Faye™ Privacy Policy

Last updated: November 16, 2022

In order to ensure transparency and give you more control over your personal information, this privacy policy (“Privacy Policy”) governs how we, Zenner, Inc., doing business as Faye (“Faye”, “Zenner”, “we”, “our” or “us”) use, collect and store personal information that we collect or receive from or about you (“you”) in connection with https://www.withfaye.com/ and the services provided therein, as well as when you make use of, or interact with, our website, and/or, mobile software application (collectively, the “Services”):

We greatly respect your privacy, which is why we make every effort to provide a platform that would live up to the highest user privacy standards. Please read this Privacy Policy carefully, so you can fully understand our practices in relation to personal data. “Important note: Nothing in this Privacy Policy is intended to limit in any way your statutory rights, including your rights to a remedy or other means of enforcement. Table of contents: 1. What information we collect, why we collect it, and how it is used 2. How we protect and retain your Personal Information 3. How we share your Personal Information 4. Your privacy rights. 5. Use by children 6. Interaction with third party products 7. Analytic tools 8. Specific provisions applicable under California privacy law 9. Contact us

This Privacy Policy can be updated from time to time and, therefore, we ask you to check back periodically for the latest version of this Privacy Policy. If we implement material changes in the way we use your information, in a manner that is different from that stated at the time of collection, we will notify you by posting a notice on our Website or by other means and take any additional steps as required by applicable law.

1. What information we collect, why we collect it, and how it is used

We Process the Following Personal Information:

Information You Provide Directly to Us. We collect the following information you provide directly to us, including, without limitation, information when you browse, download, and make use of our Services: full name, email address, phone number, home address, passport number, past insurance claim information, , as well as any other information that you decide to provide/supply us with when you communicate with Zenner (via email, website or telephone).

Information from Other Sources. Zenner may also obtain information about you from other sources, including publicly - or commercially- available information, and through third-party data platforms, partners and service providers.

Automatic Data Collection. We may automatically collect certain information through your use of the Zenner Services, such as your Internet protocol (IP) address, cookie identifiers and other device identifiers that are automatically assigned to your device, browser type and language, geo-location information, hardware type, operating system, internet service provider and other information about actions taken through the use of the Zenner Services.

We process information for the following purposes:

To provide you with the Zenner Services. Zenner will use your information to provide the Zenner Services. For example, if you request insurance coverage, we will use the information to: (i) process your request; (ii) communicate with you about the options that you may have for the requested insurance; (iii) fulfill any orders for services or products made by you; (iv) track transactions conducted by you; (v) send you more information about our products, services and offerings; and (vi) to personalize your experience with the Zenner Services. We may also use your information to contact you about incomplete applications or other forms and submissions available through the Services.

For Administrative Purposes. Zenner may use your information (i) to respond to your questions, comments, and other requests for customer support, or information, including information about potential or future services; (ii) to provide you with the Zenner Services; (iii) for internal quality control purposes; (iv) to establish a business relationship; and (v) to generally administer the Zenner Services.

To Market the Zenner Services. Zenner may use information to market the Zenner Services. Such use includes (i) notifying you about offers and services that may be of interest to you; (ii) tailoring content, advertisements, and offers for you, including, targeting and re-targeting practices; (iii) conducting market research; (iv) developing and marketing new products and services, and to measure interest in Zenner’s services; (v) other purposes disclosed at the time you provide information; and (vi) as you otherwise consent.

Security purposes. Some of the above mentioned information will be used for detecting, taking steps to prevent and prosecuting fraud or other illegal activity; to identify and repair errors; to conduct audits; and for security purposes. Information may also be used to comply with applicable laws, with investigations performed by the relevant authorities, law enforcement purposes, and/or to exercise or defend legal claims.

De-identified and Aggregated Information Use. In certain cases, we may or will anonymize or de-identify your Information and further use it for internal and external purposes, including, without limitation, to improve the services and for research purposes. We may use this anonymous or de-identified information and/or disclose it to third parties without restrictions (for example, in order to improve our services and enhance your experience with them).

We, as well as third parties (such as Google) that provide content, advertising, or other functionality on the Zenner Services, may use cookies, pixel tags, local storage, and other technologies (“Technologies”) to automatically collect information through the Zenner Services. We use Technologies that are essentially small data files placed on your device that allow us to record certain pieces of information whenever you visit or interact with the Zenner Services. If you would like to opt out of the Technologies we employ on the Zenner Services, you may do so by blocking, deleting, or disabling them as your browser or device permits. You can opt out of Google's use of cookies or device identifiers by visiting Google's Ads Settings. Alternatively, you can point your visitors to opt out of a third-party vendor's use of cookies by visiting the Network Advertising Initiative opt-out page or control the use of device identifiers by using their device’s settings.

2. How we protect and retain your information

Security. We have implemented and maintain reasonable technical, organizational and security measures designed to protect your information. However, please note that we cannot guarantee that the information will not be compromised as a result of unauthorized penetration to our servers. As the security of information depends in part on the security of the computer, device or network you use to communicate with us and the security you use to protect your user IDs and passwords, please make sure to take appropriate measures to protect this information.

