Novo Insurance, LLC ("Novo", "we" or "us") owns and distributes various software applications such as mobile phone applications and in-car embedded applications (the "Application(s)") for use by end users.

This Telematics Policy sets forth the conditions that govern your use of the Application with respect to our collection and use of telematics data you authorize us to collect. Use of the Application is more broadly governed by the terms contained in the Terms of Use and our general Privacy Policy. Additionally, the latest version of the Telematic Policy is available here: https://novo.us/telematics-policy. By "opting in" to the collection of telematics information, You (a) accept how we collect, use, disclose and otherwise handle telematics information collected not only from You but also from non-PNI (as defined below) drivers associated with your policy; and (b) represent and warrant You have the right, authority and capacity to accept these conditions on your behalf as the PNI. The use of Telematics functionalities is a voluntary, usage-based insurance program that collects and analyzes driving data to determine participants' insurance policy pricing; this program not only adjusts premiums based on driving behavior but also offers additional services, such as personalized driving insights, safety tips, and potential discounts, all aimed at encouraging safer driving habits and providing a more tailored insurance experience.

If You do not agree with all conditions of this Telematics Policy do not consent to the collection of telematics information and disable location sharing when using the Application.

If you are accepting on behalf of a company or other third party, you represent and warrant that you have full authority to act for and to bind that company or other party, in which case the term "You" refers to that company or other party. By opting into the Program, you acknowledge and accept that the Program involves telematics monitoring, which is conducted with your consent as the PNI. As part of your participation, you undertake the responsibility to ensure that all non-PNI and guest drivers associated with Your policy are informed about their involvement in the Program. This includes providing them with Program details, such as this Privacy Policy, the Program Terms and Conditions, and the Telematics Policy, and ensuring they understand the purpose and scope of telematics data collection and monitoring conducted under your consent. You further agree to communicate these requirements to all relevant drivers and to ensure their awareness of the obligations associated with the Program. Your agreement to these terms signifies your commitment to facilitating informed participation and compliance with the Program's policies and procedures.

This Telematics Policy is intended to supplement Novo's general Privacy Policy by addressing the specific data practices related to telematics-based programs and technologies. It provides further detail on how driving behavior, vehicle data, and connected technologies are used to support telematics features such as usage-based pricing, safety scoring, and personalized insights.

All general data processing purposes outlined in the Privacy Policy — such as contract performance, enrollment, customer support, compliance, claims handling, and system administration, etc. — continue to apply in full. This policy does not replace the general Privacy Policy but enhances it by describing the particularities of telematics data collection and use in the context of Novo's digital insurance offerings.

This Telematics Policy contains important information about the telematics program. Please read this carefully.

DEFINITIONS

The following terms are defined and apply to this Telematics Policy only.

"You" and "your" refer to all drivers enrolled in the "Program".

"Program" means the telematics program (Novo or Novo Safety program/NSP for existing policyholders or Novo Safety Score/NSSP for potential policyholders) which provides You with insights about your driving patterns and tips to improve your driving and allows premium adjustments.

"Telematics Device" means any hardware installed in a vehicle or Application on a mobile device that collects and transmits driving data.

"Driving Data" means any information gathered from the telematics device, including but not limited to GPS location, speed, acceleration, braking patterns, and phone usage while driving.

"Usage-Based Insurance (UBI)" means an insurance program where premiums are determined based on the driving behavior and patterns collected from telematics devices.

"Safety Score" means a score derived from driving data that reflects the safety and risk level of a driver, which is used to adjust insurance premiums.

"Bluetooth Feature" refers to the functionality within the Novo Mobile App that enables wireless data collection and trip tracking by establishing a connection between the insured's mobile Device and their vehicle's Bluetooth system. This feature allows the app to detect trip activity, assign trips to specific insured vehicles, and collect driving behavior data for usage-based insurance (UBI) purposes.

"Crash Event Data" means specific information collected during a vehicle crash, including location, speed, and time of the incident, used for analysis and facilitating the claims process.

"Opt-In" means the voluntary action by which a participant agrees to the collection and use of their driving data through the telematics program.

"Opt-Out" means the voluntary action by which a participant withdraws from the telematics program, ceasing the collection of their driving data.

"Data Protection Officer (DPO)" means the person responsible for overseeing data protection strategy and implementation to ensure compliance with privacy laws.

