Last Updated: November 09, 2021

1. Scope

Canopy Connect, Inc. (“we” or “us”) is committed to protecting
your privacy. This Privacy Policy describes how we collect,
store, use and distribute information through our software,
website, mobile applications, documentation, and related
services (together, the “Services”).

Capitalized terms not defined in this Privacy Policy have the
meaning as set forth in the Terms of Service for the Services,
which can be found on our
Terms page.

Except as set forth in this Privacy Policy, your Personal
Information will not be used for any other purpose without your
consent. We do not actively collect Personal Information for the
purpose of sale of such information in a way that specifically
identifies the individual (i.e. we don’t sell customer lists).
You may withdraw your consent to our processing of your Personal
Information at any time. However, withdrawing consent may result
in your inability to continue using some or all of the Services.

You are able to share Personal Information with third parties
through use of the Services (including our business customers,
or “Innovators”). The privacy policies of these third parties
are not under our control and may differ from ours. The use of
any information that you may provide to any third parties will
be governed by the privacy policy of such third party or by your
independent agreement with such third party, as the case may be.
If you have any doubts about the privacy of the information you
are providing to a third party, we recommend that you contact
that third party directly for more information or to review its
privacy policy.

2. Collection of Information.

Information you provide

Our technology makes it easier for you to get value and
convenience from your insurance data by making it safer and
easier to connect your personal insurance information to
software applications created by Innovators that help you do
things like verify your active insurance to close on a mortgage
or drive a car, save money, cover a home or vehicle, or
understand and select coverage options. When you connect your
insurance accounts with a Developer application or otherwise
connect your insurance accounts through us, we collect login
information required by the provider of your account, such as
your username and password, answers to challenge questions, or a
security token (these are referred to below as your “Login
Information”). When providing this information, you give the
Developer and us the authority to act on your behalf to access
and transmit your information from the relevant insurance
institution. Your Login Information, as well as any other
information we gather through the Services that may be used to
identify, contact, or locate you individually, are collectively
referred to herein as your “Personal Information.”

We may collect contact information, such as email address, phone
number, or mailing address when you request information about
our Services, register for our marketing materials, request
customer or technical support, apply for a job, or otherwise
communicate with us.

We may post job openings and opportunities on our Services. If
you reply to one of these postings by submitting your
application, CV and/or cover letter to us, we will collect and
use your information to assess your qualifications.

Information collected from your insurance institutions

The information we receive from the insurance institutions that
maintain your insurance accounts varies depending on the
information made available by those institutions. But, in
general, we collect the following types of information from your
insurance institutions:

• Account information
• Information about policies, vehicles, and Personal
  Information related to providing accurate insurance data;
• Information about billing transactions, including amount,
  date, type, quantity, price, and a description of the
  transaction.

Information received from your devices

Our technology is generally embedded in our Innovators’
applications. When you use your device to connect to our
services through a Developer application, we receive information
about that device, including IP address, hardware model,
operating system, and other technical information about the
device.

We may collect Personal Information automatically when you use
our Services:

• Cookies, Pixel Tags/Web Beacons, and Other Technologies. We,
  as well as third parties that provide content, advertising,
  or other functionality on our Services, may use cookies,
  pixel tags, local storage, and other technologies
  (“Technologies”) to automatically collect information
  through your use of our Services.
• Cookies. Cookies are small text files placed in device
  browsers that store preferences and facilitate and enhance
  your experience.
• Pixel Tags/Web Beacons. A pixel tag (also known as a web
  beacon) is a piece of code embedded in our Services that
  collects information about engagement on our Services. The
  use of a pixel tag allows us to record, for example, that a
  user has visited a particular web page or clicked on a
  particular advertisement. We may also include web beacons in
  e-mails to understand whether messages have been opened,
  acted on, or forwarded.

