GENERAL TERMS

Gore Mutual Insurance Company (“Gore”, “We”, “Us”, or “Our”) is committed to protecting the privacy of information that is about an individual who is identifiable either by such information alone or by such information in combination with some other available information (the “Personal Information”) of its customers. Your Personal Information will be treated in accordance with the Gore Drive Good Program Privacy Policy (this “Agreement”) and Gore’s Privacy Policy, which can be found on Our website, as amended by Gore from time to time.

Personal Information that is collected as part of the Program will only be used for the purposes listed in this Agreement. If Gore requires the Personal Information for additional purposes, you, as an end user of the App, will be contacted and your consent will be collected anew.

Personal Information is safeguarded and kept in strict confidence. Gore will retain your information either on Our premises or outside of Our premises (such as in the Cloud) in secure facilities.  We maintain physical, electronic and procedural safeguards to Personal Information from unauthorized access.

Access to your Personal Information is restricted to those Gore employees whom We have determined need to know that information to provide products or services to you. In addition, all Our employees are bound by a Code of Conduct and Ethics and a Privacy Policy, both of which include confidentiality and security policies, and are trained on Our privacy policies and procedures.

Personal Information is retained only as long as it is needed, or to meet any legal, regulatory or tax requirements.  We also require Our third party service providers to provide comparable safeguards to protect your information.

If you have any questions regarding Our privacy policies or procedures, you may contact Our

Privacy Office:

Gore Mutual Insurance Company
Attention: Privacy Officer
252 Dundas Street North
Cambridge, Ontario
N1R 5T3
1-800-265-8600 Ext.2423
privacy@goremutual.ca

PROGRAM SPECIFIC TERMS

The below provisions are extracted from the Program’s Conditions of Use Agreement.  “You” and “Your” refers to the end user of the App. Such end user is an individual driver of a vehicle who uses the App or any other part of the Services.

BY INSTALLING, COPYING, DOWNLOADING, ACCESSING OR OTHERWISE USING THE APP, YOU ARE CONSENTING TO BE BOUND BY AND ARE BECOMING A PARTY TO THIS AGREEMENT. IF YOU DO NOT AGREE TO ALL OF THE TERMS OF THIS AGREEMENT, YOU MAY NOT INSTALL, COPY, DOWNLOAD, ACCESS OR OTHERWISE USE THE APP OR ITS CONTENTS.

 

 

COLLECTED DATA

The App will use Your smartphone to continuously collect data about Your driving behaviour.  The App is designed to track and analyze Your driving habits and to rate each trip based on acceleration, braking, cornering, speeding, distracted driving and other contextual factors. These other contextual factors relate to the road infrastructure environment in which You are driving, such as the road name and classification, speed limit, and road features such as roundabouts or speed bumps.

The App will assign a driving score for every trip based on Your driving habits as well as an overall score that will be used on Your policy’s renewal to calculate premium adjustments.

The App will access and collect the following data (collectively, the “Collected Data”):

• Data to confirm the start and end of each trip and to characterize acceleration, braking, cornering, speed and mobile phone use while in the vehicle:
  • Device background location through network, GNSS and GPS (to enable the app to automatically detect trips; includes location, speed, heading, altitude, precision)
  • Accelerometer
  • Gyroscope
  • Magnetometer
  • Phone call state (call active or call not active) and read status/identity
  • Audio pathway (use of a handsfree kit or the internal microphone and speaker)
  • Wi-Fi, Bluetooth, and network status and connections
  • Current date and day of week, time and time zone
• Derived information:
  • Map context (urban or rural road, speed limits, road curvature, lanes, directionality, start and end addresses)
  • Driver/Passenger detection
  • Public transit usage
  • Travel patterns
• Information about the operational environment:
  • Application status (operational state and permissions granted)
  • Battery status of phone
  • Sensor status (airplane mode)
• Information to monitor distracted driving:
  • Phone model
  • Device ID
  • OS version
• Information for enrollment:
  • Name, email, phone number (for activation / engagement / rewards)

USAGE OF DATA

We will only use Your personal data (including your Collected Data) when the law allows Us to do so. The data collected will be shared with third parties and will only be used: (i) to calculate a driving score based on Your driving behaviours to determine Your Score Discount, if any, along with any rewards available to You; and (ii) in an anonymized form as part of Our general analysis and administration of the Program, which includes assessing the performance and stability of the App, and improving the features and performance of the App.

