Pocket Geek® by Assurant® Privacy Notice

What Information We Collect

How We Use & Disclose Collected Information

Your Choices

Important Information

We are a mobile device troubleshooting Service that helps you address common mobile device issues. We may also offer premium technical support services to select users.

Lifestyle Services Group Limited (registered in England and Wales no. 5114385), an Assurant group company, with principal office at Emerald Buildings, Westmere Drive, Crewe, Cheshire, CW1 6UN, respects your concerns about privacy. If you reside within the European Economic Area, United Kingdom or elsewhere, Lifestyle Services Group Limited is the controller of your personal data within the meaning of Art.4 No. 7 General Data Protection Regulation (hereinafter “GDPR”) and in the context of the Pocket Geek service (the “Service”). All references to GDPR regulations contained in the following apply only to the extent that the GDPR is applicable. If you reside in the United States, then the personal information provided to or collected by Our Service is controlled by The Signal, L.P. in the context of the Service. The terms “We”, “Us”, “Our” or “Company” refer to the relevant controller and/or processor of your personal data.

This Pocket Geek Privacy Notice (“Notice”) describes how We will collect, access, use, disclose, retain, transfer, otherwise process and protect personal information when you use the Service, a service that provides mobile device technical support and troubleshooting assistance, including such premium features as

The Service will collect personal information from and through any mobile devices on which the Mobile App is installed including, mobile devices owned or used by other individuals under the account holder’s account, if any, on which the Mobile App is installed. You are responsible for such family members’ use of the Mobile App, and represent and warrant that you have brought this Notice to the attention of such family members and that you have the authority to permit Us to use their information in accordance with this Notice, including section 6.1.

Please note that the account owner for the Service may access all information collected about any copies of the Mobile App running under the Service on devices that the account owner has authorised.

We protect your personal information using industry standard safeguards. We share information about you to provide the Service, with your consent or as required by law, and We will always let you know when We make significant changes to this Privacy Notice.

We adhere to the following principles to protect your privacy:

We protect your personal information and will only provide it to third parties:

(1) with your consent on basis of Article 6 para. 1 sentence 1 lit. a GDPR;

(2) where it is necessary to carry out your instructions on basis of Article 6 para. 1 sentence 1 lit. b GDPR;

(3) as reasonably necessary in order to provide the Service on basis of Article 6 para. 1 sentence 1 lit. b GDPR;

(4) to Our service providers (as described in Section 3.2) in connection with providing the Service on basis of Article 6 para. 1 sentence 1 lit. b GDPR;

(5) when We reasonably believe it is required by law, subpoena or other legal process on basis of Article 6 para. 1 sentence 1 lit. c GDPR;

(6) as necessary to enforce our Terms of Service, to protect the rights of the Company, or to prevent physical harm or financial loss on basis of Article 6 para. 1 sentence 1 lit. f GDPR; or

(7) as part of a reorganization or sale of all or part of Our business on basis of Article 6 para. 1 sentence 1 lit. f GDPR.

We have implemented safeguards designed to protect your information in accordance with industry standards.

This Notice applies to the Service only and does not necessarily reflect practices with respect to information gathered through other services We offer or websites We operate or the collection of information through off-line means. To review the privacy practices of those other services, please refer to the policies provided associated with each.

If you have any concern about providing information to Us or your information being used in any manner permitted by this Privacy Notice and the Terms of Service, you should not download the Mobile App. If you have already downloaded the Mobile App, you may close your account. Closing the Mobile App account has no legal effect on any usage contracts; separately agreed termination periods remain unaffected. See Section 4.3 of this Notice to view how to close your account.

1. What information We collect

Our Privacy Notice applies to any users of the Service. We collect information when users operate Our Service to troubleshoot issues with a mobile device on which the Mobile App has been installed or devices which may be covered under Our premium services.

We collect your personal information in the following ways:

1.1 When you Register

When you create an account with Us, We may collect information (including your email address, mobile phone number or password).

