Terms of use

This policy is effective December 14, 2017.

Welcome to Hugo. These Terms of Use apply to the Services (defined below) offered by Popular Lab Co. and Hugo Insurance Services (collectively, “Hugo”). The Service comprises the Site and the Apps (defined below). Any participation in this site will constitute acceptance of this agreement. If you do not agree to abide by the agreement, pleased do not use this site. Please read this agreement carefully.

Hugo allows users to access information and configure certain aspects of its Service through its website located at www.withhugo.com (the “Site”), and also provides software applications for mobile phones (the “Apps”). For the avoidance of doubt, the Service excludes Hugo’s insurance products, coverages, and services (which require your application, and Hugo’s acceptance, and which are governed by separate terms), and is limited solely to your use of Hugo’s Apps and web based information and configuration services.

Hugo reserves the right to update or modify the Terms at any time without prior notice, and such changes will be effective immediately upon being posted through the Service and these Terms will identify the date of last update.

Privacy

Whenever you submit information to Hugo you consent to the collection, processing, use and disclosure of that information in accordance with these Terms of Use and the Privacy Policy.

Account Information & Responsibilities of Registered Users

In order to access some features of the Service, you will have to create an account. You represent and warrant that the information you provide to Hugo upon registration (including information provided through your linked Facebook account, as applicable, or other third party Linked Accounts, as defined below), and at all other times, will be true, accurate, current, and complete. You also represent and warrant that this information is accurate and kept up-to-date at all times.

Do not share your account information with, or allow access to your account by, any third party. If you have any reason to believe that your account information has been compromised or that your account has been accessed by a third party, you agree to immediately notify Hugo by e-mail to support@withhugo.com. You are solely responsible for your own losses or losses incurred by Hugo and others (including other users) due to any unauthorized use of your account that occur as a result of your intentional or inadvertent disclosure of any of your login information or as a result of your delay in notifying Hugo that your account was compromised after your discovery of the compromise.

When you purchase insurance coverage from the Hugo, you may be required to connect a wireless enabled telematics device to your covered vehicle(s). The device is capable of collecting and communicating back to the Hugo a variety of information about your vehicle and your trips, including, but not limited to speed, odometer and location information.

Copyright

All original content, features, and functionality of this Site is owned by Hugo and protected by U.S. and international copyright, trademark, patent, trade secret, and other intellectual property or proprietary rights laws.

You agree and understand that Site Content may include Third Party Content, as set forth in further detail in Section 6, below. All trademarks, service marks, and trade names are proprietary to Hugo or its affiliates and/or third parties. You agree not to sell, license, distribute, copy, modify, publicly perform or display, transmit, publish, edit, adapt, create derivative works from, or otherwise make unauthorized use of the Site Content, and nothing herein shall be interpreted to grant you any right or license under any intellectual property rights of Hugo or any third party.

Hugo may, now or in the future, allow you to link your account(s) on the Service to your accounts on third party services, such as social networking sites (“Linked Accounts”). If you link your account on the Service to a Linked Account, you authorize Hugo to store and use your access credentials to access your Linked Account on your behalf as your agent to integrate your experience with the Service with content, information, and features available through such Linked Account. This may include importing the contacts, preferences, interests or “likes” of the Linked Account, and/or pushing updates regarding your use of the Service out to your Linked Accounts. Linking, accessing or using a third party service through the Service in this manner may be subject to additional terms established by the applicable third party, and it is your sole responsibility to comply with such third party terms.

Third Party Content

Hugo may display information, materials or content from third parties (“Third Party Materials”) through the Services. The display on or through the website and Services of such Third Party Materials does not in any way imply, suggest, or constitute any sponsorship, endorsement, or approval of Hugo by any such third party or any affiliation between any such third party and Hugo.

User Content

The Service may now or in the future allow users to submit, post, and share content such as text, photos, audiovisual content, and other media content (“User Content”). You retain all your rights in User Content, but if you choose to provide any User Content to Hugo, we require a license to such User Content in order to make it available through the Service. Hugo cannot guarantee any anonymity or confidentiality with respect to any User Content, and strongly recommends that you think carefully and use good judgment about what you submit to or make available through the Service.

You understand that you, and not Hugo, are entirely responsible for User Content that you make available through the Service. You are solely responsible for your own User Content and the consequences of posting or publishing it. Further, you represent and warrant that you own, or have the necessary licenses, rights, consents, and permissions to use and authorize Hugo to use all patent, trademark, copyright, or other proprietary rights in and to any and all User Content to enable the use of User Content in the manner contemplated by these Terms, and to grant the rights and license set forth herein.

You retain all of your ownership rights in original aspects your User Content. By providing User Content to Hugo you grant Hugo and its affiliates, sublicensees, partners, designees, and assignees of the Service (collectively, the “Hugo Licensees”) a non-exclusive, fully paid-up, royalty-free, perpetual, irrevocable, sublicensable, transferable, worldwide license.

Hugo does not control User Content and does not have any obligation to monitor such User Content for any purpose, but may at its sole discretion, monitor or review some or all User Content. Hugo and its designees may, at any time and without prior notice, remove any User Content that in the sole judgment of Hugo violates these Terms or is otherwise objectionable, or for any other reason, with or without notice and with no liability of any kind. You agree that you must evaluate, and bear all risks associated with the use of any User Content or other Content, including any reliance on the accuracy, completeness, usefulness or legality of such User Content. You should exercise your independent discretion and judgment before downloading any other User Content.