Our uses of these Technologies fall into the following general
categories:

• Operationally Necessary. This includes Technologies that
  allow you access to our Services, applications, and tools
  that are required to identify irregular website behavior,
  prevent fraudulent activity and improve security or that
  allow you to make use of our functionality;
• Performance-Related. We may use Technologies to assess the
  performance of our Services, including as part of our
  analytic practices to help us understand how individuals use
  our Services (see Analytics below);
• Functionality-Related. We may use Technologies that allow us
  to offer you enhanced functionality when accessing or using
  our Services. This may include identifying you when you sign
  into our Services or keeping track of your specified
  preferences, interests, or past items viewed;
• Advertising- or Targeting-Related. We may use first party or
  third-party Technologies to deliver content, including ads
  relevant to your interests, on our Services or on
  third-party websites.
• Analytics. We may use Technologies and other third-party
  tools to process analytics information on our Services. For
  example, our analytics partners include
• Google Analytics. For more information, please visit Google
  Analytics’ Privacy Policy . To learn more about how to
  opt-out of Google Analytics’ use of your information, please
  click here .

Information we receive about you from other sources

We also receive information about you directly from the relevant
Developer. For example, our Innovators may provide information
about which insurance institution you use, or what information
they expect to receive from an insurance institution.

3. Use of Information

We use the information we collect to operate, improve, and
protect the services we provide, to market our Services and to
develop new services. More specifically, we use your Personal
Information:

• To operate, provide, and maintain our Services;
• To verify your identity and manage your account;
• To improve, enhance, modify, add to, and further develop our
  Services and new products;
• To protect you, our Innovators, our partners, or Canopy
  Connect from fraud, malicious activity, and other privacy
  and security-related concerns;
• To provide customer support to you or to our Innovators,
  including to help respond to your inquiries related to our
  Service or our Innovators’ applications; -To pursue our
  legitimate interests such as direct marketing, research and
  development (including marketing research), network and
  information security, and fraud prevention;
• To audit certain interactions, transactions and other
  compliance activities;
• To enforce our agreements and policies;
• To comply with our legal obligations;
• To investigate any misuse of our service or our Innovators’
  applications, including violations of their agreements with
  us, criminal activity, or other unauthorized access to our
  Services; and
• For any other purpose described to you when the information
  was collected, such as registering for events or when
  applying for employment with us as posted on our site.

We may also use your Personal Information in an aggregated,
de-identified, or anonymized manner (that does not identify you
personally) for any purpose permitted under applicable law. This
includes creating or using aggregated, de-identified, or
anonymized data based on the collected information to develop
new services and to facilitate research.

We may use Personal Information to tailor and provide you with
content and advertisements. We may provide you with these
materials as permitted by applicable law.

We may engage in automated decision making, such as for
anti-fraud purposes. Canopy’s processing of your Personal
Information will not result in a decision based solely on
automated processing that significantly affects you unless such
a decision is necessary as part of a contract we have with you,
we have your consent, or we are permitted by law to engage in
such automated decision making. If you have questions about our
automated decision making, you may contact us as set forth in “
Contact Us ” below.

If we plan to use your Personal Information in the future for
any other purposes not identified above, we will only do so
after informing you by updating this Privacy Policy. See the
section entitled “Amendment of this Privacy Policy” below.

4. Disclosures & Transfers.

We disclose your information to third parties for a variety of
business purposes, including to provide our Services, to protect
us or others, or in the event of a major business transaction
such as a merger, sale, or asset transfer, as described below.
We have put in place contractual and other organizational
safeguards with our agents to ensure a proper level of
protection of your Personal Information (see further “Security”
below). In addition to those measures, we will not disclose or
transfer your Personal Information to third parties without your
permission, except as specified in this Privacy Policy.