To create an account on Pocket Geek to access certain premium features, and so that We can administer the Service, We ask users to provide Us with: (i) email address, (ii) mobile phone number and (iii) password on basis of Article 6 para. 1 sentence 1 lit. b GDPR in order to provide you with the Service We also collect your mobile device identification number (e.g., IMEI) and Internet Protocol (“IP”) address for the same purpose.

1.2 When you use Our Mobile App

When users operate the Service, We may collect information from your mobile device. You may request deletion of this personal data whenever you like. We also collect information about your usage of the Mobile App.

After you have registered for the Service and the Mobile App has been downloaded, information is collected from your mobile device periodically.

We collect information about the device on which you have installed the Mobile App, such as device settings (e.g. Wi-Fi On/Off), device name (e.g., “John’s phone”), activities (e.g., Bluetooth was disabled), device performance profiles, malware signatures and application/system logs (to detect application crashes and other potentially harmful occurrences) and your IP address. The legal basis for the for the foregoing processing is Article 6 para. 1 sentence 1 lit. b GDPR; the processing of your data is necessary to provide you with the functionalities of the Service.

We also collect information about your usage of Our Mobile App and use third party analytics tools to monitor and evaluate your activity within the Mobile App on basis of Article 6 para. 1 sentence 1 lit. a GDPR. When you are logged into the Mobile App, your usage and device information will be associated by Us with your account. When you are not logged into the Mobile App, We log information about devices used to access Our Service, including mobile device identifier. For more information about the tracking technologies We utilise on the Mobile App, please view Our User Analytics Notice.

Additional information may be collected depending upon the Mobile App features that you are eligible to use, and the permissions that you have granted on basis of Article 6 para. 1 sentence 1 lit. a GDPR. In the context of Our Backup and Remote Mobile Tech Support services and Our Locate, Lock & Wipe service, the information collected includes: (i) contacts / address book; (ii) calendar; (iii) bookmarks; (iv) wallpaper (e.g., background images and graphics); (v) photos and videos; (vi) installed mobile apps; (vii) documents; and (viii) audio recordings (e.g., music).

In the context of Our Backup and Remote Mobile Tech Support services and Our Locate, Lock & Wipe service, We will process geo-location data with your permission on the basis of Article 6 para. 1 sentence 1 lit. a GDPR. - Geo-location information is derived either from your wireless operator, certain third-party service providers, or directly from the mobile device on which the Mobile App is installed. This location tracking of the mobile device may occur when the application is not actively open and running, if you have enabled location tracking in the settings for the mobile device. Such information may also be stored on your device. You may at any time discontinue these geo-location services by turning off location services on your device or uninstalling the Mobile App. You may also remove your personal information by closing the account. See Section 4.3 of this Notice to view how to close your account.

1.3 When you use the Mobile App to enroll a Device for Coverage

We collect information when you use Our Mobile App to enroll a device for coverage

When you use the Mobile App to enroll a device for coverage (where a user is eligible), We will collect your device’s IMEI number and photographs of your device which you provide to enable Us to determine eligibility for coverage on basis of Article 6 para. 1 sentence 1 lit. b GDPR.

1.4 When you submit a Claim using Our Mobile App

We collect information when you use Our Mobile App to submit a claim

Certain users may be eligible to use our Mobile App claim submission feature. If eligible, when you submit a claim via the Mobile App, We will collect your name, telephone number, address (billing and delivery), email address and payment card information. We will use your telephone number to retrieve information from Our systems about the devices which you have insured. We will also request information about the circumstances of your claim (for example, the date of the incident, and whether your device has been lost, stolen or damaged), and your preferred resolution (for example, repair or replacement of your device) on basis of Article 6 para. 1 sentence 1 lit. b GDPR.

1.5 When you communicate with Us or contact Us for Customer Support

We collect information when you contact Us for customer support.

When you contact Our customer support (for example, when you use Our Tap to Talk or Tap to Chat function), We will collect information that you provide to Us in your communications (such as the query or issue that you have raised).

