Last Updated: January 1, 2021
Spero Insurance Agency, “Spero”, owns and operates each website that displays this Privacy Notice (each, a “Site”). Spero is a private company that operates in the insurance industry. Your privacy is important to us. We created this Privacy Notice to explain how we collect, use, and share the information that we collect from and about you.
Choices and Access
Information for California Consumers
Changes to This Privacy Notice
Automatically Collected Information. We collect data that your device provides when you interact with the Site or sites owned by third-parties with whom we have contractual relationships (“Media Partners”). In most cases, when you come to the Site, we will automatically gather or receive technical data which may include browser type, referrer URL, date and time of your visit, IP address, MAC address, device type, screen resolution, and OS version (“Technical Data”). Technical Data also includes “Cookie and Similar Data” described below.
Other Data You Provide: We collect additional data if you choose to engage with the Site or certain sites owned by our Media Partners. We refer to the information you choose to provide as “Provided Attributes.” This includes contact information that you choose to provide to us or our Media Partners (e.g., name, address, email address, telephone number) about yourself or others. For example, if you click on our advertisement located on a Media Partner’s site, that Media Partner may pass your contact information to us. Or, if you inquire about insurance opportunities, products and services, the Provided Attributes you may choose to disclose may also include age, gender, number of vehicles owned and homeowner status.
Third Party Data. In some cases, we may combine Technical Data and any Provided Attributes with Third Party Data. “Third Party Data” includes information that we receive from third parties such as credit reporting agencies and Partners (defined below). Third Party Data may also include information we use to confirm or supplement validate the data you provide (e.g., phone number, Vehicle Identification Number, outstanding loan amount). Finally, our Advertising Partners may also provide us with information about your interaction with their advertised products and services (e.g., whether you purchase their products or services). We may combine the Technical Data, Provided Attributes and Third Party Data. Please note, we will only obtain credit reporting information with your consent and will not retain any Social Security number you provide.
Cookie and Similar Data. When you use this Site, we may use a “cookie” or other tracking technology to recognize you or your device. These technologies act as unique identifiers and allow us to tailor this Site to your specified interests and track your activity on this Site and across devices that you use. We may use this information to deliver offers and advertisements that we believe are relevant to your interests.
We use the data we collect from and about you through this Site primarily to connect you with Advertising Partners who can provide you with information about the products and services you are seeking. We generally do this using Technical Data and Provided Attributes, but in certain cases (e.g., insurance products) we may also use Third Party Data. For example, we may have an auto insurance Partner who is only licensed in certain states. We may use Technical Data or Provided Attributes to determine if you are a resident of one of those states. We refer to Advertising Partner requirements generally as “segmentation” and the alignment of consumer data and segments as “matching.”
We may also use the data we collect from and about you: (i) to respond to your requests (e.g., to receive white papers, email, phone calls or texts); (ii) to keep you informed of our products and services (and those of our Partners); (iii) to allow you to send messages through this Site; (iv) to improve our Sites and business; (v) to fulfill any purchase you make; and (vi) to use your data in an aggregated, non-specific format for analytic and demographic purposes. We use Technical Data to monitor this Site’s performance, analyze traffic patterns and usage, ensure that this Site and any transactions function properly, and gather demographic information about our user base as a whole. We may use automated decision-making in segmentation and matching.
In addition to the primary uses described in the “Data Use” section above (i.e., sharing your data with Advertising Partners and third parties for the purpose of providing you with information about the products and services you are seeking), we may share your data as follows: (i) with other Spero businesses; (ii) with service providers who assist us in compliance and verification activities (e.g., credit agencies), or provide services such as payment processing, IT, and data analysis; (iii) if you choose to send a message through, or to contribute to public areas of, this Site (e.g., message boards, blogs); and (iv) with a third party in the event of a sale or transfer of all or part of our business.
We may also disclose the data we collect from and about you to (i) comply with legal processes; (ii) to respond to lawful requests from authorities (including public and government authorities outside your country of residence, and including to meet national security or law enforcement requirements); (iii) to enforce our Terms of Service and this Privacy Notice; (iv) to protect our business, rights, privacy, safety, or property or that of others; and (v) as necessary under applicable law (including laws outside your country of residence).