"Location Service" means a feature on mobile devices that enables the collection of GPS data to determine the Device's geographic location.

"Personal Data" means any information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household.

"Policyholder" means the individual or entity that holds an active telematics insurance policy, responsible for the premium payments, and entitled to the benefits and coverage specified in the policy terms.

"PNI" refers to the individual listed as the primary Policyholder on an insurance policy. The PNI is the person who holds the primary responsibility for the insurance contract, including managing the policy, consenting to its terms, and fulfilling its obligations. Non-PNI drivers, such as guest drivers or additional drivers listed on the policy, are individuals authorized to operate the insured vehicle but do not have decision-making authority over the policy or over the Program.

"NSS user" means the individual or entity that holds enrolls in NSS (non-policyholders) and are listed as primary users for the NSS. The NSS user is the person who holds the primary responsibility for the NSS enrollment, including managing the account, consenting to its terms, and fulfilling its obligations. Non-NSS users, such as guest drivers or additional drivers listed on the policy, are individuals authorized to operate the NSS enrolled vehicle but do not have decision-making authority over the NSS Program.

"Data Protection Laws" (US) means the legal frameworks in the United States that regulate the collection, use, storage, and sharing of personal data to protect individuals' privacy rights. Key laws include but are not limited to: California Consumer Privacy Act (CCPA), Health Insurance Portability and Accountability Act (HIPAA), Children's Online Privacy Protection Act (COPPA), Gramm-Leach-Bliley Act (GLBA), or Federal Trade Commission Act (FTC Act).

We collect necessary information through our Application, relevant third parties, or any other interactions you may have with us. Depending on the coverage you are looking for, relevant circumstances and applicable data protection laws and requirements, we may collect some or all the categories of data listed below. The following terms supplement Novo's Privacy Policy regarding the Data collected by the Device or Application and used in the Program, as defined and described within the Novo's Privacy Policy, available on our novo.us website.

The categories of data that may be collected encompass, but are not limited to, the following categories (hereafter referred to as "Data"):

• Program account data: enrollment date, status; new business participation; eligibility status; channel; notes related to the program enrollment and use; claims/requests and related solving data and documents.

• Application use: login, logout, actions in the app; status – enrolled in telematics.

• Daily Driving Data – Speed, Distance driven, Time of day, Vehicle identification number, Mileage tracking, Odometer readings, Date/time of the reading or any other Driving trends.

• Driving Events – Braking patterns, Speed/Acceleration patterns, Cornering; Percentage of time spent on primary, secondary and tertiary roads, Trip duration and any Events occurring during the trip.

• Device and Bluetooth Data – Device identification number, Time and date the Device is connected/disconnected, User activity, System activity including apps malfunction, mobile phone permissions, mobile phone sensors and activity, Phone motion (including phone screen tapping), Bluetooth connection logs such as the vehicle's Bluetooth profile name, MAC ID, connection timestamps, disconnection timestamps, and Bluetooth signal strength to determine proximity to the vehicle; (Consent and permissions for Bluetooth usage are obtained directly through the NSP App during the setup process. Users must grant the necessary Bluetooth access to enable data collection for trip tracking and policy management. This permission is fully managed through the mobile device settings, allowing users to enable or disable Bluetooth access at any time. However, maintaining an active Bluetooth connection is required for continued participation in the Mobile NSP program, and disabling it may impact compliance and program benefits.)

• Trip and Location Data – Latitude, Longitude, and Heading information regarding the location of the vehicle, or Trip location. We may collect trip start and end time, duration, distance traveled, and GPS-based trip routes recorded via mobile location services as well as self-reported annual miles for In-car NSP. Bluetooth connection helps determine the specific vehicle used for each trip.

• Vehicle information, such as a vehicle identification number (VIN), plate number, odometer, make, model, year of manufacture, primary use, ridesharing/delivery, model, and/or other relevant vehicle details, might be collected to determine the vehicle's eligibility for participation in the Novo Safety Program and Novo Safety Score. This data shall be necessary to validate compatibility with the Program's technical requirements, ensure proper enrollment, and facilitate the accurate calculation of insurance rates and program benefits.

