1. INTRODUCTION
Thank you for using AAA MWG’s services. AAA MWG understands that when you use our services, you are trusting AAA MWG with your Personal Information. The security of your Personal Information is very important and AAA MWG is committed to protecting your privacy. This Privacy Policy describes the Personal Information AAA MWG may collect and why this information is collected. It also explains the options you have regarding AAA MWG’s use of your Personal Information and how you can exercise your privacy rights regarding this information.
2. SCOPE
This Privacy Policy applies to the operations of: 1) American Automobile Association of NorthernCalifornia, Nevada & Utah, AAA Arizona, Inc., and AAA Mountain West, Inc.; and 2) affiliated companies such as AAA Smart Home and A3 Smart Home1, A3 Labs LLC, and ProtectMyID2 (collectively referred to as the “AAA MWG”, “AAA Companies”, or “Company”).
This Privacy Policy covers AAA MWG’s websites and their subdomains, all portals, applications, products, services, events, and interactive features, or other services AAA MWG provides (collectively, the “Website” or “Site”). This Privacy Policy also applies to Personal Information AAA MWG collects from you offline such as Personal Information collected at branches, via e-mail, via phone, or by other means.
Capitalized terms used but not otherwise defined in this policy should be read to have the same meaning as how the term is defined in the California Consumer Privacy Act (“CCPA”), unless the context requires otherwise.
In some cases, as described in this Privacy Policy, AAA MWG may collect, access, or receive Personal Information about you from third-party sources, including cases in which AAA MWG acts as their service provider. In these cases, the privacy policy or policies of the third-party sources may also apply to your Personal Information and such third parties may be the responsible party for addressing your requests in connection with your consumer privacy rights.
3. CONSENT
In order to provide you with AAA MWG’s products and services (collectively, the “Services”), AAA MWG may collect certain Personal Information from you and your devices. By using the Sites and/or Services or otherwise engaging with AAA MWG in any manner, you are consenting to the collection, use, and disclosure of your Personal Information in accordance with this Privacy Policy. If you do not consent to this Privacy Policy, please do not use AAA MWG’s Sites and/or Services.
4. WHAT INFORMATION DOES AAA MWG COLLECT?
AAA MWG may collect the following categories of Personal Information from you and/or about you when you use AAA MWG’s Sites and/or Services. The categories of Personal Information that AAA MWG has collected, disclosed for a business or commercial purpose, or sold over the past twelve (12) months are outlined below.
4.1 Information Provided to AAA MWG
AAA MWG may collect your Personal Information directly from you when you apply for a Membership, Insurance, purchase and/or subscribe to Services, or otherwise provide Personal Information directly to AAA MWG. Here are some examples of Personal Information that AAA MWG may collect directly from you:
Identifying Personal Information
- AAA MWG Membership Number
- Full Name;
- Contact Information (email address, telephone number, mailing address etc.);
- Account Username and Password;
- Age and Date of Birth;
- Social Security Number;
- Citizenship Status;
- Vehicle Information (year,make,model, and Vehicle Identification Number (VIN), license plate information).
- Driver’s license information (front and back of your driver’s license card). The driver’s license contains your first and last name, driver’s license number, birth date, address, signature, photograph, issuing state, physical characteristics (height, weight, eye color, etc.), and organ donor status, if applicable.
- Proof of Car Insurance (your car insurance card) – Your car insurance card contains your policy number, insured's name and contact information, vehicle information: year, make, and Vehicle Identification Number (VIN), license plate number, insurance coverage details, premium amount, credit/debit card details including card number, expiration date, and cardholder’s name.
- Geolocation (such as when requesting roadside assistance or searching for nearby gas stations on AAA MWG’s app); for nearby gas stations on AAA MWG’s app);
- Financial Information (such as billing name and address, bank and bank account information including routing and account numbers, credit card information, and credit history);
- Biometric Information (information about your physical characteristics that helps AAA MWG identify you, including, but not limited to, facial recognition, voice recognition, and fingerprints)
- Property information including (square footage of the property, year built, number of stories, exterior wall finish, foundation type, garage carport details, property features and condition, renovations, quality grade, safety and security, mortgage information).
- Health Information (such as height and weight, medical history, pre-existing health conditions, medication and treatment, lifestyle habits, drug use).
- Commercial information (such as annual income, immediate cash needs, needs at death).
4.2 Information AAA MWG Collects Automatically
AAA MWG may collect your Personal Information indirectly when you visit AAA MWG’s Site. This information may be collected via tracking technologies, including, but not limited to, cookies, log files, and web beacons. The information automatically collected may include the following:
- IP Address(es);
- Device Information (such as browser type and operating system);
- Browsing history;
- Date and Time of Visit(s);
- Information Regarding Interactions with the Site (including the pages accessed and links clicked);
- Inferences About Interests and Preferences (based on analysis of browsing habits and other predictive techniques); and
- Commercial Information (including records of products and services viewed or purchased).
4.3 Information AAA MWG Collects From Third Parties
AAA MWG may collect and/or may have collected Personal Information about you from third parties in the past twelve (12) months. For example, when you visit AAA MWG’s Site or use Services, AAA MWG’s third-party service providers may collect information about your visit and share that information with AAA MWG. The information that AAA MWG may collect about you from third parties may include the Personal Information listed above.
This Personal Information may be collected when you visit AAA MWG’s Site. In addition, you may also affirmatively authorize or direct third parties to provide AAA MWG with Personal Information through the use of different technologies, including, but not limited to the following:
- Cookies – Small files stored on your device from the website you are visiting. This includes session cookies which are temporary cookies that are erased when you close your browser and persistent cookies which are used to customize your experience on a website and remain on your device until you delete them. For more information about cookies, including how to manage and delete cookies on your browser, please review AAA MWG’s Cookie Statement.
