Data Policy

Introduction

This Privacy Policy applies to all the products, services, websites and apps offered by World Wide Warranty Life Services Inc. We refer to those products, services, websites, and apps collectively as the “Products” in this policy.

References to "data" in this Privacy Policy will refer to whatever data you disclose to Warranty Life to use our services, any data collected in a form, mobile application, or data inserted on a site hosted by us. Reference to “personal information”, “personal data”, or simply “information” in this Privacy Policy refers to information about you personally that we collect or for which we act as custodian.

At Warranty Life, we strive to align our privacy practices and program with the following data protection and privacy laws:

As we continue to expand our services globally, we will endeavour to update our privacy practices and programs to ensure ongoing compliance with the local laws of those jurisdictions.

I. What kinds of information do we collect?

To provide you with the Warranty Life Product, we must collect and process some information about you. The types of information we collect and process will depend on how you use our Products.

Here are some examples of how we process your personal data:

Things you and others do and provide.

• Information and content you provide. We collect the content, communications and other information you provide when you use our Products, including when you sign up for an account or when registering a Product. This can include information in or about the content you provide (like metadata), such as the location of a photo or the date a file was created. Our systems automatically process content and communications you and others provide to analyze context and what's in them for the purposes described below.
• Data with special protections: You can choose to provide information in the Warranty Life app.
• Your usage. We collect information about how you use our Products, such as the frequency and drop of your device, the date, time and location of such drops, and periodic check on the presence of a protective case.
• Information about transactions made on our Products. We collect a limited amount of personal information about the purchase or transaction. This includes payment information, such as your credit or debit card number and other card information; other account and authentication information; and billing, shipping and contact details.
• Things others do and information they provide about you. We also receive and analyze content, communications and information that other people provide when they use our Products. This can include information about you.
• Cookies: We place, with your consent, cookies on your browser to enhance your experience with our website, so that it runs optimally. You have the option to delete these cookies at any time in your browser settings.

Device Information

As described below, we collect information from and about the phones, and we combine this information across different devices in relation to Warranty Life products you have purchased. For example, we use information collected about your use of our Products on your phone that may enable us to provide discounted offerings.

Information we obtain from these devices includes:

• Device attributes: information such as the operating system, hardware and software versions, battery level, signal strength, available storage space, browser type, app and file names and types, and plugins.
• Device operations: information about operations and behaviors performed on the device, such as whether a window is foregrounded or backgrounded, or mouse movements (which can help distinguish humans from bots).
• Identifiers: unique identifiers, device IDs, and other identifiers.
• Device signals: Bluetooth signals, and information about nearby Wi-Fi access points, beacons, and cell towers.
• Data from device settings: information you allow us to receive through device settings you turn on, such as access to your GPS location, camera or photos.
• Network and connections: information such as the name of your mobile operator or ISP, language, time zone, mobile phone number, IP address, connection speed and, in some cases, information about other devices that are nearby or on your network, so we can do things like help you identify device issues.

II. How do we collect your data?

We collect your personal data in the following ways:

• When you visit our website: we provide you with a cookie notice whenever you visit our site
• When you sign up for our mailing list: if you choose to receive marketing communications, you also have the right to easily unsubscribe at any time
• When you purchase our services: we will need a certain amount of personal data to process payment, such as your credit card information, contact details, and other data elements required for the transaction
• When you download our app: we will provide you with a notice of our intention to collect your personal data, the purposes of doing so, and a link to this privacy policy if you have further questions or concerns
• If you choose to complete our optional customer surveys: we will ask for a number of non-identifiable demographic information, such as but not limited to: age range, gender, marital status, insurance policies previously purchased, or the like. As much as possible, we will ask for only demographic information, which we will aggregate and de-identify in order to protect your privacy.

III. How do we use this information?

We use the information we have (subject to choices you make) as described below and to provide and support for Warranty Life Products. Here's how:

Provide, personalize and improve our Products.

