PRIVACY POLICY
This Privacy Policy describes how we collect, use, and disclose Personal Information in connection with your use of Insuraroo websites, mobile applications, and related webpages (collectively, "Websites"). It also describes how we share, disclose, or sell your Personal Information with and to service providers, contractors, and third-parties to provide you the products and services you have requested throughout the Websites as well as operate our services, run our Websites, or perform other business activities on our behalf (collectively, "Services").
This Privacy Policy is incorporated by reference and incorporates herein by this reference Insuraroo.com's Terms of Service, including the obligation to arbitrate your claims under this Privacy Policy pursuant to your agreement to arbitrate in the Terms of Service titled DISPUTE RESOLUTION – CLASS ACTION LIMITATION. In addition, you agree to limit any disputes to those between us and you and not participate or act as a class representative. By using, interacting with, entering information, or viewing information on our Websites, you expressly acknowledge and consent to our practices set out in this Privacy Policy in it's entirety, including providing your consent to our use and disclosure of information collected from, or about, you in the manner described herein. You agree that we will rely on your use and interaction with our Websites as your express consent to the terms of this Privacy Notice. YOU AGREE THAT YOU HAVE READ, UNDERSTAND, AND AGREE TO BE BOUND BY THE TERMS OF SERVICE AND THIS PRIVACY POLICY.
INFORMATION WE MAY COLLECT
In order to assist you in finding the insurance service and product you seek, we may collect information from you or third-parties, information that personally identifies, relates to, describes, or is capable of being associated with you (collectively, "Personal Information"), including:
- Identifying Information, which includes your name, physical address, email address, phone number, mobile number, your car or car(s) identification, and the number of drivers in your household. In addition, we may collect other information such as your social media id, and publicly known information which may be used to identify an individual.
- Demographic Information, which may include your age and date of birth, gender, marital status, and language preference.
- Internet or Other Electronic Network Activity Information, which may include internet or other electronic information including your web history, search history, interactions with a website, email, applications, or advertisements, IP address, IP Host location, enabled cookies, or any other information that may be automatically obtained from you while you are visiting or using the Websites. This information is collected through technology on our Websites and described below and include, log data, analytics data, device ID, and other data collected through cookies, web beacons, JavaScript, and similar technologies.
- Credit and Financial Information, which includes your self reported credit score, credit accounts, and other creditworthy information about you or your household.
- Geolocation data, which includes both your general geographic location when viewing our Websites and precise location when submitting a registration providing the same.
- Audio, electronic, visual, or similar information, including, where permitted by law, recordings of phone calls between us or our customer service providers. We also record users who fill out our registration pages and retain for proof of legal compliance.
- Internet or Other Electronic Information, which may include, but is not limited to, your web history, search history, interactions with a website, email, applications, or advertisements, IP address, IP Host location, enabled cookies, or any other information that may be automatically obtained from you while making use of the Websites.
- Inferences drawn from other Personal Information or other Data, includes using your Personal Information to draw an inference about interests and preferences you would like us to use based on our and third-party's analysis of your trends.
- Sensitive Information, depends upon the state of your residency, but generally means any information that could be used to identify you individually and relates to financial information We collect this information when identifying you for registration, such as your self-reported credit score and your current insurance. This allows us to verify your identity and protect against fraud; comply with our legal and regulatory requirements; improve our services and offers; and marketing products and services by us or third-parties subject to your opt-out choices. We disclose or share Sensitive Personal Information with clients who are seeking to provide their services or products to you as you have requested through your registration; Service Providers that perform services on our behalf, such as data processing, marketing, and customer support. We contractually require these providers to protect the confidentiality and security of your Sensitive Information. In an anonymized state, we may also share this information with third-parties to explain and market our services.
HOW WE COLLECT INFORMATION
We collect Personal Information, directly from you when you answer our prompts and fill out our registration form or contact us directly. We also collect your information automatically when you visit our website through our technology. Lastly, we collect information about you from third-parties, contractors, and service providers.
Information You Provide To Us:
- We may collect Personal Information directly from you when you provide it to us through the Websites or Services.
- This may include the information you provide in response to our request or prompt.
- We may also receive information from you when you contact us with questions or concerns.
