Lemonade’s Data Privacy Pledge
TL;DR: We will never, ever, sell your data to anyone.
In light of growing concerns about companies selling customers’ private data, we thought this would be a good opportunity to tell you about what types of data we collect, why we collect it, and what we do with it.
Data is important. In fact, it’s the foundation on which most of the technology we’ve grown to love is built. Without it, services like ride sharing and music streaming wouldn’t exist. Data is what lets companies like ours personalize their service, making it instant, fun, and hassle free.
We use data to do things like personalize coverages, pay claims in seconds, prevent fraud, help our users perform instant changes to their policy, collect payments, and improve our advertising. But, what we don’t do, and never will, is sell your personal information.
We collect personal info that can identify you or be linked to you, such as your name, address, email, date of birth, social security number (only in cases that we explicitly ask for it), employment information, and your IP address. A full list of the categories of data we collect and don’t collect can be found below.
We also collect browsing and usage data from you, automatically through the use of browser cookies and similar technologies, and from other sources such as third parties and publicly available sources.
How We Use Your Data
Using our online services
We use cookies, clear GIFs and similar methods (collectively, “Cookies”) on our websites and our app. Cookies are small bits of info that are stored by browsers to keep track of usage and selections made by users. We may, for example, use Cookies to keep customers’ preferences and allow for a more personalized experience on our website. We also advertise on websites such as Google, Youtube and others and do our best to present the most relevant ads to our existing and potential customers. To be able to do that, we may use cookies or similar methods to collect interests, and website usage info.
We also collect website traffic, including web logs, to help us analyze performance and improve our service and ad efficiency. We may use the technical information and related data as described below to improve and offer you content, products, or services. For example, we evaluate the efficiency of ad campaigns by tracking visits to Lemonade from these campaigns. We’re using secure, industry-standard, third-party tools to analyze this data.
Obtaining insurance quotes
To be able to offer the best coverage at the right price, insurance companies evaluate the risks involved. We collect information from you in order to evaluate risks and to provide you with an accurate quote for our insurance services. We may ask for documents or pictures, as well as other information for proving ownership, condition and value in order to be able to process and provide you with an insurance quote. For example, to be able to insure a home, we collect the property’s exact address as well the customer’s name so we can get their insurance history. We may, in some cases, require information such as full name, date of birth, driver’s license and social security number to process and generate a quote.
Providing services to car users
If you’re an enrolled driver on a Lemonade car policy or voluntarily activated location services on our app (a “Car User”), your usage of our app and your driving habits (“Driving Data”) will be used to analyze and evaluate your risk profile, which may ultimately be used as one of the determining factors of your premium. To the extent allowed by law, your policy may be declined, canceled, or non-renewed based solely on your or other drivers’ Driving Data. We may also use Driving Data to identify possible crashes and emergency situations and may proactively reach out to assist.
If you connect a wireless-enabled telematics device (a “Telematics Device”) to your vehicle(s), the device is capable of collecting and communicating Driving Databack to us, including a variety of diagnostic information about your vehicle and your trips, such as speed, heading, acceleration, altitude, odometer and, location information. See Terms and Conditions for the Telematics Device for more information on the Telematics Device.
Fighting fraud
To be able to detect potential fraud attempts, we may collect and analyze past property or personal insurance history, as well as things like images, audio, video recordings, and criminal background information.
Paying for and using insurance
To evaluate risk, we may ask for documents, pictures as well as other information for proving ownership, condition and value. When you buy a policy, we use a third-party vendor to securely collect credit card information to handle payments.
Filing claims
To be able to review claims, we ask users to provide various information in the form of video-supported claim submission, as well as videos, pictures, signatures, receipts, appraisals, and so on. If you are enrolled in a Lemonade car policy, Driving Data for each driver may be collected and used to determine the cause of a loss. We may review information about claim submissions and/or Driving Data (collectively, “Claim Data”) as part of our investigation and review of a claim, as well as for improving our systems and services. Claim Data may be sought by third parties, such as opposing parties in a civil lawsuit or by police when investigating a claim.
Receiving payment for claims
To pay claims, we require bank account details as well as personally verifiable info, such as the claimant’s social security number.
Pricing and underwriting
We may use Claim Data to develop new insurance products and services, improve the accuracy of our rates, and optimize our underwriting. From time to time, Claim Data may be provided to state insurance departments or third party service providers on an aggregated and anonymized basis.
Processing employment applications
If you apply for a job with us, we collect information necessary to process your application or to retain you as an employee. This may include, among other things, government identification numbers, contact information, educational and employment history, and other information that you provide to us in the context of your application or during the interview process. We may also conduct a background check for applicants.
Other uses
In addition to the purposes and uses described above, we use data in the following ways:
- To communicate with you, such as to respond to and/or follow-up on your requests, inquiries, issues, or feedback.
