insurance policy pricing; this program not only adjusts premiums based on driving behavior but also offers additional services, such as personalized driving insights, safety tips, and potential discounts, all aimed at encouraging safer driving habits and providing a more tailored insurance experience.

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 (Novo or Novo Safety program) which provides You with insights about your driving patterns and tips to improve your driving.

“Telematics Device” means any hardware installed in a vehicle or application on a mobile device that collects and transmits driving data.

“Driving Data” means any information gathered from the telematics device, including but not limited to GPS location, speed, acceleration, braking patterns, and phone usage while driving.

“Usage-Based Insurance (UBI)” means an insurance program where premiums are determined based on the driving behavior and patterns collected from telematics devices. “Safety Score” means a score derived from driving data that reflects the safety and risk level of a driver, which is used to adjust insurance premiums.

“Crash Event Data” means specific information collected during a vehicle crash, including location, speed, and time of the incident, used for analysis and facilitating the claims process.

“Opt-In” means the voluntary action by which a participant agrees to the collection and use of their driving data through the telematics program.

“Opt-Out” means the voluntary action by which a participant withdraws from the telematics program, ceasing the collection of their driving data.

“Data Protection Officer (DPO)” means the person responsible for overseeing data protection strategy and implementation to ensure compliance with privacy laws.

“Location Service” means a feature on mobile devices that enables the collection of GPS data to determine the device's geographic location.

“Personal Data” means any information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household.

“Policyholder” means the individual or entity that holds an active telematics insurance policy, responsible for the premium payments, and entitled to the benefits and coverage specified in the policy terms

“Data Protection Laws” (US) means the legal frameworks in the United States that regulate the collection, use, storage, and sharing of personal data to protect individuals' privacy rights. Key laws include but are not limited to: California Consumer Privacy Act (CCPA), Health Insurance Portability and Accountability Act (HIPAA), Children's Online Privacy Protection Act (COPPA), Gramm-Leach-Bliley Act (GLBA), or Federal Trade Commission Act (FTC Act).

We collect necessary information through our Application, relevant third parties, or any other interactions you may have with us. Depending on the cover you are looking for, relevant circumstances and applicable data protection laws and requirements, we may collect some or all the categories of data listed below. The following terms supplement Novo’s Privacy Policy regarding the Data collected by the Device or Application and used in the Program, as defined and described within the Novo's Privacy Policy, available on our novo.us website.

The categories of data that may be collected encompass, but are not limited to the following categories (hereafter referred to as "Data"):

Daily Driving Data – Speed, Distance driven, Time of day, Vehicle identification number, Mileage;

Driving Events – Braking patterns, Speed/Acceleration patterns, Cornering; Percentage of time spent on primary, secondary and tertiary roads, trip duration.

Device Data – Device identification number, Time and date the Device is connected/disconnected, User activity, System activity including apps malfunction, Mobile phone permissions, Phone motion (including phone screen tapping); and

GPS Data – Latitude, Longitude, and Heading information regarding the location of the vehicle.

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

The types of Data collected may vary depending on the specific vehicle in use, and may be subject to change over time based on future updates or modifications to the data collection processes

We may obtain your personal data:

(a) Directly from you, such as when you provide information through written means (e.g., completing a form) or verbally (e.g., during a phone call), or by reviewing our interactions with you. For instance, we obtain your personal data when you: (i) purchase any of our telematics insurance services, (ii) enter into a service contract with us, or (iii) subscribe to receive promotional communications or other offers from us or our partners.

(b) from sources other than directly from you, including: (i) external public sources (for instance, external public sources may include public databases, such as public records, government databases, and industry-specific listings within the US; (ii) third party entities (for instance our suppliers or contractors (including financial service providers – for example, offering details regarding the status of a payment), survey and market research agencies, so on. and (iii) inferred/derived data generated from the information we already have about you, as details of your use of certain services (for example data regarding your use of certain services)

Novo may share your data with its affiliates, and third-party service providers who assist in managing the Program and processing or analyzing the Data. We may also share Data with Departments of Insurance, the National Association of Insurance Commissioners, or other government agencies/authorities as required by the law or for litigation purposes. Novo will not share personal information with any third-party companies for marketing purposes without your specific and informed consent

The purpose of the Program is to collect and analyze end users’ telematics data for the following:

1. Pricing of insurance policies you may purchase from Novo; When used for insurance pricing, your telematics information and driving behavior are used to create a safety score, based on which there may be adjustments to determine accurate premiums.

2. Providing you with insights which may help you improve your driving skills; Novo will provide you with driving insights based on the telematics information provided by you through the Application or from the sensors on your vehicle. 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).

3. Facilitating claims/requests or conducting investigations where the case may be;Novo will collect and process your data to communicate with you where needed, to manage your insurance policy, and handle or facilitate different claims/requests.