• Ownership data, such as: how many vehicles you own, primary use, who owns the car (whether it's you, or your company for example), who is (or will be) the registered owner, when the car was bought, your rough annual mileage, home ownership? (where relevant, based on the specific participation option selected—Novo Flex, Novo Next, or Novo Classic)

• KYC data: risk score obtained from VERISK RC1; driver's license number; home ownership; credit rating; accident/violations history; prior insurance.

• Derived data: data generated based on the data in the App, vehicle or otherwise provided to us: estimated annual mileage, coverage, Safe Score, safety score type, raw score, display score, insurance quote generated by Safe Score.

The Program gathers data using the Application and/or mobile device sensors, including Bluetooth and/or other related devices, such as sensors directly integrated into the vehicle. Please note that data charges may apply when the Application uploads data from the Application to our secure Novo storage cloud.

The types of Data collected may vary depending on the specific vehicle in use, and may be subject to change over time based on future updates or modifications to the data collection processes.

We may obtain your personal data:

• directly from you: (i) user-provided information such as when you provide information through written means (e.g., completing a form) or verbally (e.g., during a phone call), or by reviewing our interactions with you. For instance, we obtain your personal data when you: (i) purchase any of our telematics insurance services or decide to try the Novo Safety Score Program, (ii) enter into a service contract with us, or (iii) subscribe to receive promotional communications or other offers from us or our partners.
  
  

  (ii) In addition to user-provided information, we also collect vehicle and sensor data to enhance the accuracy of our services. This includes vehicle data from your car's built-in sensors, such as odometer readings and speed, when supported by OEM-integrated telematics systems or third-party platforms. We also gather Bluetooth and mobile sensor data, including GPS location, motion detection, trip duration, acceleration, braking patterns, cornering behavior, and device connectivity status, to monitor driving behavior and assess trip details. Additionally, we collect vehicle identification and compatibility details, such as car make, model, year, VIN, and Bluetooth functionality, to verify eligibility for telematics-based insurance services and determine the most suitable data collection method for each Policyholder.

• from sources other than directly from you, including (i) external public sources (for instance, external public sources may include public databases, such as public records, government databases, and industry-specific listings within the US; (ii) third-party entities, including our suppliers, contractors, and partners (such as financial service providers for payment status updates, survey and market research agencies, or technology integration partners as Smartcar) - for example, some of our partners facilitates access to vehicle data, including odometer readings, vehicle status, and other telematics information, which are essential for validating trips, calculating safety scores, and ensuring the accurate operation of the, so on. and (iii) inferred/derived data generated from the information we already have about you, as details of your use of certain services (for example data regarding your use of certain services, the premium proposed).

Novo may share your data with its affiliates, and third-party service providers who may assist in managing the Program and processing or analyzing the Data.

Novo takes steps to aggregate or deidentify personal information before sharing it with unaffiliated third parties whenever possible. This means modifying the data so that it cannot reasonably be used to identify you or be linked back to you. Before sharing any deidentified or modified data, Novo contractually requires third parties not to attempt reidentification or link the data back to you. Additionally, third parties are contractually restricted in how they can use the information, ensuring it is only processed for authorized purposes. In some cases, we may share personal information, such as your name, address, and contact details, with third parties at your direction to help you obtain insurance quotes.

We may also share Data with Departments of Insurance, the National Association of Insurance Commissioners, or other government agencies/authorities as required by the law or for litigation purposes. Novo will not share personal information with any third-party companies for marketing purposes without your specific and informed consent.

The purpose of the Program is to collect and analyze end users' telematics data for the following:

(i) pricing of insurance policies you may purchase from Novo;
When used for insurance pricing, Novo collects and processes telematics data, driving behavior insights, and vehicle-related information to price insurance policies and determine fair premiums accurately. This data may be gathered through various technologies, including Bluetooth connectivity, in-car applications, mobile telematics, and third-party platforms.

When used for insurance pricing, data from your vehicle sensors, mobile Device, and connected car applications is analyzed to assess driving patterns, trip history, vehicle usage, and behavioral risk factors. Data from Bluetooth connections and in-car telematics helps attribute trips to specific insured vehicles, ensuring an accurate assessment of individual driving habits. Data from Bluetooth connection and in-car telematics also helps attribute trips to specific insured vehicles, ensuring an accurate assessment of individual driving habits.

The collected information is used to generate a safety score, which reflects driving risk and influences premium adjustments.

