Last modified: January 4, 2023
FIMC Partners, LP, our subsidiaries, and/or our affiliate companies, (for a full list of websites please visit www.fimc.com/about) (“FIMC” or “we” or “us”) respects your privacy and is committed to protecting it through our compliance with this policy.
This policy applies to information that we collect:
- on our Websites and Applications;
- in email, text, and other electronic messages between you and us on or through our Websites and/or Application; and
- when you interact with our advertising and applications on third-party websites and services if those applications or advertising include links to this policy.
It does not apply to information collected by:
- us offline or through any other means, including on any other website operated by FIMC or any third party (including our affiliates and subsidiaries);
- us or any of our affiliates or subsidiaries related to your or any other individual’s employment or potential employment with us; or
- any third party (including your insurance provider and our affiliates and subsidiaries), including through any application or content (including advertising) that may link to or be accessible from or on the Websites and Application.
2. Children Under the Age of 18 or the Legal Age to Form a Binding Contract in Your Jurisdiction
Our Websites and Application are not intended for children under the age of 18 or under the legal age to form a contract in your jurisdiction, whichever is higher. Such children are not permitted to use our Websites or Application. We will remove any information about such a child if we become aware of it.
Our Websites and Application are not intended for children under 18 years of age or the legal age to form a binding contract in your jurisdiction, whichever is higher. No one under this age may provide any personal information to or on the Websites or Applications. We do not knowingly collect Personal Information from children under this age. If you are under this age, do not use or provide any information on our Websites or Application or on or through any of their features, become a member on the Websites or Application, make any purchases through the Websites or Application, or provide any information about yourself to us, including your name, address, telephone number, email address, or any screen name or user name you may use. If we learn we have collected or received Personal Information from a child under this age without verification of parental consent, we will delete that information. If you believe we might have any information from a child under this age, please contact us at firstname.lastname@example.org.
3. Information We Collect About You and How We Collect It
We collect different types of information about you, including information that may directly identify you, information that is about you individually but does not personally identify you, and information that we combine with our other users. This includes information that we collect directly from you or through automated collection technologies.
We collect several types of information from and about users of our Websites and Application (“Personal Information”):
- by which you may be personally identified, such as but not limited to, name, postal addresses, billing address, e-mail address, telephone numbers, a representation of your credit card or debit card number (solely for billing and payment purposes, see below), date of birth, and user-provided photograph;
- that is about you individually but does not directly personally identify you, such as website traffic data, location data, logs, referring/exit pages, date and time of your visit to our Websites and Application, error information, clickstream data, and other communication data and the resources that you access and use on the Websites and Application; and/or
- about your internet connection, you use to access our Websites and Application and usage details.
We collect this information:
- directly from you when you provide it to us;
- automatically as you navigate through the Websites and Applications. Information collected automatically may include usage details, IP addresses, and information collected through cookies, web beacons, and other tracking technologies; and
Information You Provide to Us
The information we collect on or through our Websites and Application are:
- information that you provide by filling in forms on our Websites or Application. This includes information provided at the time of becoming a member or requesting further information. We may also ask you for information when you enter a contest or promotion sponsored by us and when you report a problem with one of our Websites or Application;
- records and copies of your correspondence (including your email address), if you contact us;
- records and copies of your claims or other requests to use your benefits, including, for example, when you request roadside assistance or locksmith services and for other reimbursements;
- your responses to surveys that we might ask you to complete for research purposes;
- details of transactions you carry out through our Websites or Application and of the fulfillment of your insurance policy or renewals. You may be required to provide financial information before becoming a member or renewing your membership through our Websites or Application, and
- your search queries on the Websites or Applications.
Information We Collect Through Automatic Data Collection Technologies
As you navigate through and interact with our Websites or Application, we may use automatic data collection technologies to collect certain information about your equipment, browsing actions, and patterns:
- details of your visits to our Websites and Application as described above; and
- Information about your computer and internet connection, i.e. your IP address
The information we collect automatically includes Personal Information, or we may maintain it or associate it with Personal Information we collect in other ways or receive from third parties. It helps us to improve our Websites and Application and to deliver a better and more personalized service by enabling us to:
- estimate our number of users of our Websites and Application and their usage patterns;
- store information about your preferences, allowing us to customize our Websites and Application according to your individual interests;
- maintain whether you are logged in or logged out from our Websites and Application;
- speed up your searches; and
- recognize you when you return to our Websites and Application.
