PLEASE REVIEW THIS PRIVACY NOTICE FOR ASSURANT’S POCKET GEEK® PRIVACY WEBSITE CAREFULLY. THIS NOTICE APPLIES TO YOUR USE OF THE POCKET GEEK® PRIVACY PRODUCT.
This Privacy Notice describes the information handling and privacy practices of The Signal, LP and its subsidiaries and affiliates (collectively, ''Assurant'').
The Privacy Notice describes our practices with respect to the collection, access, use, management, disclosure, transfer, storage, and other processing of your personal information processed in connection with the Pocket Geek® Privacy product.
Pocket Geek® Privacy - Privacy Notice
What Information We Collect
How We Use & Disclose Collected Information
The Signal, LP, (hereinafter, “We”, “Us”, “Our” or “Company”), respects your concerns about privacy. The Personal information provided to or collected by Us is controlled by The Signal, 480 E. Swedesford Rd., Suite 350, Wayne, PA 19087 U.S.A. This Privacy Notice (“Notice”) describes how We will collect, access, use, disclose, retain, transfer, otherwise process and protect personal information when you use the Pocket Geek® Privacy websites or Services, a service that provides (i) password management, (ii) e-mail alias management, (iii) data management, (iv) tracker management, and (v) customer technical support services.
We may share information about you with your consent, where it is necessary to carry out the Service or as required by law, and We will always let you know when We make significant changes to this Privacy Notice.
We adhere to the following principles to protect your privacy:
We protect your personal information and will only provide it to third parties:
with your consent;
where it is necessary to carry out your instructions;
as reasonably necessary in order to provide the Service;
as reasonably necessary to Our service providers (as described in Section 3.2 ) in connection with providing the Service;
when We reasonably believe it is required by law or by order of a court of competent jurisdiction;
as necessary to enforce our Terms of Service , to protect the rights of the Company, or to prevent physical harm or financial loss; or
as part of a reorganization or sale of all or part of Our business.
We have implemented safeguards designed to protect your information in accordance with industry standards.
This Privacy Notice applies to the Service only and does not necessarily reflect practices with respect to information gathered through other services We offer or websites We operate or the collection of information through off-line means. To review the privacy practices of those other services, please refer to the policies provided associated with each.
If you have any concern about providing information to Us or your information being used in any manner permitted by this Privacy Notice and the Pocket Geek® Privacy Terms of Service , you should not use this Website or Service.
1. What information We collect
1.1 When you use our Website
When using the Pocket Geek® Privacy website, We may ask users to provide Us with: (i) name, (ii) last name, (iii) email address, (iv) phone number, (v) invitation code and, (vi) country of residence.
1.2 When you communicate with Us or contact Us for Technical Support
We collect information when you contact Us for Technical Support.
When you contact Our Technical Support or Our Technical Support contacts you, We will collect information that you provide to Us in your communications (such as the query or issue that you have raised).
With your permission, We may access your personal information contained within the Service or your Device to respond to your request. When Our Technical Support advisor accesses your device for troubleshooting purposes, while the Technical Support Advisor is logged in to your account, she or he can access and extract information (such as settings) from the device. The Technical Support advisor will only access information needed to troubleshoot the device, and once the session is over, they will not retain any of the information on their screen. Please note that when you use Technical Support, Our advisors may be able to view messages and communications sent to the Device while providing support services. We do not retain or use this information for any purpose.
You may report any problems or security concerns by contacting us by e-mail at: email@example.com Our customer support centers are located within the United States of America and may be operated by Assurant or Our service providers.
2. How We use and disclose collected information
You agree that information you provide may be used as described in this Notice and our Terms of Service.
2.1 Consent to Processing Information about You
By accessing or using the Pocket Geek® Privacy Website you indicated that you have read this Notice and expressly and voluntarily accept the terms of Our Terms of Service and freely consent, on your own behalf and on behalf of any family members you have authorized to use the Service, to Our processing of personal information as set forth in this Notice.. If you do not consent to the terms of this Notice, do not access or use the Pocket Geek® Privacy Website or services.
We do not sell or rent any of your personal information.The personal information We collect is used to provide Pocket Geek® Privacy, to manage your account, to develop new products and Services, and for other purposes to which you consented. Examples of the above uses include:
provide Pocket Geek® Privacy to you;
fix, maintain, enhance and modify the Pocket Geek® Privacy product;
communicate with you (e.g. in response to your inquiries or comments);
comply with legal and regulatory requirements;
promote Our products and Services;
provide you with offers by Our business partners that might interest you in accordance with your consent; andfor other purposes in accordance with your consent.
We communicate with you using the phone number and email address provided, and other means available to us. These communications may include servicing communications by automated SMS, MMS, text message, e-mail, or other electronic means (collectively, “SMS Messages”). You may choose to opt-out of receiving this communication by replying STOP to the received text messages (SMS) or unsubscribing to received e-mails.
3. How We share your personal information
3.1 Sharing information with affiliates
We may share your information among the Assurant family of companies.
The Signal, LP entity that collects or holds your personal information shares your personal information with Our affiliates (meaning entities controlled by, controlling or under common control with Assurant, Inc.) for the purposes stated in this Privacy Notice.
