Xfinity Mobile Care by Assurant® Privacy Notice
How We Use & Disclose Collected Information
Xfinity Mobile Care by Assurant (the “Service”) is a mobile device troubleshooting service that helps you address common mobile device issues. We may also offer premium technical support services to select users.
The personal information provided to or collected for the Service is controlled by The Signal, L.P. The terms “We”, “Us”, “Our” or “Company” refer to the Service.
This Xfinity Mobile Care by Assurant 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
- Anti-virus (which notifies you of potential malware),
- Remote Mobile Tech Support (such as Tap to Talk which allows users to connect with Our technicians who can provide in-device customer support with your permission), for certain registered Xfinity Mobile Care by Assurant users and information on how to repair common problems that occur in mobile devices that qualify for the Service, through the use of a mobile app that can detect common problems (“Mobile App”).
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 authorized.
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;
(2) where it is necessary to carry out your instructions;
(3) as reasonably necessary in order to provide the Service;
(4) to Our service providers (as described in Section 3.2) in connection with providing the Service;
(5) when We reasonably believe it is required by law, subpoena or other legal process;
(6) as necessary to enforce our Terms of Service, to protect the rights of the Company, or to prevent physical harm or financial loss; or
(7) as part of a reorganization or sale of all or part of Our business.
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
Once you have registered and an account has been created on the Xfinity Mobile Care by Assurant App; to access its features and so that We can administer the Service, We ask users to provide Us with: (i) email address, (ii) mobile phone number for the Registered Device and (iii) password. We also collect your Registered Device identification number (e.g., IMEI) and Internet Protocol (“IP”) address. With your permission, we may also access information from your device, such as your general location, contact lists, SMS messages, Call logs, photo and video library, documents, music. This information is only accessed if you grant us access to it, and if it’s required for the service to operate, or required for specific features of the service to operate.
To create an account on Xfinity Mobile Care by Assurant to access certain premium features, and so that We can administer the Service, We ask users to provide Us with their mobile phone number. 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 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. 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 accessible depending upon the Mobile App features that you are eligible to use, and the permissions (including share screen permissions) that you have granted. In the context of Our Remote Mobile Tech Support services the information accessible may include: (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 Remote Mobile Tech Support services We will process geo-location data with your permission. 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.
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).
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 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 customized 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.
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To fulfil a contract, or take steps linked to a contract with Us or register for the Mobile App. This includes:
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providing the Service, the Mobile App to you;
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verifying your identity;
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managing your account;
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determining eligibility for coverage;
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processing your claim;
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making reimbursement payments to you;
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arranging repair and/or replacement, and delivery, of your device;
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communicating with you; and
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taking payment from you.
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As required by Us to conduct Our business and pursue Our legitimate interests, in particular:
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recognizing you on the Service, the Mobile App, improving your experience, increasing security of Our networks and systems, and measuring use and effectiveness of Our Service;
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customizing Our support responses;
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investigating complaints received from you and others about the Service, the Mobile App or Our products and services and tracking potential issues and trends to better serve you;
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Making decisions about, and implementing, reorganizations or sales of all or part of Our business;
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Monitoring customer accounts to prevent, investigate and/or report fraud, misrepresentation, or crime, in accordance with applicable law;
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In connection with legal claims (for example, relating to denial of an insurance claim), compliance, regulatory and investigative purposes (for example, theft and fraud investigations) as necessary (including disclosure of such information in connection with legal process or litigation);
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Conducting market research and customer surveys;
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Advertising Our products and services and sending you information about Our products and services, special offers and similar (where your consent is not required);
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Where you give Us consent:
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We place cookies and use similar technologies in accordance with Our User Analytics Notice and the information provided to you when those technologies are used;
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We obtain geo-location information from your wireless operator, certain third-party service providers, or directly from the device on which the Mobile App is installed;
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We send you information about Our products and services, special offers and similar (where your consent is required);
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On other occasions where We ask you for consent, We will use the data for the purpose which We explain at that time.
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For purposes which are required by law:
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In response to requests by government or law enforcement authorities conducting an investigation; and
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Responding to complaints where We are under a legal or regulatory obligation to adhere to a complaints handling procedure.