We have taken certain physical, technical, and administrative steps to protect the data we collect from and about Site users. We use certain reasonable security measures to help protect your personal information from accidental loss, unauthorized use, alteration, or disclosure. However, no electronic data transmission or storage of information can be guaranteed to be 100% secure. Please note that we cannot ensure or warrant the security of any information you transmit to us. We are not responsible if you circumvent any privacy settings or security measures on our Websites. You use the Site and provide us with your data at your own risk. If we share data as detailed in this Privacy Notice with a third party we will use all reasonable efforts to ensure that they keep the information secure and that they only use the information consistent with the terms of this Privacy Notice.
We do not knowingly collect, use, share, or sell the personal information of individuals under the age of 16 and this Site is not directed to individuals under 16. If we are made aware that we have collected personal information from an individual under age 16, we will delete this information as soon as possible.
Choices and Access
Residents of certain states (e.g., California) may have additional rights (e.g., see “Information for California Consumers” below).
Marketing Emails. To stop receiving marketing emails from us, please click here and follow the instructions to unsubscribe. Even if you unsubscribe, we may still send administrative (i.e., non-marketing) messages. To unsubscribe from a third party’s communications, contact that third party directly or follow the instructions to unsubscribe in the applicable marketing email.
Phone Calls and Texts: To opt out of receiving telephone calls or texts from us, please click here and follow the instructions to be placed on our Do Not Call list.
Please note that we will not be able to remove your data from third parties’ databases, and you will need to contact them directly and/or use any available opt-out mechanisms.
In general, we will retain your data for as long as is needed to connect you with Advertising Partners who can provide you with information about the products and services you are seeking, which is typically 30-180 days. We will typically retain an archived copy of your data for six years as required or permitted by law for legal and compliance purposes.
Information for California Consumers
The California Consumer Privacy Act (“CCPA”) affords certain rights and protections to California residents with respect to their Personal Information. The CCPA defines “Personal Information” as “information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household.” This section describes (i) the categories and sources of Personal Information that Spero collects, sells or shares; (ii) the purpose for collection; (iii) the types of third parties to whom Spero discloses that information; and (iv) details about how California residents can exercise their rights under the CCPA.
Categories of Data Spero Collects in the Preceding 12 Months. Spero collects the following CCPA categories of data: (i) identifiers, such as a name, email address, telephone number, postal address, unique personal identifier, online identifier, IP address, account name, Social Security number, driver’s license number; (ii) personal identifiers under Cal. Civ. Code § 1798.80(e), such as insurance policy number, education, employment status, bank account information, credit card or debit card number, financial information, medical information, health insurance information; (iii) protected classification characteristics under California law, such as age, marital status, medical condition, gender, veteran or military status; (iv) commercial information, such as products or services obtained, or considered, or other purchasing or consuming histories or tendencies; (v) internet activity, such as browsing history and search history information; (vi) geo-location data; (vii) professional or employment information, such as consumer-reported current or past job history; and (viii) inferences drawn from some of the information above (e.g., email open rates and time).
Spero generally collects the above data as Technical Data or Provided Attributes. For example, Spero does not create user profiles to determine the gender, marital status or employment status of consumers. Spero may store aggregated data as segments based upon Technical Data and Provided Attributes. Spero receives each of those categories of data only as self-reported data from the consumer.
Sources of Data
Spero collects Technical Data and Provided Attributes from consumers who visit or engage with our Sites, our call centers or other Spero owned-properties (e.g., in response to emails from or on behalf of Spero) or becomes a customer that contracts with our insurance products.
Partners and Third Parties: Consumers who visit websites our Media Partners own may be redirected to our Sites. In some cases, we may gather data directly from Media Partner websites, or Media Partners or other third parties may post data to our Sites or otherwise transfer data to us. This may occur via display ads, click listings, inquiry forms or telephonic transfers from Media Partner call centers. Our Advertising Partners may also provide us with data.
Service Providers. Spero engages service providers to perform a variety of functions (e.g., verifying consumer consent, validating email addresses or phone numbers).
Authorization. We require all parties from whom we receive Personal Information, whether they are Partners, service providers or other third parties, to represent and warrant to us that they have appropriately obtained the Personal Information provided to us and have the authority to share the Personal Information with us.
