What does this Privacy Policy cover?
This Privacy Policy covers our treatment of personally identifiable information ("Personal Information") that we gather when you are accessing or using our services, including when you visit our site https://www.gabi.com/ (the “Site”) or download our app (collectively, the “Services”). We gather various types of Personal Information from our users, as explained in more detail below, and we use this Personal Information in connection with our Services, including to personalize, provide, and improve our Services, to allow you to set up a user account and profile, to contact you and allow other users to contact you, to fulfill your requests for certain products and services, and to analyze how you use the Services. In certain cases, we may also share your Personal Information with third parties, as described below.
Financial Products or Services: If you have or are seeking a financial product or service with us, we will use and share any nonpublic personal information that we collect from or about you in accordance with our GLBA Consumer Privacy Notice, which offers you certain choices with respect to the collection, use, sharing, and processing of your nonpublic personal information. This includes information we collect when you access or use the mobile application operated by Gabi to manage or conduct transactions.
Click on the links below to jump to each section:
- What does this Privacy Policy cover?
- What information does Gabi collect and how does Gabi use such information?
- Will Gabi share any of the Personal Information it receives?
- How does Gabi use third-party tracking technologies for online advertising?
- Is Personal Information about me secure?
- What choices do I have?
- Does Gabi collect children’s information?
- Will Gabi ever change this Privacy Policy?
- What if I have questions about this policy?
- What rights do California residents have under the California Consumer Privacy Act?
What information does Gabi collect and how does Gabi use such information?
Information You Provide to Us
We receive and store any information you provide to us. For example, through the registration process, your account settings or when are you are seeking insurance quotes, or applying for insurance, we may collect Personal Information as follows:
- Contact Information, such as your name, email address, and phone number.
- Application and Registered User Information, such as insurance underwriting information, payment information, social security number, date of birth, driver’s license number, vehicle information. This is typically collected when you fill out applications for insurance or other forms such as claims forms, accident reports or underwriting worksheets.
- Communications, including via email, chat, text, or phone, including voice recordings (as permitted by applicable law) if you speak with our representatives, or otherwise provide information to us through our website, email or paper correspondence, or otherwise. We may communicate with you regarding your insurance transactions with us or topics other than your insurance transactions with us if you’ve provided us the means to do so. For example, if you’ve given us your email address, we may send you promotional email offers on behalf of other businesses, or email you about your use of the Services. Also, we may receive a confirmation when you open an email from us. This confirmation helps us make our communications with you more interesting and improve our services.
- Third-Party Account Credentials, for example, your log-in credentials for Facebook, your current insurer or other third party sites. If you provide your third-party account credentials to us or otherwise sign in to the Services through a third party site or service, you understand some content and/or information in those accounts (“Third Party Account Information”) may be transmitted into your account with us if you authorize such transmissions, and that Third Party Account Information transmitted to our Services is covered by this Privacy Policy. For example, your current insurance information may be accessed. You may revoke your permission for us to use third party credentials provided to us at any time. Certain information may be required to register with us or to take advantage of some of our features.
Information from Third Parties
Although we often collect the Personal Information described above directly from you, we also collect this information through service providers and other third parties that collect it on our behalf, as noted below.
- Insurance Information, for example, we may obtain information regarding your insurance transactions, policies, or underwriting information from the insurance companies we contact to underwrite your insurance or from your current insurer.
- Governmental Agencies (such as the Department of Motor Vehicles) and consumer reporting agencies information, including household information and driver risk (past incidents).
- Insurance Claims, including related information from medical records and medical professionals.
- Publicly Available Information, such as government records or public review websites.
- Payment Transaction Information, including description, date, time, payment type, and amount. Please note we use third party payment processors to process payments. As such, we do not retain any personally identifiable financial information such as credit card numbers. Rather, all such information is provided to our third-party processor. The payment processor’s use of your Personal Information is governed by their privacy policy.
- Service Providers, which perform services solely on our behalf, such as survey and marketing providers, collect Personal Information and often share some or all of this information with us.
- Information Providers, including information used to correct or supplement Personal Information or underwriting information we collect. For example, we may obtain updated contact information from third-party information providers to reconnect with an individual, information about your vehicles, or other information needed to obtain a quote for insurance or bind an insurance policy.
- Business Partners, who may provide information about you or refer you to our service.
Information Collected Automatically
As is true of most digital platforms, we and our third-party providers may also collect Personal Information from an individual’s device, browsing actions and site usage patterns automatically when visiting or interacting with our Site, which may include:
- Log Data such as internet protocol (IP) address, operating system, browser type, browser id, the URL entered and the referring page/campaign, date/time of visit, the time spent on our Site and any errors that may occur during the visit to our Site;
- Analytics Data, such as the electronic path taken to our Site, through our Site and when exiting our Site, as well as usage and activity on our Site; and
- Location Data, such as general geographic location based on the log data we or our third-party providers collect.