• We may share your Personal Information with the
  Developer of the application you are using and as
  directed by that Developer (such as with another third
  party if directed by you).
• We may also share your Personal Information as directed
  by you, such as with Business Partners to provide you
  with a product or service you have requested. We may
  also share your Personal Information to business
  partners with whom we jointly offer products or
  services.
• We share your Personal Information with “Service
  Providers” who have limited access to databases of user
  information or registered member information solely for
  the purpose of helping us to provide and/or improve the
  Services and are subject to contractual restrictions
  prohibiting them from using the information about our
  users for any other purpose. Such agents or third
  parties do not have any rights to use Personal
  Information beyond what is absolutely necessary to
  assist us.
• We may disclose your Personal Information to third
  parties to protect us or others without your consent if
  we have reason to believe that disclosing this
  information is necessary to identify, contact or bring
  legal action against someone who may be causing injury
  to or interference with (either intentionally or
  unintentionally) our rights or property, other users of
  the Services, or anyone else (including the rights or
  property of anyone else) that could be harmed by such
  activities. We may disclose Personal Information when we
  believe in good faith that such disclosure is required
  by and in accordance with the law.
• We may also disclose your Personal Information
  in connection with a corporate re-organization, a
  merger or amalgamation with another entity, a sale
  of all or a substantial portion of our assets</b >
  or stock, including any due diligence exercise carried
  out in relation to the same, provided that the
  information disclosed continues to be used for the
  purposes permitted by this Privacy Policy by the entity
  acquiring the information.

Please note that if you are using the Services at the request or
as part of an organization, your organization’s account
administrator may be able to view certain activity and content
associated with your use of the Services, including, but not
limited to, elements of your Personal Information.

5. International Transfers.

The Services are hosted in the United States and are intended
primarily for visitors located within the United States. If you
choose to use the Services from other regions of the world with
laws governing data collection and use that may differ from U.S.
law, then please note that you may be transferring your Personal
Information outside of those regions to the United States for
storage and processing. We endeavor to safeguard your
information consistent with the requirements of applicable laws.
By providing your Personal Information through the Services, you
consent to the extent allowed by law to such transfer, storage,
and processing.

The files containing your information will be on our servers and
those of our service providers and will be accessible to persons
that require it for the purposes of their duties. Information
may be accessible to the courts and the law enforcement and
national security authorities of the United States. To obtain
more information about our policies and practices with respect
to service providers outside of your country, please contact us
as set forth below. If you are located in the European Economic
Area, Switzerland, the United Kingdom or Brazil, you have the
right to lodge a complaint with a supervisory authority if you
believe our processing of your Personal Information violates
applicable law.

6. Security.

The security of your Personal Information is important to us. We
use commercially reasonable efforts to store and maintain your
Personal Information in a secure environment. We take technical,
contractual, administrative, and physical security steps
designed to protect Personal Information that you provide to us.
We have implemented procedures designed to limit the
dissemination of your Personal Information to only such
designated staff as are reasonably necessary to carry out the
stated purposes we have communicated to you. The files and
records containing your Personal Information will be kept in our
offices and/or on our servers or those of our service providers
and only those employees that require it for the purposes of
their duties will have access to this file. To the fullest
extent permitted by applicable law, we do not accept liability
for unauthorized disclosure.

7. Retention.

We will keep your Personal Information for as long as it remains
necessary for the identified purpose or as required by law,
which may extend beyond the termination of our relationship with
you. We may retain certain data as necessary to prevent fraud or
future abuse, or for legitimate business purposes, such as
analysis of aggregated, non-personally-identifiable data,
account recovery, or if required by law. All retained Personal
Information will remain subject to the terms of this Privacy
Policy. Please note that if you request that your Personal
Information be removed from our databases, it may not be
possible to completely delete all of your Personal Information
due to technological and legal constraints.

8. Your Privacy Choices and Rights

The privacy choices you may have about your Personal Information
are determined by applicable law and are described below.

• Email and Telephone Communications. If you receive an
  unwanted email from us, you can use the unsubscribe link
  found at the bottom of the email to opt out of receiving
  future emails. Note that you will continue to receive
  transaction-related emails regarding products or Services
  you have requested. We may also send you certain
  non-promotional communications regarding us and our
  Services, and you will not be able to opt out of those
  communications (e.g., communications regarding our Services
  or updates to our Terms or this Privacy Policy).