The automatic data collection technologies that we use include:
- Cookies (or browser cookies). A cookie is a small file placed on the hard drive of your computer. Except for essential cookies, which are required for our Websites to operate correctly, you may refuse to accept browser cookies by making the appropriate selections in our cookie manager when prompted. You will be prompted to make these choices the first time you access our Websites and occasionally thereafter, but you may also access our cookie manager to change your choices at any time by clicking the “cookies” link at the bottom of the homepage of our Websites. Our cookie manager describes the various categories of cookies used on our Websites along with a list of each cookie in each category. Unless you have disabled non-essential cookies in our cookie manager, our system will issue the types of non-essential cookies that remain enabled when you direct your browser to our Websites. You can find more information about cookies at http://www.allaboutcookies.org;
- Web Beacons. Pages of our Websites and Application and our e-mails may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit FIMC, for example, to count users who have visited those pages or opened an email and for other related website statistics (for example, recording the popularity of certain website content and verifying system and server integrity).
For information about how you can opt-out of receiving targeted advertising from many providers, see Choices About How We Use and Disclose Your Information.
4. How We Use Your Information
We use your Personal Information for various purposes described below, including to:
· provide our Websites and Application to you;
· provide you with information you request from us;
· enforce our rights arising from contracts;
· notify you about changes; and
· provide you with notices about your account
We use information that we collect about you or that you provide to us, including any Personal Information:
- to present our Websites and Application and their contents to you;
- to verify your eligibility for membership and to process your claims;
- to provide you with information, benefit products, or benefit services that you request from us;
- to provide you with notices about your membership, including expiration and renewal notices;
- to carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collection;
- to notify you about changes to our Websites and Application or any products or services we offer or provide through them;
- in any other way we may describe when you provide the information or as otherwise outlined in applicable privacy laws;
- to calculate the premiums for your benefits;
- for our Applications to send you to push notifications. Your Personal Information may be used by our Applications to provide you with push notifications, but such Personal Information is not transmitted to us for these purposes.
- to fulfill any other purpose for which you provide it. For example, if you share your name and contact information to request a price for membership or ask a question about our benefits, we will use that personal information to respond to your inquiry. If you provide your personal information to become a member or purchase a membership, we will use that information to process your payment and facilitate making your benefits available to you and to facilitate your use of your benefits;
- to help maintain the safety, security, and integrity of our Websites and Applications, membership plans and benefit providers, databases and other technology assets, and business;
- for testing, research, analysis, and product development, including to develop and improving our Websites, Applications, and membership plans; and
- or for any other purpose with your consent.
We may also use your information to contact you about our goods and services that may be of interest to you. If you do not want us to use your information in this way or wish to change your choice, please adjust your user preferences by logging into the member portal. For more information, see Choices About How We Use and Disclose Your Information.
5. Disclosure of Your Information
· our subsidiaries and our affiliates;
· our third-party service providers that we use to support our business (including those to provide you with your benefits);
· to a company we merge, acquire, or that buys us, or in the event of change in structure of our company of any form;
· to comply with our legal obligations; and
· to enforce our rights.
- to our subsidiaries and affiliates;
- the organization from which you obtain your benefits policy;
- to contractors, service providers, and other third parties we use to support our business and provide you with your benefits. These entities provide IT and infrastructure support services, payment processing services, roadside assistance, travel assistance, healthcare, legal services, and other benefits of your membership.
- to a potential or actual buyer or other successors in the event of a planned or actual merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of FIMC’s assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which Personal Information held by FIMC about our Websites and Application’s users is among the assets transferred;
- to third parties to market their products or services to you if you have not opted out of these disclosures. For more information, see Choices About How We Use and Disclose Your Information;
- to internet cookie information recipients, such as analytics and behavioral advertising services;
- to fulfill the purpose for which you provide it. For example, if you present a membership card to a provider in our benefits network, we may share information with that provider regarding the scope of your membership benefits; and
- for any other purpose disclosed by us when you provide the information.
We may also disclose your Personal Information:
- to comply with any court order, law, or legal process, including to respond to any government or regulatory request;
- if we believe disclosure is necessary or appropriate to protect the rights, property, or safety of FIMC, our members, or others. This includes exchanging information with other companies and organizations for the purposes of fraud protection and risk reduction.