3.2 Sharing personal information with service providers
We employ third party companies and individuals to facilitate the Service (for example, payment processing, customer support, analysis, audit, application, database hosting).
These third parties have limited access to your information only to perform these tasks on Our behalf and are obligated to Us. The personnel of such third parties who use your personal information is limited to those individuals which are authorized to do so on a need-to-know basis and as necessary to provide these business services to Us. We do not authorize such third parties to disclose or use it for other purposes.
3.3 Sharing personal information with other recipients
We may disclose your personal information to public authorities if mandated by law or if required for the legal protection of Our legitimate interests in compliance with applicable laws.
We may also disclose your personal information to parties acquiring part or all of Our assets, as well as to attorneys and consultants. Also, if any bankruptcy or reorganization proceeding is brought by or against Us, your information may be considered a company asset that may be sold or transferred to third parties.
4. Your Choices
You may request access to, modify, correct, delete or limit the use and disclosure, where required by applicable law, of your account information or close your account. You can also request additional information We may have about your account.
4.1 Access, correct, delete or limit use of your personal information and Closing your account
You may (1) request access to, modification or correction of, deletion of, or limit or object to the use and disclosure, where required by applicable law, of your personal information controlled by Us or (2) close your account. You can request access to your personal information held by Us, including information that is not viewable through the Website (for example, your IP access logs) through Our customer support center by e-mail at : firstname.lastname@example.org. You can also request as by sending a written request to Us at the address provided in the “Contact Us” section of this Notice.
If you close your account(s), your information, including device information that you have provided will be removed from the Service 30 days after cancellation/termination. We delete logs and other information through the deletion process within 90 days of account closure, except as noted in Section 3.3
If you think that any personal information, We have collected about you is inaccurate, or if you would like to limit the use and disclosure of such information, you may send a reasonable written request for review to Us at the address provided below in the “Contact Us” section of this Notice. We will investigate your request and make appropriate changes or deletions if warranted. We will respond to any reasonable requests for access to personal information in 45 days or as permitted under applicable law.
In certain situations, and subject to applicable laws, we may not be able to provide access to all of the personal information that We hold about you. For example, We may not provide access to information if doing so:
would likely reveal personal information about a third party;
could reasonably be expected to threaten the life or security of another individual;
would reveal Our or third-party confidential information;
includes information that is protected by solicitor or attorney client privilege; or
includes information that was processed in relation to the investigation of a breach of an agreement or a contravention of a law.
In order to safeguard your personal information from unauthorized access, We may ask that you provide sufficient information to identify yourself prior to providing access to your personal information. We will respond to your request in accordance with applicable law.
Depending on the circumstances and applicable laws, We may refuse to process certain access requests.
Notice for California Consumers
This section of our Privacy Notice applies to Consumers who reside in the State of California and is included to comply with the California Consumer Privacy Act of 2018 (“CCPA”) and other California privacy laws. It applies to Our processing of personal information that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household subject to the CCPA (“Personal Information”).
Information We Collect
We describe the Personal Information we have collected from consumers and the sources from which we collect this information, in the twelve (12) months preceding the effective date of this Privacy Notice, in the section of our Privacy Notice titled “What Information We Collect.” The information we collect includes the following:
Identifier such as first and last name, e-mail address, telephone number, address, Internet Protocol address, and other data elements entered by the user.
Personal Records under Cal. Civil Code § 1798.80(e) such as name, email address, telephone number, address, and mobile device type.
Internet and other Electronic Network Activity Information such as Internet Protocol address, browser, devices and operating system types; device identifiers; and information regarding your internet service provider.
We collect location information such as state and zip code relating to your computer or device when you interact with the Services. We do not collect your precise geolocation.
We aggregate information such as your state, zip code, or device type with similar information of other users of the Services to analyze interactivity with the Website. We do not use Personally Information identifiable to you for this purpose.
For information regarding the purposes for which we collect and use the Personal Information we collect, please see “How We share your personal information”.
We have disclosed Personal Information in all or substantially all of the categories identified in this Notice for California Consumers for various business purposes. For more information about the categories of Personal Information we have disclosed, the categories of entities with which we have disclosed this information, and the purposes for which we have disclosed the information, please see “How We Share Your Personal Information.”
In the last 12 months we have not sold any Personal Information. We do not sell any Personal Information to third parties for a business or commercial purpose, and we have not sold any Personal Information to third parties for a business or commercial purpose within the past 12 months. Additionally, we do not sell the Personal Information of minors under 16 years of age.
Your Rights and Choices
The CCPA provides consumers with specific rights regarding their Personal Information. This section describes your CCPA rights and explains how to exercise your rights.
Exercising CCPA Rights
To exercise the rights afforded to you under the CCPA, please submit a verifiable consumer request to us by either:
Visiting https://www.assurant.com/dataCare/consumer-page; or
Calling us at 1-866-342-8527
Only you or a registered agent may make a verifiable consumer request related to your Personal Information. If applicable, you may also make a verifiable consumer request on behalf of your minor child. You may only make a verifiable consumer request for access or disclosure twice within a 12-month period, and the request must:
Provide sufficient information that allows us to reasonably verify you are the person about whom we collected Personal Information; and
Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.