- Third-Party Software Development Kits (“SDKs”) - SDKs may be used by some of AAA MWG’s applications to increase functionality.
- Action Tags, Beacons, or Pixels - These are tiny images that may be embedded within web pages and emails that give AAA MWG information about your device and Site activity. AAA MWG may use these to track the effectiveness of advertisements on AAA MWG’s Site and advertisements placed on AAA’s behalf by third party sites as well.
AAA MWG may use Cookies, SDKs, Action Tags, Beacons, Pixels, and related technologies to improve your browsing experience, targeted marketing, and analyze site performance and traffic. By continuing to use the Sites, you consent to AAA MWG’s use of these technologies, as explained in this Privacy Policy and AAA MWG’s Cookie Statement.
5. HOW DOES AAA MWG USE YOUR PERSONAL INFORMATION?
AAA MWG may use your Personal Information (including the categories of Personal Information described above) and Site and/or Services data (collectively, the “Collected Information”) for the following purposes:
5.1 Membership Application and Renewal
When you apply to become a Member, AAA MWG collects your Personal Information to process your application. This information may be used to maintain and renew your Membership, subscription, or account as a Member.
5.2 Providing You With Services
AAA MWG may use your Personal Information to provide you with various services, such as:
- To provide you with AAA MWG’s Services and other Member benefits, including 24/7 Member support through the Member support team as described in Section 18 (How to Contact AAA) below.
- Facilitating reservations, billing, account management, account maintenance, and any of AAA MWG’s reward and recognition programs you may choose to join.
- To provide you with AAA MWG’s Site’s features, such as when you grant AAA MWG access to certain information on your device (such as geo-location) when you request certain Services.
5.3 Communicating With You and Sending You Materials
AAA MWG may use your Personal Information to contact you and to respond to your requests. AAA MWG may also use your Personal Information to communicate with you as needed, including by email, mail, phone call, mobile alerts, and SMS text messaging. The purpose(s) for the communication(s) may include, but is not limited to:
- Upcoming travel notifications;
- Notifications Regarding Changes To Branch Locations and/or Agents;
- Providing and Improving AAA MWG’s Customer Service;
- Administrative Information (e.g., information relating to changes to AAA MWG’s terms, conditions, and policies);
- AAA MWG may also use your collected Personal Information to maintain and improve AAA MWG’s Services (for example, sending emails to solicit your feedback and to enroll you in AAA’s promotional email programs); and
- Responding to your request for Services (e.g., responding to your request for an insurance quote or other inquiries).
Mobile opt-in data will not be shared with any third parties or affiliates. Sharing excludes text messaging originator opt-in data and consent.
5.4 Marketing
AAA MWG may, as permitted by law, use your Personal Information to market products and services on AAA MWG’s behalf, or on behalf of the AAA MWG companies, including subsidiaries, partners, and/or other third parties.
Should you no longer wish to receive these marketing or promotional communications, you may opt out as described in Section 12 (The Right to Opt-Out From Marketing) below.
5.5 Conducting and Growing AAA MWG’s Business
AAA MWG may use your Personal Information for one or more of the following business purposes:
- To conduct data analysis;
- To perform audits;
- To control risk;
- To detect and prevent fraud;
- To comply with legal obligations
- To develop new products and services;
- Maintain existing Services;
- Identify usage trends;
- Determine the Effectiveness of Marketing Campaigns and Promotions; and
- Operate and Expand AAA MWG’s Business Activities.
AAA MWG may also use aggregated and/or de-identified data, which does not identify you individually, for our business purposes, which may include:
- Offering products or services;
- Research;
- Marketing or Analyzing Market Trends; and
- Other purposes consistent with applicable laws;
AAA MWG may use your Collected Information to personalize your experience on the Sites and to improve the security, design, and functionality of our Sites.
5.6 Confirming Your Identity
AAA MWG may use your collected Personal Information to confirm your identity, including in connection with any requests made pursuant to Section 13 (Exercising Your Rights As a Consumer) listed below.
5.7 DMV Services
Any Personal Information AAA MWG obtains from the Department of Motor Vehicles (“DMV”) in connection with the DMV services is used solely for the purpose of providing the DMV services requested by you. AAA MWG does not store or disclose such Personal Information for any other purpose.
5.8 Site Data
AAA MWG may use Site data to improve its Sites and to help AAA MWG understand how users are using its Sites. This information is also collected for statistical analysis, to improve the utility of the Sites, and for other purposes described in this Privacy Policy.
5.9 Security Purposes
AAA MWG may use your collected Personal Information to detect security incidents, protect against malicious, deceptive, or illegal activity, and prosecute those responsible for that activity.
AAA MWG may also use your collected Personal Information to debug, to identify, and repair errors that impair existing intended functionality.
5.10 Other Uses In Agreements
AAA MWG may also use your collected Personal Information for the specific uses identified in any agreements you may have with AAA MWG.
5.11 Other Purposes
AAA MWG may use your Personal Information for other purposes specifically disclosed to you at the time AAA MWG requests your Personal Information. By providing your Personal Information, you consent to all disclosed uses.
5.12 Point of Collection Notice
If you would like to view a summary of the Personal Information provided in the sections above, please view Appendix I - Point of Collection Chart, Main. It identifies the categories of data collected at the various Points of Collection at which you may interact directly with Us. Similarly, it discloses the instances when We collect data about you from third parties, describes by reference to the individual headings of this Section 5, and the intended business or commercial uses for each category of data. Moreover, it also provides information regarding the categories of third parties with whom We may share your Personal Information.