With your permission We will access your personal information contained within the Service or your mobile device to respond to your request (e.g., lock your mobile device). When Our support technician accesses your device for troubleshooting purposes, while the technician is logged in to your account, she or he can access and extract information (such as settings) from the device. The technician will only access information needed to troubleshoot the device, and once the session is over, the technician will not retain any of the information on his or her screen. With the use of certain premium features, such as Remote Mobile Tech Support, Our technicians may be able to view messages and communications sent to the mobile device while providing support services. We do not retain or use this information for any purpose. We process your data on basis of Article 6 para. 1 sentence 1 lit. b GDPR in order to process your query and/or answer your questions.

You may report any problems or security concerns with the Mobile App by sending an email to support@pocketgeek.com.

1.6 Links to other Websites

Our Mobile App may contain links to other websites. We are not responsible for the privacy and security practices of other websites.

The Mobile App may contain links to other web sites that may have online information practices different from Ours. We are not responsible for the privacy and security practices of those websites, and We encourage you to learn about the privacy and security practices of those web sites if you choose to access and use them.

1.7 What happens if You do not provide your personal information

If you do not provide your personal information, you may not be able to use all aspects of Our Service.

To use the Services the provision of personal information is mandatory. If relevant data is not provided, then We will not be able to provide you with the premium services for which you are eligible: We may not be able to provide Our services to You, either to the same standard or at all; We may not be able to provide You with information about services that You may want, including information about special promotions; or We may be unable to tailor Our content to Your preferences and Your experience using the Services may not be as enjoyable or useful. For example, Android device users need to provide their email address and mobile number at the time of registration to use the Mobile App, while iOS users must provide their email address and mobile number to use premium features. All other provision of your information is optional. For example, you would not receive customised tips for your device, if you do not provide information about your smartphone or tablet.

2. We process your personal information for the following purposes:

We collect information from you to provide the Service.

2.1 Withdrawing consent

Wherever We rely on your consent, you can always withdraw your consent at any time with effect for the future by contacting us via any means. You may change your mobile app analytics settings at any time.

2.2 Automated decision making

We do not use automatic decision making or profiling.

2.3 Communications

We communicate with you through email, text messaging and the Service. We may send you messages relating to the Service and your use of the Service, as well as information about promotions.

We communicate with you through email and other means available through the Service, including mobile text messaging (e.g., SMS) and push notifications. Examples of these communications include: (1) welcome and registration communications, and (2) service communications. These messages will be sent to you based on your registration information and messaging preferences. You may change your email and contact preferences at any time by signing into your account and changing your email settings.

Please be aware that you cannot opt out of receiving Service-related messages from Us.

3. How We share your personal information

3.1 Sharing personal information with affiliates

We may share your information among the Assurant family of companies.

We share your personal information with Our affiliates (meaning entities controlled by, controlling or under common control with Assurant, Inc.) for the purposes stated in this Notice. For example, your support enquiry may be handled by an Assurant contact center or technical support staff located within or outside the European Union (such as in the United States). Your personal information may be shared with Our affiliates, such as the Assurant group company through which you obtained the Service, for customer relationship management purposes (for example – when you make a complaint). In accordance with Art. 28 of the GDPR, we concluded necessary commissioned data processing agreement(s) with our affiliates.

3.2 Sharing personal information with service providers

We employ third parties to help Us with the Service.

We employ third party companies and individuals to facilitate the Service (for example, customer support, analysis, audit, application, database hosting).

These third parties have limited access to your information only to perform these tasks on Our behalf and are obligated to Us. The personnel of such third parties who use your personal information is limited to those individuals which are authorised to do so on a need-to-know basis and as necessary to provide these business services to Us. We do not authorise such third parties to disclose or use it for other purposes.

Please see Our List of Service Providers to learn more about the service providers We use and the services that they provide to Us.

3.3 Sharing personal information with other recipients

We may disclose your personal information if mandated by law or if required for the legal protection of Our legitimate interests in compliance with applicable laws.

We may disclose your personal information to public authorities if mandated by law or if required for the legal protection of Our legitimate interests in compliance with applicable laws.

