This Privacy Policy explains the policies and procedures relating to the use of information collected through our websites, mobile apps, or our physical business location (collectively “Site”) from visitors to or users of our Site, potential customers, and customers (collectively “Customers”, “you,” or “your”), whether through the Internet or otherwise, by broadarrowauctions.com, a Speed Digital, LLC client and its affiliates (collectively “Company”, “we”, “us” or “our”). Because Company’s products and services are not directed to or intended for (a) individuals under the age of 18 nor (b) individuals located or residing outside of North America, we ask that individuals in those categories not submit any information to us and not use our Site. By visiting or using our Site or our services, you consent to the collection, use, disclosure, retention, and protection of information as described in this Privacy Policy.

This Privacy Policy does not apply to:

• Credit-related products, which are covered by the issuing bank or financial institution’s privacy notices that appear on credit applications or that you receive with your credit accounts;
• Your interactions with third parties or their websites that are linked to or accessible from our Site or that are operated by unaffiliated third parties;
• Our employment-related records.

 

Information That We May Collect About You

• Identification information that can be used to identify you, such as your name, alias, address, phone number, email address, phone number, payment information, signatures, or other identifiers. We may also collect online identifiers, such as your IP address, when you browse or use our Site. For the purposes of facilitating some sales transactions, we may collect information from your government-issued ID, your social security number, insurance policy information, or bank account information, but please only provide this information if requested by us. We may also collect information about any automobile you sell, offer for sale, or purchase through our site, including the make, model, trim, model year, mileage, color, options, vehicle identification number (VIN), license plate number. When you apply to see if you pre-qualify for auto financing through one of our participating lenders, that lender may require you provide additional information, but that financing information is not captured or retained by us;
• Commercial information, such as goods or services you purchased or considered purchasing, including automobile sales information such as advertised price, purchase offers, actual sale price, and sale location;
• Protected class information under state or federal laws, such as age, gender, and family status; Online activities information, such as browsing history, search history, and other information when you interact with our Site, advertisements, and emails;
• Geolocation data, including precise geolocation data if the settings on the device you use to access our Site grants permission to obtain this information;
• Audio, electronic, or visual information, such as audio or video recording when you call us or when you visit our physical business location;
• Professional or employment information, such as when you provide us this information via a survey;
• Education information, such as when you apply for a job with us or respond to a customer survey;
• Inferences or preferences we learn or infer about you; and
• Other personal information, if it identifies, relates to, and can be reasonably associated with or linked to you or your household.

 

Sources of Collected Information

We collect different types of information about you from a variety of sources, including information you provide to us, information we automatically collect, information we obtain from other sources (see below), and information we derive or infer about you.

Information You Provide. You may choose to provide us with information when you interact with us, including:

• Identification information. We may collect and retain any information provided to us by you or your devices when you visit our Site, including when you register for an account, use our services, communicate with us, complete sales transactions, and subscribe to our email newsletters or other content we offer. When completing sales transactions, we may collect your payment information (e.g., credit/debit card information), signature, and, in some cases, government-issued ID information and date-of-birth.
• Commercial information. You may provide us or generate commercial information regarding your purchases from or involving our Site and any related transactions.
• Protected class information. You may provide us your protected demographic information, including age, gender, family status, such as when you complete a user profile or consumer survey.
• Your preferences and inferences. You may indicate your preferences when you complete our surveys, submit reviews and comments, or participate in our contests, promotions, or sweepstakes.
• Professional or employment-related information. You may also provide information related to your profession or employment when you complete our surveys, submit reviews and comments, or participate in our contests and promotions.
• Education information. You may provide information relating to your education when applying for a job with us or when responding to our customer surveys.
• Other information. When you apply to see if you pre-qualify for auto financing through one of our participating lenders, that lender may require you provide additional information, but that financing information is not captured or retained by us.

Automatically Collected Information. We may collect and retain your personal information automatically when you visit our Site. When using our website or mobile applications or when interacting with our emails, we and our partners may collect certain information by using first and third-party cookies, pixel tags, and similar technology that may exist today or that may be developed in the future. We may allow third parties to use these tools on our Site, and the information collected through these tools may be used on our Site or on other websites or services, including third-party sites. We may automatically collect the following information:

• Identification information, such as your IP address, device ID, cookie ID, mobile advertising identifier, pixel identifier, or phone number.
• Online activities, such as browse and search history, vehicles you view or configure, interactions with our websites, applications, or other information about your online interactions. When you use social networks to access our Site, information from those social networks may be made available to us. By associating a social network account with our Site, you agree that we may access and retain that information in accordance with the policies of the social network and this Privacy Policy.
• Geolocation data. If permitted by your browser, app, or device settings, we may collect certain information about your precise location to help you locate us, provide you with information relevant to your geographic area, or determine geographic information relevant to sales transactions.
• Audio, video, and electronic information, such as audio or video recording of telephone or online conversations between you and our customer support personnel for purposes of quality control, training, security, and analytics. We may also use video monitoring at our physical location to protect against theft and other crimes, although this information may not be capable of association with you.

Information Collected From Other Sources

• Identification information. We may collect your contact information or information relating to your sales transactions from our affiliates, acquired businesses, partners, public sources, or other individuals.
• Commercial information. We may obtain your commercial information, such as your purchase history and information relating to your sales transactions, from our affiliates, partners, public sources, or other individuals, including individuals involved in sales transactions with you facilitated by our Site.
• Inferences or preferences about you, protected class information under federal and state law, professional or employment-related information, education background, and geolocation information may be collected from our affiliates, partners, public sources (e.g., a publicly available customer review), or other individuals.

