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OPENEYES PRIVACY POLICY

Last updated on August 2025

This Privacy Notice describes the information collection, use, retention and sharing practices of OpenEyes Insurance Agency, Inc. (“OpenEyes”, “we”, “us”, “our”) and its affiliates and subsidiaries when you interact with us through our website, www.openeyes.com (the “Website”). For information regarding our collection and use of personal information in connection with our risk prevention system, please see the OpenEyes Device Privacy Notice.

As used in this Privacy Notice, “personal information” means information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a natural person (i.e. data subject). Personal information includes “personal data”, as such term is defined under applicable data privacy laws.

OUR ROLE IN DATA PROCESSING

To the extent the General Data Protection Regulation (“GDPR”), Regulation (EU) 2016/679, and the UK Data Protection Act 2018 (“DPA”) apply (collectively referred to in this Privacy Notice as “EU or UK data protection laws”), the entity responsible for the collection and use (processing) of your personal data is OpenEyes Insurance Agency, Inc., the data controller. You may contact OpenEyes by emailing support@openeyes.com.

PERSONAL INFORMATION WE COLLECT, WHY AND FOR HOW LONG

We collect personal information as you engage with our Services, including when you:

  • Contact us or choose “Get a quote”. When you contact us or select the “Get a Quote” form, we collect, from you, your personal identifiers (name and email address), professional or employment-related information (job title, company, fleet size), and any additional information you choose to include in your message. We use this information to respond to your questions or inquiries and to troubleshoot where necessary. To the extent the EU or UK data protection laws apply, the legal basis for the processing of this information is that it is necessary for the performance of the service requested by you. We retain this information for ninety (90) days.
  • Schedule an appointment. When you schedule an appointment, we collect, from you, your personal identifiers (name, email address, telephone number, city/state), professional or employment-related information (job title, company), and any additional information you choose to include in your message. We use this information to communicate with you and to schedule the appointment. We retain this information for twelve (12) months.
  • Book a demo. When you book a demo, we collect, from you, your personal identifiers (name, email address, professional or employment-related information (job title, company, DOT, insurance agency), and any additional information you choose to include in your message. We use this information to communicate with you and to schedule the demo. We retain this information for twelve (12) months.
  • Sign up for our newsletter. When you subscribe to our newsletter, we collect, from you, your personal identifiers (name, email address). We use this information to send you updates about our products and services. To the extent the EU or UK data protection laws apply, the legal basis for this processing is your consent. You may revoke your consent at any time with effect moving forward by clicking the “unsubscribe” link included within each email we send to you. However, we will continue to send you service-related messages. We, through our service provider, use tracking pixels to determine whether you open emails, the time of opening, information about the device you use (including IP address), whether you interacted with the email, the topic of the email, whether it was delivered, sender and recipient addresses. We use this information to: (1) measure the effectiveness of our communications and make them more attractive, particularly by improving email subject lines; (2) limit the frequency of sending or stop it, ensuring emails continue to reach their recipients; (3) detect and analyze suspected fraud; (4) personalize communications based on your interest in received emails and interaction with them. This personalization includes: adapting message content, adjusting sending frequency or communication channel and/or optimizing campaigns based on reactions (e.g., adjusting email subject lines. You can avoid downloading the pixel by rejecting the download of images in the email.
  • Interact with us on social media. Interact with us on social media. When you interact with our social media pages on social networking websites, such as LinkedIn, and YouTube (each a “Social Media Page” and collectively, “Social Media Pages”), we collect basic engagement metrics and use it to tailor content and marketing and use it to improve user experience as set forth in this section. Please note that we do not control the use or storage of the information that you have posted to any social networking websites. This information is collected and processed by the social networking websites for their own purposes, including marketing. For more information on how LinkedIn, and YouTube use your personal information, please see LinkedIn’s Privacy Policy and YouTube’s Privacy Policy.