Retention of your information. Your information will be stored until we delete our records, and we proactively delete it, or if you send a valid deletion request. Please note that in some circumstances we may store your information for longer periods of time, for example (i) where we are required to do so in accordance with legal, regulatory, tax or accounting requirements, or (ii) for us to have an accurate record of your dealings with us in the event of any complaints or challenges, and/or (iii) if we reasonably believe there is a prospect of litigation relating to your information or dealings.

3. How we share your information

In addition to the recipients described above, we may share your information as follows:

The information Zenner gathers is shared with our partners and other third parties. We disclose your information as is necessary for us to provide you with the insurance products and services you expect us to provide, including, without limitation, insurers, reinsurers, insurance intermediaries, brokers, reinsurance brokers, wholesale brokers, underwriters, actuaries, insurance reference bureaus, fraud detection agencies, advisers, loss adjusters, claim adjusters, lawyers, accountants, bookkeeping and others involved in the insurance production, and insurance claims handling process. For example, we may share some of your information with an insurance carrier and/or an independent insurance agency for the purpose of obtaining a quote. Please Note: Third party insurance carriers and independent insurance agencies have their own privacy policies and we are not responsible for these policies nor the products and/or services offered by third party providers, so please make sure to review the privacy policy of any third party carrier from whom you may purchase a policy.

In order to provide you with our services, and only where permitted by law, we may share information you submitted with: (1) our partners who may share with certified credit bureaus to verify information about your credit report; and (2) government agencies to verify your previous claims history and other relevant information. Your information is maintained by credit agencies and disclosed by them to others as permitted by law.

We may also share information with our affiliated companies about you.

We may use third party service providers to process your information for the purposes outlined above, including, without limitation:

With cloud service providers for hosting purposes;

With websites and web content creation platforms in order to help us manage our Website;

With email providers, marketing, CRM, other similar tool providers and/or sales dialer software;

With analytic companies, in order to help us understand and analyze information we collect in accordance with this policy;

With insurance carriers integration platforms, comparative raters;

With government agencies, such as departments of insurance, where required by law;

With billing companies; and/or

With data validation and enrichment companies.

To the extent necessary, with regulators, courts, banks or competent authorities, to comply with applicable laws, regulations and rules (including, without limitation, federal, state or local laws), and requests of law enforcement, regulatory and other governmental agencies or if required to do so by court order, as well as for internal compliance procedures and to protect the safety, security, and integrity of Zenner, our Services, customers, employees, property, and the public.

If, in the future, we sell or transfer, or we consider selling or transferring, some or all of our business, shares or assets to a third party, we will disclose your information to such third party (whether actual or potential) in connection with the foregoing events (including, without limitation, our current or potential investors). In the event that we are acquired by, or merged with, a third party entity, or in the event of bankruptcy or a comparable event, we reserve the right to transfer, disclose or assign your information in connection with the foregoing events.

Where you have otherwise provided your consent to us for sharing or transferring your information.

4. Your privacy rights

Rights: You can exercise your rights by contacting us at [email protected]. Subject to legal and other permissible considerations, we will make every reasonable effort to honor your request promptly in accordance with applicable law or inform you if we need further information in order to fulfill your request. When processing your request, we may ask you for additional information to confirm or verify your identity and for security purposes, before processing and/or honoring your request. We reserve the right to charge a fee where permitted by law, for instance if your request is manifestly unfounded or excessive. In the event that your request would adversely affect the rights and freedoms of others (for example, would impact the duty of confidentiality we owe to others) or if we are legally entitled to deal with your request in a different way than requested, we will address your request to the maximum extent possible, all in accordance with applicable law.

Marketing emails – opt-out: You may choose not to receive marketing email of this type by sending a single email with the subject "BLOCK" to [email protected]. Please note that the email must come from the email account you wish to block OR if you receive an unwanted email from us, you can use the unsubscribe link found at the bottom of the email to opt out of receiving future emails, and we will process your request within a reasonable time after receipt.

5. Use by children

We do not offer our products or services for use by children and, therefore, we do not knowingly collect information from, and/or about children under the age of 18. If you are under the age of 18, do not provide any information to us without the involvement of a parent or a guardian. In the event that we become aware that you provide information in violation of applicable privacy laws, we reserve the right to delete it. If you believe that we might have any such information, please contact us at [email protected].

6. Interaction with third party products

We enable you to interact with third party websites, mobile software applications and products or services that are not owned, or controlled, by us (each, a “Third Party Service”). We are not responsible for the privacy practices or the content of such Third Party Services. Please be aware that Third Party Services can collect information from you. Accordingly, we encourage you to read the terms and conditions and privacy policies of each Third Party Service.