Information We Generate

• Inferences or preferences. We may generate or derive inferences or analyses based on collected, aggregated, or de-identified information to improve our services and understand user behaviors. We may generate or derive some information about you based on other information we collect. We may also conduct analyses based on aggregated or de-identified information.

 

Use of the Collected Information

We generally use the information collected about you to provide and improve our services. We may use this information to:

• Provide and deliver services to you, process transactions, and send related information such as confirmations and invoices, and revise, update and develop new services;
• Send you communications including technical and support notices, administrative messages, and inquiry/customer support responses;
• Communicate with you about products, services, offers, and promotions offered by us and certain third parties, and provide you with information that may be of interest;
• Personalize our services and present you with advertising, content, or features of interest to you;
• Allow you to participate in contests, sweepstakes, or similar promotions and to administer them;
• Link or combine with information we get from third parties to help understand your needs and provide you with better service;
• Monitor and analyze trends, usage, and activities in connection with our services;
• Detect, investigate, and prevent fraudulent transactions and other illegal activities and protect our rights and the rights of third parties;
• Respond to law enforcement requests or as required in connection with court orders, government regulations, or litigation; and
• Carry out any other purpose described to you at the time the information was collected.

 

Sharing of Collected Information

We may use or share (i) your personal identifiable information (PII) and (ii) de-identified and pseudonymized information based on your PII, for any purpose including marketing, research, and product and service development and improvement. We may share your PII with our affiliates, service providers and business partners, third parties that are not affiliated with us for business purposes, with other third parties as required by law, and also:

• With our service providers and business partners to perform services on our behalf or on your behalf, including email delivery and other communications with you, credit card and other payment processing, marketing, advertising, data analytics, website hosting, customer service, and similar services;
• With other automobile dealers, manufacturers, and similar businesses that may be unaffiliated with us, including to facilitate communications between these businesses and you;
• With lending companies and other financial institutions for purposes of determining your creditworthiness and facilitating financing, and for marketing their financial services to you;
• We may share information relating to the offering for sale and sale of automobiles on and through our Site, including make, model, year, VIN, listing price, sale price, sale date, and sale location with unaffiliated third parties for purposes of compiling, analyzing, marketing, selling, and publishing automobile sales data;
• With appropriate authorities or third parties to enforce our rights and those of our affiliates, customers, and members of the public, and to apply with applicable laws and legal processes, and for preventing fraud, theft, and injury to you or others;
• When we are involved in a business merger, acquisition, liquidation, valuation or similar business transaction;
• Unaffiliated third-party businesses so that they may market goods or services that may be of interest to you; and
• At such other times and for such other purposes as you may authorize us to disclose the information.

 

Your Privacy Choices and Rights

• You may have the right to opt out of the disclosure of personal information about you to third parties for monetary or other valuable consideration. To request to opt-out, please email optout@speeddigital.com with a subject of “Opt Out Request”. Please include your name and email address in your correspondence so we can identify your records in our system.. Note this will not affect the collection, storage, compilation, use, transfer, or sale of de-identified or pseudonymized information that may have been derived in part from your personal information (e.g., sales information).

• You may also have the right to request that we delete personal information about you that we have collected from you or through other sources, and you may request we do so by emailing us at optout@speeddigital.com with a subject line of “Deletion Request”. Please include your name and email address in your correspondence so we can identify your records in our system. You can also fill out our data deletion request form at speeddigital.com/privacy-request. Please be aware that you are not able to opt out of receiving communications about your account, the provision of our services to you, or related transactions with us.

• If you would like to opt-out of receiving email marketing communications from us, you may click the “Unsubscribe” link found at the bottom of our marketing emails.
• Please note that like many websites our Site does not make any modifications or otherwise respond to Do Not Track signals generated by your browser or device.
• Most major web browsers provide users the option to accept or reject cookies. If you delete cookies, use a different device, or change web browsers, you may need to repeat the steps to accept or reject cookies on the new device or browser. If you use your browser settings to block all cookies you may not be able to access parts of our Site. The “Help” future on most browsers will tell you how to prevent your browser from accepting new cookies, how to have the browser notify you when you receive a new cookies, or how to disable cookies altogether. If you block or otherwise reject our cookies, you may not be able to utilize certain features on our Site including services requiring you to sign in.
• A pixel tag (i.e., tracking pixel, web beacon, clear GIF, 1x1 pixel) is an invisible tag or small graphic placed on certain pages of our Site or in emails but not on your computer. When you access these pages or emails, the pixel tags help maintain a record that you visited a webpage or received or opened an email. When such a message is opened in an HTML-capable email program, the recipient’s computer or device will communicate with our server to retrieve the pixel tag file, allowing us to record and store the date and time the email was viewed, the fact that the email client is capable of receiving HTML-encoded email, other standard logging information, and the recipient’s email address. These pixel tags help us analyze our customers’ online behavior and measure the effectiveness of our marketing. You can disable the pixel tag feature by changing the settings on your email client to prevent the automatic downloading of images, changing your browser settings to omit images, disabling Javascript, or utilizing commercially available software that can omit pixel tags and most advertisements.
• Where applicable, the California Consumer Privacy Act (CCPA) affords you the right to request that we disclose to you the personal information we collect, use, or disclose, and information about our data practices; the right to request that we delete your personal information that we have collected from you; and our assurances that we will not discriminate against you for exercising these rights.

 

Policy Changes

We reserve the right to modify and revise this Privacy Policy from time to time. If we make material changes to this policy, we will notify you of such changes by posting them on our Site or by sending you an email or other communication, and we will notify you of the effective date of the changes. By continuing to access or use our Site or our services after these changes become effective, you are agreeing to be bound by the revised Privacy Policy.