We use the information we have to deliver our Products, including to personalize Product offerings, pricing and features

• To create personalized Products that are unique and relevant to you, we use your data we collect and learn from you and others; and how you use and interact with our Products.
• Information across Warranty Life Products and Services: We connect information about your activities with us to additionally support Product offerings and improvements.
• Location-related information: We use location-related information-such as your current location, where you live, the places you like to go, and the businesses and people you're near-to provide, personalize and improve our Products.
• Product research and development: We use the information we have to develop, test and improve our Products, including by conducting surveys and research, and testing and troubleshooting new products and features.

Provide measurement, analytics, and other business services.

We use the information we have to help manufacturers and insurance companies and other partners measure the effectiveness and distribution of their products and understand the types of people who use their services and how people interact with these partners.

Promote safety, integrity and security.

We use the information we have to verify accounts and activity, combat harmful conduct, detect and prevent spam and other bad experiences, maintain the integrity of our Products, and promote safety and security on and off of Warranty Life Products. For example, much of the data we collect will be used to identify and help prevent fraud.

Communicate with you.

We use the information we have to send you marketing communications, communicate with you about our Products, and let you know about our policies and terms. We also use your information to respond to you when you contact us.

Research and innovate for social good.

We use the information we have (including from research partners we collaborate with) to conduct and support research and innovation.

IV. How is this information shared?

Your information is shared with others in the following ways:

Sharing on Warranty Life Products

People and accounts you share and communicate with

When you share and communicate using our Products, you choose the audience for what you share. For example, at your choice, you may provide a unique warranty number to list publicly for the purposes of warranty confirmation when selling your device.

Public information can be seen by anyone, on or off our Products, including if they don't have an account and identify information about your active status or presence with our Product.

Apps, websites, and third-party integrations on or using our Products.

If the ownership or control of all or part of our Products or their assets changes, we may transfer your information to the new owner.

Sharing with Third-Party Partners

We work with third-party partners who help us provide and improve our Products. When you opt in for SmartSaver Driving, you authorize insurance companies (or their agents) and marketing partners to place marketing calls (including via text/SMS) to the phone number you provided above using automated telephone dialing systems and/or artificial or pre-recorded messages. You acknowledge that consent is not a condition to purchase goods or services, and that you may revoke your consent at any time. We also impose strict restrictions on how our partners can use and disclose the data we provide. Here are the types of third parties we share information with:

Partners who use our analytics services.

We provide aggregated statistics and insights that help businesses understand how people are engaging with their products. For example, we may use information to improve or identify better case products.

Vendors and service providers.

We provide information and content to vendors and service providers who support our business, such as by providing technical infrastructure services, analyzing how our Products are used, providing customer service, facilitating payments or conducting surveys.

Researchers and academics.

We also provide information and content to research partners and academics to conduct research and innovation that support our business or mission, and enhance discovery and innovation.

By consenting to using your information for research purposes, you are not waiving your rights. If we do collect your data, collected data will be anonymized and aggregated so as not to connect it to individuals.

Location of Processing

We store your information with Amazon Web Services, using both their Canadian and American servers. The storage of your personal data in Canada is compliant with the EU’s adequacy decision recognizing that Canadian data privacy laws are sufficient to safeguard EU data subject personal data.

We also store a limited amount of personal data at AWS’s US servers, which is permitted due to AWS having all proper data protection measures in place, in compliance with the data sovereignty and transfer requirements under the General Data Protection Regulation (GDPR). For more information about AWS’s GDPR-compliant program, click here

Storage of Personal Information

In order to provide services, we disclose and store some of your personal information with third-party service providers as indicated above. For transparency and accountability purposes, the following is a chart depicting the personal information we collect, why we use it, and if we disclose this information to a service provider or partner.

We also collect optional personal information to better enhance your overall customer experience with Warranty Life. For those additional pieces of optional personal information, we disclose the data as follows:

It should be noted that for any additional personal data you provide, we do not disclose your identity to third parties when we perform customer demographic analysis. Your personal data will not be used to contact you for market research purposes without your express consent.