In order to process your request safely and protect your Personal Information, it is required that you go through an identification verification process that will ask you for certain required information (including but not limited to your name, your date of birth, the last four digits of your SSN, your email address, your product, your address, your photo, and a copy of your photo ID). In the instance that your identification can not be verified, you will be contacted. We cannot respond to requests if we cannot verify your identity. Making a verifiable consumer request does not require you to create an account with us.
Response Timing and Format
We will respond to a verifiable consumer request within 45 days of its receipt. If we require more time, we will inform you of the reason and the extension period in writing. Any disclosures we provide will only cover the 12-month period before the date the verifiable consumer request was received. If we cannot process your request, we will explain the reasons why we cannot comply with the request. All responses will provide your Personal Information in an easy to read format. We will not charge a fee to process or respond to your request provided, however, in certain circumstances we may charge a fee if permitted under applicable law.
Deletion Request Rights
You have the right to request that we delete Personal Information that we collected from you, subject to certain exceptions. Please note that even if you make a request to delete your Personal Information, applicable law may permit or require us to retain Personal Information that was collected to complete transactions and services you have requested or that are reasonably anticipated, for security purposes, for legitimate internal business purposes, including maintaining business records, to comply with law, to exercise or defend legal claims, to cooperate with law enforcement and for other legally permissible reasons.
Right to Know About Personal Information Collected, Disclosed, or SoldIf we use your Personal Information for a business purpose or if we sell your Personal Information, you have the right to request the following to be disclosed:
The categories of Personal Information that the business collected about you;
The categories of Personal Information that the business sold about you and the categories of third parties and/or service providers to whom the Personal Information was sold;
The categories of Personal Information that the business disclosed about you for a business purpose.
Under California law, you may designate an authorized agent to make a request on your behalf. You may make such a designation by providing the agent with written permission to act on your behalf. As permitted by law, we may require you to verify your own identity in response to a request even if you choose to use an agent. We may choose to deny a request from an agent that does not submit proof that they have been authorized by a consumer to act on their behalf.
We will not discriminate against you for exercising any of your CCPA rights. This means, unless permitted by the CCPA, we will not:
Deny you goods or services;
Charge you different prices or rates for goods or services, including granting discounts or other benefits, or imposing penalties;
Provide you a different level or quality of goods or services; or
Suggest that you may receive a different price or rate for goods or services, or a different level or quality of goods or services.
5. Important Information
5.1 Data Retention
We keep your information for as long as it is need. In addition, We may keep certain information if it is necessary to comply with Our legal obligations, meet regulatory requirements, resolve disputes, prevent fraud and abuse, or enforce this agreement.
We retain personal information you provide as needed to provide the Service. Our customer support may retain information for as long as is necessary to provide support-related reporting and trend analysis only, but We generally delete or anonymize data consistent with this Notice.
We may retain your personal information for longer than the periods set out above where necessary, for example to comply with Our legal obligations, meet regulatory requirements, resolve disputes, prevent fraud and abuse, or enforce Our Terms of Service.
5.2 Changes to this Privacy Notice
We may update this Privacy Notice from time to time. If We make any material changes to this Privacy Notice, it will be posted on this Pocket Geek® Privacy Website so that you may review the changes before you continue to use the website. As We may make changes to this Privacy Notice, We suggest that you review it each time you access and use the Website or Service. Please review changes carefully. If any changes are made to this Privacy Notice, We will revise the Effective Date that is indicated at the bottom of it.
5.3 Security Procedures
We have measures in place to restrict access to information to those employees and individuals whom We know have a valid business purpose to have access to such data. We maintain physical, electronic and procedural safeguards. We follow generally accepted standards designed to protect the personal information submitted to Us, both during transmission and once We receive it. We require those who provide services for Us and to whom We provide information collected through the Service to keep such information safeguarded and confidential. However, no method of transmission over the Internet or method of electronic storage is totally secure. Therefore, We cannot guarantee its absolute security.
5.4 Cookies and Web Browsing Information.
We may collect information from your devices and about your web browsing when you visit our Site. We may collect information such as:
Your IP address
The type of browser, devices and operating systems you use
Identifiers associated with the device(s) you use to access our Site
The pages you visit and the features you use, including dates and times
If you navigated from or navigate to another website, the address of that website
Information regarding your internet service provider
5.5 Data Analytics
5.6 Google® Analytics and Web Beacons.
Some of the areas of the Site may contain electronic images known as web beacons (sometimes known as clear gifs) that allow Assurant to count and track users who have visited certain portions of the Site
5.7 Contact Us
We welcome your questions or comments regarding this Notice. Please write to Us at Assurant Privacy Office, 260 Interstate North Circle SE, Atlanta, Georgia 30339, USA or send Us an email at ThePrivacyOffice@assurant.com .
If you have an unresolved privacy or data use concern that We have not addressed satisfactorily, please contact Our US-based third-party dispute resolution provider (free of charge) at https://feedback-form.truste.com/watchdog/request .
Effective date: April 13, 2022