4. Security and fraud detection including illegal activities, and ensuring compliance with regulations and law enforcementWe aim to protect customer data from unauthorized access, preventing identity theft, detecting and preventing fraudulent claims, complying with data protection regulations, and ensuring the integrity and confidentiality of the company's systems and data.

5. For research and development including to respond to your product or service information requests and improving your customer experience. 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 internal and 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.

Understanding how your driving affects your insurance cost is essential. This chapter provides a comprehensive overview of Novo's telematics program, including data collection methods, scoring calculations, and the factors that determine your insurance premium. This chapter shall be duly supplemented in accordance with Novo Safety Program ("NSP") Terms and Conditions.

In order to have your telematics data used for insurance pricing, you must drive at least five (5) trips and fifty (50) miles within each evaluation period, generally thirty (30) days, (the “Minimum Scoring Requirement”) for connected vehicle(s). Upon enrollment in the Novo Safety Program you will receive either (i) an enrollment score, if there is insufficient telematics data available to determine your safety score; or (ii) a safety score, if there is an adequate amount of telematics data available. Once a telematics-based safety score is established, it will be used to calculate the premium applicable for the upcoming billing month. The enrollment score or safety score will be used to determine your policy premium for the first two months. Your insurance policy may include a rate adjustment beginning in the third month of the policy period based on the safety score assigned from telematics data collected from your vehicle. Please note that the safety score is calculated at the vehicle level and not the driver level. The driving behavior of all drivers of the vehicle enrolled in the Novo Safety Program will be used for the calculation of the safety score.

Novo reserves the right to modify our scoring methodology and the interpretation of resulting scores over time. These changes may be influenced by various factors, including but not limited to, evolving industry standards, technological advancements, and regulatory requirements. Updated scoring criteria will be submitted to the appropriate state insurance departments for review and approval. The use of these revised scoring models will impact underwriting decisions and premium calculations at policy renewal. It is important to note that these adjustments are made to ensure the accuracy and fairness of our rating system and to reflect changes in the insurance landscape.

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 (mobile and embedded Applications) and enable location services and motion permissions for the mobile Application. When You elect to participate in the Program using the mobile Application, 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.

Importantly, a single consent, once granted, encompasses all vehicles listed under a policy, unless explicitly excluded by the policyholder. Adding or removing vehicles from a policy can consequently modify the overall insurance premium due to alterations in the assessed risk profile. To entirely withdraw from the telematics program, customers must formally revoke consent for all vehicles associated with their policy. It's crucial to understand that opting out may result in higher premiums as traditional risk assessment methods, which are less precise than telematics in capturing individual driving behaviors, will be employed. For accurate data collection and analysis, consistent and correct mobile app usage is paramount, including precise trip categorization and the avoidance of intentional app disabling. By comprehending these details, customers can make informed decisions regarding their participation in the telematics program and its potential financial implications

In the event you believe there has been an error in calculating your safety score and/or you believe a false crash event has been detected, you may contact Novo to register a dispute by contacting Novo’s Customer Service Representatives at 1-866-862-7757. Kindly note that the provisions of the present section shall be duly supplemented by the Novo Safety Program Terms and Conditions.

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. For “Mobile Application” Participants, You may “opt out” of the Program at any time by changing the Application settings to remove location sharing. For “Embedded Technology” Participants, You may “opt out’ of the Program at any time by contacting Novo’s Customer Service Representatives at 1-866-862-7757 or optout@novo.us. If you “opt out” of the Program, Novo will cease the collection of telematics data from you.

If you have any concerns about the automated decision-making process, you can always speak with a human representative by contacting Novo’s Customer Service Representatives at 1-866-862-7757.

For “Mobile Application” Participants, if You “opt out” of the Program before Minimum Scoring Data has been collected or the Minimum Scoring Requirement (as applicable) is met, You will not be eligible for telematics-based insurance pricing on Your current and/or renewal policies from Novo and may have Your insurance rate adjusted. For “Embedded Technology” Participants, if you “opt out” of the Program, a non-fulfillment score will be applied for the remainder of your policy term and for each renewal thereafter.

Protecting your privacy is very important to us.

The Telematics Policy is a component of Novo's comprehensive privacy framework. For a complete understanding of how Novo collects, uses, shares, and protects personal information, including telematics data, please refer to the Novo Privacy Policy. The Privacy Policy provides additional details on data rights, security measures, and other relevant privacy matters.

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 within the Privacy Policy.

For California residents, the CCPA grants additional rights, including the right to know what personal data is being collected about you, the right to request deletion of your personal data, and the right to opt-out of the sale of your personal data. All your rights shall be found within the Novo's extended Privacy Policy, available on the link above. You can exercise these rights by contacting us at privacy@telenav.com. We implement appropriate technical and organizational measures to ensure a level of security appropriate to the risk of processing your personal data. All collected data is stored securely and access is restricted to authorized personnel only.