MileUp™ Mobile Application
Important Notice Concerning Your Privacy Rights
Last Updated: September 1, 2017
Information You Provide to Us
Personal information is captured when downloading and using this Application. You may make updates to your Personal Information at any time by going to The Basics tab in the Account section of the Application (including your mobile phone number).
When you use this Application you may voluntarily provide us with personal information, which may consist of the following (“Personal Information”):
Join MileUp: When you join MileUp, you provide us with your mobile telephone number.
Redeem Points for Gift Card Rewards: When you redeem the Points you have earned for electronic gift card(s) offered by participating Merchants, you provide us with your name and email address.
Redeem Points for Sweepstakes Entries: When you redeem the Points you have earned for sweepstakes entries, you provide us with your name, email address and date of birth.
Purchase Points to Round-Up Gift Card Points Balance: When this feature is available and you elect to round-up your Gift Card Points balance to acquire the minimum Points balance required to redeem Points for an electronic gift card, you provide us with your name, email address, date of birth, gender, and information about your motor vehicle (the make, model and year). When you elect to purchase Points, you provide us with your name, email address, and certain payment information from your credit/debit card, namely, your credit/debit card number, expiration date, security code and billing zip code. Your credit/debit card information is not stored in the Application.
Report an Accident for Points: When this feature is available to you and you elect to report an accident through the Application, you provide us with your name, email address, motor vehicle registration State and license plate number, the location of the accident, either a photo of an official police report or insurance claim filed in connection with the accident, and other details concerning the accident, which may be required by Agero, in its sole discretion, for verification of truth and accuracy of your accident.
C.L.U.E.® Auto Report: C.L.U.E. stands for Comprehensive Loss Underwriting Exchange and is a database that allows automobile and homeowners insurance providers to exchange information – without notice to you – about claims for loss of property. You may have voluntarily submitted a copy of your C.L.U.E. Auto Report and follow-up materials to Agero, which provided Agero with up to seven years of personal auto claims history, as well as the following Personal Information: your name, date of birth, insurance policy number, date(s) of loss, type(s) of loss, amount the insurance company paid in connection with such loss(es), description of the vehicles (including VIN).
Get Help: Personal Information may be captured when you communicate with us through the “Get Help” link located in the Settings page of the Application. You are advised to limit the information you provide to us through such messaging communications to only that which is necessary to assist you with the Application, or to respond to our request, and in any event, you should never include any sensitive data, such as credit card numbers, passwords, or other personal and/or sensitive information.
Accident Alert (Beta): When this feature is made available to you and you elect to enable the Application to include the Accident Alert (Beta) feature, you will be asked to provide us with profile information including, your name, email address, date of birth, gender, and certain information about your motor vehicle, including the make, model and year of your motor vehicle. You will also be asked to provide us with the name(s) and mobile phone number for up to three individuals who may be contacted by us in the event of an Accident Alert (“Emergency Contact”), and the relationship of the Emergency Contact to you (i.e. spouse). By providing us with the name(s) and mobile phone number(s) of Emergency Contact(s), you are representing to us that the contact information you have provided for such Emergency Contact(s) is truthful and accurate, and you have the express consent of each such Emergency Contact to be contacted by us at the phone number listed in the event of an Accident Alert (including the ability to call notwithstanding being listed on a state or federal “do-not-call” registry, and the ability to contact the individual on their mobile phone).
Automatically Collected Information
This Application operates in the background and automatically collects certain information about you. This information may include, but is not limited to, some or all of the following items: (a) the real-time geographic location of your Device and motion activity, (b) the type and version of software and operating system you use; (c) date, time, and duration of your Device use; (d) your IP address; (e) Device specific activity, such as battery level, Bluetooth connectivity, and Wi-Fi connectivity; (f) type of Device and your Device’s unique device identifier; and (h) mobile network provider, and/or Internet service provider. Additionally, every time you view or use the Application, certain information is automatically collected in an aggregated manner about your use of the Application. This information may include, but is not limited to, the specific pages, buttons, images, videos, links, or forms that you access on the Application. Automatically collected information is collected in an aggregated manner in which you are not personally identified. If you do not want us to collect this information, do not download the Application or delete or uninstall the Application from your Device.
This Application does not respond to web browser “Do Not Track” signals or other similar mechanisms regarding the collection of personal information.