    LinkedIn and YouTube (the “Social Networks”) process personal data in the USA where the laws may be less protective than in your country of residence. For example, in accordance with U.S. laws, in certain circumstances, courts, law enforcement agencies, regulatory agencies, or security authorities in other countries may be entitled to access your personal data.
    • Social Media Pages. When interacting with our Social Media Pages, we collect, from you, your personal identifiers (first and last name) and visual information (photograph (i.e., profile picture)), as well as any information that you provide when interacting with our Social Media Pages (e.g., commenting, sharing, and rating). We use this information to advertise our products, for events and invitations, and to communicate with users via the contribution and comment function. To the extent the EU or UK data protection laws apply, the legal basis for the processing is our legitimate interest in advertising our products via our Social Media Pages and communicating with users, customers, and interested parties. Because our Social Media Pages are publicly accessible, when you use them to interact with other users, for example by posting, leaving comments or liking or sharing posts, any personal information that you post in them or provide when registering can be viewed by others or used by them as they see fit. The content posted on our Social Media Pages or other public areas of social networking websites can be deleted in the same way as other content that you have created. If at any time you want content posted to be deleted, please email your request to us at support@openeyes.com.
    • Community Management. We collect, from you, your contact, including “likes”, shares, messages and other interactions with the content, in order to analyze and evaluate how our content is perceived, to learn from it, and to improve our public relations efforts. To the extent the EU and UK data protection laws apply, the legal basis for analyzing your content is our legitimate interest in organizing, facilitating, and optimizing communication with our users and the general public. If you object to this processing of your personal information and believe you have an overriding interest, you can submit your objection via email to support@openeyes.com.
    • Page Insights. When you visit our Social Media Page, the applicable Social Network records your IP address and other information about your usage behavior on our Social Media Page. The Social Network collects this information through trackers in the browser of your device or via the advertising ID (IDFA from Apple or GAID from Google), when you open the Social Network app through your mobile device (e.g., smartphone or tablet). The Social Network uses this information to provide us with statistical evaluations of the use of our Social Media Page. We receive this information directly from Social Network, in the form of aggregated data and anonymous statistics regarding certain data points, such as: age; gender; city/country; device; inquiries from fans about other Social Media Pages; region and language settings of the users; proportion of men and women; the number of people reached; clicks on posts, “likes” and reactions; comments and shared content; and total video views. We use this information to analyze and improve the advertising campaigns we conduct through our Social Media Pages. We do not collect or process any other personal information in connection with Social Network “Page Insights” function.

      To the extent the EU and UK data protection laws apply, we are joint controllers with the Social Network for this processing. For the purpose of the EU and UK data protection laws, the legal basis for this processing is our legitimate interest in statistical evaluation of users on our Social Media Page for the improvement and adjustment of our advertising measures based on the information collected. If you object to this processing of your personal information and believe you have an overriding interest, you can submit your objection via email to support@openeyes.com.

      We do not retain this information independently. For information on data protection and the storage period on the Social Network in relation to its Insights function, see the Social Network privacy policy linked above. It has been contractually agreed with the Social Network that the Social Network is responsible for providing you with information about the processing for Page Insights.

    • Information Processed Solely by Social Networks. We do not know how the Social Networks use personal information for their own purposes, how long the personal information is stored on the Social Networks or whether the Social Networks’ data is passed on to third parties. If you are currently logged in to a Social Network as a user, the Social Network automatically collects, through trackers on your device, your Social Network ID or a link between the Social Network ID and the advertising ID (IDFA from Apple or GAID from Google) when you open the Social Network app through your mobile device (e.g., smartphone or tablet). This enables the Social Network to understand that you have visited our Social Media Page along with other social media pages that you have clicked on, whether you clicked on Social Network buttons integrated into websites that partner with the Social Network, and other online interactions that report user data to the Social Network. Based on this data, content or advertising tailored to you can be offered. You can find more information about the personal information collected by Social Networks, how it is used and how long it is stored by visiting the Social Network’s privacy policies, linked above.
  • Interact with the Website. In addition to the personal information you provide directly to us, in the EU or UK: if you consent to the deployment of cookies and other technologies, we will also collect information from you automatically as you use the Website via cookies, pixels, web beacons, and similar tracking technologies. To the extent the EU or UK data protection laws apply to placement of cookies on the Website, the legal basis for this processing is your consent. You may withdraw your consent at any time with effect moving forward by adjusting your Cookie Preferences Link. To the extent the EU or UK data protection laws apply, the legal basis for the placement and access of strictly necessary cookies is the performance of a contract. These cookies are necessary to provide the Website to you.