Information Automatically Collected:
- When you visit or interact with the Websites, we may use a variety of technologies such as Google or third-party Tags, cookies, clear GIFs, pixel tags, log files, JavaScript, web beacons, and other technologies or third-party services to collect Personal Information automatically or passively about you, your viewing device, and your interactions with Websites.
- We may also automatically collect the following information about you:
- Computer or Device Information: We automatically collect your Internet Protocol ("IP") address or other unique identifier or information from the computer, mobile device, tablet you use to access the Websites, including but not limited to, your browser type, device type, system type, and the domain name from which you accessed the Websites.
- Usage Information: We may collect information about your use of the Websites, including the date and time you visit the Websites, the content, areas or pages of the Websites that you visit, the website or app from which you navigated to the Websites, the page or app you visit after leaving the Websites, the amount of time you spend viewing or using the Websites, the number of times you return to the Websites, as well as other click-stream or usage data, and whether you open, forward, or click-through an email or display ad to the Websites. For legal compliance purposes, we may also capture or record your interactions with the Website to confirm that your information was submitted to us.
- Third-party Service Providers: We use third-party service providers to support our Websites. Some of these service providers may use technology such as cookies, web beacons, pixel tags, log files, Flash cookies, or HTML5 cookies to receive, collect, and store information on your computer for later access and usage.
- Use of Third-Party Analytics and Technologies: We use third-parties' analytics and tracking tools, such as Google Analytics, Google Tag Manager for marketing, to better understand our audience, how they are using the Websites, and how to improve the effectiveness of the Websites and its content, and our marketing. We may use this technology and third-parties to target advertising to you through the internet. These technologies may use cookies, web beacons, pixel tags, log files, Flash cookies, or other technologies to collect and store information about you. They may also combine information they collect from your interaction with the Websites with information they collect from other sources. We do not have access to, or control over these third-parties' use of cookies or other tracking technologies. These technologies will track your website page view, button clicks, external links/outbound clicks, conversions, how you scroll and behave on a page, as well as your geolocation, device type, and at times your screen width.
- Information from Third-Party Websites or Services: If you link to us through a third-party website, email, or service, such as a social media account, we may automatically receive certain information about you based on your registration and privacy settings on those third-party websites or services. This may include, but may not be limited to, your name, username, demographic information, updated address or contact information, location, interests, and online activity.
- Recordation of Registration by Third-party Service Provider: If you choose to register for our services, we provide you with a registration box to enter your personal information and agree to us or one of our providers to contact you. We record your entire interaction with our registration box, including the information you enter when requested, as well as the boxes you check agreeing to certain legal agreements. This recordation is preserved for a period of up to five (5) years from the date of recordation and may be accessed by us or the provider we introduce you to as legal proof that you registered on our Websites and agreed (by checking the required boxes). That recordation is then transferred to the provider for proof of legal compliance.
Information Collected From Third-party Sources:
- Service Providers: We use third-party service providers to support our Websites and Services and business processes including without limitation, services which confirm your identity, determine the truthfulness of the information you submitted, and determine which of our client's we will submit your information to in order to provide you with the products and services you are seeking by your registration.
- Third-Parties: We obtain Personal Information about you from third-party sources, including commercially available sources, such as data aggregators and public databases. This information may include your name, demographic information, interests, and publicly-observed data.
Combining Information: We may combine the Personal Information we receive from you, third-parties, and information we automatically collect through the Websites and/or Services, as well as information collected from other online or offline sources, including from third-party sources. This will provide us with a profile of you which we may be able to use for provision of our services to you as well as identify other products and services that may interest you.
HOW WE COLLECT INFORMATION USING TECHNOLOGY ON OUR WEBSITES
We may collect information about you other than Personal information, or Sensitive Personal Information, which does not reveal your specific identity, such as browser information, information collected through cookies, pixel tags, web beacons, and other technologies, demographic information, and aggregated and de-identified data. Other Information may also include geographic information, referral information and URL information. Although such information may not by itself reveal your specific identity, it could be used by third-parties that have independent relationships with you to identify you, your web activities, and your interests.
We may also install cookies, web beacons, or other technologies, including technologies that identify the dialing, routing, addressing, and signaling information generated by Website users, that provide access to third-parties to your information, including but not limited to your IP address and browsing activity on pages of our Websites where these devices are placed. Cookies may be active for a period of anywhere from 30 to 90 days, however, you may remove cookies using your browser settings. You understand that we do not control any information gathered by such devices or its use by such third-parties. These third-parties are required to handle your personal information in accordance with their own privacy policies and applicable data protection laws and regulations.