How We Use and Share Your Information
We limit the information we collect from you while using the Application to what is necessary to administer our business, design and offer products and services that may be of benefit to you and our other mobile programs, and ensure technological compatibility with your Device. From time to time, we may use, share and transfer information that personally identifies you that we collect or you provide:
- To our affiliates;
- To contractors, service providers, Merchants, and other non-affiliated third parties we use to support our business, process payments (including debit/credit card payments through the Application), and who are bound by contractual obligations to keep personal information confidential and use it only for the purposes for which we disclose it to them;
- To third party service providers, including, without limitation, a 911 emergency call center in the event of an Accident Alert;
- In response to judicial proceeding, subpoena, court order or other legal process, or to otherwise comply with legal, regulatory or administrative requirements of governmental authorities;
- In connection with a corporate merger, consolidation, restructuring, the sale of some or all of our equity and/or assets, or other corporate change of control, including, during the course of any due diligence process related to such corporate change;
- To protect the rights or property of Agero, its clients, suppliers or customers, and to enforce the provisions of our terms or policies, in cases of customer fraud or disputes, and/or to prevent harm to you or others;
- In connection with a sweepstakes, survey, contest or other promotion that is sponsored by us and administered by a third party, we may share information with the administrator. Any subsequent use of such information by the third party administrator shall be subject to such third party’s privacy policies and practices. Surveys, sweepstakes and other promotions conducted on behalf of us and a third party administrator will include branding from or otherwise identify such third party administrator; or
- As permitted or required by law, or as authorized by you (including, without limitation, to your Emergency Contact(s)).
General Privacy Disclosure
(a) Technical Information. You agree that Agero and its affiliates may collect and use technical and related information, including but not limited to information about your Device, system and application software, peripherals or other similar information, that is gathered periodically to facilitate the provision of software updates, product support and other services to you (if any) related to this Application, and to verify compliance with these Terms. Agero may also use this information to improve its products or to provide better services or technologies to you moving forward.
(b) Location Information. The services provided through this Application may rely upon location information. To provide these services, Agero, and its affiliates and partners may transmit, collect, maintain, process and use your location data, including the real-time geographic location of your Device. By using this Application, you agree and consent to Agero, and its affiliates and partners’ transmission, collection, maintenance, processing and use of your location data to provide you with services. The location data is collected in a form that personally identifies you and/or your Device. You may at any time opt-out from allowing the Application to use your location information by turning off this feature at the Device level, by going into Settings and switching off “Location Services” for the Application. Note, however, that opting out of the Application’s collection of location information will cause its location-based features to be disabled and some parts of the Application may then be inaccessible or not function properly, including, without limitation, the Application’s ability to detect Accident Alerts and track and collect Points in your MileUp account. In the event an Accident Alert is detected, the location data and other information collected through the Application may be transmitted to an Agero call center agent, and a 911 emergency call center agent. We may also disclose information (including your location) to your Emergency Contacts. You expressly acknowledge that you have obtained the express consent from your Emergency Contacts to be contacted by us by phone call at the number provided by you for such Emergency Contact in the event of an Accident Alert.
(c) Driver Behavior. You acknowledge and agree that the Application may periodically access and collect information about your Device and driving activity that can be detected by your Device, including the following “Driver Behaviors”: speed of your automobile, braking and acceleration habits, distracted driving habits through use of your Device while driving, distances and precise routes driven and time spent driving, and other driving events, which may include detection of an Accident Alert. The Driver Behaviors collected through the Application may be collected for any motor vehicle that you are in, regardless of whether you are the driver or the passenger. You may edit the driving information tracked on a particular trip by going to the “Daily Driving” link in the Application and selecting the appropriate mode of transportation and whether you were the driver or the passenger for any particular driving trip.
(d) Get Help. You may communicate with Agero by sending messages through the Application’s “Get Help” link located in the Application’s Settings page. The information you provide us through this messaging service may be shared with our affiliates and third party service partners in connection with the support of the Application and our business. You acknowledge and agree that Agero may communicate with you through this messaging feature to respond to your inquiries, feedback and requests, or to inform you of promotions, updated features and services or to manage your account. By using this Application, you agree and consent to Agero, and its affiliates and partners’ transmission, collection, maintenance, processing and use of the information you provide to us through this messaging service to provide you with services. You should limit the information you provide to us through this messaging service to only that which is necessary to assist you with the Application, or to respond to our request, and in any event, you should never include any sensitive data, such as credit card numbers, passwords, or other personal and/or sensitive information.
(e) Quality Assurance. You acknowledge and agree that communications, including “chat” services with Agero or its third party agents may be monitored and recorded and retained by Agero.