In addition to behavioral insights, vehicle-specific data such as odometer readings, make, model, year, and telematics compatibility might be factored into pricing calculations.

Kindly note that if certain features or technical functionalities such as Bluetooth connectivity, GPS, motion sensors, or other required telematics components are turned off or disabled during a trip, it may result in incomplete data collection, impacting the accuracy of your safety score and potentially affecting compliance with the Program's requirements. This could lead to adjustments in premium calculations and may impact your eligibility for certain Program benefits or discounts.

Legal grounds: performance of a contract – to prepare a policy quote or administer your current policy; legitimate interest (limited) – to verify quote accuracy and ensure fair risk-based pricing, where not overridden by user rights; enhancing customer loyalty through personalized services; promoting road safety, preventing accidents; reducing insurance claims; consent – where required to collect telematics data via the Program.

(ii) providing you with discounts and other benefits as offered from time to time;
If you opt so, Novo will use the driving behavior data and safety score to provide you with discounts and benefits. Currently, you may benefit from the Driving Insights discount when you opt to share your data for research and development purposes as for example in Novo Classic.

Legal grounds: consent – for use of telematics data for reward programs; legitimate interest – to incentivize safe driving and increase program participation.

(iii) providing you with functional communications and/or insights which may help you improve your driving skills;
Novo will provide you with driving insights based on the telematics information you provide through the Application or from the sensors on your vehicle and/or mobile Device. These driving insights are provided to inform you of improvements you can make to your driving behavior (e.g., such as making you aware to slow down earlier when approaching a red light to avoid a hard braking event) or be more safety conscience (e.g., not answering a call on your phone while driving). Novo may also provide reminders to set up program features, notifications of missed requirements, or updates on your safety score and eligibility.

Legal grounds: consent – for processing telematics data to generate and deliver insights; legitimate interest – to promote safe driving and optimize user engagement; ensure smooth communication and services/product functionality.

(iv) evaluating driver's behavior;
Novo collects and processes data through various technologies, including Bluetooth connectivity, OEM-integrated telematics systems, and third-party platforms such as SmartCar to assess your driving behavior and determine risk profiles. This data includes trip details, acceleration and braking patterns, speed variations, and phone usage while driving. By analyzing these factors, Novo generates safety scores, which influence insurance pricing and policy management.

Legal grounds: performance of a contract – to support your insurance policy or Novo Test Drive trial; legitimate interest – to improve underwriting accuracy and policyholder safety; consent – when required for telematics-based data collection.

(v) validating trips and maintaining program compliance;
Your telematics data, including odometer readings and trip details, is used periodically to validate trips for the Program. This ensures compliance with the Program's requirements and calculates your participation-related benefits, such as discounts based on validated mileage.

Legal grounds: performance of a contract – for enforcing program rules and eligibility; legitimate interest – to ensure accurate and fair benefit distribution.

(vi) communication regarding Novo services, features, and products;
Novo may use your personal information such as your e-mail or phone number to communicate with you about our services, features, technical aspects, and products. This includes providing updates or confirmations related to your account, policy, or products. We may also send service-related messages, alerts, and important notifications (for example welcome notification, trip notification, weekly reports, quote alerts). Such communication may be delivered via e-mail, text messages, push notifications, or other available methods to ensure you stay informed and receive timely assistance.

Legal grounds: performance of a contract – to deliver your policy-related updates; legitimate interest – to inform you of important developments; consent – where marketing communications or optional alerts are involved.

Understanding how your driving affects your insurance cost is essential. This chapter provides a comprehensive overview of Novo's telematics program, including data collection methods, scoring calculations, and the factors that determine your insurance premium. This chapter shall be duly supplemented in accordance with Program ("NSP") Terms and Conditions.

To participate in the Program, your vehicle must meet the eligibility requirements, which may depend on various technical and functional aspects. These requirements can include compatibility with telematics systems, such as specific vehicle makes, models, or years that support connected vehicle technology. Additionally, as the Program evolves, other features, functionalities, or technical specifications may also impact eligibility, ensuring that enrolled vehicles meet the necessary data collection and assessment standards. For example, vehicles shall have Bluetooth connectivity or must be equipped with OEM-integrated telematics systems or supported through third-party platforms like Smartcar to enable data collection, such as odometer readings, driving patterns, and vehicle status. Additional details about vehicle eligibility can be found in the NSP Terms and Conditions and correspondingly in the NSS Terms and Conditions.