 

Contacting Us

You can contact us with questions or comments about privacy practices or this Privacy Notice by emailing us at legal@speeddigital.com or by calling us at 866-457-7333

 

 

Hagerty Privacy Notice

At Hagerty, we respect your car skills and your privacy – because both deserve a smooth ride. This Privacy Notice explains our information handling practices in connection with the website located at Hagerty.com, any other websites owned or operated by Hagerty where this Notice appears, and our mobile applications (collectively, “Services”). When you interact with an entity in the Hagerty family of companies, your personal information is subject to this Privacy Notice (unless a different privacy notice is posted on that entity’s website – different garage, different manual). If you already have an insurance policy with us or are thinking about it, you clearly have good taste. Please check out our Insurance Member Privacy Notice for additional specific insurance privacy rights.

If you have any questions about our privacy practices, please contact us as set forth in the “Questions” section below. If you are a resident of California, please see the additional disclosures at the end of this Privacy Policy.  

By using our Services, you acknowledge that you have read and agree to this Privacy Notice and expressly consent to Hagerty’s data processing as described below. You additionally agree that you are subject to the Terms and Conditions.

This Privacy Notice does not apply to anybody else, including third party products or websites that may be linked in our website.

Table of Contents

1. Information We May Collect About You
2. Use of Personal Information
3. Disclosing and Sharing of Your Personal Information
4. Data Retention
5. Security
6. Internet Privacy and Information Collected Online
7. Additional Information Regarding U.S. State Data Privacy Rights
8. Artificial Intelligence
9. Our Policies Concerning Children
10. International Data Transfers
11. Links and Other Information
12. Changes to Our Privacy Notice
13. Questions

 

1. Information We May Collect About You

Hagerty and people who represent Hagerty collect personal information in several situations while we provide you with our products and services. We don’t want any surprises under the hood, so please note that, depending on your relationship to us, we may collect the following categories of personal information:

• Contact information, such as name, mailing address, e-mail address, telephone number, birth date, marital status and other similar identifiers.
• Demographic information and interests, such as age, contact information and gender. We may also collect information on your vehicle hobby interests to suggest content and events relevant to you.
• Event registration and attendance information, such as event registrations, ticket purchases, attendance records, dietary restrictions or accessibility needs you provide, and vehicle show entries.
• Photographs and recordings at events, such as photographs, video recordings, and audio recordings captured at auctions, car shows, and other events we host or sponsor, which may include images of attendees, their vehicles, and the surrounding event environment.
• Vehicle-related records, such as information from motor vehicle records and/or driving records about you, other people listed as policyholders, other drivers, and household members, in accordance with applicable law. This includes license status, driving violations, collisions, driving restrictions, claims history, etc.
• Products and services such as information about your business and/or interactions with us or other Hagerty companies, such as information about your insurance policy or information about the products and services you request or purchase.
• Website and device usage information such as your device data and how you interact with our website, including IP address, browser type, and unique device identifier, as well as usage information, including the pages or content you view. For more information, please see Section 6, “Internet Privacy and Information Collected Online.”
• Insurance claim information, such as insurance claims history for you, other policyholders, drivers, or household members.
• Additional vehicle information, such as information about your other vehicles, including Vehicle Identification Number, value, mileage and usage, and registration information.
• Vehicle consignment information, such as consignor contact details, vehicle provenance documentation, ownership history, and reserve prices when you consign a vehicle for auction.
• Employment information. As part of an insurance claim, we may collect current or past employment information from you or other claimants.
• Job application information, such as information required to process job applications and evaluate employment candidates.
• Sensitive personal information, such as your driver’s license number for insurance related purposes or, if you have been involved in a bodily injury claim, we may collect health information to process that claim.
• Information from Third Parties, such as demographic data, online identifiers, or purchase insights we receive from service providers, advertising or analytics partners, or publicly available sources.
• Geolocation Information, such as coarse geolocation.   
• Financial and Payment Information, such as credit card details, financial information, and payment preferences.
• Auction and bidder information, such as bidder registration details, bidder numbers, paddle assignments, bid history, auction purchases, and payment information for auction transactions.
• Inferences, such as inferences drawn from any of the personal information identified and discussed in this Privacy Notice.
• Deidentified or Aggregate Information, which we may use or share for research, analytics, or to improve our Services, provided it does not identify you.
• Other information submitted by you, such as information including those provided through surveys, polls, questionnaires, social media or similar means, information you may voluntarily provide to us, and any other information we may collect as permitted or required by law.

We may collect this information directly from you when you provide it to us, automatically from you as you navigate our Services, or from third parties, including insurance companies, other insurance brokers or agents, motor vehicle and driver licensing authorities, financial institutions, consumer reporting agencies, third-party data suppliers, operators of third-party content distribution channels and platforms, and social media platforms and similar services. We may also collect this information directly from you in person at auctions, car shows, and other events we hold or sponsor.

 

2. Use of Personal Information

Hagerty generally uses personal information for the following reasons:

• To operate, manage, and maintain our business;
• To fulfill the purpose for which you provided us the information;
• To verify your identity;
• To improve our customer service and website;
• To get, issue, renew and service an insurance policy for you;
• To help determine your insurance needs;
• To recognize you as a previous visitor and to customize your interactions and account with us;
• To enhance our services, improve user experience, and perform research, analysis, and development, including with machine learning and artificial intelligence (“AI”) systems (please refer to Section 8 of this Privacy Notice to learn more);
• To detect and prevent fraudulent activities, including using AI systems;
• To maintain business records for reasonable periods, and generally manage and administer our business;
• To protect Hagerty and you against fraud;
• To process your requests, purchases, and payments for our products and services;
• To manage event registrations, ticketing, logistics, and attendee communications, including sending you information about upcoming auctions and events that may interest you;
• To photograph, record, and broadcast auctions and events, including for live streaming, promotional videos, marketing materials, social media content, and archival purposes;
• To facilitate auction transactions, including bidder registration, bid processing, vehicle sales, consignment services, and post-sale title transfers;
• To keep your information accurate and up-to-date;
• To meet legal, regulatory, insurance, and security requirements;
• To hold up our end of our business transaction with you. For example, we will share some information with a flatbed tow company for our roadside service;
• To analyze our business and identify trends;
• To customize content, develop and conduct advertising and marketing campaigns and provide recommendations for content, products, and services you might be interested in based on your behaviors and actions. You can opt-out of these email communications if you want;
• To deliver video content to you in the ordinary course of our business;
• To communicate with you, such as when we respond to your inquiries and send you other communications regarding our products and services. This may also include administrative email notifications such as security or support and maintenance advisories.
• To send you surveys, news, and/or marketing communications (by email, phone, or text), subject to your marketing preferences and choices, including information about us or third-party offerings we think may be of interest to you.
• To conduct market research, analytics, and quality assurance activities, including studying, developing, and improving our Services. This may include measuring and analyzing the effectiveness of our Services, audience traffic, user interests, trends, and patterns.
• To serve you targeted advertising or content and understand how you interact with our Services to personalize your experience (including advertising and messaging campaigns).
• To maintain the safety, security, and integrity of our Services, including monitoring for fraud, misuse, or illegal activity.
• To debug, detect, and secure our systems, networks, and websites against errors and vulnerabilities.
• To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations;
• To communicate with you about your job application with us and evaluate your potential employment with us; and
• To fulfill any other use that we describe when you provide the information.

Please note that we may anonymize or reasonably deidentify your personal information so that it can no longer be reasonably associated with or used to identify you in some circumstances. We may retain and use such information for any legitimate business purpose, in accordance with applicable law, without further notice to you or obtaining your consent, unless required by law.

3. Disclosing and Sharing of Your Personal Information

A. Disclosing Personal Information.

We may disclose some or all the personal information collected from or about you with any of the following and for business purposes:

• Vendors that perform professional, business services for us, including software, IT, financial, recruiting, and legal service providers;
• Banks and credit card processors for Hagerty to process payments and deliver its products;
• Our underwriting companies or your broker or agent (most of the information collected about you and described above will be disclosed to our underwriting company and your broker or agent for evaluating, issuing, renewing and servicing your insurance policy);
• Regulatory and self-regulatory agencies;
• Consumer reporting agencies, for example, during the underwriting process;
• Other Hagerty companies or subsidiaries;
• Licensed agencies and brokerages that have referred you to us, information regarding any policy you obtained;
• Third parties (such as law enforcement, attorneys, or parties to a lawsuit) if we are required to do so by a court subpoena or other law;
• Adjusters or insurance companies for purposes of claims handling;
• Advertiser and marketing service providers that help us deliver content, products, and services that fit your interests;
• Vendors that assist with recruiting, application management, background checks (where applicable), or regulatory compliance for Hagerty job applicants;
• With other parties to process and fulfill your requests for video content offered through our Services, including to provide you with access to localized content and video content recommendations;
• Vendors that help us fulfill our membership services. For example, we will share some information with a flatbed tow company for our roadside service;
• Collaborators with whom we jointly develop or promote our Services, including sponsorship and co-branded opportunities and promotions.
• Title companies, escrow services, and transportation providers to facilitate the completion of auction vehicle sales;
• Auction houses, consignment partners, and co-sponsors with whom we jointly conduct or promote auctions and events;
• Buyers and sellers as necessary to complete auction transactions, including sharing contact and payment information to facilitate vehicle transfers;
• Media partners, broadcasters, and streaming platforms in connection with live coverage or recordings of auctions and events;
• To the new owner, if Hagerty or its assets were to be sold or transferred, including in a bankruptcy proceeding or to our affiliates;
• With your consent and/or direction.

B. Sharing and Selling Personal Information.

Sharing Personal Information. In this Notice, "sharing" means disclosing personal information to third parties for cross-context behavioral advertising or targeted advertising. Hagerty shares personal information with trusted third-party marketing partners to deliver personalized advertisements tailored to your interests, helping you discover products and services that align with your preferences – helping you find the right lane faster. This information may include device identifiers, IP address, browser type, website usage and referring URLs, purchase activity, and non-precise geolocation information.

Selling Personal Information. To be clear, we do not sell personal information to any third parties for money. Hagerty also does not disclose text messaging-related information with any third parties. 

4. Data Retention

We store personal information about you on computer systems operated by us or our service providers. As a highly regulated company, we keep various records that contain personal information in accordance with applicable state and federal regulations, or pursuant to contractual obligations. In general, we aim to keep personal information only for as long as necessary and only for the reason(s) we collected it – no storage in the garage longer than needed. It may be necessary to keep personal information longer than our official retention periods for legal or regulatory reasons, including litigation.

We consider the following criteria when determining how long a particular record will be retained, including any personal information contained in that record:

• How long the record is needed to provide you with the products and services you request.
• How long the record is needed to support and enhance our operational processes.
• How long the record is needed to protect our rights and legal interests.
• How long the record must be retained to comply with applicable laws and regulations.

The same personal information about you may be included in more than one record and used for more than one purpose, each of which may be subject to different retention periods based on the factors listed above.

5. Security

We use commercially reasonable administrative, technical, personnel, and physical measures designed to safeguard information in its possession against loss, theft, unauthorized use, disclosure, or modification. However, the confidentiality of information transmitted over the Internet cannot be guaranteed. We urge you to exercise caution when transmitting personal information over the internet. We cannot guarantee that unauthorized third parties will not gain access to your information; therefore, when submitting personal information to us, you do so at your own risk.