6. Choices About How We Use and Disclose Your Information
|We offer you choices on how you can opt out of our use of tracking technology, disclosure of your Personal Information for third-parties to advertise to you, our advertising to you, and other targeted advertising.|
We do not control the collection and use of your information collected by third parties described above in Disclosure of Your Information. When possible, these organizations are under contractual obligations to use this data only for providing the services to us and to maintain this information strictly confidential. These third parties may, however, aggregate the information they collect with information from their other customers for their own purposes.
In addition, we strive to provide you with choices regarding the Personal Information you provide to us. We have created mechanisms to provide you with control over your Personal Information:
- Tracking Technologies and Advertising. You can refuse to accept non-essential browser cookies by making the appropriate selections in our cookie manager when prompted. You will be prompted to adjust the settings in our cookie consent manager when you first access our Websites and occasionally thereafter, but you may also access or cookie manager to change your choices at any time by clicking the “Cookies” link at the bottom of the homepage of our Websites. Note that you can set your browser to refuse all or some browser cookies, or to alert you when cookies are being sent, however, if you do so some parts of our Websites may not be accessible or no longer function properly, especially if you refuse essential cookies.
- Promotional Offers from FIMC. If you do not you’re your contact information used by FIMC to provide you with promotional offers from FIMC or other third parties products or services, you can opt-out by logging into the member portal and adjusting your user preferences in your account profile by checking or unchecking the relevant boxes or by sending us an email stating your request to email@example.com. If we have sent you a promotional email, you may click the unsubscribe link at the bottom of promotional emails or you may send us a return email asking to be omitted from future email distributions or select an option to be omitted in the promotional email. This opt-out does not apply to communications related to product purchase, warranty registration, product service experience, or other similar transactions you make with FIMC.
- Targeted Advertising. We will use information that we collect, or you provide to deliver advertisements on our Websites or in our Application according to our advertisers’ target-audience preferences unless you opt-out of such use. If you wish to opt-out of such use, you can check or uncheck the relevant box located on the form on which we collect your Personal Information. If you wish to change your choice, you may do so at any time by logging into the Websites and Applications and adjusting your user preferences in your account profile by sending us an email stating your request to firstname.lastname@example.org.
- Google AdWords Remarketing. If you have enabled advertising cookies in our cookie manager, we may use Google AdWords Remarketing to advertise to you across different websites. If you do not wish to participate in our Google AdWords Remarketing, you can opt-out by visiting Google’s Ads Preferences Manager at https://www.google.com/settings/ads.
- Push Notifications. If you do not wish us to send you to push notifications, push notifications can be configured in the settings for your mobile device. Please refer to the user guide for your mobile device for more information on how to configure these notifications.
You can learn more about interest-based advertisements and your opt-out rights and options from members of the Network Advertising Initiative (“NAI”) on its website (www.networkadvertising.org) and from members of the Digital Advertising Alliance on its website (www.aboutads.info). We do not control third parties collection or use of your information to serve interest-based advertising. However, these third parties may provide you with ways to choose not to have your information collected or used in this way. You can also opt-out of receiving targeted ads from members of the NAI on its website.
7. Accessing and Updating Your Information
|You may review and update your Personal Information by logging into the Websites or Application and visiting your “Member” page. We may notify you of any changes or errors in any Personal Information. We are not able to accommodate any requests if we believe it would violate any law or legal requirement or cause the information to be incorrect.|
Access and Update. You can review and update some of your Personal Information by logging into the Websites or Applications and visiting your “Member” page. You may also notify us through the Contact Information below of any changes or errors in any Personal Information we have about you to ensure that it is complete, accurate, and as current as possible. We may also 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 and some Personal Information may not be changed.
8. State-Specific Privacy Rights
|The law in certain states may provide their residents with additional rights regarding our use of your Personal Information|
The law in some states may provide you with additional rights regarding our use of Personal Information. To learn more about any additional rights that may apply to you as a resident of one of these states, please see the privacy addendum for your state that is attached to this Privacy Notice.
Your California Privacy Rights
If you are a resident of California, you have the additional rights described in the California Privacy Addendum.
9. Consent to Storage and Processing of Personal Information outside of Other Countries
|We may transfer and process your Personal Information outside of other countries, including the United States. We only do this when we are legally permitted to do so and when we have appropriate safeguards in place to protect your Personal Information|
10. Do Not Track Signals
|We may use automated data collection technologies to track you across websites and Application. We currently do not honor do-not-track signals that may be sent by some browsers.|
Our Websites or Application may use automated data collection technologies to collect information about your online activities over time and across third-party websites or other online services (behavioral tracking). Some web browsers or operating systems permit you to broadcast a signal to websites and online services indicating a preference that they “do not track” your online activities. At this time, we do not honor such signals and we do not modify what information we collect or how we use that information based upon whether such a signal is broadcast or received by us.