6. NOTICE AT COLLECTION
This notice informs Members and consumers, at or before the time of collection of Personal Information, of the categories of Personal Information AAA MWG collects from them and the purposes for which the categories of Personal Information will be used. This notice also provides Members and consumers with a description of AAA MWG’s practices regarding the collection, use, and disclosure of Personal Information and the rights of consumers regarding their personal information pursuant to CCPA and/or other applicable data privacy laws.
If you would like to view a summary of the Personal Information, please see Appendix I - Point of Collection Chart, Main. This Appendix identifies the categories of data collected at various points of collection at which you may interact directly with AAA MWG. This Appendix also discloses when AAA MWG may collect data about you from third parties, as described in Section 5, and the intended business or commercial uses for each category of data. This Appendix also provides information regarding the categories of third parties with whom AAA MWG may share your Personal Information.
- For AAA Car Buying, please see Section 19 (Additional Information for Car Buying Users).
- For PMID, please see Section 20 (Additional Information for Protect My ID Users).
- For AAA Credit Card holders, please see Section 21 (Additional Information for AAA Credit Card Holders).
- For Smart Home, please see Section 22 (Smart Home Device Privacy Policy).
- For AAA Travel, please see Section 23 (Additional Information for AAA Travel Users).
7. WHY WE SHARE YOUR INFORMATION
The Personal Information AAA MWG collects about you will only be shared as permitted or required by law.
If you are a current or former Member, most of the Personal Information AAA MWG collects about you is maintained in your Membership records. This Personal Information is used to process and service your Membership.
The following are some examples of how AAA MWG may have shared your Personal Information in the past (12) months:
7.1 AAA MWG Companies, Subsidiaries, and Company Affiliates
AAA MWG may have shared in the past twelve (12) months your Personal Information with AAA MWG Companies, subsidiaries, and affiliates for the business purposes described in this Privacy Policy.
7.2 Service Providers
AAA MWG may have shared in the past twelve (12) months your Personal Information with Service Providers that are providing services to AAA MWG and acting on AAA MWG’s behalf, such as consultants, professional advisers, data analytics providers, and other service providers. The services being provided by the service providers may include:
- The provision, operation, maintenance, administration, promotion, improvement, and oversight of the Services, the Sites, and Member benefits;
- The provision of advertising and/or marketing services; and
- The fulfillment of your requests for Personal Information or Services.
7.3 Other Third Parties
AAA MWG may have shared in the past twelve (12) months your collected Personal Information with certain other third parties in the following circumstances:
- If you direct AAA MWG to share your Personal Information with a certain third party.
- If you authorize AAA MWG to share your Personal Information with a certain third party as part of AAA MWG’s provision of Services to you.
- If you authorize AAA MWG to share your Personal Information with a certain third party as part of fulfilling your request for other services.
- To comply with laws and regulations (including to fulfill AAA MWG's regulatory obligations relating to AAA MWG’s business), respond to legal processes (for example, a court order, search warrant, or subpoena) or requests from law enforcement authorities, or as otherwise required by law.
- If AAA MWG believes the Sites and/or the Services are being or have been used in violation of AAA MWG’s Terms and Conditions, other agreements with you, applicable law, or otherwise in the commission of a crime.
- If AAA MWG has a good faith belief that there is an emergency that poses a threat to the safety of you or another person;
- If necessary to protect AAA MWG’s rights, safety, security, or property or those of third parties, including to enforce AAA MWG’s rights against unauthorized access or attempted unauthorized access to AAA MWG’s information technology assets or against other inappropriate use of AAA MWG’s Sites.
- To prevent or investigate fraud, security, or technical issues or otherwise manage risks.
- To report to credit bureaus, if applicable.
- To share or transfer your collected Personal Information for a business deal,such as a proposed or consummated sale, acquisition, transfer, merger, or consolidation of all or part of AAA MWG’s organization.
8. WHY WE MAY “SELL” YOUR INFORMATION TO THIRD PARTIES
Under the CCPA, it is considered a “sale” if AAA MWG shares Personal Information with third parties in exchange for money or valuable consideration. Under this definition, AAA MWG may have sold your Personal Information to third parties in the past (12) months in exchange for financial benefits or other valuable consideration.
The following are categories of Personal Information that AAA MWG may have sold in the past twelve (12) months:
- Personal identifiers and contact information;
- Commercial information;
- Internet or other activity information; and
- Inferences resulting from information referenced under the categories listed above.
9. DATA RETENTION
AAA MWG may retain your Personal Information for the period necessary to fulfill the purposes outlined in this Privacy Policy, including for regulatory, audit, or record-keeping purposes. When your Personal Information is disposed of, AAA MWG will dispose of your Personal Information in a manner that is consistent with this Privacy Policy and applicable legal requirements.
10. YOUR RIGHTS AS A MEMBER
AAA MWG Members are entitled to certain rights. These rights include the following:
- The right to access certain information in your account, such as contact and mailing information and any preferences or payment methods you may have shared with AAA MWG.
- The right to correct and/or update your Personal Information.
You can access, update, and correct your Personal Information by:
- Logging on to your account; or
- Contacting Member support.
AAA MWG may ask you to verify your identity and to provide other details before it provides access to, updates, and/or removes any of your Personal Information. Your right to have Personal Information removed is subject to any retention requirements and/or other legal requirements that may authorize or require AAA MWG to retain your Personal Information.
11. YOUR RIGHTS AS A CONSUMER
Under the California Privacy Rights Act (“CPRA”) which amended the CCPA, California residents have certain rights with regards to their Personal Information. AAA MWG has expanded these rights to all Members and consumers, regardless of where they live. The following are the privacy rights available under the CCPA and CPRA:
11.1 The Right To Know
You have the right to request that AAA MWG disclose what type of Personal Information AAA MWG has collected about you, the purpose for collecting that information, and whether AAA MWG has shared that information with any third party and for what purpose. The fulfillment of this request is subject to AAA MWG receiving a verifiable request (See Section 13, Exercising Your Rights As A Consumer).