You agree that any Personal Information, or other information collected through cookies, pixel tags, web beacons, and other technologies, including any technologies that identify the dialing, routing, addressing and signaling information generated by website users may be used and shared by us as provided in this Policy.
Types of Cookies
In general, we use types of cookies:
- Necessary Cookies. These cookies are essential for the basic functioning of our Websites. Without these cookies, our Websites may not function properly, or some features might be unavailable. They are considered vital for our Websites operation. Without these cookies, you would not be able to view and use the basic features of our Websites.
- Functional Cookies. These cookies are used to enhance our Website's performance and functionality, allowing us to remember user preferences, settings, and choices made during browsing. These cookies contribute to a more user-friendly and personalized experience for you as they remember your visits to our Website, your preferences, and choices you make on the Websites. We also use functional cookies to facilitate navigation, to display content more effectively, and/or to personalize your experience.
- Advertising Cookies. Advertising cookies allow us to select which advertisements or offers are most likely to appeal to you. We also use them to track responses to online advertisements and marketing, and we may use them to better understand your interests so we can present you with relevant messages and offers. These cookies may also allow you to share certain pages with social networks.
- Analytics Cookies. Analytics cookies help us improve our Websites by collecting and reporting information on how you use it, which pages you visit, the length of time spent on a page, and the like. These cookies are primarily used for tracking user behavior and interests across multiple websites, enabling advertisers to deliver targeted ads and measure the effectiveness of advertising campaigns.
You can learn more about cookies at: http://www.allaboutcookies.org/manage-cookies/index.html.
Managing Cookie Choices
There are several ways to manage cookies:
- Browser Settings. You can opt-out of cookies on your browser. Every browser is different, please check the instructions provided by your browser. Should you choose to opt-out of cookies on your browser or disable cookies, this may impact your use of our Websites.
- Google Analytics. We collect information through Google Analytics, which uses cookies and technologies to collect and analyze data about the use of our Websites. These services also collect data regarding the use of other websites, apps, and online resources. You can learn about Google's practices by going to www.google.com/policies/privacy/partners/ and opt-out by downloading the Google Analytics opt-out browser add-on, available at https://tools.google.com/dlpage/gaoptout.
HOW WE USE YOUR INFORMATION
We use the Personal and non-Personal Information we collect from and about you for any of the following business purposes:
- To provide our Websites and/or Services to you or respond to or fulfill your requests.
- To inform you about important information regarding the Site, products, or services for which you may apply or in which you are enrolled, changes to terms, conditions, policies, and/or other administrative information.
- To analyze, improve, operate, and maintain our Websites, Services, and systems, or develop new products, services, or marketing.
- To obtain on your behalf the information, products, or services that you request from us, and this includes passing it on to our clients who provide the products and services to communicate with you directly.
- To carry out our obligations and enforce our rights arising from any contracts entered into between you, us, our clients, or other service providers, or third-parties, involving the services or products you have requested.
- To provide you and other users with customized content, targeted offers, and advertising, or across other websites, social media, or online services, or using email, and/or telemarketing regarding offers, events, news, and other related and unrelated services and products that we believe may be of interest to you.
- To determine the effectiveness of our marketing programs including use of your data in an aggregated non-specific format for analytical and demographic purposes.
- To allow us to verify your identity or other information collected from or through our social media pages or campaigns and other interaction with online forms generated on our behalf. We may combine and use Personal Information you provide through your registration on our Websites with the information collected from our social media pages or from your interaction with online forms generated on our behalf.
- We may use third-parties to measure and target advertisements on our behalf that are tailored to your online interests or improve our marketing efforts. To facilitate these activities, we allow these third-parties to use cookies, web beacons, pixel tags, and similar technologies to collect certain data and other information about your online activity. We also may display interest-based ads through social media platforms or other party's websites. These tools allow us to personalize our ads based on your experience, without having to share your Personal Information with these social media platforms.
WHO WE MAY DISCLOSE, SHARE, AND SELL YOUR PERSONAL INFORMATION TO
- Third-party Product and Service Providers: We disclose, share, and sell your Personal Information to third-party product and service providers to provide you with the products and services you have requested through your registration on our Websites and Services which may include service providers who are expressly disclosed to you during the registration process as well as service providers whose names are not disclosed at the time of registration, but offer similar products or services.
