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Regarding personal information

Thank you for your recent request to know about your personal information – your privacy is very important to us. Provided with this document is a file containing your specific pieces of personal information.

The personal information was sought from the records from Direct Auto companies. To learn more about the personal information from the records of National General Insurance and Roadside Companies, please review their online privacy statements which contain information about their privacy practices and how to submit a request for your personal information they may have collected.

Per your verified request, we are providing you a file containing the personal information about you that is subject to the California Consumer Privacy Act (CCPA). Some of the personal information we collect about you in connection with our insurance products is not subject to CCPA because it is collected or processed pursuant to certain federal or state laws such as the Gramm-Leach-Bliley Act.

Please also note the following about your personal information file:

• The amount and type of personal information included in the attached file will vary based on your relationship with the National General companies. Based on the personal information about you that we located, it appears that you are not a customer, but you were directly or indirectly involved in a claim or requested a quote.
• The way the personal information is presented will vary based on how the information is kept in each system. Some of your information has been redacted or not returned due to risk of fraud as required by CCPA, such as your social security number, drivers’ license number, financial account number or account passwords. We will let you know that we have collected it but will not provide you with the actual personal information in the response.
• For each piece of personal information returned, we have indicated the category in which that piece of personal information belongs. The categories are listed below with examples of the types of personal information that fall into each category. Those categories allow you to better understand the personal information that is shared and with whom it is shared.
• To protect consumer’s privacy, we only return personal information that we are confident belongs to you. That would mean some data that might belong to an individual with a similar name or address may not be returned to you if we aren’t certain it is yours.

To view your personal information, please refer to the attached document titled with your name.

For additional information on how to read the personal information file, please see the attached “Frequently Asked Question” document.

As required by the CCPA, the following response, together with the information contained in the personal information file, explains the following for the personal information collected in at least the past 12 months:

1. The categories of personal information collected;
2. the categories of sources from which personal information was collected;
3. the business or commercial purposes for collecting personal information; and
4. the categories of third parties with whom we share personal information and the personal information shared with those categories of third parties.

The file of your personal information shows the category of personal information for each piece of information. These are the categories:

Personal information categories	Examples
Personal identifiers	Name, alias, signature, postal address, phone number, date of birth, unique personal identifier, online identifier, email address, internet protocol (IP) address, state identification number, account name, Social Security number, driver's license number, passport number, or other similar identifiers.
Personal characteristics	Age, race, ancestry, national origin, citizenship, religion, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information), and other description of your physical characteristics (e.g., height).
Service or product related information	Policy coverage information, policy number, premiums, account name and payment history, driving record, claims history, credit information, records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies, bank account or credit card number or other payment or financial information, medical information or health insurance information, professional or employment‐related information, education records such as grades or transcripts, and family member information.
Biometric and multimedia information	Fingerprint, voice print, retinal print, scan of hand or facial geometry, audio, electronic, visual or similar information.
Internet or other electronic network activity information	Browsing history, search history, information regarding your interaction with our website, application or advertisement, links you use or web pages you visit while visiting our site or applications, browser type, internet service provider (ISP), cookies, and mobile device information including device identifier or other information.
Geolocation data	Physical location, movements, or trip tracking information.
Inferences	Inferences drawn from the personal information collected to create a profile reflecting preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities and aptitudes.

We collect personal information in different ways and from several sources based on your relationship with us including:

• Directly from you Including when you sign up for services, buy a product, subscribe to a membership or mailing list, set up an account with us, or during the quoting, registering, application, claims handling or roadside assistance process. Personal information collected may include name, address, and other important identifying information,
• Automatically when you use one of our websites, mobile apps, view our emails or otherwise engage with us through a computer or mobile device (“Sites”) such as IP address, cookies, browsing history and other device or internet information, and
• From other parties to help us set up, manage, protect, or service your account or send marketing communications, such as consumer reporting agencies, service providers, marketing companies and data providers.

We use your personal and other information for business and commercial purposes based on your relationship with us including to:

• Provide and maintain services and products. We may use your personal information to provide or maintain service or products including to handle a claim, complete a transaction, repair a product, or respond to customer service requests or other inquiries. We may also collect information about other parties from you to carry out necessary services and/or requests. If you provide us personal information about others, or if others give us your information, we will only use that information for the specific reason for which it was provided to us.
• Improve, develop, and analyze our Sites, services, and products. We use your personal information and other information to:
  • analyze, improve, develop, or deliver our Sites, products and services and develop new services, products or features using algorithms, analytics software, and other similar methods,
  • conduct actuarial or research studies to maintain, protect and develop our networks, services, and products and protect our customers, and
  • analyze how visitors use our Sites to improve the Sites and enhance and personalize your experience.
  We collect some information used for these purposes using analytics software, cookies, and other tracking technologies. For more information about the collection and use of this information, see Cookies and Other Tracking Technologies in our Privacy Statement found at https://nghcprivacy.com/direct-auto/onlineprivacystatement.
• Communicate with you about a claim. We may communicate with you about a claim or respond to an inquiry.
• Provide marketing communications. We may use your personal information collected from other parties to send you promotional communications about products, services, features, and options we believe may be of interest to you. We may send communications via e-mail, regular mail or may send push notifications via a mobile device. Push notification preferences are controlled in your device. We may also use your information to serve you ads or customized content online.
• Comply with legal requirements and protect the safety and security of our business, services, and Sites. We may use your personal information to comply with laws, regulations, or other legal obligations, to assist in an investigation, to protect and defend our rights and property or the rights of third parties or enforce terms and conditions. We may also use your personal information to prevent suspected fraud, threats to our network or other illegal activities, prevent misuse or for any other reason permitted by law. We may use your personal information to protect our company, our affiliates, our customers, our network, and our Sites.
• Update or correct our records. We may receive personal information about you from other sources, including publicly-available databases or third parties from whom we have purchased data, and combine that personal information with other personal information we have about you to update our records. For example, we may obtain change of address information from public sources and use that personal information to update or correct your address information.
• Find locations on request. Your location may be obtained from the mobile device or the network using your device's GPS functionality or directly from you. We may use your location information to search for information including searching for an agent or identifying the location of an accident you are reporting. If you do not want location information used, you can disable the GPS functionality on your mobile device.

We do not sell your personal information. We may share your personal information with our affiliates for business purposes consistent with the uses described in our Privacy Statement. We may also share information about you with third parties whenever you consent to or direct such sharing.

The following table lists the categories of personal information that we may have collected from you and the categories of service providers or third parties to whom we have disclosed those categories of personal information for a business purpose. Please refer to your personal information file for the categories of information for the personal information we have collected from you specifically.

A checkmark (✓) below indicates we share the personal information with that category of service provider or third party.

For more information about our privacy practices, please review our Privacy Statement at https://nghcprivacy.com/direct-auto/onlineprivacystatement.

Sincerely,

The Direct Auto Privacy Team