6. Internet Privacy and Information Collected Online

A. Website Analytics

We currently use Adobe Analytics to help us collect various pieces of demographic information, including geographic and general website movement patterns. The tools used to collect this information may vary but, in general, include cookies, pixels, tags, or web beacons. You can opt-out of these features that we use by applying Adobe's currently available opt-outs.

B. Cookies and Similar Technologies

We and our partners use various tools to collect data when you visit our sites and apps, including cookies, pixels, localStorage, and other similar technologies. Some of these technologies store data in the browser or on your device. Other technologies may use network-related or other information to recognize your device (e.g., IP address). Our Services use these technologies, for example, when you first request a web page and data is then stored on your computer or other device so the website or mobile application can access personal information when you make subsequent requests for pages from that Service. These technologies may also be used to collect and store information about your usage of the Services, such as pages you have visited and other content you viewed, and search history. Additionally, we may use these technologies to collect analytics and measure the use of our Services.

We and our partners may also use these technologies to gather personal information about how you view and use our Services and content and to connect your activity with other data we store about you. We and our partners may collect your personally identifiable information about your online activities over time and across different websites when you use the Services. The use of these technologies helps us serve you better by understanding what you are interested in, tracking trends, measuring the effectiveness of ads, saving your preferences, and storing information you may want to retrieve on a regular basis. We also allow specific, approved partners to collect data from your browser or device for advertising and measurement purposes using their own similar tools.

Your web browser can be set to allow you to control these technologies, such as whether you will accept cookies, reject cookies, or to notify you each time a cookie is sent to your browser. If your browser is set to reject cookies, websites that are cookie-enabled will not recognize you when you return to the website, and some website functionality may be lost. The Help section of your browser may tell you how to prevent your browser from accepting these technologies, such as cookies. To find out more about cookies, visit https://www.aboutcookies.org. Depending on the make and model of your phone, you may be able to use device settings to opt out of the use of certain device IDs for targeted advertising. For more information about Google Analytics, please review the site “How Google uses data when you use our partners’ sites or apps,” located at https://www.google.com/policies/privacy/partners/. To opt out of Google Analytics specifically, please go to https://tools.google.com/dlpage/gaoptout.

Some browsers permit the user to send a “Do Not Track” (“DNT”) preference to websites that the user visits indicating that the user does not wish to be tracked over time and across websites. Because there is not yet a common understanding of how to interpret DNT, we do not currently respond to the DNT signal on our website. We do, however, respond to global privacy preferences, such as Global Privacy Control, when required by law.

7.  Additional Information Regarding U.S. State Data Privacy Rights

California residents may have several rights concerning personal information, as described below. Since we provide the Services as an insurance company, the Personal Information we process, except when it relates to California residents, is generally not subject to certain U.S. state data privacy laws. As such, while we may not be required to respond to requests from residents of other states with comprehensive data privacy laws, we will make a good-faith effort to do so as a courtesy, as long as fulfilling the request does not conflict with applicable law or with a legitimate need to protect personal information from disclosure. We may also take steps to verify your identity before responding to any such request. 

Categories of Personal Information Collected, Disclosed, “Shared”, or “Sold”

In the last 12 months, we have collected, processed, and shared the categories of personal information disclosed in the chart below. Note the categories listed in the chart refer to the categories of “personal information” as defined under the California Consumer Privacy Act (“CCPA”). The inclusion of a category in the list below indicates only that, depending on the services and products we provide you, we may collect some information within that category, but it does not necessarily mean that we collect all information listed in a particular category for all of our customers, nor does it necessarily mean that the CCPA applies to that data (e.g., if the data is governed by the federal Gramm Leach Bliley Act or Fair Credit Reporting Act, then it is exempted under the CCPA).