11.2 The Right To Delete
You have the right to request that AAA MWG delete the Personal Information that AAA MWG has collected from you. The fulfillment of this request is subject to AAA MWG receiving a verifiable request from you (See Section 13, Exercising Your Rights As A Consumer) and it is also subject to the exceptions listed below:
- To provide a product or service specifically requested by a consumer, to complete the transaction for which the personal information was collected, to perform a contract to which a consumer is a party, including fulfilling the terms of a written warranty, or otherwise perform a contract between the business and the consumer.
- To help ensure security and integrity to the extent the use of the consumer’s personal information is reasonably necessary and proportionate for those purposes.
- To debug, to identify and repair errors that impair existing intended functionality.
- To exercise free speech, ensure the right of another consumer to exercise that consumer’s right of free speech, or exercise another right provided for by law.
- Comply with the California Electronic Communications Privacy Act pursuant to Chapter 3.6 (commencing with Section 1546) of Title 12 of Part 2 of the Penal Code.
- To engage in public or peer-reviewed scientific, historical, or statistical research that conforms or adheres to all other applicable ethics and privacy laws, when the business’ deletion of the information is likely to render impossible or seriously impair the ability to complete such research, if the consumer has provided informed consent.
- To enable solely internal uses that are reasonably aligned with the expectations of the consumer based on the consumer's relationship with the business and compatible with the context in which the consumer provided the information.
- To comply with a legal obligation.
11.3 The Right to Correct
Where you have exercised your right to know what Personal Information AAA MWG has collected about you and discover that the Personal Information is incorrect, you can submit a request for AAA MWG to correct this information. AAA MWG will use commercially reasonable efforts to correct your incorrect Personal Information.
11.4 The Right to Opt-Out of the Sale or Sharing of Your Personal Information
You have the right to opt out of the sale or sharing of your Personal Information. If you opt out of the sale of your Personal Information, AAA MWG will not ask if you would like to opt back into the sale of your Personal Information for at least twelve (12) months from the date AAA MWG received your request; however, you may change your mind and inform AAA MWG in writing that you are opting back in during this period.
To exercise your right to opt out of the sale or sharing of your Personal Information, you can use the opt out button on AAA MWG’s Site’s home page. You can also submit your request online at /privacy-rights or over the phone at 1 (844) 973-0727.
AAA MWG will not require verification of your identity prior to honoring your opt out request. However, in certain circumstances, the law authorizes AAA MWG to refuse your request. In such instances, AAA MWG will provide you with an explanation of why we are unable to honor your request. You may also use an authorized agent to submit a request to opt out on your behalf. You must provide the authorized agent with written permission to submit a request on your behalf and the agent must provide proof to AAA MWG of this permission when submitting your request. If you change your mind and wish to opt back into the sale of your Personal Information or if the sale of your Personal Information is required to complete a transaction, please use the opt in mechanism described in Section 13.6 (Opting-In Following an Opt-Out) below.
11.5 The Right to Limit Use and Disclosure of Sensitive Personal Information:
You have the right to limit the sharing of your Sensitive Personal Information. Specifically, you have the right to opt out of the disclosure of your Sensitive Personal Information to a third party in the context of behavioral advertising regardless of whether there is an exchange of monetary or other valuable consideration. The CPRA introduces “sensitive personal information” as a subcategory of Personal Information. Sensitive Personal Information includes the following:
- Social security, driver’s license, state identification card, or passport number;
- Account log-in, financial account, debit card, or credit card number in combination with any required security or access code, password, or credentials allowing access to an account;
- Precise geolocation;
- Racial or ethnic origin, religious or philosophical beliefs, or union Membership;
- The contents of a consumer’s mail, e-mail, and text messages unless the business is the intended recipient of the communication;
- A consumer’s genetic data;
- The processing of biometric information for the purpose of uniquely identifying someone such as Personal Information collected and analyzed concerning health and/ or personal information collected and analyzed concerning a consumer’s sex life or sexual orientation.
AAA MWG will not require you to verify your identity prior to honoring your request to limit the use and disclosure of your Sensitive Personal Information. However, the fulfillment of this request is subject to the exceptions outlined in the CCPA. Where AAA MWG cannot fulfill your request due to these exceptions, we will provide you with an explanation of why we are unable to honor your request.
11.6 The Right to No Retaliation
The CCPA provides consumers with a right to no retaliation when they exercise their privacy rights. This means that AAA MWG will not discriminate against you in any of the following ways when you exercise your privacy rights:
- Deny you goods or services;
- Charge you different prices or rates for goods or services, including through the use of discounts, other benefits, or imposing penalties;
- Provide you a different level or quality of goods or services;
- Suggest that you may receive a different price or rate for goods and services, or a different level/quality of goods and services; and
- Reduce the quality of your experience on the web page, you intend to visit after exercising the right to opt-out.
11.7 The Right to a Private Right of Action
You have the right to a private right of action in the event of a data breach, if the data breach is a result of AAA MWG’s failure to “implement and maintain reasonable security procedures and practices. ”
12. THE RIGHT TO OPT- OUT FROM MARKETING
You may receive promotional content from AAA MWG periodically via email, mail, or by other means. However, you can always opt-out of receiving marketing content from AAA MWG.
- To opt-out from receiving promotional content via email, please follow the opt-out instructions provided in the email. There is an “unsubscribe” button in the footer of AAA MWG’s marketing emails, and you can click on this button to opt-out of receiving further marketing emails from AAA MWG.