If you would like further information with respect to the data inventory above, please contact us (see Part IX below for our contact information).

V. How can I manage or delete information about me?

We store data until it is no longer necessary to provide our services, or until your account is deleted - whichever comes first. This is a case-by-case determination that depends on things like the nature of the data, why it is collected and processed, and relevant legal or operational retention needs.

When you delete your account, you won't be able to recover that information later. To delete your account at any time, please send an email to service@warrantylife.com. Please note that we may be required to retain a limited amount of your personal data even after you delete your account to comply with legal or other due diligence requirements.

VI. How do we respond to legal requests or prevent harm?

We access, preserve and share your information with regulators, law enforcement or others:

• In response to a legal request (like a search warrant, court order or subpoena) if the law requires us to do so. This may include responding to legal requests from jurisdictions outside of the United States when we have a good-faith belief that the response is required by law in that jurisdiction, affects users in that jurisdiction, and is consistent with internationally recognized standards.
• When we have a good-faith belief that it is necessary to: detect, prevent and address fraud, unauthorized use of the Products, violations of our terms or policies, or other harmful or illegal activity; to protect ourselves (including our rights, property or Products), you or others, including as part of investigations or regulatory inquiries; or to prevent death or imminent bodily harm. For example, if relevant, we provide information to and receive information from third-party partners about the reliability of your account to prevent fraud, abuse and other harmful activity on and off our Products.
• Information we receive about you can be accessed and preserved for an extended period if or when it is the subject of a legal request or obligation, governmental investigation, or investigations of possible violations of our terms or policies, or otherwise to prevent harm. We also retain information from accounts disabled for terms violations for at least a year to prevent repeat abuse or other term violations.

VII. How will we notify you of changes to this policy?

We'll notify you before we make changes to this policy and give you the opportunity to review the revised policy before you choose to continue using our Products. These changes will be communicated to you via email, or via a pop-up notification in the app

VIII. EU Residents – Your Data Privacy Rights

If you are a resident of the EU, you have data subject rights under the General Data Protection Regulation (GDPR). Your data privacy rights are as follows:

• Right of Access to Information: You have the right to obtain a copy of your personal data from Warranty Life. We may charge you a small fee for processing this request.
• Right to Rectification: You have the right to rectify or correct any personal data we have collected about you if it is factually incorrect or inaccurate. You also have the right to ask us to complete any personal data about you that is incomplete.
• Right of Erasure (to be Forgotten): You have the right to direct us to delete your personal data. This right of erasure is limited, however, as we reserve the right to retain your personal data in compliance with applicable laws or court orders. Please note that this right does not apply to any personal data that is necessary to continue to provide you with our services.
• Right to Limit Processing of Data: You have the right to direct Warranty Life to restrict the processing of your personal data, subject to certain restrictions. Please note that this right does not apply to any personal data that is necessary to continue to provide you with our services.
• Right to Object to Processing of Data: You have the right to object to the processing of your personal data, subject to certain restrictions. Please be advised that once we have received your objection, we will stop processing your data, but it may severely limit our ability to provide you with goods and services. Please note that this right does not apply to any personal data that is necessary to continue to provide you with our services.
• Right of Portability: You have the right to direct us to provide you a copy of your personal data, and to transfer that personal data to the entity of your choice. All data sets and records in data portability requests shall be provided in a common, machine-readable format.

If you wish to exercise your data subject rights, please make your requests in writing. We will endeavour to respond to your request within 30 calendar days. Please note that if your request is unclear, we will contact you to seek additional clarification. If you make an access request and there is a large volume of personal data to gather, or you make several requests within a short period of time, we reserve the right under GDPR to take a two-month extension to fully respond to your request.

IX. How to contact us with questions

If you have questions about this policy, you can contact us at privacy@warrantylife.com.