We process requests to be placed on do-not-mail, do-not-phone,
and do-not-contact lists as required by applicable law.

• Text Messages. You may opt out of receiving text
  messages from us by following the instructions in the text
  message you have received from us or by otherwise contacting
  us.
• Mobile Devices. We may send you push notifications
  through our mobile application. You may opt out from
  receiving these push notifications by changing the settings
  on your mobile device. With your consent, we may also
  collect precise location-based information via our mobile
  application. You may opt out of this collection by changing
  the settings on your mobile device.]
• “Do Not Track.” Do Not Track (“DNT”) is a privacy
  preference that users can set in certain web browsers.
  Please note that we do not respond to or honor DNT signals
  or similar mechanisms transmitted by web browsers.
• Cookies and Interest-Based Advertising. You may stop
  or restrict the placement of Technologies on your device or
  remove them by adjusting your preferences as your browser or
  device permits. However, if you adjust your preferences, our
  Services may not work properly. Please note that
  cookie-based opt-outs are not effective on mobile
  applications. However, you may opt-out of personalized
  advertisements on some mobile applications by following the
  instructions for Android , iOS and others.

The online advertising industry also provides websites from
which you may opt out of receiving targeted ads from data
partners and other advertising partners that participate in
self-regulatory programs. You can access these and learn more
about targeted advertising and consumer choice and privacy by
visiting the Network Advertising Initiative , the Digital
Advertising Alliance , the European Digital Advertising Alliance
, and the Digital Advertising Alliance of Canada . Please note
you must separately opt out in each browser and on each device.

In accordance with applicable law, you may have the right to:

• Access Personal Information about you, including: (i)
  confirming whether we are processing your Personal
  Information; (ii) obtaining access to or a copy of your
  Personal Information, in a structured, commonly used, and
  machine readable format; and (iii) receiving an electronic
  copy of Personal Information that you have provided to us,
  or asking us to send that information to another company in
  a structured, commonly used, and machine readable format
  (the “right of data portability”);
• Request Correction of your Personal Information where it is
  inaccurate or incomplete. In some cases, we may provide
  self-service tools that enable you to update your Personal
  Information;
• Request Deletion of your Personal Information;
• Request Restriction of or Object to our processing of your
  Personal Information; and
• Withdraw your Consent to our processing of your Personal
  Information.

If you would like to exercise any of these rights, please
contact us as set forth below. We will process such requests in
accordance with applicable laws.

9. Notice to California Consumers.

Under California Civil Code Sections 1798.83-1798.84, California
residents are entitled to ask us for a notice identifying the
categories of Personal Information which we share with our
affiliates and/or third parties for marketing purposes, and
providing contact information for such affiliates and/or third
parties. We do not share your Personal Information with third
parties for the third parties’ direct marketing purposes unless
you provide us with your express consent to do so.

Pursuant to the California Consumer Privacy Act of 2018
(“CCPA”), natural persons who are California residents have
certain rights concerning their Personal Information held by us,
as described below.

Personal Information Collection, Use, and Disclosure: The
following table describes (i) the categories of Personal
Information (as defined in the CCPA) we may collect about you;
(ii) the sources from which that information is collected; (iii)
the business and/or commercial purposes for collecting that
information; and (iv) the categories of third parties to whom
that information is disclosed.