NSP particulars:
Our NSP enables usage-based insurance by leveraging the insured's mobile Device for trip and driving behavior data collection. Setup requires downloading the App, granting Bluetooth permissions, and pairing the phone with the vehicle's Bluetooth system. Once a trip begins, Bluetooth detects the vehicle in use, and the system starts recording data. Compliance is tracked by monitoring Bluetooth connection status and App engagement; Note that failure to maintain Bluetooth connectivity may result in the loss of NSP discounts. We use such technology to accurately assign trips to insured vehicles and enhance policy management. By integrating Bluetooth technology, Novo offers a more inclusive solution, and any newly added vehicle eligible for Bluetooth NSP will be transitioned to the BT-based NSP model.

In order to have your telematics data used for insurance pricing, you must drive at least five (5) trips and fifty (50) miles within each evaluation period, generally thirty (30) days, (the "Minimum Scoring Requirement") for connected vehicle(s). Upon enrollment in the Program, you will receive either (i) an enrollment score, if there is insufficient telematics data available to determine your safety score; or (ii) a safety score, if there is an adequate amount of telematics data available. Once a telematics-based safety score is established, it will be used to calculate the premium applicable to your policy, depending on the participation option in the NSP you opt for:

• Novo Flex (Monthly Participation Option): the premium will be calculated for the upcoming billing month. The enrollment score or safety score will be used to determine your policy premium for the first two months. Your insurance policy may include a rate adjustment beginning in the third month of the policy period based on the safety score assigned from telematics data collected from your vehicle. This option enables dynamic monthly adjustments in order to reflect the most recent driving behavior.

• Novo Next (Fixed Participation Option): this option applies the safety score to adjust your premium only once per policy term—at renewal. Telematics data is still collected throughout the policy period; however, your premium remains fixed during the term and is reviewed for potential adjustment solely at the time of renewal.

• Novo Classic (Data Sharing Participation Option): by selecting this option, you agree to share your driving behavior data and the associated safety score strictly for non-pricing purposes—such as educational use, product development, analytics, and research. In return, you may qualify for the Driving Insights Discount. The safety score in this option does not impact your premium.

Please note that the safety score is calculated at the vehicle level and not at the driver level. The driving behavior of all drivers of the vehicle enrolled in the Program will be used for the calculation of the safety score.

All existing NSP policies up to implementation of the 3 NSP participation options (date) will remain in the monthly variable telematics option, unless you opt otherwise before or upon renewal date.

Novo Test Drive Program particulars: This Program offers an opportunity for non-policyholders to try out our service and receive a more accurate quote based on their driving behavior.

Novo Test Drive ("NTD") is available only to residents of Arizona (AZ), and users must confirm their residency during the registration process. Those who do not reside in AZ will be informed that they are ineligible for the program at this time but may be added to a waitlist for future availability in other states.

Our NTD Program enables usage-based initial quotation of the insurance policy by leveraging the insured's mobile Device for trip and driving behavior data collection. Setup requires downloading the App and, granting Bluetooth permissions, and pairing the phone with the vehicle's Bluetooth system. Once a trip begins, Bluetooth detects the vehicle in use, and the system starts recording data. Compliance is tracked by monitoring Bluetooth connection status and App engagement; Note that failure to maintain Bluetooth connectivity may result in the loss of NTD discounts. We use such technology to accurately assign trips to insured vehicles and enhance policy management. By integrating Bluetooth technology, Novo offers a more inclusive solution, and any newly added vehicle eligible for Bluetooth NTD will be transitioned to the BT-based NTD model.

In order to have your telematics data used for insurance quotation, you must drive at least five (5) trips and two hundred (200) miles within each evaluation period, generally thirty (30) days, (the "Minimum Scoring Requirement") for connected vehicle(s). NTD users can already see the score in case the prerequisites are fulfilled in 2 weeks. Upon enrollment in the Program, you will receive either (i) an enrollment score, if there is insufficient telematics data available to determine your start score; or (ii) a start score, if there is an adequate amount of telematics data available.

