Privacy Policy

FIGO PET INSURANCE, LLC PRIVACY POLICY
Last modified: September 2018
 
This Privacy Policy outlines what types of information are collected from our policy holders, users, visitors, and customers (“you”, “your” or “User”), to whom it may be disclosed, and how that information may be used by Figo Pet Insurance, LLC (“Figo”, “we”, “our” or “us”), as each of the foregoing relates to your use of our Sites or Services.  Please see Section 2 below for definitions of certain important terms used in this Privacy Policy.
 
By using the Sites or Services, you agree that you have read, understood, and consented to this Privacy Policy, our Terms of Use, all amendments, addenda, and licenses to each of the Privacy Policy and the Terms of Use (collectively, the “Agreement”). By using our Sites or Services, you consent to Figo’s use of your information and data as described in the Agreement. If you do not agree to the terms of this Privacy Policy, do not use the Sites or Services.
 
We reserve the right to modify or change these Terms after providing notice to you. The form of such notice is at our discretion. For more information, please see Section 17 below.
 
The official language used by Figo is English; in the event of a conflict between the English language version of this document and any version translated into any other language, the English language version shall prevail.
 
Figo understands the importance of your privacy and the information that you may supply to us when using our website.  Figo strives to protect your information and keep it secure.
 
Figo undertakes electronic, physical, and procedural security measures to protect the Personal Data of its customers and visitors as well as that of veterinarians and other vendors.
 
SSL Certificates. Figo’s sites currently undergo daily website security tests through Symantec Corporation’s website security solutions program, an identity and authentication security service. 
 

  1. Scope of this Privacy Policy.
Figo provides insurance and technology products and services for the pet industry. This Privacy Policy describes the security measures we apply to the use of all Sites or Services by you. This Privacy Policy applies to all Figo Sites or Services and provides important information regarding the use and disclosure of information collected by Figo. If you do not agree to the terms of this Privacy Policy, you must not use Figo Sites or Services.
 
At Figo, we value your relationship and we believe strongly in protecting your privacy. Please read this Privacy Policy carefully to learn more about the ways in which we use and protect your Personal Data. This Privacy Policy outlines what types of non-public information is collected, to whom it may be disclosed, and how that information may be used. 
 
  1. Definitions
Account” is defined in our Terms of Use and means the account established by you in order to obtain certain benefits of our Sites or Services.
“Affiliates” means companies that, either directly or indirectly, we control, are controlled by, or that are owned or controlled by the same entity that controls us.
Agreement” means this Privacy Policy, our Terms of Use, all amendments, addenda, and licenses to each of the Privacy Policy and the Terms of Use.
Authorization” means the set of rights and privileges on the Sites or Services assigned to a User by Figo.
Content” means all information and other materials present on the Sites, including Figo’s products and services, text, images, photos, opinions rumors, advice, charts, financial information, ratings, reviews, or similar information.
Controller” means a person or entity who, either alone or jointly, determines the purposes and means of the processing of Personal Data, controls the data, and is responsible for it, and does so with respect to persons (Data Subjects) who are physically located in the European Union.
Cookies” means small files that are placed on your hard drive for identification purposes. These files are used for site registration and customization the next time you visit us.
Credit Card Information” means certain credit card information, including your card number, CVV number, expiration date, phone number, name, billing address, and email address.
Data Subject” means an identified or identifiable natural person.
Debit Card Information” means certain debit card information, including your card number, CVV number, expiration date, phone number, name, billing address, and email address.
EU” means the European Union.
Figo” (“we”, “our” or “us”) means Figo Pet Insurance, LLC, an Illinois limited liability company.
Sites or Services” means all Figo domains, websites, software, applications, online services, and products.
GDPR” means the General Data Protection Regulation, adopted as Regulation (EU) 2016/679 of the European Parliament on April 14, 2016. The GDPR is effective as of May 25, 2018.
Images or Content” are defined in our Terms of Use.
Log Data” means information that your browser sends whenever you visit a website; this information is automatically recorded by our servers.
Personal Data” means any information relating to an identified or identifiable natural person.
Privacy Officer” means the individual at Figo who is responsible for implementation of this Privacy Policy.
Sensitive Data” means data that reveals racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, data that concerns health, or data that concerns a natural person’s sex life or sexual orientation.
Sites or Services” means all Figo domains, websites, software, applications, online services, and products.
Terms” means Figo’s Terms of Use.
Third Party Services” means applications, products, services, or websites that are not under the control of or maintained by Figo.
User” means a natural person granted Authorization to use the Figo Sites or Services on behalf of such individual.
User Submission” means any comment, personal information, or indication of interest, including ideas, suggestions, opinions, comments, observations, or other material, posted to any public form on our Sites or Services, including any publication, article, social network page, blog, chat room, or other such forum.
You” and “Your” means our policy holders, users, visitors, and customers.
 