- Parent and Affiliated Companies: We may disclose and share your information with our parent company and its subsidiaries for business and operational purposes.
- Service Providers: We disclose and share your information to third-party contractors and other service providers that we use to support our business, Websites, and Services.
- Sale or Transfer of Business or Assets: We may disclose, share, and sell your Personal Information as part of our sale of assets during the normal course of our business. If another entity acquires us or any of our assets, information we have collected about you may be transferred to such entity. If we file for bankruptcy or reorganization, information we have collected about you may be considered our asset and may be included in the assets transferred.
- Marketing Vendors and Other Third-Parties: We may disclose, share, or sell your information to third-parties who provide display and/or email services or other third-party vendors we use who provide cookies, pixel tags, web beacons, clear GIFs, or other similar technologies for our and third-parties use on and to manage and improve our advertising campaigns. The marketing may be on our behalf or on behalf of other unrelated parties and offers.
- Compliance with Laws: We may disclose your Personal Information to government investigative officials to comply with any court order, law, or legal process, including responding to any subpoenas, judicial processes, or government or regulatory requests and investigations. We may disclose and share your Personal Information to third-parties to assist us in compliance with Laws.
- Enforcing Our Rights: We may disclose and share your information to enforce or apply our terms of service or other agreements, including for billing and collection purposes, with clients, third-party service providers, and other third-parties or contractors who provide you with the product or service which you have requested, or to protect the security of our Websites, servers, network systems, and databases, and enforce our contractual rights with these parties.
- Aggregate or Anonymous Non-Personal Information: We may disclose, share, or sell aggregate, anonymous, or de-identified non-personal information to third-parties for their marketing or analytics uses.
YOUR CHOICES AND OPTING OUT
- Cookies, Tracking Options, and California Do Not Track Disclosures: We, third-parties, and service providers place Cookies and Tracking Technology on parts of our Website. You may decline or adjust these technologies through your device or Internet browser settings to limit certain tracking or to decline cookies. Please note that by doing so, you may not be able to use certain features on our Websites or take full advantage of all of our offerings. Please refer to your device's settings or your Internet browser's "Help" section for more information on how to delete and/or disable cookies or to control your tracking preferences. Please note that our Websites may not recognize "do not track" requests or headers from some or all browsers.
- Interest-Based Advertising: You have choices for receiving more relevant advertising on the Websites or across other websites and online services, to learn more about these choice please see relevant articles at http://www.aboutads.info/choices/, http://www.networkadvertising.org/choices/ or for your mobile device, please see http://www.aboutads.info/appchoices. If you wish to prevent your data from being used by Google Analytics, Google has developed the Google Analytics opt-out browser add-on available at https://tools.google.com/dlpage/gaoptout/. Your mobile device may also allow you to adjust your privacy and advertising settings to control advertising. Even if you opt-out, you still may receive advertising from us that is not customized based on your Service or usage information, or advertising from other third-parties.
- Unsubscribing from Our Marketing Communications: We provide our customers, as well as individuals referred by our customers, with the opportunity to opt-out of having their information used for purposes not directly related to placement, processing, fulfillment, or delivery of a product or service. To opt-out of marketing communications or to request to be added to our Do Not Call List or Do Not Mail List, you may use our Contact Us Form.
- Do Not Contact: If you do not want to receive marketing phone calls from us, you may also use our Contact Us Form. Once we place your name on our internal "Do Not Call" list, we will no longer call you for marketing purposes (unless you submit another inquiry or request another consultation/quote from us after your initial do-not-call request). We will honor your request as soon as reasonably practicable. You may still receive calls from third-parties who are not calling on our behalf regarding their products and services, and you will need to separately request that those parties not call you. If you receive marketing communications from one or more of our affiliates or subsidiaries, you must opt-out individually from each of the brands from which you are receiving brand-specific marketing communications.
- Third-Party Communications: Any third-parties to whom we have disclosed, shared, or sold your information may have their own privacy policies which describe how they use and disclose your information and your choices. We encourage you to visit the websites of those third-parties.
CHILDREN'S PRIVACY
We do not direct market our Websites to children under the age of 16. We do not knowingly collect any Personal Information from children under the age of 16. If we learn that a child under the age of 16 has provided personally identifiable information to the Websites, we will use reasonable efforts to remove such information from our files.