7. Analytics tools/cookies

You may control the way in which your devices permit the use of cookies and other tracking technologies. If you so choose, you may block or delete our cookies from your browser; however, blocking or deleting cookies may cause some of the Services, including features and general functionality, to work incorrectly. Some of the cookies and tracking technologies that we use in our Services include:

Google Analytics. The Website uses a tool called “Google Analytics” also known as “Firebase Analytics,” to collect information about use of the Website. Google Analytics collects information such as how often users visit this Website, what pages they visit when they do so, and what other websites they used prior to coming to this Website. We use the information we get from Google Analytics to maintain and improve the Website and our products. We do not combine the information collected through the use of Google Analytics with information we collect. Google’s ability to use and share information collected by Google Analytics about your visits to this Website is restricted by the Google Analytics Terms of Service, available at https://marketingplatform.google.com/about/analytics/terms/us/, and the Google Privacy Policy, available at http://www.google.com/policies/privacy/. You may learn more about how Google collects and processes data specifically in connection with Google Analytics at http://www.google.com/policies/privacy/partners/. You may prevent your data from being used by Google Analytics by downloading and installing the Google Analytics Opt-out Browser Add-on, available at https://tools.google.com/dlpage/gaoptout/.

Facebook Pixels and SDKs. We use Facebook pixels or SDKs, which are tools that provide help to website owners and publishers, developers, advertisers, business partners (and their customers) and others integrate, use and exchange information with Facebook, as such the collection and use of information for ad targeting and retargeting. Please note that third parties, including Facebook, use cookies, web beacons, and other storage technologies to collect or receive information from our website and elsewhere on the internet and use that information to provide measurement services and target ads. Facebook’s ability to use this information is governed by the Facebook Business Tools Terms, available at: https://www.facebook.com/legal/technology_terms/. You can prevent your data from being used by Facebook Pixels and SDKs by exercising your choice through these mechanisms: http://www.aboutads.info/ choices or http://www.youronlinechoices.eu/.

Mixpanel. We collect information such as your email address and your user activity through the use of Mixpanel. Mixpanel’s ability to use and share information is governed by the Mixpanel Terms of Use, available at https://mixpanel.com/terms/, and the Mixpanel Privacy Policy, available at https://mixpanel.com/privacy/. You can opt-out of Mixpanel’s services by clicking on the following link: https://mixpanel.com/optout/.

Hotjar. We use Hotjar in order to better understand our users’ needs and to optimize this service and experience. Hotjar is a technology service that helps us better understand our users’ experience (e.g. how much time they spend on which pages, which links they choose to click, what users do and don’t like, etc.) and this enables us to build and maintain our service with user feedback. Hotjar uses cookies and other technologies to collect data on our users’ behavior and their devices. This includes a device's IP address (processed during your session and stored in a de-identified form), device screen size, device type (unique device identifiers), browser information, geographic location (country only), and the preferred language used to display our website. Hotjar stores this information on our behalf in a pseudonymized user profile. Hotjar is contractually forbidden to sell any of the data collected on our behalf. For further details, please see the ‘about Hotjar’ section of Hotjar’s support site.

mParticle. We use mParticle in order to better understand our users’ needs and to optimize this service and experience. Collected information may include your IP Address and Email address. You can view their privacy policy here: https://www.mparticle.com/legal/website-terms-of-service.

Through our Services we may allow third party advertising partners to set technologies and other tracking tools to collect information regarding your activities and your device (e.g., your IP address, mobile identifiers, page(s) visited, location, time of day). We may also combine and share such information and other information (such as demographic information and past purchase history) with third party advertising partners. These advertising partners may use this information (and similar information collected from other websites) for purposes of delivering targeted advertisements to you when you visit third party websites within their networks. This practice is commonly referred to as “interest-based advertising” or “online behavioral advertising”. We may allow access to other data collected by the services to share information that may be useful, relevant, valuable or otherwise of interest to you.

We also use some targeting and retargeting tools, including, Google, Twitter, LinkedIn, Taboola, Criteo, AppsFlyer and Reddit.

We reserve the right to remove or add new analytic tools, cookies, pixels and other tracking technologies.

8. Specific provisions applicable under California privacy law

California Privacy Rights: California Civil Code Section 1798.83 permits our customers who are California residents to request certain information regarding our disclosure of information to third parties for their direct marketing purposes. To make such a request, please send an email to [email protected]. Please note that we are only required to respond to one request per customer each year.

Our California Do Not Track Notice: Do Not Track (“DNT”) is a privacy preference that users can set in certain web browsers. Please note that we do not respond to or honor DNT signals or similar mechanisms transmitted by web browsers, but we may allow third parties, such as companies that provide us with analytics tools, to collect personally identifiable information about an individual consumer’s online activities over time and across different web sites when a consumer uses the Services.

9. Contact us

If you have any questions, concerns or complaints regarding our compliance with this notice and the data protection laws, or if you wish to exercise your rights, we encourage you to first contact us at [email protected].

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Faye is the brand name for customizable travel protection plans offered by Zenner, Inc. and its subsidiaries including Zenner Insurance Services LLC, California license #6006067. Plans consist of travel insurance underwritten by United States Fire Insurance Company and non-insurance assistance services provided by Zenner, Inc., and Global Excel Management Inc. The information on this website is provided for informational purposes only and does not include all terms, conditions, and exclusions of the travel insurance coverage. Some or all coverages may not be available in your state. Click here to review the full disclaimer.