Purpose for Personal Information Collection. As described above in “Data Use,” Spero primarily uses the Personal Information it collects to connect consumers with Advertising Partners who can provide information about the products and services those consumers are seeking.
Categories of Third Parties with Whom Spero Has Disclosed Personal Information in the Preceding 12 Months. In addition to sharing data for the primary use described in “Data Sharing,” we may share identifiers and internet activity (e.g., name, email address, telephone number, browsing history) with other Spero businesses, service providers, and third party websites.
Spero may also disclose or sell Technical Data, Provided Attributes and Third Party Data to other Spero businesses or with a third party in the event of a sale or transfer of all or part of our business. Additionally, Spero may disclose or sell Technical Data, Provided Attributes, and Third Party Data (e.g., identifiers, personal identifiers, protected classification information, geo-location data, and inferences) with service providers who assist us in compliance and verification activities (e.g., credit agencies), or provide services such as payment processing, IT, and data analysis information.
Categories of Personal Information Disclosed or Sold. As described above in “Data Use” and “Data Sharing,” Spero may disclose or sell Technical Data, Provided Attributes and Third Party Data, including identifiers, internet activity, personal identifiers, and protected classification characteristics (e.g., name, email address, telephone number, browsing history, education, credit information, veteran or military status, browsing history, geo-location data) to Advertising Partners who can provide the consumer with information about the products and services they are seeking. We may receive a fee for the transfer of that data or when the consumer purchases a product or service. Spero does not knowingly collect, disclose, or sell personal information from individuals under the age of 16.
CCPA Rights. The CCPA affords certain rights and protections to California residents including: (i) the right to request that we delete any “Personal Information” that we have collected from you (“Right to Delete”); (ii) the right to request that we disclose the categories and/or specific pieces of “Personal Information” collected, used, disclosed, and sold (“Right to Know”); and (iii) the right to direct us not to sell your “Personal Information” (“Right to Opt-Out”).
California residents who would like to submit a Request to Know, Delete, or Opt-Out should follow the links below.
You may also submit a Request to opt-Out by calling our toll-free number (877) 450-4880 or going to our Opt-Out Form.
Verifying Your Identity. Consumers who interact with our Sites are not required to set up an account, to register, or to validate their Personal Information, and Spero may maintain an ongoing relationship with consumers who provide their Personal Information. Because of these factors, Spero is able to reasonably verify the identity of any consumer based on the information provided through our Sites, but not through our Third Party Sites or through a submitted Third Party request. Therefore, Spero cannot honor Requests through Third Parties. Instead, Spero can provide in response to such requests a description of Spero’s business practices regarding its handling of Personal Information, including a description of the categories of Personal Information collected, maintained, and sold.
As a California consumer, you have the right not to receive discriminatory treatment by Spero for the exercise of your privacy rights under the CCPA. If you provide authority to another person to submit a request on your behalf, or are a person submitting a request on behalf of another person, please notate “on behalf of another person”. Spero will review the request and may contact you for additional information to validate your identity, to show proper authorization to make a request on behalf of another, and/or to confirm that the authorized agent is properly registered with the Secretary of State to do business in California or otherwise legally authorized.
Changes to this Privacy Notice
We may amend this Privacy Notice from time to time. When we do, we will post an updated version of the Privacy Notice and revise the “LAST UPDATED” date at the top. We will provide appropriate notice to you if we change the Privacy Notice in any material way. Using this Site after we make any changes means you accept those changes and the revised Privacy Notice.
For purposes of this Privacy Notice, “you” or “your” means the person(s) using this Site or the products or services offered through this Site. “Spero,” “us,” or “we” includes (but is not limited to) Spero Insurance Agency is the party responsible for this Privacy Notice and compliance with it.
You have the right to submit feedback about this Privacy Notice, or the practices described in it, to the applicable supervisory authority in your jurisdiction of residence. For U.S. residents this includes the Federal Trade Commission and your state Attorney General.
If you have any questions about this Privacy Notice you may: (1) submit an inquiry at the Contact Us page, (2) email at email@example.com, (3) call us at 877-450-4880, or (4) mail at:
Privacy Notice Questions
c/o Spero Insurance Agency [Legal Department]
899 Northgate Drive, Ste 301
San Rafael, CA 94903