- You can also opt-out of receiving promotional content whether by email, mail, or by other means by contacting Member Support. This also includes unsubscribing from AAA MWG’s magazine. You can contact Member Support by:
- Calling 1 (800) 922-8228
- E-mailing [email protected]
You may continue to receive promotional content while AAA MWG processes your opt- out request. You will also continue receiving transactional content from AAA MWG, including communications related to your account, your use of the Services and Sites, and other important notices.
13. EXERCISING YOUR RIGHTS AS A CONSUMER
If you are a California consumer or a AAA MWG Member who is not a California resident, you may make a request to correct, disclose, and/or delete Personal Information that AAA MWG has collected from you.
13.1 Methods For Submitting Requests
You can submit a verifiable consumer request to Us, using one of the following methods:
- Calling (844) 973-0727; or
- Visiting /privacy-rights
13.2 Limitations
You may only make a consumer request to exercise your right to know twice within a twelve (12) month period. This does not apply to your right to opt-out of a sale of your Personal Information. To exercise your right to opt-out of a sale of your Personal Information, please follow the instructions provided in Section 11.4 (The Right to Opt Out of the Sale or Sharing of Your Personal Information) above. Only you have the authority to initiate a verifiable consumer request related to your Personal Information. However, you may also authorize another person or a business entity registered with the California Secretary of State to submit a CCPA request on your behalf.
13.3 Verification of Request
Before AAA MWG can fulfill your request to correct, disclose, and/or delete your Personal Information, AAA MWG must verify your identity either through AAA MWG’s Site or by telephone using AAA MWG’s security mechanisms (such as a verification code sent to your email or phone). Depending on the method of communication used by you, AAA MWG may then require you to provide an online, written or oral declaration under the penalty of perjury to confirm “that you are who you are. ”
13.4 Verification Criteria
AAA MWG’s verification process consists of comparing the identifying information you provide to AAA MWG during your request with the Personal Information AAA MWG has on file. In order for a request to be considered verifiable, at least three of the data points must match.
AAA MWG uses a risk based approach to balance your right to exercise Consumer Privacy Rights with AAA MWG’s interest in preventing access to Personal Information by unauthorized parties and preserving the security and integrity of AAA MWG’s systems. Therefore, AAA MWG may use additional verification methods in the event that AAA MWG is unable to reach the legally required degree of certainty. These additional verification methods are based on the outcome of AAA MWG’s standard process(es), the value or the sensitive nature of the Personal Information involved, and the potential for harm in the case of unauthorized disclosure or deletion.
13.5 Processing of Request
If you are a resident of California, Montana, or Utah, AAA MWG will confirm receipt of your request within ten (10) days, unless AAA MWG has already responded to your request within this time period. AAA MWG will respond to your request within forty-five (45) calendar days after receipt. However, AAA MWG may deny your request if you do not provide sufficient information and AAA MWG cannot verify your request within this period of time. If needed, AAA MWG may take up to an additional 45 calendar days to respond to your request, for a maximum of 90 calendar days from the date your request is received. If AAA MWG needs additional time, AAA MWG will contact you to explain why additional time is needed.
If you are a AAA MWG Member or consumer who is not a resident of California, Montana, or Utah, AAA MWG will confirm and respond to your request as soon as reasonably possible.
13.6 Opting-In Following an Opt-Out
If you decide to opt back in after opting out from the sale of your Personal Information, AAA MWG will use a two-step process to confirm your decision. Please notify AAA MWG of your decision to opt back in by using any of the methods listed in Section 13.1 (Methods For Submitting Requests) and include a valid email address or phone number capable of receiving text messages with your request. AAA MWG must reconfirm your opt-in decision and will use the email address or phone number provided to send you a link for this purpose.
14. TRACKING – THIRD PARTY ANALYTICS PROVIDERS
14.1 “Do Not Track” Disclosure
Certain web browsers may provide a do-not-track (“DNT”) option. You may be able to ask your browser to inform websites that you do not want your activities tracked, either with cookies or other persistent identifiers, commonly called “DNT signals. ” At this time, AAA MWG does not honor do-not-track signals; however, AAA MWG does provide you with the ability to opt out of behavioral advertising. Please see AAA MWG’s About Online Advertising page for more information.
14.2 Third Party Analytics and Identity Providers
AAA MWG works with third party analytics service providers, including, but not limited to, Google Analytics, Optimizely, and Tealium (the “Analytics Providers”), to help AAA MWG better understand how users use AAA MWG’s Sites. Specifically, AAA MWG uses Analytics Providers to learn more about the types of users that visit the Sites and how they use the Sites and to help AAA MWG improve the Sites. Analytics Providers may collect certain information about you from your computer, including through the use of tracking technologies like cookies. Such information may include information regarding your visit (such as the pages you visit and the length of your visit), information about your device (such as your IP address), how you got to the Site, and other information about you.
- You can learn more about Google Analytics and how it collects and processes data (including how to control the information sent to Google) by visiting: www.google.com/policies/privacy/partners/.
- You can opt-out of Google Analytics by using the Google Analytics opt-out browser add-on, available at https://tools.google.com/dlpage/gaoptout/.
- You can learn more about Optimizely and how it collects and processes data (including how to control the information sent to Optimizely) by visiting: https://www.optimizely.com/privacy/. You can learn about how to opt-out of Optimizely by visiting: https://www.optimizely.com/legal/opt- out/.
- You can learn more about Tealium and how it collects and processes data (including how to control the information sent to Tealium) by visiting: https://tealium.com/privacy/. You can update your privacy preferences with Tealium by visiting: https://tealium.privacy.saymine.io/Tealium.
