Novo Telematics Policy

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 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) which provides You with insights about your driving patterns and tips to improve your driving.

“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.

“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 cover 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"):

• 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. 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, and/or other relevant vehicle details, might be collected to determine the vehicle's eligibility for participation in the Novo Safety Program. 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.

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:

(a) 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, (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, 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.

(b) 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).

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:

1. 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.

2. 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.

3. 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.

4. Facilitating claims/requests or conducting investigations where the case may be; Novo will collect and process your data to communicate with you where needed, to manage your insurance policy, and handle or facilitate different claims/requests.

5. Security and fraud detection, including illegal activities, and ensuring compliance with regulations and law enforcement; We aim to protect customer data from unauthorized access, preventing identity theft, detecting and preventing fraudulent claims, complying with data protection regulations, and ensuring the integrity and confidentiality of the company's systems and data.

6. For research and development including to respond to your product or service information requests and improving your customer experience; When used for research and development purposes, telematics information will be used to draw insights and make predictions about driving patterns, safety, and the impact of internal and external factors (such as weather) on accidents and driving events. These research and development activities will inform changes to our existing products as well as new products we and/or our affiliates may develop in the future.

7. 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.

8. 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. 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.

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 Novo Safety 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. 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 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 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 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. Please note that the safety score is calculated at the vehicle level and not 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 theNovo 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 change.

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 or opted out, our approach to telematics data collection depends on the nature of the cancellation. If the insured 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, 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, all telematics data collection and tracking shall be discontinued. The insured is then fully removed from the Program, and no further data is monitored unless a new opt-in and program re-enrollment are completed.

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. 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 the 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.