We may also disclose your personal information to parties acquiring part or all of Our assets, as well as to attorneys and consultants. Also, if any bankruptcy or reorganization proceeding is brought by or against Us, your information may be considered a company asset that may be sold or transferred to third parties.

3.4 Data processing outside of your country

We may process your information outside the country where you live, including in countries that may not provide the same level of data protection.

In providing the Service, and the Mobile App, personal information may be transferred to, and processed in, countries where data protection and privacy regulations do not offer the same level of protection as the European Economic Area (“EEA”) and other parts of the world:

Sharing personal information with Our affiliates as noted in Section 3.1 involves transfers outside the EEA to the US and to the UK (following the withdrawal of the UK from the European Union) to provide the Service (for example – to respond to your customer service enquiry or reporting performance metrics).

Sharing personal information with Our service providers involves transfers to the US (hosting, data analytics, performance management, anti-virus, messaging, remote support, customer management, and mapping), Ireland (log management and performance reporting, Israel (backups), and Romania (contact center support).

Where personal information is transferred outside the EEA to a country that is not subject to an adequacy decision by the EU Commission, it is adequately protected by European Commission approved standard contractual clauses, an appropriate Privacy Shield certification or a vendor’s Processor Binding Corporate Rules. To obtain a copy of the relevant transfer mechanism or additional information on the transfers, please address these requests to Us.

4. Your Choices and Rights

If the GDPR is applicable to Our processing of your personal data, you have the following rights.

You may request access to, modify, correct, delete or limit the use and disclosure, where required by applicable law, of your account information or close your account. You can also request additional information We may have about your account.

4.1 General rights

You have the following rights with regard to the data processed by us:

4.2 right of objection pursuant to Art. 21 GDPR.

You have the right, pursuant to Art. 21 GDPR, to object to the processing of your personal data by us or by a third party on the basis of a legitimate interest (in particular for the purposes of usage analysis and the needs-based design of the mobile app), insofar as there are reasons to do so which result from your particular situation. We no longer process the relevant personal data unless we can prove compelling grounds for processing worthy of protection which outweigh your affected interests, rights and freedoms, or if the processing serves the assertion, exercise or defence of legal claims.

If we process your personal data for the purpose of direct marketing, you have the right at any time to object to the processing of your personal data for the purpose of such marketing; this also applies to profiling, insofar as it is connected with such direct marketing. If you object to the processing for purposes of direct marketing, we will no longer process your personal data for these purposes.

4.3 Additional information

You can exercise any of your rights by contacting Us via any means. In order to safeguard your personal information from unauthorised access, We may ask that you provide sufficient information to identify yourself prior to providing access to your personal information.

Please note that certain personal information (for example – mobile number) can also be accessed via the mobile app. You may correct your mobile number via the “Settings” in the mobile app if you choose. In addition, you may close your Mobile App account by uninstalling the mobile app from your device.

In certain situations and subject to applicable laws, including data protection laws, We may not be able or obliged to comply with all or part of your request. For example, We may not comply with an access request if doing so would reveal personal data about another person, or comply with a deletion request relating to information which We are required by law to keep or have compelling legitimate interests in keeping.

If you have unresolved concerns, you have the right to complain to an EU data protection authority (‘supervisory authority’) where you live, work or where you believe a breach may have occurred.

CALIFORNIA CONSUMERS: To learn more about your data privacy rights and how to exercise your rights please visit www.assurant.com/DataProtection/USA

5. Data Retention

We keep your information for as long as your account is active or as needed. In addition, We may keep certain information even after you close your account if it is necessary to comply with Our legal obligations, meet regulatory requirements, resolve disputes, prevent fraud and abuse, or enforce this agreement.

We retain personal information you provide while your account is active or as needed to provide the Service. If you close your account(s), your information, including information that has been backed up from your mobile device, will generally be removed from the Service within 24 hours. We delete logs and other backup information through the deletion process within 90 days of account closure. You may access records retention details [here].

Our customer support may retain information for as long as is necessary to provide support-related reporting and trend analysis only, but We generally delete or anonymise closed account data consistent with this Notice.