- To detect and protect against malicious, deceptive, fraudulent, or illegal activity, including violation of our policies and terms and conditions, security incidents, and harm to the rights, property, or safety of our company and our users, employees, or others.
- To debug, identify and repair errors that impair existing intended functionality of our services.
- To comply with our legal or regulatory obligations, to establish or exercise our rights, and to defend against a legal claim.
- For administrative purposes, as well as to manage our relationships.
- For such other purposes as you may consent (from time to time).
When we disclose data
We may disclose your information to third parties outside of our company. These external recipients may include, in particular:
TYPE OF DATA | COLLECTED AND REQUIRED TO PROVIDE OUR SERVICES | SOLD TO A THIRD PARTY (TL;DR: NEVER GONNA HAPPEN) | MAY BE SHARED WITH A THIRD PARTY TO IMPROVE OUR SERVICES | MAY BE SHARED WITH A THIRD PARTY FOR CROSS-CONTEXT BEHAVIORAL ADVERTISING |
Images, audio and video recordings | ✔ | X | ✔Claim support service providers | X |
Bank account number | ✔Claim payments | X | ✔Secure payment processors (to facilitate claim payments) | X |
Biometric information (such as identity-verifying voice, handwriting and facial features, excluding behavioral characteristics, like driving behaviors, etc.) | X | X | X | X |
Characteristics of protected classifications (e.g., age, sex, race, ethnicity, physical or mental handicap, etc.) | ✔Age, gender | X | ✔Analytics providers; service providers that assist with the employment applicant hiring process (only in accordance with applicable law) | X |
Commercial information (e.g., products or services purchased, or other purchasing or consuming histories or tendencies) | X | X | X | ✔Advertising networks; social networks |
Credit card number | X | X | ✔Secure payment processors (to process your purchases) | X |
Debit card number | ✔ | X | ✔Secure payment processors (to process your purchases) | X |
Driver’s License Number / State ID | ✔Car users, Term Life applications, and rarely during claims | X | ✔Authentication service providers; claim support service providers | X |
Driving Behaviors (e.g., speed, distance, hard breaks) | ✔Car User only | X | ✔ Companies that provide risk analytics; companies that provide telematics services | X |
Driving Distractions (e.g., your mobile phone usage while driving) | ✔Car User only | X | ✔ Companies that provide risk analytics; companies that provide telematics services | X |
Education | X | X | ✔Service providers that assist with the employment applicant hiring process | X |
Electronic network activity (e.g., browsing history) | ✔Only on our website / apps | X | ✔Analytics providers | ✔Advertising networks; social networks |
Email address | ✔ | X | ✔ Claim support service providers; marketing services providers; application analytics service providers; companies that provide telematics services; agency partners; analytics providers | ✔ Advertising networks; social networks |
Employment/Employment History | ✔During claims | X | ✔Claim support service providers; service providers that assist with the employment applicant hiring process | X |
Geolocation data | X | X | ✔ Companies that provide risk analytics; companies that provide telematics services; companies that provide mapping services for Car Users; roadside assistance providers | X |
Health insurance information | ✔Sometimes during claims | X | ✔ Claim support service providers; the company servicing your Term Life policy (if not Lemonade) | X |
Identifiers (e.g., name or alias) | ✔ | X | ✔Claim support service providers | ✔ Advertising networks; social networks |
Location and Driving Distance | ✔Car User only | X | ✔ Companies that provide risk analytics; companies that provide telematics service | X |
Insurance Policy Number | ✔ | X | ✔Claim support service providers | ✔ Advertising networks; social networks |
Medical information | ✔Only for Term Life applications, and rarely during claims | X | ✔Claim support service providers; the company servicing your Term Life policy (if not Lemonade) | X |
National origin, citizenship, immigration status | ✔Car User only | X | ✔Service providers that assist with the employment applicant hiring process | X |
Non-Driving Behavior (e.g. being a passenger or using other modes of transportation) | ✔Term Life Only | X | ✔Claim support service providers; the company servicing your Term Life policy (if not Lemonade) | X |
Online identifier (e.g. IP address) | ✔ | X | ✔Analytics providers | ✔ Advertising networks; social networks |
Other financial information | ✔Sometimes during claims | X | ✔ Claim support service providers; fraud detection service providers | X |
Passport Number | ✔Rarely during claims; sometimes for employees | X | ✔ Claim support service providers; service providers that assist with the employment hiring process | X |
Physical Characteristics | ✔Term Life Only | X | ✔The company servicing your Term Life policy (if not Lemonade) | X |
Postal address | ✔ | X | ✔ Claim support service providers; insurance background check providers; identification and authentication service providers | ✔ Advertising networks |
Signature | ✔ | X | X | X |
Social Security Number | ✔We may ask for it sometimes, mostly the last 4 digits | X | ✔Claim support service providers; insurance background check providers; identification and authentication service providers | X |
Technical Data and Related Information (e.g. technical information about your smartphone, how you use our app, etc) | ✔ | X | ✔ Service providers that provide technical support for our websites and app; companies that provide telematics services | ✔ Advertising networks; social networks |
Telephone Number | ✔ | X | ✔Claim support service providers; companies that provide telematics services | ✔ Advertising networks; social networks |
Transaction information | ✔ | X | ✔Secure payment processors | X |
Vehicle Information (odometer reading, engine codes, miles driven, impacts) | ✔Car User only | X | ✔ Device provider; Companies that provide risk analytics; companies that provide telematics services | X |
In addition to the third parties described above, we may disclose any of the categories of personal information we collect with providers of professional services (e.g., our lawyers and accountants), technical support service providers and government entities, when required.