When you use AAA MWG’s website, AAA MWG may share information that it collects from you, such as your email (in hashed form), IP address, or information about your browser or operating system, with our third party identity partners/service providers (such as LiveRamp, Inc.). These partners return an online identification code that AAA MWG may store in our first-party cookie for our use in online, in-app, and cross-channel advertising and it may be shared with advertising companies to enable interest-based and targeted advertising. To opt out of this use, please click here https://liveramp.com/opt out/.
15. LINKS TO OTHER SITES AND OTHER PRIVACY POLICIES
The Sites may contain third-party links, include third-party integrations, or offer co-branded or third-party-branded services. Through these links, third-party integrations and co-branded or third-party-branded services may be providing your information (including Personal Information) directly to the third party, AAA MWG, or both.
You acknowledge and agree that AAA MWG is not responsible for how these third parties collect, share, or use your information. Because AAA MWG has no control over the privacy practices or content of these linked sites, AAA MWG recommends that you carefully review the privacy policies of every third-party service that you visit or use, including those third parties you interact with through AAA MWG’s Sites and/or Services.
16. Children's and Minor's Privacy
The Sites and/or Services are not intended to target individuals under the age of thirteen (13) and AAA MWG does not knowingly collect Personal Information directly from children under the age of thirteen (13). If AAA MWG discovers that it has received Personal Information directly from a child under the age of thirteen (13), AAA MWG will delete the Personal Information. If you are a parent or guardian of a child under the age of thirteen (13) and believe that AAA MWG may have collected Personal Information directly from your child, you may contact AAA MWG using the information provided in Section 13.1 (Methods For Submitting Requests) above.
AAA MWG will not sell (and has not sold for the past twelve (12) months) the Personal Information of individuals under 16 years of age if AAA MWG knows that the individual is a minor and AAA MWG does not have affirmative authorization to do so. Individuals between the ages of thirteen (13) and sixteen (16) may communicate their affirmative authorization by using the method for opt-in requests described in Section 13.6 (Opting-In Following An Opt-Out).
17. PROTECTING YOUR PERSONAL INFORMATION
To protect your Personal Information from unauthorized access and use, AAA MWG maintains security procedures and practices appropriate to the nature of the Personal Information provided to AAA MWG and the type of processing activities performed by AAA MWG. However, there is always some risk in transmitting information over the Internet. Because the Sites are provided through the Internet, when you use the Sites, your communications may be intercepted by others. For this reason, AAA MWG cannot guarantee the security and privacy of transmissions via the Internet, and AAA MWG is not responsible or liable for any security issues that may be related to your use of the Sites. You agree that you will not hold AAA MWG liable for any damages resulting from any loss of privacy or security occurring in connection with any communications over such networks.
18. HOW TO CONTACT US
If you have any questions or comments about AAA MWG’s privacy policies and practices, or would like more information regarding how to exercise your rights as described in this Privacy Policy, or would like to obtain a copy of this Privacy Policy in a different format, please contact AAA MWG using one of the methods provided below:
- By e-mail to: [email protected]
- By mail to: American Automobile Association of Northern California, Nevada & Utah, Attn: Privacy Requests, 1277 Treat Boulevard, Suite 1000, Walnut Creek, CA 94597
For Member Support services, please contact Us at: 1 (800) 922-8228 or visit [email protected].
19. ADDITIONAL INFORMATION FOR CAR BUYING USERS
AAA MWG’s car buying service allows users to purchase their new or used vehicles from the convenience of their own home. The following information explains what kind(s) of information is collected from you when you use AAA MWG’s car buying service. Please keep in mind, this section supplements AAA MWG’s Privacy Policy. You should read the entire Privacy Policy for full details.
19.1 Initial Process
As part of the initial process, the following information may be collected from you:
- First and Last Name
- Zip Code /Postal Code
- Phone Number
- Email Address
19.2 If Purchasing
The initial information is used to help you find the vehicle you’re looking for. If you decide to move forward with the car buying process, we may collect additional information from you such as:
- Driver’s license information (front and back of the Driver’s license card). The driver’s license likely contains the following information:
- First and last name
- Driver’s license number
- Birth date
- Address
- Signature
- Photograph
- Issuing state
- Physical characteristics (height, weight, eye color, etc.)
- Organ donor status, if applicable
Proof of Car Insurance (Your car insurance card). Your car insurance card likely contains the following information:
- Policy number
- Insured’s name and contact information
- Vehicle information: year, make, model, and Vehicle Identification
- Number (VIN)
- License plate number
- Insurance coverage details
- Premium amount
19.3 If Financing
If you decide to purchase a vehicle and finance it with AAA MWG, we may collect the following additional information from you and your cosigner if applicable:
- Social Security Number (SSN)
- Residential status
- Previous address (if applicable)
Professional and employment related information including:
- Employment type (e.g. employed, self- employed)
- Salary
- Occupation
- Length of employment
- Previous employment information
- Other income sources
- Credit Report/s to determine creditworthiness
- Signature
20. ADDITIONAL INFORMATION FOR PROTECT MY ID USERS
AAA MWG has partnered with Experian to provide identity theft protection to our Members. This product is ProtectMyID or (“PMID”) and it is offered directly by Experian. By enrolling in and using PMID, you may be required to provide personal and financial information directly to Experian. For more details on how your information is collected, used, and protected when using PMID, please refer to Experian’s privacy policy, available at https://aaa.protectmyid.com/privacy-policy
California and Nevada Residents: AAA MWG does not sell your Personal Information that’s submitted for purposes of providing you with PMID services. If you are a California Consumer or a Member who is not a California resident, please see Section 13 (Exercising Your Rights As a Consumer) for additional information on exercising your privacy rights.