  1. Collection of Personal Data
Figo may require you to register on Figo Sites or Services and we may collect Personal Data from you to provide or service our insurance products, our services and products on the Figo Pet Cloud, and to complete various other transactions.  Registration is required if you wish to maintain an Account with Figo and to obtain the benefits of the Figo Pet Cloud.
 
The Personal Data we may collect from you in the process of creating and maintaining an Account may include:
• Your name, postal address, email address, and telephone number
• Policy coverage, claim history, premiums, and payment history
• Information from a veterinary medical provider concerning your pet’s medical records
 
We will collect such Personal Data from you in the following ways:
  • electronically
  • in person
  • via telephone
  • over the Internet
  • via forms you submit to us such as applications, claims, and policy updates
 
Figo Sites or Services may provide links to Third Party Services for your convenience and information. If you access those Third Party Services, you will leave the Figo site. Figo does not control those Third Party Services or their privacy practices, which may differ from Figo’s practices. We do not endorse or make any representations about Third Party Services. The Personal Data you choose to provide to, or that is collected by, those Third Party Services is not covered by the Agreement. We cannot control the activities of third parties, and we have no responsibility for any use of your Personal Data by such third parties. Any information you choose to provide to Third Party Services will be governed by the policies of Third Party Services. 
 
If you post a User Submission, Images or Content to any public forum on the Figo Sites or Services, including any social network page, blog, or other such forum, please be aware that any Personal Data disclosed in your User Submission, Images or Content can be read, viewed, collected, or used by other users of these forums, and could be used to contact you, send you unsolicited messages, or for purposes that neither you nor Figo control. Figo is not responsible for the Personal Data contained in your User Submission, Images or Content. 
 
  1. Legal basis for collecting your Personal Data
Your consent to our Terms of Use and this Privacy Policy constitutes the legal basis upon which we may collect your Personal Data.
 
 
  1. Purposes for which we collect Personal Data
Figo uses the information we collect for the following purposes:
  • Provide our Services. To provide the services we offer on our Sites or Services, to communicate with you about your use of our Sites or Services, to respond to your inquiries, to provide troubleshooting, and for other customer services designed to make your experience better.
  • Personalization. To tailor the content and information that we may send or display to you, to suggest personalized help and instructions, and to otherwise personalize your experience while visiting or using our Sites or Services.
  • Advertising. To display interest-based advertising to you, to improve our advertising and measurement systems so that we can show you more relevant ads, and to measure the effectiveness and reach of ads and services.
  • Marketing and Promotions. For marketing and promotional purposes, such as to send you news and updates, special offers, and promotions, or other otherwise contact you about products, services, or information we think may interest you, including information about third party products and services.
  • Analytics. To gather metrics to better understand how users access and use the Sites or Services; to evaluate and improve the Sites or Services; and to develop new products and services.
  • Comply with the Law. To comply with legal obligations, as part of our general business operations, and for other business administration purposes.
  • Prevent Misuse. Where we believe it is necessary to investigate, prevent, or take action regarding illegal activities, suspected fraud, situations involving potential threats to the safety of any person, or violations of our Terms of Use or this Privacy Policy.
 
  1. How we use and share your information
The information Figo collects to understand your needs and interests helps Figo deliver a consistent and personalized experience. For example, Figo may use your Personal Data to:
  • assist you in completing a transaction or order
  • supply you with relevant research on pet health
  • administer your policy
  • process your claims
  • underwrite insurance policies
  • communicate with you about products and services
  • provide and improve service and support
  • update you on new services and benefits
  • develop new products and services
  • provide personalized promotional offers
  • select content to be communicated to you
  • measure performance of marketing initiatives, ads, and websites “powered by” another company on Figo’s behalf
  • aggregate certain types of information to better understand or provide better engagement with our customers
  • prevent and detect security threats, fraud or other malicious activity.
 
We may also use your Personal Data for:
  • the general administration of your records by us
  • the general maintenance of our database and records
  • training our employees in connection with providing our service to you.