If you’re into legalese, this part’s for you
In parallel to this Privacy Pledge, Lemonade also follows state laws implementing the Gramm-Leach-Bliley Act’s (GLBA) notification requirements. Information that we collect from you when you apply for, or obtain our insurance products and services for personal, family, or household purposes is subject to our GLBA policy.
Your Choices
To request to access, change, or delete your data, email us at [email protected] or call us toll-free at 844-733-8666.
How we protect and retain information
If (god forbid) there is a breach to your data, we will make sure to notify you via email, regular mail, or phone – as required by law.
We retain your personal information for only as long as necessary to fulfill the purposes outlined in this Privacy Policy, including for the purposes of satisfying any legal, accounting, or reporting requirements, unless a longer retention period is required or permitted by law. To determine the appropriate retention period for personal information, we consider the amount, nature, and sensitivity of the information, the potential risk of harm from unauthorized use or disclosure of the information, the purposes for which we obtained the information and whether we can achieve those purposes through other means, as well as applicable legal requirements.
Changes to this Privacy Pledge
We may need to update this Privacy Pledge from time to time. No matter what we change, we will always maintain our commitment to protecting your privacy. We will post all revisions, along with their effective dates.
Information for California Residents
California law indicates that organizations should disclose whether certain categories of personal information are collected, transferred for “valuable consideration,” transferred for an organization’s “business purpose,” or shared for cross-context behavioral advertising (as those terms are defined under California law). Please see the table above, which indicates the categories of personal information we collect and transfer in a variety of contexts. Note that we do not “sell” your personal information for monetary consideration.
Sensitive Information: We collect the following categories of sensitive personal information (as defined under California law): social security, driver’s license, state identification card, or passport number; precise geolocation; and data concerning health. This information is collected in order to process employment applications, comply with laws, manage our business, or provide you with services. We do not use sensitive personal information for any purposes that are not identified within the California Privacy Rights Act Section 1798.121. We do not “sell” or “share” sensitive personal information for purposes of cross-context behavioral advertising.
Your Rights: As a California resident, you have the following rights:
- You can request the categories and specific pieces of personal information we have collected about you;
- You can request that we delete personal information (although note that we may have the legal obligation or right to keep this information);
- You can request that we correct information about you that is inaccurate or incomplete;
- You can opt-out of online tracking based targeted advertising (e.g., cookies) by clicking the “Manage cookies” link here or the “Do not share my personal info” link on our homepage. Please note that if you change browsers or computers, or if you clear your browser’s cache, you may need to click the link again to apply your preference.
Please note, not all of the rights described above are absolute, and they do not apply in all circumstances. In some cases, we may limit or deny your request because the law permits or requires us to do so, or if we are unable to adequately verify your identity. We will not discriminate against individuals who exercise their privacy rights under applicable law.
As required by law, we will require you to prove your identity if you make a data request. We may verify your identity by phone call or email. Depending on your request, we will ask for information such as your full name, email, address, date of birth and last 4 digits of the payment method on file. We may also ask you to provide a signed declaration confirming your identity.
Following a request, we will use reasonable efforts to supply, correct or delete personal information about you in our files. In some circumstances, you may designate an authorized agent to submit requests to exercise certain privacy rights on your behalf. If you are an authorized agent submitting a request on behalf of an individual, you must attach a letter, signed by the individual and notarized, indicating that you are able to act on that person’s behalf.
We do not currently recognize the “Do Not Track” signal.
We
By the way, throughout this privacy pledge, anytime we said “Lemonade” or “we” or “us” we’re talking about Lemonade, Inc., and our affiliates and subsidiaries.
Contact Information
If you have any questions, comments, or complaints concerning our privacy practices please contact us at the appropriate address below.
Email: [email protected]
Phone: 844-733-8666