11. Data Security
|Information transmitted over the Internet is not completely secure, but we do our best to protect your Personal Information. You can help protect your Personal Information and other information by keeping your password to our Websites and Application confidential.|
We have implemented measures designed to secure your Personal Information from accidental loss and unauthorized access, use, alteration, and disclosure.
The safety and security of your information also depend on you. Where we have given you (or where you have chosen) a password for access to certain parts of our Websites and Application, you are responsible for keeping this password confidential. We ask you not to share your password with anyone outside of your family.
Although we do our best to protect your Personal Information, we cannot guarantee the security of your Personal Information transmitted to our Websites and Application. Any transmission of Personal Information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on the Websites and Applications.
13. Contact Information
|You may contact our Data Protection Officer through the contact information below. If you wish to contact us, you must contact us through the contact information below or through the “Contact Us” page on our Websites or Application.|
To Contact FIMC
FIMC Partners, LP
P.O. Box 1440
Sarasota, FL 34236
FIMC Privacy Addendum for California Residents
This Privacy Addendum for California Residents (the “California Privacy Addendum”) supplements the information contained in FIMC’s generally applicable Privacy Notice (the “Privacy Notice”) and applies solely to all visitors, users, and others who reside in the State of California (“consumers” or “you”). We adopt this California Privacy Addendum to comply with the California Consumer Privacy Act of 2018 (“CCPA”) and any terms defined in the CCPA have the same meaning when used in this California Privacy Addendum.
Information We Collect or Have Collected
Our Websites and Applications collect information that identifies, relates to, describes, references is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or device (“Personal Information”). In particular, FIMC’s Websites and Applications collect and have collected the following categories of Personal Information from its consumers within the last twelve (12) months:
|A. Identifiers.||A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, or other similar identifiers.|
|B. Personal information categories are listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).||
A name, signature, physical characteristics or description, address, telephone number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information.
Some Personal Information included in this category may overlap with other categories.
|C. Protected classification characteristics under California or federal law.||Age (40 years or older) (indirectly through birthdate), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth, and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information). Note that your provision of some of this information is completely optional and at your discretion.|
|D. Commercial information.||Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.|
|F. Internet or other similar network activity.||Browsing history and other information on a consumer’s interaction with a website, application, or advertisement.|
|G. Geolocation data.||Physical location or movements.|
Personal information does not include:
- Publicly available information from government records.
- Deidentified or aggregated consumer information.
- Information excluded from the CCPA’s scope, like:
- health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and the California Confidentiality of Medical Information Act (CMIA) or clinical trial data;
- Personal Information is covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FRCA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver’s Privacy Protection Act of 1994.
FIMC obtains the categories of Personal Information listed above from the categories of sources described in our Privacy Notice.
Use of Personal Information
We may use, sell, or disclose the Personal Information we collect for business or commercial purposes described in our Privacy Notice. FIMC will not collect additional categories of Personal Information or use the Personal Information we collected for materially different, unrelated, or incompatible purposes without providing you notice.
Sharing Personal Information
Disclosures of Personal Information for a Business or Commercial Purpose
FIMC may disclose your Personal Information to a third party for a business or commercial purpose (not including “sales” of your Personal Information as discussed below). When we disclose Personal Information for a business or commercial purpose, we enter a contract that describes the purpose and requires the recipient to both keep that Personal Information confidential and not use it for any purpose except performing the contract.
We share your Personal Information with the categories of third parties described in our Privacy Notice. In the preceding twelve (12) months, FIMC has disclosed the following categories of Personal Information for a business or commercial purpose:
Category A: Identifiers.
Category B: California Customer Records Personal Information categories.
Category C: Protected classification characteristics under California or federal law.
Category D: Commercial information.
Category F: Internet or other similar network activity.
We disclose your Personal Information for a business or commercial purpose to the categories of third parties described in our Privacy Notice.
Sales of Personal Information
We do not sell your Personal Information as the term “sale” is defined in the CCPA. If our Websites detect that you are in California, we will automatically disable the use of advertising and other analytics cookies by default, however, you may change this setting (or any previous setting you may have made) at any time by accessing our cookie manager as described in our Privacy Notice. However, by enabling these cookies, you are explicitly instructing us that we may share your information collected by or through these cookies with third parties for their own purposes, including, but not limited to, for behavioral advertising on our Websites or other websites.