We may share your Personal Data with our Affiliates or with third parties that provide services to us and that agree to keep such Personal Data confidential. We only disclose your Personal Data with your consent or as may be required by law. Where such disclosure is required by law, we may disclose certain of your Personal Data without your prior consent. We may collect and aggregate general information about you and your pets and use that information for limited commercial purposes; however, we will not sell information that could be used by a third party to identify you individually, whether by name, address, or other similarly private information. For example, we may collect and aggregate broadly measurable demographic information such as the breed of your pets and your city of residence. In order for us to obtain or to service the insurance products that you ask for from us, we may need to disclose your Personal Data to our Affiliates and to unaffiliated companies but will only do so with your prior affirmative and unequivocal consent, and we will share the only the amount of Personal Data as is necessary to provide a particular service or product.
 
We may disclose Personal Data to the following:
  • Veterinary facilities or providers, to verify coverage and benefits
  • Financial companies, such as life, automobile, and property insurers, and insurance agents or brokers
  • A group policyholder for purposes of billing and collecting premiums, or reporting claims experience
  • Service providers that perform insurance or business functions for us, including our insurance carrier and our actuarial consultants
  • Service providers, including veterinary services providers, who help process or service your account or respond to your queries.
 
We may share Personal Data with entities or organizations that collect insurance data about claim history, and amounts paid. Such entities or organizations may retain that information and disclose it to other insurance companies and others legally entitled to see such data.
 
Figo may post customer news, events, or testimonials on Figo Sites.  The Figo Pet Cloud contains Images and Content supplied by Users with Accounts.  Such information is only posted with the express permission of the individual or company who provided that information, which consent may be granted in the process of registering to obtain an Account. Figo may, from time to time, take photographs and videos of events at Figo locations or Figo-sponsored events. Figo may post such photographs and videos on Figo sites, including FIGO’s social network pages (e.g., Facebook, Instagram, Pinterest, Twitter, YouTube, and LinkedIn). Figo will use its reasonable efforts to remove any posted photo or video upon written notice from you requesting such removal. All such requests should be submitted to privacy@FigoPetInsurance.com or you may write to us at the address listed in Section 17 below.

We may also disclose Personal Data under the following circumstances:
  • to respond to duly authorized information requests from police and governmental authorities
  • to comply with any law, regulation, subpoena, or court order
  • to investigate and help prevent security threats, fraud, or other malicious activity
  • to enforce and protect the rights and properties of Figo or its Affiliates
  • to protect the rights or personal safety of Figo employees and third parties on or using Figo property.
 
In the event of a merger, consolidation, or sale or transfer of all or substantially all of the assets of Figo or its Affiliates, Personal Data from our customers and stored in our customer database will be transferred to the purchasing or new entity. However, the use of this information by any purchasing or surviving entity would be governed by the terms of this Privacy Policy, as amended from time to time, including any amendment after such transaction.
 
Credit Card Information, Debit Card Information and other payment method information is used only for payment processing and fraud prevention. Credit Card Information, Debit Card Information, and other Personal Data required to process a credit transaction is not used for any other purpose by Figo and will not be kept longer than necessary for providing the services. We do not store Credit Card Information, Debit Card Information, or other payment method information. Credit card payments, debit card payments and ACH direct debit payments are processed through our third-party vendor. Information about such vendors may be found by contacting privacy@FigoPetInsurance.com.
 
Your information may be transferred to and maintained on computers and servers located outside of your state, province, country, or other governmental jurisdiction where the privacy laws may not be as protective as those in your jurisdiction. If you are located outside the United States and choose to provide information to us, Figo transfers Personal Data to the United States and processes it there. Your consent to this Privacy Policy followed by your submission of such information represents your agreement to that transfer.
 
User Data from our Users who reside in the European Union is processed in the United States. Figo shall process such User Data in accordance with the requirements of the GDPR. 
California Privacy Rights
 
Pursuant to Section 1798.83 of the California Civil Code, residents of the State of California have the right to request from a business, with whom the State of California resident has an established business relationship, certain information with respect to the types of Personal Data the business shares with third parties for direct marketing purposes by such third party and the identities of the third parties with whom the business has shared such information during the immediately preceding calendar year.
 
To request a copy of the information disclosure provided by us pursuant to Section 1798.83 of the California Civil Code, please contact privacy@FigoPetInsurance.com.
 