DATA SECURITY AND RETENTION
Security: We use reasonable industry-accepted technology and controls to protect your information and data from disclosure to unauthorized third-parties. This includes firewalls, secured facilities, and logged and limited access. Although mostly effective to prevent disclosure, no guarantee can be given that all information you provide to us will not be accessed by unauthorized persons. Thus, please note that no method of transmission over the Internet or method of electronic storage is 100% secure. Any transmission of information, communications, and data to us or through our Websites is at your own risk.
Retention of Personal Information: We retain Personal Information as long as is reasonably necessary to fulfill the purpose for which it was collected, as required by an applicable law, rule, regulation, or contractual provision. We will retain your Personal Information for the purposes of commercial marketing to you until you request we cease further efforts to provide you such offers or in the event you request deletion of your Personal Information. To determine the appropriate duration of the retention of Personal Information, we consider the amount, nature, and sensitivity of the Personal Information, the potential risk of harm from unauthorized use or disclosure of Personal Information, and if we can attain our objectives by other means, as well as our legal, regulatory, tax, accounting, and other applicable obligations. In addition, we will retain Personal Information provided, including complaints, claims, and any other Personal Information provided during the duration of your agreement with us for the Services until the statutory limitation periods have expired and the necessary for the establishment, exercise, or defense of legal claims. Once retention of the Personal Information is no longer necessary for the purposes outlined above, we will either delete or de-identify the Personal Information or, if this is not possible (for example, because Personal Information has been stored in backup archives), then we will securely store the Personal Information and isolate it from further processing until deletion or de-identification is possible.
CHANGES TO OUR PRIVACY POLICY
We reserve the right to make changes to this Privacy Policy including collection, use, sale, and sharing of your Personal Information. We do not provide notice of changes except through our posting on this page. We use your information only in the manner described in this Privacy Policy at the time you register your information with us. Please be sure to review this policy each time you communicate or register with us for the latest policy. Your continued use of the Websites and/or Services after we post a change in the Privacy Policy means you accept those changes.
CONTACT INFORMATION
To ask questions or comment about this Privacy Policy and our privacy practices, contact us:
STATE RESIDENT RIGHTS
In the United States, numerous states have enacted data privacy laws, granting their residents certain state privacy rights. These are regulations at the state level and provide that consumers in the state have certain rights over how their information is collected, used, and shared. Please check your state of residence for further information on the rights granted to you, as you may have one or more of the following rights:
- RIGHT TO KNOW: The right to confirm whether we are processing Personal Information about you and to obtain certain personalized details about the Personal Information we collected about you, including:
- The categories of Personal Information collected;
- The categories of sources of the Personal Information;
- The purposes for which we collected the Personal Information;
- The categories of Personal Information disclosed to third-parties, and the categories of recipients to whom we disclosed the Personal Information;
- The categories of Personal Information shared for cross-context behavioral or targeted advertising purposes, and the categories of recipients to whom we disclosed the Personal Information for those purposes; and
- The categories of Personal Information sold, and the categories of third-parties to whom we sold the Personal Information.
- RIGHT TO CORRECT: The right to correct inaccuracies in your Personal Information, taking into account, the nature of the Personal Information, and the purposes of processing the Personal Information.
- RIGHT TO DELETE: The right to have us delete the Personal Information we maintain about you, subject to statutory exemptions.
- RIGHT TO CONTROL SENSITIVE PERSONAL INFORMATION: The right to exercise control over our collection and processing of Sensitive Personal Information.
- RIGHT TO OPT-OUT OF SALE OR SHARING OF PERSONAL INFORMATION: The right to direct us not to "sell" your Personal Information to third-parties for monetary or other valuable consideration. You also have the right to direct us not to use your Personal Information for automated decision-making or profiling for certain purposes. The exception to this Right is our ability to disclose, share, and sell your Personal Information to the third-parties who provide to you the services and products you requested at registration.
- RIGHT TO OPT-OUT OF TARGETED ADVERTISING/SHARING: You have the right to broadcast a signal from your browser or device that directs an organization to cease providing Personal Information to third-parties for the purposes of targeted advertising. Again, in making this request, we will need to verify your Personal Information in order to ensure we remove any Personal Information from our database that may be shared for targeted advertising.