Category of Personal Information Collected	Sources	Purpose of Collection, Processing, and Disclosure	Categories of Third Parties to Whom Personal Information may be “Sold” or “Shared”	Categories of Parties to Whom Personal Information may be Disclosed
Identifiers, such as a real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, or other similar identifiers	You, when you use our websites or applications, request or obtain products and services from us, or otherwise provide us with personal information   Insurance Companies   Insurance Brokers or Agents   Motor vehicle and driver licensing authorities   Financial institutions   Consumer reporting agencies   From a third party or intermediary (for example, an agent, customer, or business partner)   From our service providers   From data brokers   From public sources	Verifying your identity   Improving our customer service and website   Getting, issuing, renewing, and servicing an insurance policy for you   Helping determine your insurance needs   Managing and administering our business   Protecting Hagerty and you against fraud   Keeping your information accurate and up to date   Meeting legal, regulatory, insurance, and security requirements   To complete a business transaction with you   To show you personalized content or market products to you   For data analytics to improve our business and services   To process payments and issue refunds	Advertising and Marketing service providers, including for the purposes of targeted advertising	Service providers and other providers or partners that support our operational business purposes or perform professional and business services for us.   Our underwriting company   Your insurance broker or agent   Regulatory and self-regulatory agencies   Other Hagerty companies or subsidiaries   Licensed agencies and brokerages that have referred you to us   Adjusters or insurance companies for claims handling   Consumer reporting agencies
Personal information, as defined in the California Customer Records law, such as contact and financial information	You, when you use our websites or applications, request or obtain products and services from us, or otherwise provide us with personal information   Insurance Companies   Insurance Brokers or Agents   Motor vehicle and driver licensing authorities   Financial institutions Consumer reporting agencies   From a third party or intermediary (for example, an agent, customer, or business partner)   From our service providers   From data brokers   From public sources	Helping determine your insurance needs   Managing and administering our business   Protecting Hagerty and you against fraud   Keeping your information accurate and up to date   Meeting legal, regulatory, insurance, and security requirements   To complete a business transaction with you   To show you personalized content or market products to you   For data analytics to improve our business and services   To process payments and issue refunds	Other Hagerty companies or subsidiaries     Advertising and Marketing service providers	Service providers and other providers or partners that support our operational business purposes or perform professional and business services for us.   Our underwriting company   Your insurance broker or agent Regulatory and self-regulatory agencies   Other Hagerty companies or subsidiaries   Licensed agencies and brokerages that have referred you to us   Adjusters or insurance companies for claims handling   Consumer reporting agencies     Research and analytics providers
Characteristics of protected classifications under California law and federal law, such as age or gender	You, when you use our websites or applications or social media platforms, request or obtain products and services from us, or otherwise provide us with personal information   Insurance Companies   Insurance Brokers or Agents   Motor vehicle and driver licensing authorities   Financial institutions   From our service providers   From data brokers	Verifying your identity   Getting, issuing, renewing, and servicing an insurance policy for you   Helping determine your insurance needs   Managing and administering our business   Protecting Hagerty and you against fraud   Keeping your information accurate and up to date   Meeting legal, regulatory, insurance, and security requirements   To complete a business transaction with you   To show you personalized content or market products to you   For data analytics to improve our business and services	N/A	Service providers and other providers or partners that support our operational business purposes or perform professional and business services for us.   Our underwriting company   Your insurance broker or agent Regulatory and self-regulatory agencies   Other Hagerty companies or subsidiaries   Licensed agencies and brokerages that have referred you to us   Adjusters or insurance companies for claims handling   Consumer reporting agencies
Commercial information, such as transaction information and purchase history	You, when you use our websites or applications, request or obtain products and services from us, or otherwise provide us with personal information   Insurance Companies   Insurance Brokers or Agents   Motor vehicle and driver licensing authorities   Financial institutions   Consumer reporting agencies   From our service providers   From public sources	Verifying your identity   Getting, issuing, renewing, and servicing an insurance policy for you   Helping determine your insurance needs   Managing and administering our business   Protecting Hagerty and you against fraud   Keeping your information accurate and up to date   Meeting legal, regulatory, insurance, and security requirements   To complete a business transaction with you   To show you personalized content or market products to you   For data analytics to improve our business and services	N/A	Service providers and other providers or partners that support our operational business purposes or perform professional and business services for us.   Our underwriting company   Your insurance broker or agent Regulatory and self-regulatory agencies   Other Hagerty companies or subsidiaries   Licensed agencies and brokerages that have referred you to us
Biometric information	N/A	N/A	N/A	N/A
Internet or network activity information, such as hardware model, device software platform, mobile carrier, preferred languages, and interactions with our Services, including chat messages and metadata.	You, when you use our websites or applications, request or obtain products and services from us, or otherwise provide us with personal information	Managing and administering our business   Meeting legal, regulatory, insurance, and security requirements   To show you personalized content or market products to you   To improve our business and services, including through data analytics and the development and improvement of AI technologies.	Advertising and Marketing service providers   Research and analytics providers and data brokers	Service providers and other providers or partners that support our operational business purposes or perform professional and business services for us. Other Hagerty companies or subsidiaries
Geolocation data, such as coarse location information (city, state, country)	You, when, you use our website, request, or obtain products and services from us, or otherwise provide us with personal information	Verifying your identity   Managing and administering our business   Meeting legal, regulatory, insurance, and security requirements   To show you personalized content or market products to you   For data analytics to improve our business and services	Research and analytics providers	Service providers and other providers or partners that support our operational business purposes or perform professional and business services for us.   Other Hagerty companies or subsidiaries
Audio, electronic, visual and other similar information.	You, when, you interact with our agents by phone or if you attend events	To improve our services   Meeting legal or regulatory requirements and security requirements   For data analytics to improve our business and customer experience at events	N/A	Other Hagerty companies or subsidiaries   As required by applicable law (e.g., subpoena)   Service providers that help us process business or provide analytics for events
Professional or employment-related information, such as work history and CV	You, when you use our website, request, or obtain products and services from us, or otherwise provide us with personal information   From a third party or intermediary (for example, an agent, customer, or business partner)   From our service providers	Verifying your identity   Managing and administering our business   Protecting Hagerty and you against fraud   Keeping your information accurate and up to date   Meeting legal, regulatory, insurance, and security requirements   For data analytics to improve our business and services	N/A	Service providers and other providers or partners that support our operational business purposes or perform professional and business services for us.
Inferences drawn from any of the Personal Information listed above to create a profile or summary about, for example, an individual’s interests, preferences, and characteristics	You, when you use our websites or applications, request or obtain products and services from us, or otherwise provide us with personal information   Marketing service providers   From our service providers   From data brokers	Improving our customer service and website   Helping determine your insurance needs   To show you personalized content or market products to you   For data analytics to improve our business and services	Advertising and Marketing service providers	Service providers and other providers or partners that support our operational business purposes or perform professional and business services for us.
Sensitive Personal Information, such as social security number, driver’s license, state identification card, and passport number.	You, when you use our websites or applications, request or obtain products and services from us (such as roadside services), or otherwise provide us with personal information or consent to provide us the information   Insurance Companies   Insurance Brokers or Agents   Motor vehicle and driver licensing authorities   Financial institutions   Consumer reporting agencies   Directly from you via survey responses you voluntarily provide, or from your interactions with our website     Healthcare providers (for bodily injury claims)	Verifying your identity   Getting, issuing, renewing, and servicing an insurance policy for you   Helping determine your insurance needs   Protecting Hagerty and you against fraud   Keeping your information accurate and up to date   Meeting legal, regulatory, insurance, and security requirements   To complete a business transaction with you   Fulfilling our membership services	N/A	Our underwriting company   Your insurance broker or agent   Regulatory and self-regulatory agencies   Other Hagerty companies or subsidiaries   Licensed agencies and brokerages that have referred you to us   Adjusters or insurance companies for claims handling   Consumer reporting agencies   Banks and payment processors   Third party roadside providers   Other service providers that perform professional and business services for us, e.g., lawyers, accountants, analytics providers, IT providers   As authorized by you to third parties to assist with insurance claims   Verification providers

Sensitive Personal Information

We do not process “sensitive” Personal Information for purposes other than those permitted by the CCPA and its associated regulations (such as to provide the services and for security purposes).