    We use essential, performance, marketing, and analytics cookies to collect your usage, device, and location information (determined through your IP address) when you interact with the Website. We use this information to: (i) enhance user experience on the Website; (ii) conduct analytics to improve the Website; (iii) prevent fraudulent use of the Website and detect unlawful activity; (iv) diagnosis and repair Website errors, and, in cases of abuse, track and mitigate the abuse; and (v) deliver targeted advertisements. Analytics and advertising cookies may be considered a sale or sharing or disclosure for targeted advertising under the Texas Data Privacy and Security Act. To opt out (or review your consent), please visit your Cookie Preferences Link.

    Particular third-party analytics/advertising cookies to note on our Website include the following:

    • Google Analytics. We use Google Analytics to collect information on your use of the Website for its improvement. To collect this information, Google Analytics installs cookies on your browser or reads cookies that are already there (for more information about how Google collects and uses the information see here). Google Analytics also receives information about you from applications you have downloaded or services that you use that partner with Google. Google’s ability to use and share information collected by Google Analytics about your visits to our Website or to another application which partners with Google is restricted by the Google Analytics Terms of Use and Privacy Policy. To prevent your data from being used by Google Analytics, you can download the Google Analytics opt-out browser add-on, which can be accessed here. You can also adjust your Ad Settings or change settings in your Google My Activity if you are signed into your Google Account. To opt out, please visit your Cookie Preferences Link.
    • DoubleClick. We utilize DoubleClick by Google to serve ads based on a user’s prior visits to our Website. Each visitor to our Website receives a different cookie, and the information collected by the cookie is used to generate conversion statistics and allows us to see the total number of individuals who clicked on our ads. DoubleClick enables Google and its partners to serve ads to you based on your visits to our Website in addition to other websites on the Internet. Please review Google’s Privacy Policy for additional information on how Google uses the information collected. To opt out of targeted advertising by Google and this sharing, you can go to Google’s Ad Settings, or you can install the DoubleClick opt-out browser plugin. To opt out, please visit your Cookie Preferences Link.
  • Aggregate and anonymize data. We deidentify and/or aggregate the data we collect and use and share it, in deidentified and/or aggregated form, for benchmarking purposes , advertising, and internal analytics. We maintain and use this data in deidentified form. We will not attempt to reidentify the data, unless it is necessary to determine whether our deidentification processes satisfy applicable data protection laws.

OpenEyes will also use the personal information we collect as described in this section to comply with the law, to efficiently maintain our business, and for other limited circumstances as described in HOW WE SHARE YOUR PERSONAL INFORMATION.

DATA RETENTION

Unless otherwise stated in this Privacy Notice, we retain your personal information (i) for as long you maintain an account with us, (ii) until we receive a valid request to delete the information, in which case we will delete or anonymize the information within thirty (30) days after receiving the request (subject to certain exceptions), (iii) until we no longer need the information to fulfill the purposes for which we collected it, or (iv) until the information is no longer needed for a service provider or contractor’s operational purpose(s).

We use the following criteria to determine whether it remains reasonably necessary to retain your personal information for such purposes or a service provider or contractor’s operational purpose(s): (i) whether there is a retention period required by statute or regulations; (ii) the existence of actual or threatened litigation for which we are required to preserve the information; (iii) the statutes of limitations for potential legal claims; and (iv) generally accepted best practices in our industry, including in relation to the safety and security of our properties and assets. When we determine that it is no longer reasonably necessary to retain your personal information for one or more disclosed operational purposes based on the above criteria, we will delete or anonymize your personal information.

HOW WE SHARE YOUR PERSONAL INFORMATION

A. General Sharing
OpenEyes shares personal information as described in the PERSONAL DATA WE COLLECT, WHY AND FOR HOW LONG section, and generally in the following instances:

  • Within OpenEyes. We share your personal information within OpenEyes for the legitimate business purposes of efficiently and effectively providing the Services, such as accounting and customer service support. Access to your personal information is limited to those on a need-to-know basis. To the extent the EU or UK data protection laws apply, the legal basis for this is our legitimate interest in providing the Services more efficiently.
  • In the event of a corporate reorganization. In the event that we enter into, or intend to enter into, a transaction that alters the structure of our business, such as a reorganization, merger, acquisition, sale, joint venture, assignment, consolidation, transfer, change of control, or other disposition of all or any portion of our business, assets or stock, we would share personal information with third parties, including the buyer or target (and their agents and advisors) for the purpose of facilitating and completing the transaction. We will also share personal information with third parties if we undergo bankruptcy or liquidation, in the course of such proceedings. To the extent the EU or UK data protection laws apply, the legal basis for this is our legitimate interest in carrying out our business operations or, if required by law, consent.
  • For legal purposes. We share personal information where we are legally required to do so, such as in response to court orders, subpoenas, governmental/regulatory bodies, law enforcement or legal process, including for national security purposes. We may share your information with our legal advisors or auditors to establish, protect, or exercise our legal rights or as required to enforce our terms of service or other contracts or to defend against legal claims or demands. We also share this information with third parties as necessary to: detect, investigate, prevent, or take action against illegal activities, fraud, or situations involving potential threats to the rights, property, or personal safety of any person; to comply with the requirements of any applicable law; or to comply with our legal obligations. To the extent the EU or UK data protection laws apply, the legal basis for this processing is compliance with the law or our legitimate interest in complying with non-EU data protection laws to which we are subject.
  • With your consent. Apart from the reasons identified above, we may request your permission to share your personal information for a specific purpose. We will notify you and request consent before you provide the personal information or before the personal information you have already provided is shared for such purpose. You may revoke your consent at any time with effect moving forward and may do so by contacting us via email at support@openeyes-insurance.com.

B. Sharing in the Last Twelve (12) Months
For a business purpose. In the preceding twelve (12) months, OpenEyes has disclosed the following categories of personal information for a business purpose to the following categories of third parties:

  • We have disclosed your personal information to service providers that assist us in providing the Website. These service providers assist us with the following: information technology (“IT”) support; website hosting; cloud storage; data analysis; customer service; email delivery; marketing; and similar services. 
  • We have disclosed your internet or other electronic network activity information collected by cookies to our IT support to detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, and to identify and repair the Website and platform errors. 
  • We have disclosed your internet or other electronic network activity information collected by cookies to our IT support to update, improve, and maintain the Website. 

C. Sale of Personal Information
In the preceding twelve (12) months, OpenEyes has shared your internet or other electronic network activity information collected via cookies and other tracking technologies with our data analytics providers and ad networks as described in PERSONAL INFORMATION WE COLLECT, WHY AND FOR HOW LONG to provide targeted advertising. Such sharing may be deemed a sale under the Texas Data Privacy and Security Act. To opt out of this sharing or the processing of your personal information for purposes of targeted advertising, please visit your Cookie Preferences Link. 

YOUR INFORMATION CHOICES

You have the following choices with respect to your personal information: 

  • Correct or View Your Information. You may access your account to correct or view certain personal information you have provided to us, and which is associated with your account.
  • Opt Out of Google Analytics. To prevent your personal information from being used by Google Analytics, you can download the Google Analytics opt-out browser, which can be accessed here.
  • Opt Out of Advertising Cookies. In addition to opting out of certain trackers in your Cookie Preferences Link, all session cookies are temporary and expire after you close your web browser. Persistent cookies can be removed by following your web browser’s directions. To find out how to see what cookies have been set on your computer or device, and how to reject and delete the cookies, please visit: https://www.aboutcookies.org/. Please note that each web browser is different. To find information relating to your browser, visit the browser developer’s website and mobile application. If you reset your web browser to refuse all cookies or to indicate when a cookie is being sent, some features of our website may not function properly. If you choose to opt out, we will place an “opt-out cookie” on your device. The “opt-out cookie” is browser specific and device specific and only lasts until cookies are cleared from your browser or device. The opt-out cookie will not work for essential cookies. If the cookie is removed or deleted, if you upgrade your browser or if you visit us from a different computer, you will need to return and update your preferences. By clicking on the “Opt-Out” links below, you will be directed to the respective third-party website where your computer will be scanned to determine who maintains cookies on you. At that time, you can either choose to opt out of all targeted advertising or you can choose to opt out of targeted advertising by selecting individual companies who maintain a cookie on your machine. Our use of third-party marketing and analytics cookies is considered a sale/sharing under certain state privacy laws and is also considered to be what is known as interest-based advertising (IBA). To opt out of the sale/sharing through cookies and IBA across various platforms, please visit the Digital Advertising Alliance’s YourAdChoices program tools (Your Ad Choices) or visit one of the links below.
    • Network Advertising Initiative (NAI) Opt-Out: https://www.networkadvertising.org/managing/opt_out.asp
    • Digital Advertising Alliance (DAA) Opt-Out: https://optout.aboutads.info
    • European Union (EU) /European Economic Area (EEA) Opt-Out: http://www.youronlinechoices.eu
    • In general, you can also disable cookies by setting your browser to refuse cookies or indicate when a cookie is being sent.
  • Opt Out of Email Tracking. You can disable this tracking by blocking automatic loading of images in your email.  
  • Opt Out of Marketing Communications. You may opt out of receiving marketing emails from us by clicking the “unsubscribe” link provided at the bottom of each email we send. Please note that we will continue to send you notifications necessary to the services. 
YOUR DATA SUBJECT RIGHTS (EU & UK)