European Union General Data Protection Regulation 2016/679
European Union General Data Protection Regulation EU 2016/679 (“GDPR”), approved by the European Parliament on April 14, 2016, and effective May 25, 2018, addresses the protection of natural persons located in the EU with respect to the processing of their Personal Data.
 
GDPR recognizes that Personal Data shall be:
  • processed lawfully, fairly and in a transparent manner
  • collected for specified, explicit and legitimate purposes and not further processed in a manner that is incompatible with those purposes
  • adequate, relevant and limited to what is necessary in relation to the purposes for which it is processed
  • accurate and, where necessary, kept up to date
  • kept in a form which permits identification of Data Subjects for no longer than is necessary for the purposes for which the personal data are processed
  • processed in a manner that ensures appropriate security of the personal data, including protection against unauthorized or unlawful processing and against accidental loss, destruction or damage, using appropriate technical or organizational measures
 
As a Controller, Figo shall be responsible for, and shall be able to demonstrate compliance with, the foregoing principles. Therefore, you have the right:
  • to request the correction or update of any Personal Data that is incorrect or incomplete
  • to request the erasure of your Personal Data (the right to be forgotten)
  • to portability of your Personal Data
  • to object to the processing of your Personal Data
  • not to be subject to a decision based on automated decision-making, including  profiling
  • to withdraw consent to the processing of your Personal Data
  • to register a complaint with a supervisory authority (if you are located in the EU)
 
Unless otherwise prohibited by law, Figo will effect any such request without delay.
Under the GDPR, you have the right to be forgotten. If you reside in an EU territory, you may request the deletion of your personal data that we collect, store, or process. When you make your request, we will balance the privacy rights of the individual concerned with the interest of the general public in having access to the information, as well as the right of others to distribute the information. For instance, we may refuse to delete information regarding financial scams or other unlawful activities. In the event Figo receives a request for erasure, or a request to be forgotten, Figo has the obligation to erase the personal data without undue delay (and no longer than 30 days after the request is received), where one of the following grounds applies:
  • The Personal Data is no longer necessary for the purpose for which it was originally collected or processed.
  • You withdraw your consent to the collection processing of your Personal Data.
  • You object to the processing and there is no overriding legitimate interest for continued collection or processing of your personal data.
  • You believe that your Personal Data was unlawfully processed or collected (i.e., in breach of the GDPR).
  • Your Personal Data must be erased in order to comply with an EU or an EU Member State law to which we are subject.
  • Such Personal Data was processed in relation to the offer of information society services to a child.
 
If you would like to submit a request for erasure (request to be forgotten), please use the form linked here.
 
  1. Where the processing of Personal Data takes place
The processing of Personal Data takes place in the United States of America.
 
  1. Figo as Data Controller for purposes of GDPR
Pursuant to the terms of the GDPR, where Figo, either alone or jointly, determines the purposes and means of the processing of Personal Data, controls the data, and is responsible for it, and does so with respect to Data Subjects who are physically located in the European Union, Figo is a Controller. As a Controller, Figo is bound by the provisions of the GDPR and agrees to comply with those provisions when in possession of such Personal Data. If you have any questions or comments or seek any additional information on Figo, please email us at privacy@FigoPetInsurance.com. You may also call us at +1 844-738-3446 or write to us at:
 
Designated Agent
Figo Pet Insurance LLC
540 N. Dearborn Street
Post Office Box No. 10873
Chicago, Illinois USA 60610
 
  1. Contact Information for Figo’s Privacy Officer
Figo’s Privacy Officer can be contacted by mail at the following address
Privacy Officer
Figo Pet Insurance LLC
540 N. Dearborn Street
Post Office Box No. 10873
Chicago, Illinois USA 60610
 
You may contact our Privacy Officer at any time with questions or requests regarding your Personal Data at privacy@FigoPetInsurance.com. You may also call us at +1 844-738-3446 write to us at the above address.
 
  1. Access to and accuracy of your information
Figo strives to keep your Personal Data accurately recorded. You have the right to access and request the correction, amendment, or deletion of all of your recorded Personal Data that has been collected by us. If you wish to review your recorded Personal Data, please contact us at:
Figo Pet Insurance LLC
Attn: Compliance Department
Email: privacy@FigoPetInsurance.com
U.S. Mail:  540 N. Dearborn Street
Post Office Box No. 10873
Chicago, Illinois USA 60610
 
If you write to us, please include your name, address, telephone number, and policy number and let us know what kind of information you want to see. You may see and copy your information in person or, if you prefer, we will copy and send you your information. If you see any mistakes, let us know and we will review it. If we agree, we will correct our files. If we disagree, you may file a short statement of dispute with us. Your statement will be included with any data we disclose in the future. We will also send the statement to anyone you ask us to who received your information from us in the past two years.
 