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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 Sensitive personal information, Automated decision making, Profiling, Selling, Targeted Advertising
We do not sell your personal information.
We do not use your personal information for automatic decision making or profiling as such terms, or similar terms, are defined in applicable privacy laws.
We do not use your personal information to engage in Targeted Advertising as such term, or similar terms, are defined in applicable privacy law.
We do not collect, use, or disclose sensitive personal information as defined by applicable privacy law other than as permitted by law or with your consent (where required).
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 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. 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).
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 authorized to do so on a need-to-know basis and as necessary to provide these business services to Us. We do not authorize 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 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.
4. Your Choices and 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 Privacy Rights
Under certain state laws, you may have the following rights:
Right to Know: the right to request we disclose to you the following:
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Whether we are processing personal information about you.
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The categories of personal information we collected about you.
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The categories of sources from which we collected the personal information.
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The business or commercial purpose for collecting, sharing, and using personal information about you.
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The categories of third parties to whom we disclosed personal information about you.
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The specific pieces of personal information we collected about you.
Right to Correct: the right to request that we correct inaccurate personal information that we maintain about you.
Right to Delete: the right to request that we delete personal information we, or an entity acting on our behalf, collected about you. We will not discriminate against any consumer who exercises any of their privacy rights found under this Notice by denying a good or service, charging a different price or providing a different level of quality or service.
How to Exercise Your Privacy Rights
You may exercise your privacy request rights by:
Calling: 1-800-280-9577
Completing the online form available at: https://www.assurant.com/dataprotection/consumer-page
You must provide sufficient information that allows us to reasonably verify you are the person who is the subject of the rights request, or such person’s authorized representative. We use a service provider to assist with identity verification and, as required or permitted by law, we may take steps to verify your identity prior to granting you access to information or acting on your request to exercise your rights. We may limit our response to your exercise of your rights as permitted under applicable law.
You may designate an authorized agent to request any of the above rights on your behalf. You may make such a designation by providing the agent with written permission, signed by you, to act on your behalf. If an agent makes a request on your behalf, as permitted by law, we may require verification of the agent’s authorization to act on your behalf, require you to confirm you have authorized the agent to act on your behalf, or require you to verify your own identity. This may include, but is not limited to, a notarized financial/general power of attorney, court order, or official proof of guardianship. Upon receiving your request, we will confirm receipt within ten (10) business days and respond to a verifiable consumer request within the timeframe and in the format required by relevant law. If we are unable to honor your request, we will provide you with a written explanation of the reason(s). You have the right to contact us in writing if you wish to appeal our decision and we will provide you with a written response.
Request Metrics
Assurant’s record-keeping details as required under applicable privacy law are available here: https://www.assurant.com/dataprotection/usa/ccpa-metrics
4.3 Additional 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. You may delete your account from within the Xfinity Mobile Care by Assurant mobile app. This will not affect your mobile protection; it will just delete your credentials and data from Our systems.
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.
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 will generally be removed from the Service within 24 hours. We delete logs through the deletion process within 90 days of account closure.
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 anonymize 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 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. 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.
We welcome your questions or comments regarding this Notice. Please send Us an email at ThePrivacyOffice@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.
Effective Date: July 10, 2024
User Analytics Notice
Analyze Mobile App Performance
We collect personal information, on an individual and collective basis based on your consent, to track and analyze 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.
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:
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Analytics: These analytics collect information about how users interact with a mobile app, for instance which screens users go to most often, and if they get error messages from a mobile app. The information these analytics collect is used to improve how a mobile app works.
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Analytics: These analytics tools collect information about how a user interacts with a mobile app. For instance, which screens visitors go to most often, and if they get error messages. The information collected is used to improve Mobile App performance.
| 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: July 10, 2024
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 Xfinity Mobile Care by Assurant 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 |
| 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) | Ozmo |
| 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) | Microsoft |
| Location (Country) | United States |
| Service Provider’s Processing Purposes | Provides customer relationship management support |
| Service Provider (Name) | Teleperformance |
| 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: July 10, 2024