Individuals in the European Union and United Kingdom are entitled to certain rights under General Data Protection Regulation (“GDPR”) and the Data Protection Act 2018 (“DPA”), respectively. To the extent these laws apply to our processing of your personal data, you are entitled to the following rights:

  • Right to access: For any of the processing described above, you have the right to ask us for copies of your personal data. However, this right has some exemptions, which means you may not always receive all the personal data we process. Applicable exemptions may include the management information exemption (data that we process for management forecasting or management planning about a business or other activity), or certain instances of ongoing or prior negotiations with the requestor, among others.
  • Right to rectification: For any of the processing described above, you have the right to ask us to rectify personal data you think is inaccurate or incomplete. 
  • Right to erasure: You have the right to ask us to erase your personal data except when the legal basis for the processing is to fulfill our legal obligations or to carry out a task in the public’s interest. 
  • Right to restrict processing: For any of the processing described above, if you believe that your personal information is inaccurate, that our processing is unlawful, or that we do not need your personal information for a specific purpose, you have the right to request that we restrict the processing of this personal information. You also have the possibility to request that we stop processing your personal information while we assess your request. If you object to our processing (per your right to object below), you may also request us to restrict processing of your personal data while we make our assessment.
  • Right to object to processing: You have the right to object to our processing of your personal data when the legal basis for the processing is pursuant to our legitimate interests by referencing your personal circumstances. This may apply, for example to processing in connection with our social media pages.
  • Right to data portability: You have the right to ask that we transfer the personal information you gave us from one organization to another or give it to you. However, this right only applies when: (i) you have provided your personal information to us; (ii) the legal basis for the processing is your consent or for the performance of a contract; and (iii) the processing is carried out by automated means. You can invoke this right for the processing of the information we automatically collect from you as you interact with the Website via cookies, pixels, and similar tracking technologies. This may also apply in connection with your account information. 
  • Right to lodge a complaint: If you are located in the UK, you have the right to lodge a complaint with the Information Commissioner’s Office at: https://ico.org.uk/make-a-complaint/data-protection-complaints/data-protection-complaints/y or accessicoinformation@ico.org.uk at their helpline on 0303 123 1113. If you are located in the EU, you have the right to lodge a complaint with the relevant Supervisory Authority.

To exercise these rights, please email support@openeyes.com.

RIGHTS OF TEXAS RESIDENTS

The Texas Data Privacy and Security Act (“TDPSA”) entitles Texas residents to certain rights. To the extent the TDPSA applies to our processing of your personal information, you are entitled to the following rights: 