  1. Keeping your personal data secure
Figo takes the trust you place in us seriously. To prevent unauthorized access or disclosure, to maintain data accuracy, and to ensure the appropriate use of the information, Figo utilizes generally accepted industry standards to protect your Personal Data submitted to Figo. All of our employees and sub-contractors with access to Personal Data or who are associated with the processing of Personal Data are contractually obligated to respect the confidentiality of such Personal Data. No method of transmission over the internet, or method of electronic storage is 100% secure; therefore, we cannot guarantee the absolute security of your Personal Data. 
 
  1. Children's privacy
Figo does not knowingly collect information from children under the age of 13, solicit information from children, or market products to children. Figo Sites or Services are not intended for use by children and we do not target our websites to children under the age of 16.  Account holders must by over the age of 18. 
 
  1. Sensitive data
We do not intentionally collect, process, transfer, or store Sensitive Data. 
 
  1. Use of cookies
Figo Sites or Services use standard Internet technologies such as “cookies” and “web beacons” in order to retrace your interaction with our sites and services. “Cookies” are small files that are placed on your hard drive for identification purposes. These files are used for site registration and customization the next time you visit us. You should note that cookies cannot read data off of your hard drive and they cannot be used to identify you personally. Your web browser may allow you to be notified when you are receiving a cookie, giving you the choice to accept it or not. You have the ability to prevent cookies from being saved on your computer by making the appropriate adjustments in your browser options. By not accepting cookies, some pages may not fully function and you may not be able to access certain information on this site.
 
Cookies help us to understand your website usage, so we can continually improve its usability. For example, we may use cookies to personalize your experience on our website, if you have accepted this option (e.g., to remember your customer ID on a login page). We may also use cookies to offer you other insurance and financial services products that may suit your needs. During the period you are logged into our site, we log IP addresses (a number assigned to your computer when you use the Internet), browser and platform types, domain name, access times, referral data (the last site or URL you visited before logging into our site and the first site or URL you visit after leaving our site), and your activity while using our site.
 
There are two types of cookies you may encounter when using Figo Sites or Services. First Party Cookies are our own cookies controlled by us and used to provide information about usage of our site. Third party cookies are set by third party sites. Figo does not have control over third party cookies. One of the third party cookies we use is the web analysis tool, “Google Analytics”. Google Analytics is a popular web analytics service provided by Google to help us analyze how users use Figo Sites or Services. Find out more about how these cookies are used on Google’s privacy site.
 
  1. Acceptance of and modifications to this Privacy Policy
You must affirm that you have read, understand, and accept the terms of this Privacy Policy. If you do not accept the terms of this Privacy Policy, you must discontinue your use of the Sites or Services.
 
The terms of the Privacy Policy may change from time to time. If we modify our Privacy Policy, we will notify you and post the revised statement here, with an updated revision date. You must affirm that you have read, understand, and accept the revised terms of this Privacy Policy. If you do not accept the revised terms of this Privacy Policy, you must discontinue your use of the Sites and Services.
 
  1. Conflicts
This website was designed to provide you with helpful information about our products. Information presented throughout the website is subject to policy terms, conditions and limitations. In the event that there is any discrepancy between any information on this website and an actual insurance policy, the terms, conditions and limitations of the insurance policy will govern.
Nothing on this website is intended or should be construed as a solicitation or offer to sell insurance products in any jurisdiction in which we are not properly licensed.
 
  1. Contacting us

We value your opinions. If you have comments or questions about our Privacy Policy, please send them to privacy@FigoPetInsurance.com
 
You may also contact us at 540 N. Dearborn Street, No. 10873, Chicago, Illinois USA 60610 or call us at +1 844-738-3446.
 
©2018 Figo Pet Insurance, LLC. All Rights Reserved.
 
Last Updated September 2018

Attachments

Figo_Forms_GDPR_Right_to_be_Forgotten_Form_-_August_2018-_00126971xCED56.pdf Figo_Forms_GDPR_Right_to_be_Forgotten_Form_-_August_2018-_00126971xCED56.pdf

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