Your Rights and Choices
The CCPA provides consumers (California residents) with specific rights regarding their Personal Information. This section describes your CCPA rights and explains how to exercise those rights.
Access to Specific Information and Data Portability Rights
You have the right to request that FIMC disclose certain information to you about our collection and use of your Personal Information over the past 12 months. Once we receive and confirm your verifiable consumer request (see Exercising Access, Data Portability, and Deletion Rights), we will disclose to you:
- The categories of Personal Information we collected about you.
- The categories of sources for the Personal Information we collected about you.
- Our business or commercial purpose for collecting or selling that Personal Information.
- The categories of third parties with whom we share that Personal Information.
- The specific pieces of Personal Information we collected about you (also called a data portability request).
- If we sold or disclosed your Personal Information for a business purpose, two separate lists disclosing:
- sales, identifying the Personal Information categories that each category of recipient purchased; and
- disclosures for a business purpose, identifying the Personal Information categories that each category of recipient obtained.
Deletion Request Rights
You have the right to request that FIMC delete any of your Personal Information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request (see Exercising Access, Data Portability, and Deletion Rights), we will delete (and direct our service providers to delete) your Personal Information from our records, unless an exception applies.
We may deny your deletion request if retaining the information is necessary for us or our service provider(s) to:
- Complete the transaction for which we collected the Personal Information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you.
- Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
- Debug products to identify and repair errors that impair existing intended functionality.
- Exercise free speech, ensure the right of another consumer to exercise their free speech rights or exercise another right provided for by law.
- Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 seq.).
- Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information’s deletion may likely render impossible or seriously impair the research’s achievement if you previously provided informed consent.
- Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
- Comply with a legal obligation.
- Make other internal and lawful uses of that information that are compatible with the context in which you provided it.
Exercising Access, Data Portability, and Deletion Rights
To exercise the access, data portability, and deletion rights described above, please submit a verifiable consumer request to us by either:
- Call us at 800-621-5287.
- Visiting one of our Websites.
- Logging into your account on the Websites or Application and visiting your “Member” page and making such a request.
Only you, or a person registered with the California Secretary of State that you authorize to act on your behalf, may make a verifiable consumer request related to your Personal Information. You may also make a verifiable consumer request on behalf of your minor child.
You may only make a verifiable consumer request for access or data portability twice within a 12-month period. The verifiable consumer request must:
- Provide sufficient information that allows us to reasonably verify you are the person about whom we collected Personal Information or an authorized representative.
- Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.
We cannot respond to your request or provide you with Personal Information 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. However, we do consider requests made through your password-protected account sufficiently verified when the request relates to Personal Information associated with that specific account.
We will only use Personal Information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.
For instructions on exercising sale opt-out rights, see Personal Information Sales Opt-Out and Opt-In Rights.
Response Timing and Format
We will provide you with confirmation of our receipt of your verifiable consumer request within ten (10) days of its receipt. We endeavor to process these requests within forty-five (45) days of its receipt. If we require more time (up to 90 days since we received your request), we will inform you of the reason and extension period in writing.
We will deliver our written response by mail or electronically, at your option.
Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request’s receipt. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your Personal Information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance.
We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.
We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not:
- Deny your memberships, membership plans, or services.
- Charge you different prices or rates for membership, membership plans, or services, including through granting discounts or other benefits, or imposing penalties.
- Provide you with a different level or quality of membership, membership plans, or services.
- Suggest that you may receive a different price or rate for membership, membership plans, or services or a different level or quality of goods or services.
However, we may offer you certain financial incentives permitted by the CCPA that can result in different prices, rates, or quality levels. Any CCPA-permitted financial incentive we offer will reasonably relate to your Personal Information’s value and contain written terms that describe the program’s material aspects. Participation in a financial incentive program requires your prior opt-in consent, which you may revoke at any time. We currently do not provide any such financial incentives.
Changes to Our Privacy Notice
FIMC reserves the right to amend this California Privacy Addendum as outlined in our Privacy Notice. When we make changes to this California Privacy Addendum, we will inform you of such updates, and such updates will become effective, as described in our Privacy Notice.
If you have any questions or comments about this California Privacy Addendum, how FIMC collects and uses your information described in this California Privacy Addendum or the Privacy Notice, your choices and rights regarding such use, or wish to exercise your rights under California law, please do not hesitate to contact us as described in our Privacy Notice.