Data Retention

To learn more about how long Hagerty retains your personal information (our service schedule), please see Section 4, Data Retention, above.

Rights Regarding Your Personal Information

• To access/know. You may have the right to know and request information about the categories and specific pieces of personal information we have collected about you within the last 12 months, as well as the categories of sources from which such information is collected, the purpose for collecting such information, and the categories of third parties with whom we share such information. You also have the right to know if we have sold or disclosed personal information.
• To portable data. You may have the right to obtain your personal data in a portable and, to the extent technically feasible, readily usable format that allows you to transmit the data to another entity without hindrance.
• To correct. You may have the right to notify us through the methods identified in the “Exercising Your Rights” section below to correct any mistakes in your personal information. We may not be able to accommodate your request if we believe it would violate any law or legal requirement or cause the information to be incorrect; data solely retained for data backup purposes is generally excluded.
• To delete. You may have the right to request deletion of your personal information, subject to certain exceptions.
• To non-discrimination. We will not discriminate against any person exercising any of these rights. We may, however, provide a different level of service or charge a different rate reasonably relating to the value of your personal information.
• To opt-out of the selling or sharing of information. You may have the right to opt out of selling, sharing, and targeted advertising (as such terms are defined under applicable laws). We do not knowingly sell data about minors under 18.

A. Exercising Your Rights

Methods of Exercising Rights. If you or your authorized agent would like to exercise any of the above rights or contact us regarding this privacy policy, please submit your request using Hagerty’s Privacy Request Form. You can open the form by clicking the button below, or you can call us at 800-922-4050 to make your request over the phone. To exercise your right to opt-out of the sale/sharing of personal information, please visit our “Your Privacy Choices” page here. To the extent required by law, we will honor opt-out preference signals.

Required Information. When you submit a request to delete or correct your information, we will ask for your name, email address, and state of residence. When you submit a request to know or for a copy of your personal information, we will require additional information to verify that you are the person to whom the information relates. We will match this information against information we have previously collected about you to verify your identity and to respond to your request. If you maintain an account with us, we may require you to login to that account as part of submitting your request.

Identity Verification For Verifiable Consumer Requests. We cannot respond to your verifiable consumer request (e.g., right to correct, access, delete) if we cannot verify your identity or authority to make the request and confirm the personal information relates to you. Making a verifiable consumer request does not require you to create an account with us. We will use the personal information you provide to us when submitting a verifiable consumer request only to verify the requestor's identity or authority to make the request. You also may designate an authorized agent to make a request on your behalf. If you are submitting a request through an authorized agent, the authorized agent must provide us with your signed written permission stating that the agent is authorized to make the request on your behalf. We may also request that you and/or any authorized agents verify their identity and may reach out to you directly to confirm that you have provided the agent with your permission to submit the request on your behalf.

Response Timeline. We will respond to verifiable consumer requests within a reasonable timeframe as permitted and required under applicable law.

B. California “Shine the Light”

In addition to the above rights, under California Civil Code Section 1798.83 (“Shine the Light”), California residents may have the right to request in writing from businesses with whom they have an established business relationship: (a) a list of the categories of personal information, as defined under Shine the Light, such as name, email address, and mailing address, and the type of services provided to the customer that a business has disclosed to third parties (including affiliates that are separate legal entities) during the immediately preceding calendar year for the third parties’ direct marketing purposes; and (b) the names and addresses of all such third parties. To request the above information, please contact us by email at privacy@hagerty.com. Hagerty does not share your information with non-Hagerty companies for direct marketing purposes. However, Hagerty does share information with other Hagerty companies to offer the full breadth of our products and services. If you do not want your personal information shared with any third party (including Hagerty companies) who may use such information for direct marketing purposes, then you may opt out of such disclosures by sending an email to us at privacy@hagerty.com. 

8. Artificial Intelligence

We use certain artificial intelligence (AI) tools to help tune our services, improve your experience behind the wheel of our sites and apps, and support research and development. We may use your personal information with AI technology to improve or provide you with our services, to develop and provide you with new products, features, and technologies, to prevent fraud or misuse of our services, and for any other uses consistent with this privacy notice and Hagerty’s AI Principles. For example, when you interact with our chat agent, we may use information such as chat transcripts to develop, train, and improve our services. We do not use AI tools or process personal information derived from our Services to make decisions that produce legal or similarly significant effects on individuals, including decisions related to financial or lending services, employment, credit, housing, or healthcare.

Hagerty AI Principles: We are committed to using your data responsibly according to our AI Principles, which govern the AI technologies we develop and deploy. These AI Principles convey our commitment to fairness and ethics, accountability, legal compliance, transparency, security, safety and robustness, and privacy enhancement.

When using data for AI training and development, we implement appropriate data minimization techniques to limit the amount of data used to that which is necessary.

9. Our Policies Concerning Children

You must be 16 years or older to use our Services. Our Services are for a general audience, are not targeted to children, and we do not knowingly collect personal information from children under 16 years of age.  If a parent or guardian becomes aware that his or her child or minor has provided us with information without their consent, he or she should contact us at 800-922-4050 or privacy@hagerty.com.