Once a telematics-based safety score is established, provided that: (i) it is of minimum 75; (ii) the NTD User provided this minimum data: first and last name, home address, date of birth and vehicle info (make, model, year) (iii) the driving record can be verified and (iv) the NTD user is not qualified as High Risk based on past claims or violations in the Novo Platform, the score will be used to determine your Novo Test Drive quote (the projected/estimate quote). This quote will continue to be updated based on your latest score until the end of the NTD trial period or until you decide to obtain a final quote (you will receive a notification with relevant information when such is possible) and conclude an insurance policy with us.

The Application will provide you with regular updates on your driving performance and safety score. Additionally, you will receive weekly reports summarizing your driving habits, including key metrics like acceleration, braking, and total mileage. A rate simulator will be available to you from day one, showing a projected quote based on your safety score. Initially, the simulator will provide an estimated quote based on a simulated vehicle score, but once your driving data has been fully captured, the system will update this quote using real data. Additionally, you will receive notifications once your driving data is sufficient to generate an accurate quote. This quote will be updated as your safety score evolves, ensuring that the quote reflects your most recent driving behavior.

After NTD user successfully completes the bind step, user must get alert on mobile letting them know that their Novo account is now linked to an active novo policy. After transitioning to a policy holder account, you will be able to see trip history for the vehicle for the most recent 30 days during the NTD.

For a vehicle transitioning from NTD into Policy accounts, it's first month score should be capped using raw scores from NTD.

Please note that the safety score is calculated at the vehicle level and not at the driver level. The driving behavior of all drivers of the vehicle enrolled in the Program will be used for the calculation of the safety score.

Novo reserves the right to modify our scoring methodology and the interpretation of resulting scores over time. These changes may be influenced by various factors, including but not limited to, evolving industry standards, technological advancements, and regulatory requirements. Updated scoring criteria will be submitted to the appropriate state insurance departments for review and approval. The use of these revised scoring models will impact underwriting decisions and premium calculations at policy renewal. It is important to note that these adjustments are made to ensure the accuracy and fairness of our rating system and to reflect changes in the insurance landscape.

Participation in the Program is strictly voluntary. In order to participate in the Program, you must "opt in" to the collection of your telematics data (for mobile and/or embedded Application) and enable location services and motion permissions for the mobile Application. When You elect to participate in the Program using the mobile Application, you agree to (i) enable the Application at the beginning of each driving trip you make; (ii) properly categorize your journey (e.g. by properly selecting if you are the driver or a passenger or if you are traveling by car or bicycle); (iii) not engage in a pattern of disabling the Application to avoid the recordation of driving behavior; and (iv) preserve all driving data if you are in an accident as such data may be subject to a lawful subpoena from the insurance carrier or legal representative, other parties involved in the accident, their insurance carriers and legal representatives.

Importantly, a single consent, once granted, encompasses all vehicles listed under a policy, unless explicitly excluded by the Policyholder. Adding or removing vehicles from a policy can consequently modify the overall insurance premium due to alterations in the assessed risk profile. To entirely withdraw from the telematics program, customers must formally revoke consent for all vehicles associated with their policy. It's crucial to understand that opting out may result in higher premiums as traditional risk assessment methods, which are less precise than telematics in capturing individual driving behaviors, will be employed. For accurate data collection and analysis, consistent and correct mobile app usage is paramount, including precise trip categorization and the avoidance of intentional app disabling. By comprehending these details, customers can make informed decisions regarding their participation in the telematics program and its potential financial implications.

In the event you believe there has been an error in calculating your safety score and/or you believe a false crash event has been detected, you may contact Novo to register a dispute by contacting Novo's Customer Service Representatives at 1-866-862-7757. Kindly note that the provisions of the present section shall be duly supplemented by the Novo Safety Program Terms and Conditions.

We reserve the right to amend, waive, modify, or supplement the terms of the Program at any time for any reason. If we significantly change the telematics information we collect, we will inform you of such a change.