(f) Aggregate Information. Our definition of Personal Information does not include “aggregate” information. Aggregate information is data we collect about a group or category of products, services or customers, from which individual customer identities have been removed, and which may be disclosed by Agero. In other words, information about how you use a service may be collected and combined with information about how others use the same service, but no personally identifiable information will be included in the resulting data. Likewise, information about the services you provide or receive may be collected and combined with information about the services provided or received by others. Aggregate data helps us understand trends and customer needs so that we can better consider new products and services, and tailor existing products and services to customer desires. We may use, share, transfer or disclose aggregated information about our users and information that does not identify any individual or Device without restriction.
Social Sharing Services
Your use of social sharing services (such as Facebook or Twitter) (collectively, “Social Sharing Services”) enables the sharing of information with your friends or the public, depending on the settings you establish with the Social Sharing Service. Please refer to the privacy policies of the Social Sharing Services for more information about how they handle the data you provide to or share through them.
Use of Third Party Service Providers
We may use third party service providers (including, Facebook) to evaluate and provide data analytics services, audience measurement services and place target advertisements. These third party service providers may set and access their own cookies, web beacons, embedded scripts and other storage technologies to collect or receive information from your Device when you use the Application, as well as when you visit other websites and applications, and they may otherwise collect or have access to information about you, including non-personally identifiable information. You may opt-out of receiving ads targeted to your interests by accessing your Device’s “limit ad tracking” button located in the Settings app on your Device.
Sweepstakes, Contests, Promotions and Surveys
From time to time, we may offer you the opportunity to participate in sweepstakes, contests, surveys and other promotions. Any personal information submitted in connection with such activities will be treated in accordance with this policy, except as specifically set forth in the rules, terms or conditions for those sweepstakes, contests, surveys or promotions.
The Personal Information we collect is stored within our databases on cloud-based servers hosted by Amazon Web Services, with the use of standard, industry-wide, commercially-reasonable security practices designed to help us protect your information. You can learn more about Amazon Web Services’ data security policies here: https://aws.amazon.com/security/.While such security standards are used, we cannot guarantee the security of our databases, nor can we guarantee that personally identifiable information you supply won’t be intercepted while being transmitted to us over wireless communication, and any information you transmit to Agero you do at your own risk.
Notice to Persons Accessing this Application Outside of the United States
The Application is not intended for use outside of the United States. If you travel or reside outside the U.S., any information you provide to us on this Application will be transferred out of your country and into the U.S. or any other country in which Agero or its affiliates, subsidiaries or service providers maintain facilities. If you do not want your personally identifiable information to leave your country, do not provide the information to us. By providing personally identifiable information to us, you explicitly consent to the transfer of your information to the U.S. or any other country in which Agero or its affiliates, subsidiaries or service providers maintain facilities. Personally identifiable information collected on this Application or during the provision of Services may be stored and processed in the U.S. or any other country in which Agero or its affiliates, subsidiaries or service providers maintain facilities.
No Use of this Application by Children
The application is not intended for users under age 18. We do not intend to collect information from children who are under 18 years of age. If you are under 18, you should not use this Application.
Your California Privacy Rights
California Civil Code Section 1798.83 permits Application users who are California residents to opt-out of having your information shared with third parties for direct marketing. If you are a California resident and wish to opt-out of having your information shared in this manner, you may go to the “Legal” tab in the “Account” section in the Application and click on the “CA Data Share Opt-out” button. Once the “CA Data Share Opt-out” button in the Application is selected, an email directed to our privacy manager will automatically open within the Application for you to send with your opt-out request. Alternatively, you may send us an email without using the “CA Data Share Opt-out” button in the Application, by emailing us directly at email@example.com. If you elect to send us an email directly, please be sure to include “CA Data Share Opt-out” in the subject line of your email, and provide sufficient detail in your email, so that we may appropriately respond to your request.
Should you wish to contact us relating to the Application, your MileUp account, or the Terms, please contact us at: MileUp, One Cabot Road, Medford, MA 02155, Attention: General Counsel; or by email: firstname.lastname@example.org. Please be sure to provide sufficient detail so that we may appropriately respond to your question or concern.
MileUp and the MileUp logo are trademarks of Agero, Inc. C.L.U.E. is a registered trademark of LexisNexis Risk Solutions, Inc.
Agero Customer Services, Inc. is a subsidiary of Agero, Inc.
©2017 Agero, Inc. All rights reserved.