10. International Data Transfers

The love of cars is international and so are we. Hagerty complies with the EU-U.S. Data Privacy Framework (EU-U.S. DPF) and the UK Extension to the EU-U.S. DPF as set forth by the U.S. Department of Commerce. Hagerty has certified to the U.S. Department of Commerce that it adheres to the EU-U.S. Data Privacy Framework Principles (EU-U.S. DPF Principles) with regard to the processing of personal data received from the European Union in reliance on the EU-U.S. DPF and from the United Kingdom (and Gibraltar) in reliance on the UK Extension to the EU-U.S. DPF. If there is any conflict between the terms in this privacy policy and the EU-U.S. DPF Principles, the Principles shall govern. To learn more about the Data Privacy Framework (DPF) program, and to view our certification, please visit https://www.dataprivacyframework.gov/.

In compliance with the EU-U.S. DPF and the UK Extension to the EU-U.S. DPF, Hagerty commits to resolve DPF Principles-related complaints about our collection and use of your personal information. EU and UK individuals with inquiries or complaints regarding our handling of personal data received in reliance on the EU-U.S. DPF and the UK Extension to the EU-U.S. DPF should first contact Hagerty at: privacy@hagerty.com.

In compliance with the EU-U.S. DPF and the UK Extension to the EU-U.S. DPF, Hagerty commits to refer unresolved complaints concerning our handling of personal data received in reliance on the EU-U.S. DPF and the UK Extension to the EU-U.S. DPF to TRUSTe, an alternative dispute resolution provider based in the United States. If you do not receive timely acknowledgment of your DPF Principles-related complaint from us, or if we have not addressed your DPF Principles-related complaint to your satisfaction, please visit https://feedback-form.truste.com/watchdog/request for more information or to file a complaint. The services of TRUSTe are provided at no cost to you.

The Federal Trade Commission has jurisdiction over Hagerty’s compliance with the EU-U.S. Data Privacy Framework (EU-U.S. DPF) and the UK Extension to the EU-U.S. DPF.

As set forth in Annex I of the DPF Principles, an individual has the possibility, under certain conditions, to invoke binding arbitration for complaints regarding DPF compliance not resolved by any of the other DPF mechanisms.

If Hagerty receives personal information under the DPF Principles and then transfers that personal information to a third-party, Hagerty shall remain liable under the DPF Principles to the extent the third party’s actions are inconsistent with the DPF Principles, unless Hagerty provides information in support of Hagerty not having responsibility for the event.

The following United States Hagerty Group companies are adhering to the DPF Principles to include the UK Extension to the EU-U.S. DPF: Hagerty Insurance Agency, LLC; Hagerty Motorsports, LLC; Hagerty Classic Marine Insurance Agency, LLC; Hagerty Media Properties, LLC; Hagerty Drivers Club, LLC; and Hagerty Management, LLC; Broad Arrow Auctions, LLC, Broad Arrow Capital, LLC, and Broad Arrow Private Sales, LLC.

11. Links and Other Information

A. Links

Our website contains links to other third-party sites. Please be aware that when you leave our site, the sites you visit are governed by their own privacy notices. This Privacy Notice only applies to our website (and related Hagerty.com webpages). We are not responsible for the privacy practices of these websites.

B. Surveys and Contests

Sometimes we offer surveys or contests. These are 100% voluntary. Any information collected from a survey or contest will only be used to make our website or products better and to contact any winners.

C. Communications

We may, as permitted by law, record, review, and store your communications with us. This includes phone calls, posts on our site, messages with other members, or conversations with our agents, whether by phone or online (such as through chat). We use these communications for internal reasons, like improving our services and for security. However, we are not required to review these communications or take any specific action based on them. Please note, anything you post in your profile or any public area of our website can be seen by other users.

D. Your Marketing Preferences

We may periodically send promotional materials or notifications related to our Services. If you no longer wish to receive promotional marketing materials from us, you may opt out of receiving such materials. You may unsubscribe from receiving marketing or other commercial emails from us by following the unsubscribe instructions included in the email.

There are certain service notifications and other non-promotional emails that you may not opt out of, such as notifications of changes to our Services or policies.

E. Text Messaging (SMS/MMS)

If you have opted in to receive promotional text messages from Hagerty, you consent to receive recurring automated marketing and informational text messages (SMS and MMS) at the phone number you provided. Message frequency varies. Message and data rates may apply. You may opt out of receiving text messages at any time by replying STOP to any message you receive from us or by contacting us at privacy@hagerty.com or 800-922-4050. After you opt out, you may receive one final confirmation message. Opting out of text messages will not affect your receipt of other communications from us, such as email. Your consent to receive text messages is not a condition of any purchase.

Text messages may include reminders, alerts, promotional offers, event notifications, auction updates, and other information related to our products and services. We do not share your phone number or text messaging information with third parties for their marketing purposes. For help with text messaging, reply HELP to any message or contact us at privacy@hagerty.com.

We may periodically send promotional materials or notifications related to our Services. If you no longer wish to receive promotional marketing materials from us, you may opt out of receiving such materials. You may unsubscribe from receiving marketing or other commercial emails from us by following the unsubscribe instructions included in the email.

There are certain service notifications and other non-promotional emails that you may not opt out of, such as notifications of changes to our Services or policies.

 

12. Changes to Our Privacy Notice

We must modify this Privacy Notice from time to time with aftermarket parts to keep it accurate and comprehensive. We will notify you of material changes on this webpage, and we will keep old versions of this Notice archived.

13. Questions

If you have any questions about this privacy notice, or need to contact us for any reason, simply contact us at 800-922-4050 or privacy@hagerty.com.