We may retain your personal information for longer than the periods set out above where necessary, for example to comply with Our legal obligations, meet regulatory requirements, resolve disputes, prevent fraud and abuse, or enforce Our Terms of Service.

6. Important Information

6.1 Minimum age

You must be at least 18 years of age, or the equivalent minimum age in the relevant jurisdiction, to use the Service.

We do not knowingly collect personal information from anyone under the age of 18 or such equivalent minimum age for consenting to data processing in the relevant jurisdiction. You must be at least 18 years of age, or the equivalent minimum age in the relevant jurisdiction, to use the Service.

6.2 Changes to this Privacy Notice

We will notify you when We change this Privacy Notice.

We may update this Notice from time to time. If We make any material changes to Our Notice, We will notify you by email or by means of a notice through Our Mobile App or Service, or by other means prior to the change becoming effective, so that you may review the changes before you continue to use the Service. As We may make changes to this Notice, We suggest that you review this Notice each time you access and use the Service. Please review changes carefully. If any changes are made to this Privacy Notice, We will revise the Effective Date that is indicated on the Privacy Notice.

6.3 Security Procedures

We take privacy and security seriously. Please know that the Internet is not a secure environment.

We have measures in place to restrict access to information to those employees and individuals whom We know have a valid business purpose to have access to such data. We maintain physical, electronic and procedural safeguards. We follow generally accepted standards designed to protect the personal information submitted to Us, both during transmission and once We receive it. We require those who provide services for Us and to whom We provide information collected through the Service to keep such information safeguarded and confidential. However, no method of transmission over the Internet or method of electronic storage is totally secure. Therefore, We cannot guarantee its absolute security.

6.4 Contact Us

If you have questions or comments about this Privacy Notice, please contact Us online or by postal mail.

For users within the United States

We welcome your questions or comments regarding this Notice. Please write to Us at Assurant Privacy Office, 260 Interstate North Circle SE, Atlanta, Georgia 30339, USA or send Us an email at ThePrivacyOffice@assurant.com.

For users within the European Economic Area and Elsewhere (except United States)

The Assurant group companies have appointed an EU Data Protection Officer. Customers who feel that the rights afforded to them under the GDPR or applicable data protection law have been infringed, or that the data controller is processing personal information in contravention of the GDPR or applicable data protection law, may submit complaints or inquiries to:

Data Protection Officer, Lifestyle Services Group Limited, Emerald Buildings, Westmere Drive, Crewe, Cheshire, CW1 6UN, United Kingdom, or send Us an email at dataprotectionofficer@assurant.com.

If you have an unresolved privacy or data use concern that We have not addressed satisfactorily, please contact Our US-based third party dispute resolution provider (free of charge) at https://feedback-form.truste.com/watchdog/request.

You also have the right to file a complaint directly with the local Supervisory Authority, as relevant, under EU data protection law.

Effective Date: Sep 30, 2020

User Analytics Notice

Analyse Mobile App Performance

We collect personal information, on an individual and collective basis on the basis of Article 6 para. 1 sentence 1 lit. a GDPR, based on your consent, to track and analyse preferences and trends, improve the quality of the Mobile App, evaluate possible new features, functionality and services, and improve Our Mobile App. We collect information when you use Our Mobile App, and use third party analytics tools to evaluate user traffic. For example, We collect information when you view a Mobile App screen. Additionally, We collect log in information about devices used to access Our Service, including user ID, device information (e.g., device manufacturer, OS), and how you use the Mobile App (e.g., when you tap the Backup button).

What types of cookies (or analytics) are used with the Mobile App?

We use first party cookies (or analytics) with the Mobile App. The analytics used in our Mobile App can be categorised in the following ways:

Analytics Service Provider Google Analytics
Purpose Google Analytics stores a Google Analytics client ID which is used to identify users across all the devices used to access the app. Users may manage their opt in preferences within the Mobile App under “Settings” at any time. Click here to access an overview of privacy at Google.
Analytics Service Provider Mixpanel
Purpose Mixpanel enables Us to perform event-based analytics within the Mobile App so effectiveness may be measured. Users may manage their opt in preferences within the Mobile App under “Settings” at any time.