- RIGHT TO OPT-OUT OF PROFILING: You have the right to opt-out of use of your Personal Information being used to create a profile of you for targeted advertising.
- RIGHT TO PORTABILITY: The right to obtain a copy of your Personal Information in a portable and, to the extent technically feasible, readily usable format that allows you to transmit the data to another entity without hindrance.
- RIGHT AGAINST DISCRIMINATION OR RETALIATION: You have the right to not receive retaliatory or discriminatory treatment in connection with a request to exercise the above rights.
- RIGHT TO THIRD-PARTY IDENTITY: Depending on your state, you have the right to the category of entities with whom we disclosed your Personal Information. Residents of Delaware, Maryland, Minnesota, and Oregon may be able to obtain the identity and contact information of those parties.
HOW TO EXERCISE YOUR RIGHTS: Submit your request to exercise one of the privacy rights identified above by calling (302) 493-5435.
RESPONSE TO STATE RESIDENT RIGHTS
Response and Timing: Before processing your request, we may need to verify your identity and confirm you are a resident of the state you have identified. In order to verify your identity, we will generally either require the successful authentication of your email, or the matching of sufficient information you provide us to the information we maintain about you in our system. We will process requests to opt-out of sharing your sensitive information within ten (10) business days, subject to any applicable exceptions and extensions permitted by law. We will process all other privacy requests within forty-five (45) days, subject to any applicable exceptions and extensions permitted by law. In certain circumstances, we may decline a privacy rights request, particularly where you are not a resident of a state which grants you additional state rights, or where we are unable to verify your identity, or our retention of your information is compelled by law or is preserved for proof of compliance.
Submitting Authorized Agent Requests
In certain circumstances, you are permitted to use an authorized agent to submit requests on your behalf through the designated methods set forth above where we can verify the authorized agent's authority to act on your behalf. In order to verify the authorized agent's authority, we require evidence of either: (i) a valid power of attorney; or (ii) a signed letter containing your name and contact information, the name and contact information of the authorized agent, and a statement of authorization for the request. Depending on the form provided to us and your state of residency, we may contact you by email to confirm the authorized agent has permission to act on your behalf and to verify your identity in connection with the request.
Opt-Out Preference Signal (Global Privacy Control)
You may use an Opt-Out Preference Signal, such as the Global Privacy Control ("GPC"), to opt-out of the sale/sharing of your personal information. However, this technology and our use of it is not fully developed by the market. Our database containing your information may not be linked to your browser identification and because your request to opt-out of sale/sharing will be linked to your browser identifier only and not linked to any account or database information as the connection between your browser and our database is not known to us, we may not be able to fulfill this request. If you would like us to make the connection between your browser and your account within our database or wish to opt-out of the sale of your personal information, please call us at (302) 493-5435.
OTHER STATE RESIDENT DISCLOSURES
California "Shine the Light" Disclosure: The California "Shine the Light" law gives residents of California the right under certain circumstances to request information from us regarding the manner in which we disclose certain categories of Personal Information (as defined in the Shine the Light law) to third-parties for their direct marketing purposes. You may make this request one time a year through our contact page.
Additional Disclosures on Sales, Sharing, or Targeted Advertising. As further described in the Privacy Policy, we may “sell” or “share” your Personal Information (as those terms are defined by the CCPA to third-parties, subject to your right to opt-out of those sales).
In the last 24 months, we sold, shared (for cross-context behavioral or targeted advertising purposes), or disclosed the Personal Information (for the purposes described in our Privacy Policy) as follows:
- Third-party Business (clients) and Marketing Companies: Identifiers, Commercial information, Internet, or other electronic network activity information, Geolocation data.
- Online Advertising Networks, Social Networks, and Analytics Providers: Identifiers, Commercial information, Internet, or other electronic network activity information, Geolocation data.
We also disclose Personal Information to third-parties for our corporate business transaction; or to comply with legal or contractual obligations; as described in our Privacy Policy. In the last 12 months, we may have disclosed each category of Personal Information for these purposes.
De-identified Information: We may receive or process Personal Information to create, de-identified data that can no longer reasonably be used to infer information about, or otherwise be linked to, a particular individual or household. Where we maintain de-identified data, we maintain and use the data in de-identified form and not attempt to reidentify the data except as required or permitted by law.