To manage cookies, an individual may change their browser settings to: (i) notify them when they receive a cookie, so the individual can choose whether or not to accept it; (ii) disable existing cookies; or (iii) automatically reject cookies. Please note that doing so may negatively impact an individual’s experience using our Site, as some features and offerings may not work properly or at all. Depending on an individual’s device and operating system, the individual may not be able to delete or block all cookies. In addition, if an individual wants to reject cookies across all browsers and devices, the individual will need to do so on each browser on each device they actively use. An individual may also set their email options to prevent the automatic downloading of images that may contain technologies that would allow us to know whether they have accessed our email and performed certain functions with it.
Your browser may offer you a “Do Not Track” option, which allows you to signal to operators of websites and web applications and services (including behavioral advertising services) that you do not wish such operators to track certain of your online activities over time and/or across different websites. Our Services do not support Do Not Track requests at this time, which means that we collect information about your online activity both while you are using the Services and after you leave our Services.
We and our third-party partners may also use cookies and tracking technologies for advertising purposes. For more information about tracking technologies, please see How does Gabi use third-party tracking technologies for online advertising? below.
Will Gabi share any of the Personal Information it receives?
We may share your Personal Information with third parties as described in this section:
Information that’s no longer personally identifiable. We may anonymize your Personal Information so that you are not individually identified, and provide that information to our partners. We may also provide aggregate usage information to our partners, who may use such information to understand how often and in what ways people use our Services, so that they, too, can provide you with an optimal online experience. However, we never disclose aggregate usage information to a partner in a manner that would identify you personally, as an individual.
Legally Required Disclosures. We may disclose Personal Information about you to a State Insurance Division or Department of Insurance or other insurance regulatory authority, law enforcement, or other governmental authority in order to protect our interests or if we are required by law to divulge the information.
Information Required for the Conduct of Your Insurance Transactions. We may disclose Personal Information about you to a third party if the disclosure will enable the third party to perform a business professional or insurance function for use, including insurance carriers, technical service providers, credit reporting agencies, and our attorneys and auditors. We may also disclose Personal Information about you to other contractors, service providers and other third parties we use to support our business and who are bound by contractual obligations to keep Personal Information confidential and use it only for the purposes for which we disclose it to them.
Advertisers. We may allow advertisers and/or partners (“Advertisers”) to choose the demographic information of users who will see their advertisements and/or promotional offers and you agree that we may provide any of the information we have collected from you in non-personally identifiable form to an Advertiser, in order for that Advertiser to select the appropriate audience for those advertisements and/or offers. For example, we might use the fact you are located in San Francisco to show you ads or offers for San Francisco businesses, but we will not tell such businesses who you are. Or, we might allow Advertisers to display their ads to users with similar usage patterns to yours, but we will not disclose usage information to Advertisers except in aggregate form, and not in a manner that would identify you personally. Note that if an advertiser asks us to show an ad to a certain audience or audience segment and you respond to that ad, the advertiser may conclude that you fit the description of the audience they were trying to reach. For more information, please see How does Gabi use third-party tracking technologies for online advertising? below.
Business partners. In certain situations, businesses or third party websites we’re partnering with may sell or provide products or services to you through or in connection with the Services (either alone or jointly with us). You can recognize when a business partner is associated with such a transaction or service, and we will share your Personal Information with that business partner only to the extent that it is related to such transaction or service. One such service may include the ability for you to automatically transmit Third Party Account Information to your Services profile or to automatically transmit information in your Services profile to your third party account. We have no control over the policies and practices of third party websites or businesses as to privacy or anything else, so if you choose to take part in any transaction or service relating to an affiliated website or business, please review their policies.
Agents. We employ other companies and people to perform tasks on our behalf and need to share your information with them to provide products or services to you; for example, we may use a payment processing Gabi to receive and process your credit card transactions for us. Unless we tell you differently, our agents do not have any right to use the Personal Information we share with them beyond what is necessary to assist us.
User Profiles and Submissions. Certain user profile information, including your name, location, and any video or image content that you have uploaded to the Services may be displayed to other users to facilitate user interaction within the Services or address your request for our services. Additionally, if you sign into the Services through a third party social networking site or service, your list of “friends” from that site or service may be automatically imported to the Services, and such “friends,” if they are also registered users of the Services, may be able to access certain non-public information you have entered in your Services user profile. Again, we do not control the policies and practices of any other third party site or service.