This User Analytics Notice should be read in conjunction with Our Privacy Notice. If you have any questions or concerns about these Notices or their implementation you may send Us an email at: support@pocketgeek.com.

Effective Date: Sep 30, 2020

List of Service Providers

This List of Service Providers identifies the third party service providers (who are not considered to be part of the Assurant group companies) We use in connection with the Pocket Geek Mobile App:

Service Provider (Name) Amazon Web Services
Location (Country) United States
Service Provider’s Processing Purposes Mobile app hosting
Service Provider (Name) Mixpanel
Location (Country) United States
Service Provider’s Processing Purposes Mobile analytics to improve user experience
Service Provider (Name) Avast
Location (Country) United States
Service Provider’s Processing Purposes Antivirus Services and Wi-Fi Security Scanning Services
Service Provider (Name) Rapid7
Location (Country) United States, Ireland
Service Provider’s Processing Purposes Log management and reporting for benchmarking and performance
Service Provider (Name) NewRelic
Location (Country) United States
Service Provider’s Processing Purposes Manage and track technical performance
Service Provider (Name) LucidCX
Location (Country) United States
Service Provider’s Processing Purposes Self-help and troubleshooting content provider
Service Provider (Name) SendGrid
Location (Country) United States
Service Provider’s Processing Purposes Email for mobile app users
Service Provider (Name) Twilio
Location (Country) United States
Service Provider’s Processing Purposes SMS verification before filing a claim from the app
Service Provider (Name) LogMeIn
Location (Country) United States
Service Provider’s Processing Purposes Remote support via remote device control and screen sharing
Service Provider (Name) Rollbar
Location (Country) United States
Service Provider’s Processing Purposes App Crashing Monitoring
Service Provider (Name) Intercom
Location (Country) United States
Service Provider’s Processing Purposes In app chat service
Service Provider (Name) Firebase
Location (Country) United States
Service Provider’s Processing Purposes Supports measurement of mobile app performance (for example – when the app crashes)
Service Provider (Name) Synchronoss
Location (Country) United States
Service Provider’s Processing Purposes Data backup services
Service Provider (Name) Microsoft
Location (Country) United States
Service Provider’s Processing Purposes Provides customer relationship management support
Service Provider (Name) CGS
Location (Country) Romania
Service Provider’s Processing Purposes Call Center services for the EU region
Service Provider (Name) Google Maps
Location (Country) United States
Service Provider’s Processing Purposes Google Maps API supports the Locate feature of the mobile app
Service Provider (Name) Google Analytics
Location (Country) United States
Service Provider’s Processing Purposes Mobile analytics to improve user experience

Effective Date: Sep 30, 2020

Additional Provisions for Individuals Located in Canada

All references in the Privacy Notice to the General Data Protection Regulation or “GDPR” shall be read, with the necessary modification as the context requires, to the Personal Information Protection and Electronic Documents Act (Canada) and all substantially similar Canadian provincial privacy legislation.

All collection, use, processing and disclosure of your personal information is made on the basis of your express or implied consent, except where collection, use, processing or disclosure is permitted by PIPEDA without consent.

We rely on implied consent to collect, use, process and disclose your personal information in the following situations:

We rely on express consent to collect, use, process and disclose your personal information in the following situations:

We rely on one or more exceptions in PIPEDA to collect, use, process and disclose your personal information in the following situations:

Occasionally we use service providers located outside of Canada to collect, process or store personal information on our behalf. Please note that the laws of other countries from which your personal information may be collection or in which it may be processed or stored may provide for a different level of protection than exists under Canadian laws. If you would like to receive more information about our policies and procedures concerning our use of service providers outside of Canada, please contact us at email: support@pocketgeek.com.

Your Choices and Rights

Under PIPEDA, you have the following rights with regard to the data processed by us:

Effective Date: Sep 30, 2020