21. ADDITIONAL INFORMATION FOR AAA CREDIT CARD HOLDERS
AAA MWG has partnered with Bread Financial to offer a credit card program to our valued AAA MWG Members. If you choose to apply for a AAA credit card, you may provide personal information such as your name, address, social security number, financial history and credit score directly to Bread Financial. Bread Financial manages the AAA credit card program. Please refer to Bread Financial’s privacy policy at https://www.breadfinancial.com/en/legal/privacy.html for details on how your AAA Credit Card related personal information is handled.
22. SMART HOME DEVICE PRIVACY POLICY
22.1 Personal Information
When you use AAA MWG’s Smart Home service, AAA MWG may collect certain personal information that is necessary for providing the service and ensuring its functionality. This may include the following personal information:
- AAA Membership number
- Full name
- Date of birth
- Street address
- City, state, and zip code
- Phone number
- Email address
- Billing address
- Square footage of the property
- Records of products or services purchased (the specific security system package selected).
- Credit/Debit Card details including card number, expiration date, and cardholder’s name.
- Geolocation - (home location information)
- Internet activity
- Social security number, if financing
- Account number
22.2 Data
In addition to personal details, data may also be collected from devices installed or used in your residence or business for the purpose of providing you with the Smart Home monitoring and alarm services (collectively, “Smart Home Device” or “Device”). Information collected may include:
- Location Information– Information about your location, your personal device location, or the physical location of your Smart Home Devices;
- Audio, Video, and Still-image Information– Depending upon how you configure your Smart Home Device, the Company may collect certain still-images as well as audio and video;
- Smart Home Device Information– Information about motion detection, door and window usage, utility usage, and climate data (including temperature and moisture data);
- Monitoring Information– Information about arming and disarming the Smart Home Device;
- Aggregate Usage Information– Information that helps the Company track patterns and improve Smart Home Devices in order to meet your smart home needs; and
- Biometric Information– Information about your physical characteristics that helps the Company identify you, including, but not limited to, facial recognition.
The Company may use Device Data to do any or all of the following:
- Provide you with the Company’s Services;
- Facilitate your interactions and transactions with the Company;
- Respond to your requests, communications, suggestions, comments, inquiries, and requests (including your feedback about Devices and Services);
- Provide you with relevant notifications;
- Administer the Company’s relationship with you, including managing your account;
- Maintain and improve the Company’s Devices and Services, including measuring the Company’s performance;
- Develop new products, features, and services;
- Better understand the preferences of customers;
- Facilitate your participation in the Company’s surveys and promotions;
- Respond to requests from law enforcement, regulatory authorities, or other third parties
- Defend, protect or enforce the Company’s rights or applicable terms of service or to fulfill the Company’s legal or contractual obligations;
- To prevent fraud or the recurrence of fraud;
- Assist in the event of an emergency;
- Comply with applicable law; or
- Any other purposes specifically disclosed to you at the time the Company requests, and you provide, the information.
The Company may also combine Device Data with other Personal Information collected from your use of the Company’s Services and develop a customer profile that will be used for the purposes above.
22.3 Camera-Enabled Services
If you enable smart monitoring camera-enabled services, the Company may record, stream, store, or process video and/or recordings pursuant to your account instructions and camera-enabled device configuration settings. Please visit https://a3smarthome.com/installation/indoor-hdr-camera for more information on using and enabling your smart monitoring camera. If you enable the recording features during your subscription term, the Company will capture, process and retain video and audio data recordings from the Device pursuant to your settings or until the storage limit is reached (older videos will be deleted once the storage limit is reached) and you will be able to access those recordings during that time.
22.4 Identity Verification
The Company may use the Device Data to verify your identity or the identity of other persons. If you choose to upload the photos and identity of other persons to the Smart Home Device, the Company will process this information for the purpose of enabling the Smart Home Device to recognize familiar faces and to notify you of both familiar and unknown people. Using the mobile application and your account, you control whether this biometric processing and analysis occurs. Only upload photos of individuals who have consented to have their information used in accordance with this Privacy Policy. The Company may retain Device Data for the period necessary to fulfill the purposes outlined in this Privacy Policy, including, but not limited to, regulatory, audit, or record-keeping purposes.
22.5 Anonymized and Aggregated Information
The Company may use Device Data to create anonymized and aggregated information that does not personally identify an individual (“non-personal information”). The Company may use non-personal information for any legitimate business purpose. Except as disclosed in this Privacy Policy, the Company does not share Device Data with any companies other than the Company’s partners and affiliates and their directors, officers, employees, agents, consultants, advisors or other representatives.
22.6 Third-Parties
The Company may share Device Data with the Company’s third-party service providers, suppliers, vendors, and business partners to help the Company in the operation, management, improvement, research and analysis of the Company’s Devices and/or Services, and to comply with your directions or any consent you have provided the Company.
22.7 Law Enforcement and Regulatory Authorities
The Company may share Device Data with law enforcement and regulatory authorities or other third parties as required or permitted by law for the purpose of:
- Responding to a subpoena, court order, or other legal processes;
- Preventing or investigating fraud, security, or technical issues or otherwise manage risks;
- Defending, protecting, or enforcing the Company’s rights, safety, security, or property;
- Reporting to credit bureaus (if applicable);
- Assisting in the event of an emergency; and
- Complying with applicable law.
22.8 Legal Proceedings
If the Company is involved in defending a legal claim, then Company may disclose Device Data about you that is relevant to the claim, to third parties as a result of, or in connection with the associated legal proceedings
22.9 Change of Control
The Company may also transfer or assign Device Data to third parties as a result of, or in connection with, a sale, merger, consolidation, and change in control, transfer of assets, bankruptcy, reorganization, or liquidation.