Business Transfers. We may choose to buy or sell assets. In these types of transactions or in contemplation of a transaction, Personal Information is typically one of the business assets that would be transferred. Also, if we (or our assets) are acquired, or if we go out of business, enter bankruptcy, or go through some other change of control, Personal Information could be one of the assets transferred to or acquired by a third party.
Protection of Gabi and Others. We reserve the right to access, read, preserve, and disclose any information that we reasonably believe is necessary to comply with law or court order; enforce or apply our Terms of Service at gabi.com/terms and other agreements; or protect the rights, property, or safety of Gabi, our employees, our users, or others.
How does Gabi use third-party tracking technologies for online advertising?
Gabi may participate in interest-based advertising and use third party advertising partners to collect information from visitors to the Site for the purpose of displaying interest-based advertisements on other websites, apps or services, social networks, or on other devices you may use. Typically, though not always, these third party ad networks use cookies and tracking technologies to recognize your browser or device and to collect information about your visit to our Service to provide you customized content, advertising and commercial messages which may be more relevant to your interests, as well as to provide advertising-related services such as reporting, attribution, analytics and market research.
To learn about interest-based advertising and how you may be able to opt-out of some of this advertising, you may wish to visit the Network Advertising Initiative’s online resources, at http://www.networkadvertising.org/choices, and/or the DAA’s resources at www.aboutads.info/choices. You may also be able to limit interest-based advertising through the settings on your mobile device by selecting “limit ad tracking” (iOS) or “opt-out of interest-based ads” (Android). You may also be able to opt-out of some – but not all – interest-based ads served by mobile ad networks by visiting http://youradchoices.com/appchoices and downloading the mobile AppChoices app.
Please note that opting-out of receiving interest-based advertising through the NAI’s and DAA’s online resources will only opt-out a user from receiving interest-based ads on that specific browser or device, but the user may still receive interest-based ads on his or her other devices. You must perform the opt-out on each browser or device you use.
Is Personal Information about me secure?
Your account is protected by a password for your privacy and security. You must prevent unauthorized access to your account and Personal Information by selecting and protecting your password and/or other sign-on mechanism appropriately and limiting access to your computer or device and browser by signing off after you have finished accessing your account.
We use certain physical, administrative, and technical safeguards that are designed to protect the integrity and security of your information. We cannot, however, ensure or warrant the security of any information you transmit to us through the Services, and you do so at your own risk.
What choices do I have?
Updating Your Information
Once you have registered for an account, you may update or correct your profile information and preferences at any time by accessing your account settings page through the Site or the app.
Deactivating Your Account
We do not delete information about you upon deactivation of your account. Although your deactivated status is reflected promptly in our user databases, we may retain the information you submit for a variety of purposes, including legal compliance, backups and archiving, prevention of fraud and abuse, and analytics. Upon deactivation, you will no longer receive emails from Gabi and links to third-party financial accounts and services will automatically terminate.
Unsubscribing from Emails
If you do not wish to receive email offers or newsletters from us, you can opt out of receiving email information from us (except for emails related to the completion of your registration, correction of user data, change of password, and other similar communications essential to your transactions through the services) by using the unsubscribe process at the bottom of any marketing email from us. Although your changes are reflected promptly in active user databases, we may retain all information you submit for a variety of purposes, including backups and archiving, prevention of fraud and abuse, and analytics.
Correcting Credit Reports
Information related to your creditworthiness is maintained by the credit bureaus. If you find that there is an error or you want to dispute the information found in your credit report, please contact the credit reporting bureaus.
- Experian: http://www.experian.com/
- Transunion: https://dispute.transunion.com/
- Equifax: https://www.ai.equifax.com/
Gramm-Leach-Bliley Act Data
Please see our GLBA Consumer Privacy Notice for more information about how you can limit your sharing options in connection with Gramm-Leach-Bliley Act (“GLBA”) data.
Does Gabi collect children’s information?
We do not knowingly collect or solicit Personal Information from anyone under the age of 13. If you are under 13, please do not attempt to register for the Services or send any Personal Information about yourself to us. If we learn that we have collected Personal Information from a child under age 13, we will delete that information as quickly as possible. If you believe that a child under 13 may have provided us personal information, please contact us at legal@gabi.com.
Will Gabi ever change this Privacy Policy?
We’re constantly trying to improve our Services, so we may need to change this Privacy Policy from time to time as well, but we will alert you to changes by placing a notice on gabi.com and/or by some other means. If you use the Services after any changes to the Privacy Policy have been posted, that means you agree to all of the changes. Use of information we collect now is subject to the Privacy Policy in effect at the time such information is used.
What if I have questions about this policy?