Category of Personal Information	Examples	Sources of Personal Information	Business and/or Commercial Purpose(s)	Disclosure of Personal Information
Identifiers	Name, email address, mailing address, phone number, signature, user ID, Login Information, IP address	You, Innovators	Performing the Services, maintaining the quality or safety of the Services, internal research, debugging, auditing and analysis of user interactions, advancing our commercial or economic interests, short-term, transient use, provided the Personal Information is not disclosed to another third party and is not used to build a profile about a consumer or otherwise alter an individual consumer’s experience outside the current interaction	We may disclose this information pursuant to the section above entitled “Disclosure of Your Information.”
Commercial information	Information regarding your insurance policies	You	Performing the Services, maintaining the quality or safety of the Services	We may disclose this information pursuant to the section above entitled “Disclosure of Your Information.”
Internet or other electronic network activity information	Browser type and settings, the date, time, and length of your visit, your browsing history, mobile carrier, application activity, system configuration information	You (including through the use of tools such as cookies and web beacons)	Performing the Services, maintaining the quality or safety of the Services, internal research, debugging, auditing and analysis of user interactions, advancing our commercial or economic interests	We may disclose this information pursuant to the section above entitled “Disclosure of Your Information.”
Professional or employment-related information	Employment history, employer name, position	You	Performing the Services, maintaining the quality or safety of the Services	We may disclose this information pursuant to the section above entitled “Disclosure of Your Information.”

FOR PURPOSES OF THE CALIFORNIA CONSUMER PRIVACY ACT, WE DO NOT
AND WILL NOT SELL YOUR PERSONAL INFORMATION. California Privacy
Rights: To the extent provided for by law and subject to
applicable exceptions, California residents have the following
privacy rights in relation to the Personal Information we
collect:

• The right to know what Personal Information we have
  collected and how we have used and disclosed that personal
  information;
• The right to request deletion of your Personal Information;
  and
• The right to be free from discrimination relating to the
  exercise of the foregoing privacy rights.

Exercising Your Rights: California residents can exercise the
above privacy rights by emailing us at hello@usecanopy.com or
calling us at 707-789-1110.

Verification: in order to protect your Personal Information from
unauthorized access or deletion, we may require you to verify
your login credentials before you can submit a request to know
or delete Personal Information. If you do not have an account
with us, or if we suspect fraudulent or malicious activity, we
may ask you to provide additional Personal Information for
verification. If we cannot verify your identity, we will not
provide or delete your Personal Information.

Authorized Agents: you may submit a request to know or a request
to delete your Personal Information through an authorized agent.
If you do so, the agent must present signed written permission
to act on your behalf and you may also be required to
independently verify your identity with us.

10. Supplemental Notice for Nevada Residents

If you are a resident of Nevada, you have the right to opt-out
of the sale of certain Personal Information to third parties who
intend to license or sell that Personal Information. Please note
that we do not currently sell your Personal Information as sales
are defined in Nevada Revised Statutes Chapter 603A. For any
questions, or to request that we do not sell your information in
the future, please contact us as set forth below.

11. Children’s Information

The Services are not directed to children under 13 (or other age
as required by local law), and we do not knowingly collect
Personal Information from children. If you are a parent or
guardian and believe your child has uploaded Personal
Information to our site without your consent, you may contact us
as described below. If we become aware that a child has provided
us with Personal Information in violation of applicable law, we
will delete any Personal Information we have collected, unless
we have a legal obligation to keep it.

12. Amendment of this Privacy Policy.

We reserve the right to change this Privacy Policy at any time.
If we decide to change this Privacy Policy in the future, we
will post or provide appropriate notice. The date on which the
latest update was made is indicated at the top of this document.
We recommend that you print a copy of this Privacy Policy for
your reference and revisit this policy from time to time to
ensure you are aware of any changes. Your continued use of the
Services signifies your acceptance of any changes.

13. Contact Us.

You can help by keeping us informed of any changes such as a
change of email address or telephone number. If you would like
to access your information, if you have any questions, comments
or suggestions, if you find any errors in our information about
you, or if you have a complaint concerning our compliance with
applicable privacy laws, please contact us at
hello@usecanopy.com or by mail at: Canopy Connect, Inc., 9450 SW
Gemini Dr, PMB 37656, Beaverton, Oregon 97008 USA.