23. ADDITIONAL INFORMATION FOR AAA TRAVEL USERS
We collect personal information from clients or guests in order to manage their travel needs and fulfill our agreements. This information may include the following:
- AAA Membership Information
- Full Name
- Date of Birth
- Home Address
- City, State, ZIP Code
- Phone Number
- Email Address
- Signature
For Domestic Travel – We will need a copy of your Driver's license (front and back of the Driver’s license card). The driver’s license would contain the following details:
- First and last name
- Driver’s License Number
- Birth Date
- Address
- Signature
- Photograph
- Issuing State
- Physical characteristics (height, weight, eye color, etc.)
- Organ Donor Status, if applicable
For International Travel – we will need a clear and legible copy of your passport which contains the following details:
- Full name
- Date of birth
- Place of birth
- Photograph
- Passport number
- Issuing authority
- Nationality
- Gender
- Signature
- Passport issue date and expiration date
- Visa stamps/ travel history
Travel Preferences
Travel Insurance information
Emergency Contact Information, including name, relationship, and contact details
Credit/Debit Card details including card number, expiration date, and cardholder’s name.
AAA MWG collects this information to provide you with comprehensive travel-related support, and for other travel-related purposes as outlined below:
- The management of travel, transportation, reservations, and bookings;
- The management and communication of travel information on itineraries, safety alerts, and fare optimization;
- To provide customers with travel-related support;
- Quality assurance and training purposes;
- The prevention and detection of fraud and incidents; and
- To comply with applicable laws and regulations.
In order to fulfill the purposes described above, and in line with travel industry practices, AAA MWG may share your Personal Information with the relevant third-party service providers listed below:
- Travel suppliers (airlines, hotels, car rental companies, transportation companies).These travel suppliers provide the actual travel, transportation, reservations, and/or bookings requested;
- Computerized reservation systems (systems with real-time airline seat, hotel room inventory, rental car availability, etc.);
- Online portals displaying airline and hotel options (for client preferences); and
- Card payment companies
This Privacy Policy does not apply to these third-party service providers. AAA MWG has no control over, and is not responsible for, their data collection and/or data handling practices. AAA MWG encourages you to be aware of any applicable third-party service providers’ data collection and/or data handling practices. The inclusion of a link to a third-party service provider does not imply that AAA MWG endorses any of the third party’s data collection and/or handling practices or that this Privacy Policy covers the third parties’ products, services, or practices.
AAA MWG reserves the right to disclose your Personal Information if required to do so by law or in the good faith belief that such action is reasonably necessary to comply with applicable law.
24. UPDATES TO PRIVACY POLICY
From time to time, AAA MWG may update this Privacy Policy, including at least once annually. If AAA MWG updates this Privacy Policy, AAA MWG will post the revised version here and note near the top of this Privacy Policy the date that any changes are made and/or when they become effective. If the changes being made are material, or if it is appropriate to do so under applicable law(s), AAA MWG may provide a more prominent notice. You should check here regularly for the most up-to-date version of this Privacy Policy. Your continued use of the Sites or Services, or your provision of Personal Information to AAA MWG after any such notices, represents your agreement, acceptance, and consent to these Privacy Policy changes. If you do not agree to the Privacy Policy changes, please do not use the Sites or Services.
Appendix I – Point of Collection Chart, Main
A) Visit of Sites, including general inquiries and browsing of our Sites
Categories of Personal Information Collected | Business or Commercial Purpose of Intended Use (described in Section 5 above) | Categories of Sources from which Personal Information has been Collected | Categories of Third Parties with which Personal Information has been Shared |
|---|---|---|---|
Identifying Personal Information, such as name, contact information, and/or IP address | See Section 5 of the Privacy Policy - How Does AAA MWG Use Your Personal Information | Directly obtained from consumer |
|
Browsing history and information regarding your interaction with the Sites from your device, browser or cookies | See the following sections:
|
|
|
Inferences about interests and preferences based on analysis of browsing habits and other predictive techniques | See the following sections:
|
|
|
B) Signing up for News and Information Services
Categories of Personal Information Collected | Business or Commercial Purpose of Intended Use (as described in detail in Section 5 of the Privacy Policy) | Categories of Sources from which Personal Information has been Collected | Categories of Third Parties with which Personal Information has been Shared |
|---|---|---|---|
See Section A ( Visit of Sites) | See the following sections:
| See section A (Visit of Sites) |
|
Commercial Information, including records of products and services viewed/ or purchased | See the following sections:
|
|
|
C) Online Purchase and/or use of goods and Services including memberships, subscriptions, road side assistance, DMV and travel services
Categories of Personal Information Collected | Business or Commercial Purpose of Intended Use (as described in detail in Section 5 of the Privacy Policy) | Categories of Sources from which Personal Information has been Collected | Categories of Third Parties with which Personal Information has been Shared |
|---|---|---|---|
See Section A ( Visit of Sites) and Section B (Signing up for News and Information Services). Additional identifying information may include
| See the following sections:
|
|
|
Payment and other Financial information, including credit card and bank account information, credit history | See the following sections:
|
|
|
D) Off-line by phone, regular mail, or visit in our branches
Categories of Personal Information Collected | Business or Commercial Purpose of Intended Use (as described in detail in Section 5 of the Privacy Policy) | Categories of Sources from which Personal Information has been Collected | Categories of Third Parties with which Personal Information has been Shared |
|---|---|---|---|
May include sections A-C above, excluding browsing history and Site use | May include sections A-C above, excluding browsing history and Site use | May include sections A-C above, excluding browsing history and Site use | May include sections A-C above, excluding browsing history and Site use |