If you have any questions or concerns regarding our privacy policies, please send us a detailed message to legal@gabi.com, and we will try to resolve your concerns.
What rights do California residents have under the California Consumer Privacy Act?
California law requires us to disclose to California residents certain information regarding the categories of personal information we collect. For purposes of this section, “personal information” has the meaning provided by the California Consumer Privacy Act (the “CCPA”) and does not include information that is publicly available, that is deidentified or aggregated such that it is not capable of being associated with us, or that is excluded from the CCPA’s scope, such as personal information covered by certain sector-specific privacy laws, such as the Fair Credit Reporting Act, GLBA or the Driver’s Privacy Protection Act of 1994. This section does not apply to information relating to our employees, contractors, applicants and other personnel.
Collection and use of personal information. We collect personal information from and about you for a variety of purposes. For example, we use personal information to fulfill your requests, process your transactions and provide our Services to you; to communicate with you; for marketing and advertising purposes; to monitor, improve, and develop our products and Services; and to protect the security and integrity of our business, comply with legal requirements and obligations; for our business and operational purposes; and as otherwise permitted or required by law.
In the last 12 months, we have collected the following categories of personal information:
- Identifiers, such as your name, address, phone number.
- Internet/Network information, such as device information, logs and analytics data;
- Geolocation data, such as precise location data from your device or generated based on your IP address; and
- Inferences about your interests and preferences, generated from your use of our sites.
We collect this information directly from you, from our business partners and affiliates, from your browser or device when you visit our websites, or from third parties that you permit to share information with us. For more information on our collection and use of your information, please see the section headed What information does Gabi collect and how does Gabi use such information?
Disclosure of Personal Information. We share personal information with third parties for business purposes (see Your CCPA Rights and Choices below). The categories of third parties to whom we disclose your personal information may include: (i) other brands and affiliates in our family of companies; (ii) our service providers and advisors, (iii) marketing and strategic partners; (iv) ad networks and advertising partners; (v) analytics providers; and (vi) social networks.
In the previous 12 months, we have disclosed the following categories of personal information to third parties for a business purpose:
- All of the categories of personal information we collect as described in this Privacy Policy.
Your CCPA Rights and Choices. As a California resident, you may be able to request to exercise the following rights:
- The Right to Know any or all of the following information relating to your personal information we have collected and disclosed in the last 12 months, upon verification of your identity:
- The specific pieces of personal information we have collected about you;
- The categories of personal information we have collected about you;
- The categories of sources of the personal information;
- The categories of personal information that we have disclosed to third parties for a business purpose, and the categories of recipients to whom this information was disclosed;
- The categories of personal information we have sold and the categories of third parties to whom the information was sold; and
- The business or commercial purposes for collecting or selling the personal information.
- The Right to Request Deletion of personal information we have collected from you, subject to certain exceptions.
- The Right to Opt Out of Personal Information Sales to third parties in the future.
You also have the right to be free of discrimination for exercising these rights. However, please note that if the exercise of these rights limits our ability to process personal information (such as in the case of a deletion request), we may no longer be able to provide you our products and services or engage with you in the same manner.
To Submit your California Consumer Rights Requests. You may submit a request to exercise your California Consumer Rights through the mechanism described below. We will need to verify your identity before processing your request, which may require us to request additional personal information from you or require you to log into your account, if you have one. In certain circumstances, we may decline or limit your request, particularly where we are unable to verify your identity or locate your information in our systems, or as permitted by law.
To Exercise Your Right to Request, Know or Delete
To exercise your California consumer rights to request, know or delete, please send us an email at legal@gabi.com with the subject line “CCPA Request.”
Before processing your request, we will need to verify your identity and confirm you are a resident of the State of California. In order to verify your identity, we will generally either require the successful authentication of your account, or the matching of sufficient information you provide us to the information we maintain about you in our systems. This process may require us to request additional personal information from you, including, but not limited to, your email, phone, or address.
In certain circumstances, we may decline a request to exercise the right to know and/or right to deletion, particularly where we are unable to verify your identity.
Authorized Agents
In certain circumstances, you are permitted to use an authorized agent (as that term is defined by the CCPA) to submit requests on your behalf through the designated methods set forth in these Disclosures where we can verify the authorized agent’s authority to act on your behalf by:
For requests to know or delete personal information: (i) receiving a power of attorney valid under the laws of California from you or your authorized agent; or (ii) receiving sufficient evidence to show that you have: (a) provided the authorized agent signed permission to act on your behalf; (b) verified your own identity directly with us pursuant to the instructions set forth in these Disclosures; and (c) directly confirmed with us that you provided the authorized agent permission to submit the request on your behalf.