We acknowledge the confidential nature of the Collected Data We will collect or otherwise possess under this Agreement and covenant and agree to protect it from unauthorized use or disclosure by using not less than reasonable physical, technical and administrative safeguards.  We may disclose such information where required by law or for purposes of enforcing this Agreement.

When You enrol in the Program, You acknowledge and consent that Gore and Trak Global Solutions Holdings (Canada) Inc. (“Trak”) may collect and use the Collected Data, some of which may constitute Personal Information about You or any other individual driver of Your vehicle or vehicle in which You are a passenger, solely for the conduct of the Program and related business planning and analysis. You also understand and consent that such Personal Information may be disclosed to Gore and Trak, and vice versa, and to You though the App, as described in this Agreement. You also acknowledge and agree that the Collected Data, including Personal Information, may be accessed by Trak employees located in the United Kingdom for any customer service or support requests You may have in regards to the App; however, the Collected Data and Personal Information will at all times be securely stored in Canada. Gore and Trak will not use Collected Data or Personal Information in any manner that is not permitted in this Agreement.

If You do not consent to Gore’s usage of the Collected Data, You will not be eligible to participate in the Program, and You must accordingly promptly notify Your broker and delete the App from Your smartphone.

RETENTION AND STORAGE OF COLLECTED DATA

In order to satisfy Our obligations under this Agreement as well as any legal, accounting, or reporting requirements, We will retain the Collected Data for 7 (seven) years from the date of its collection. Once Your enrollment in the Program is terminated, You may subsequently contact Your broker to request the deletion of your Collected Data, and We will not retain any of Your Collected Data after the processing of such request. For greater certainty, You may request the deletion of your Collected Data at any time; however, such request will render you ineligible to participate in the Program.

Where Trak has collected or derived Collected Data in accordance with this Agreement, it may reproduce such data into an anonymous derivative data set. Provided no such resulting information is Personal Information, Trak and Gore may aggregate such resulting data with data they collect from other customers to create a compilation of anonymous, aggregated data (the “Aggregated Data”) and use such Aggregated Data for their internal or commercial purposes.  For certainty, Trak and Gore shall ensure such Aggregated Data cannot be used to identify any individual where such data is used on its own or in combination with any other available information.  You agree that We and/or Trak may keep such Aggregated Data for up to ten (10) years.

Trak uses a third party vendor and hosting partner to provide the cloud storage, software, networking, and technology required to run the Services and the App, specifically the APIs of Mapbox, Inc. (“Mapbox”). Mapbox’s privacy policy can be found at https://www.mapbox.com/privacy. The App will provide the Collected Data to Mapbox, which Mapbox may use: (a) for purposes of fulfilling its contractual obligations to Trak; (b) to improve its mapping products and services and for internal diagnostic and analytic purposes; (c) to create aggregated and anonymized usage statistics that it may share with third parties; (d) to provide information back to Trak about how the App is being used; and (e) to track the number of monthly active users using a random ID, which ID is used only for this limited purpose.

Trak and Mapbox are contractually obligated to handle all Personal Information (including the Collected Data) collected by or accessible to them through Gore in accordance with all federal, provincial, state, municipal or other applicable statutes, laws or regulations of any governmental or regulatory authority in any jurisdiction governing the handling of Personal Information (“Privacy Laws”), and to perform their contractual obligations to Gore in a manner that will facilitate Gore’s compliance with Privacy Laws.