Telematics Program general opt-out:
We may terminate your participation in the Program at any time for any reason. For mobile Application Participants, You may "opt out" of the Program at any time by changing the Application settings to remove location sharing. For embedded Application Participants, You may "opt out" of the Program at any time by contacting Novo's Customer Service Representatives at 1-866-862-7757 or optout@novo.us If you "opt out" of the Program, Novo will cease the collection of telematics data from you. However, in connection with the Program, we strive to ensure a seamless and efficient experience for our drivers. Therefore, when a policy is canceled/NSSP participation is cancelled or opted out, our approach to telematics data collection depends on the nature of the cancellation. If the insured/NSS User explicitly initiates an opt-out from the Program or requests the cessation of telematics tracking, we immediately cease data collection and tracking for the vehicle and drivers associated with the policy. This ensures that we fully comply with the user's expressed preferences, terminating their participation in the Program without delay. However, for policy cancellations due to non-payment, administrative reasons, or other causes not explicitly requested by the insured or NSSP enrollment suspension/deactivation due to NSS user non-compliance, we implement a 30-day buffer period during which data collection and tracking continue independently. The continuation of telematics monitoring during this window preserves data continuity, which is essential for accurate policy updates and the Application of appropriate rates. After the 30-day buffer period, if the policy shall not be reinstated, renewed, or rewritten or the NSS reactivated, all telematics data collection and tracking shall be discontinued. The insured/NSS User is then fully removed from the Program, and no further data is monitored unless a new opt-in and program re-enrollment are completed.

Telematics Program options opt-out specific scenarios
You may choose to opt out of telematics participation at any time. The impact of opting out depends on the availability of driving data and the reason for withdrawal.

• Standard Opt-Out (Voluntary): a) no prior Driving Data: monthly variable: Default score 203; Fixed: Default score 303; b) with prior Driving Data: your most recent score will be used until the end of the policy term. If You remain opted out at the time of renewal, your policy will transition to Not Currently Monitoring status.

• Non-Compliance Opt-Out: if your vehicle is not properly set up or has not shared sufficient driving data: a) default scores of 203/204 (monthly variable) or b) 303/304/401/403/404 (fixed) may apply based on your setup and data status. If unresolved by policy term-end, the vehicle will be moved to Not Currently Monitoring status.

• Educational Opt-Out: if You are participating in the telematics program solely for educational purposes (e.g., viewing driving behavior without impacting your insurance rate): You may request to opt out of scoring while still viewing your data in the app. In this case, no score will be applied to your policy, and the system will treat the vehicle as Educational Only - Not Scored. You will not be penalized for opting out in this context, but You must notify us explicitly of this intent. If your status is not updated by the end of the term, your vehicle may transition to Not Currently Monitoring.

Manual Assistance
If You are experiencing technical difficulties in setting up your vehicle contact Customer Support. Based on your situation, we may apply an adjusted score (e.g., 204/304) or default non-compliance score (203/303) manually.

Data Use and Tracking: we maintain internal flags to distinguish between: voluntary Opt-Out; non-compliance and educational use. This ensures your telematics data is handled appropriately, and your policy is treated fairly. For more detailed use cases, contact us for assistance.

If you have any concerns about the automated decision-making process, you can always speak with a human representative by contacting Novo's Customer Service Representatives at 1-866-862-7757.

For mobile Application Participants, if you "opt out" of the Program before Minimum Scoring Data has been collected or the Minimum Scoring Requirement (as applicable) is met, you will not be eligible for telematics-based insurance pricing on your current and/or renewal policies from Novo and may have your insurance rate adjusted or in case of NTD you will not be eligible for a quote. For embedded Application Participants, if you "opt out" of the Program, a non-fulfillment score will be applied for the remainder of your policy term and for each renewal thereafter.

Protecting your privacy is very important to us. The Telematics Policy is a component of Novo's comprehensive privacy framework. For a complete understanding of how Novo collects, uses, shares, and protects personal information, including telematics data, please refer to the Novo Privacy Policy. The Privacy Policy provides additional details on data rights, security measures, and other relevant privacy matters.

We take our obligation to safeguard and secure your personal information very seriously. Along with our technology partners, we follow strict data security and privacy protocols to protect your information and will not disclose information except as described herein and as described within the Privacy Policy.

For California residents, the CCPA grants additional rights, including the right to know what personal data is being collected about you, the right to request deletion of your personal data, and the right to opt-out of the sale of your personal data. All your rights shall be found within Novo's extended Privacy Policy, available on the link above. You can exercise these rights by contacting us at privacy@telenav.com. We implement appropriate technical and organizational measures to ensure a level of security appropriate to the risk of processing your personal data. All collected data is stored securely and access is restricted to authorized personnel only.