  • Right to Access/Know. You have the right to request what personal information we have collected, used, disclosed, and sold about you, subject to certain exceptions.  
  • Right to Deletion. You have the right to request the deletion of your personal information that we collect or maintain, subject to certain exceptions. For example, if we are required by law to retain the information that you are asking to be deleted, we would not be able to delete the information until we are legally permitted to delete it. 
  • Right to Correct. You have the right to correct inaccurate personal information that we collect or maintain. 
  • Right to Opt Out of Sale. You have the right to opt out of the sale of your personal information to third parties. 
  • Right to Opt Out of Targeted Advertising. You have the right to opt out of the processing of your personal information for purposes of targeted advertising. To opt out of targeted advertising, please visit your Cookie Preferences Link. 
  • Right to Opt Out of Profiling. You have the right to opt out of profiling (i.e. automated processing of personal information) in furtherance of decisions that produce legal or similarly significant effects. We do not engage in such processing. 
  • Right to Data Portability. You have the right to request that we transfer your personal information to another organization or give it to you.
  • Right to Non-Discrimination. You have the right to not receive discriminatory treatment in the processing of your personal information if you choose to exercise your privacy rights under the TDPSA. Such discriminatory treatment may include but is not limited to: (i) the denial of goods or services, (ii) being charged a different price or rate, or (iii) receiving a different level of quality in goods or services. 
  • Right to Appeal. You have the right to appeal an action taken (or not taken) by OpenEyes in response to your request. We will inform you of any action we have taken in response to your request without delay and, in any event, within forty-five (45) days after we receive your request. To exercise your right to appeal, you may submit your appeal by emailing support@openeyes.com. If you are a concerned with our response as a result of your appeal, you may submit a complaint to the Texas Attorney General here. 

If you are a Texas resident and wish to exercise your privacy rights, you may submit your request by emailing support@openeyes.com, calling toll-free 866-944-8235. To opt out of the processing of your personal information for purposes of targeted advertising, please visit your Cookie Preferences Link. If the browser or extension that you (or your authorized agent) are using supports Global Privacy Control (GPC) (see here for more information), you may utilize the GPC opt out preference signal to instruct us to not sell or share any of your personal information collected online. The GPC opt out preference signal will apply to the device, platform, or browser in which you utilize it. You can utilize the opt out preference signal by turning on the signal in your device, platform, or browser settings.  Please note that you must opt out of each device and each browser. 

For requests submitted via telephone, you must provide us with sufficient information that allows us to reasonably verify you are the person about whom we collected the personal information and describe your request with sufficient detail to allow us to properly evaluate and respond to it. In doing so, we will take steps to verify your request by matching information provided by you with the information we have in our records. If we are not able to verify your identity for access and deletion requests with the information provided, we may ask you for additional pieces of information. 

Only you, or a person that you authorize to act on your behalf may make a request related to your personal information. If you are an authorized agent making a request on behalf of another individual, you must provide us with signed documentation that you are authorized to act on behalf of that individual.

NEVADA RESIDENTS

If you are a consumer in the State of Nevada, you may request to opt-out of the current or future sale of your personal information. We do not currently sell any of your personal information under Nevada law, nor do we plan to do so in the future. However, you can submit a request to opt-out of future sales by contacting us at support@openeyes.com regarding the sale of such information. Please include “Opt-Out Request Under Nevada Law” in the subject line of your message.

DO NOT TRACK

We do not respond to Do Not Track requests. Do Not Track is a preference you can set in your web browser to inform websites and mobile applications that you do not want to be tracked. You can enable or disable Do Not Track by visiting the Preferences or Settings page of your web browser. 

INFORMATION SECURITY

We implement appropriate technical and organizational security measures, such as access controls and encryption, to protect the personal information that we collect and maintain from unauthorized access, destruction, use, modification, or disclosure. However, no security measure or modality of data transmission is 100% secure, and we are unable to guarantee the absolute security of the personal information we have collected from you. 

CHILDREN’S PRIVACY

The Website is not intended for anyone under the age of eighteen (18). We do not knowingly collect the personal information of anyone under the age of eighteen (18). If we learn that we have collected or received personal information from individuals under the age of eighteen (18), we will delete the personal information. If you believe we have personal information on individuals under the age of eighteen (18), please contact us at the contact information provided below.

CHANGES TO THIS PRIVACY NOTICE

We may amend this Privacy Notice in our sole discretion at any time. If we do, we will post the changes to this page and will indicate the date the changes go into effect. We encourage you to review our Privacy Notice to stay informed. If we make changes that materially affect your privacy rights, we will notify you by prominent posting on the Website and/or via email, and obtain your consent, if required.

CONTACT US

If you have any questions about this Privacy Notice or need to access this Privacy Notice in an alternative format due to having a disability, please contact us by email at support@openeyes.com.