Customer Contact

Our Service may involve contacting you by phone call, SMS/MMS messaging, or email. If you use a feature of our Service that involves such contact, you are responsible for any and all service fees associated with any voice minutes, SMS/MMS delivery, and mobile network access, including all applicable data fees, and for complying with all terms of use imposed by your carrier. You are also responsible for having a mobile device that is compatible with software and/or applications made available by Hugo. Unless otherwise stated, Hugo does not represent or warrant that the software made available will be compatible with your mobile device. You represent and warrant that any telephone numbers, email addresses, or other contact information that you provide to Hugo currently belongs to you and not to a family member or any other third party, and you commit to notifying Hugo should such contact information cease to be accurate.

Prohibited Uses

You agree not to use the Service or any aspect or feature thereof for any unlawful purpose or in any way that might harm, damage, or disparage any other party. You agree that you will not, do or attempt to:

Reproduce, duplicate, copy, sell, trade, resell, distribute or exploit, any part of the Service, use of the Service, access to the Service, or content obtained through the Service (including without limitation Site Content, Third Party Content, and User Content), for any purpose other than for your personal, noncommercial purposes;
Access or use the Service for any commercial or business purpose, including without limitation for comparative or competitive research purposes or to transmit unauthorized advertising;
Remove, circumvent, disable, damage or otherwise interfere with any security-related features of the Service, or features that enforce limitations on the use of the Service or any content therein;
Threaten, harass, abuse, slander, defame or otherwise violate the legal rights (such as rights of privacy and publicity) of others; or
Use the Service in any manner whatsoever that could lead to a violation of any federal, state or local laws, rules or regulations.

Termination

Hugo, in its sole discretion and for any reason or no reason, may terminate your account on the Service, disable your access to the Service (or any part thereof), discontinue the Service, or terminate any license or permission granted to you, at any time, with or without notice, including without limitation in connection with any termination of any insurance policy you may have with the Hugo. You agree that Hugo shall not be liable to you for any such termination.

If you are dissatisfied with the Service, then please let us know by e-mailing us at support@withhugo.com. Your only remedy with respect to any dissatisfaction with (i) the Service, (ii) any of these Terms, (iii) any policy or practice of Hugo in operating the Service, or (iv) any content or information transmitted or made available through the Service, is to terminate your use of the Service. You may terminate only by discontinuing your insurance policy (and thus your account on the Service) by calling Hugo at 515.303.2410.

Indemnity

You agree to indemnify and hold harmless Hugo and its parent, subsidiaries, affiliates or any related companies, licensors and suppliers, and their respective directors, officers, employees, agents, representatives, customers, and contractors, from all damages, injuries, liabilities, costs, fees and expenses (including, but not limited to, legal and accounting fees) arising from or in any way related to (i) your use or misuse of the Service (including your use or misuse of Third Party Materials); (ii) your User Content; (iii) your breach or other violation of these Terms including any representations, warranties and covenants herein; (iv) your violation of the rights of any other person or entity, including, but not limited to claims that any User Content infringes or violates any third party intellectual property rights. Hugo reserves the right, at your expense, to assume the exclusive defense and control of any matter for which you are required to indemnify us and you agree to cooperate with our defense of these claims. You may not settle any matter without the prior written consent from Hugo.

Disclaimers

THE SERVICE (INCLUDING, WITHOUT LIMITATION, THE SITE, SITE CONTENT, OR ANY OTHER PRODUCT, SERVICE OR INFORMATION PROVIDED BY COMPANY), USER CONTENT, THIRD-PARTY CONTENT, AND ANY OTHER SOFTWARE, SERVICES OR APPLICATIONS MADE AVAILABLE IN CONJUNCTION WITH OR THROUGH THE SERVICE, ARE PROVIDED ON AN “AS IS”, “AS AVAILABLE”, “WITH ALL FAULTS” BASIS WITHOUT REPRESENTATIONS OR WARRANTIES OF ANY KIND, EITHER EXPRESS, IMPLIED, OR STATUTORY, INCLUDING, BUT NOT LIMITED TO, IN TERMS OF CORRECTNESS, ACCURACY, RELIABILITY, OR OTHERWISE.

TO THE FULLEST EXTENT PERMISSIBLE BY APPLICABLE LAW, COMPANY HEREBY DISCLAIMS ALL WARRANTIES OF ANY KIND, EITHER EXPRESS OR IMPLIED, INCLUDING, ANY WARRANTY OF MERCHANTABILITY, FITNESS FOR A PARTICULAR PURPOSE, NON-INFRINGEMENT, OR ARISING FROM A COURSE OF DEALING, WITH RESPECT TO THE PRODUCTS OR SERVICES PROVIDED BY COMPANY.

Limitation of Liability

IN NO EVENT WILL COMPANY, ITS OFFICERS OR DIRECTORS BE LIABLE TO ANY PARTY FOR ANY DIRECT, INDIRECT, SPECIAL OR OTHER CONSEQUENTIAL DAMAGES ARISING OUT OF OR IN CONNECTION WITH (I) YOUR USE OF THE SERVICE, SITE CONTENT, THIRD PARTY MATERIALS OR THE SITE; (II) THE USE OR ACCESS OF OR INABILITY TO USE OR ACCESS THE SERVICE OR ANY CONTENT; OR (III) PLANS MADE OR INFORMATION ACQUIRED THROUGH THE SERVICES, INCLUDING, WITHOUT LIMITATION, (I) ANY FEES OR COSTS ASSOCIATED WITH CANCELLED, INTERRUPTED OR DELAYED PLANS; (II) ANY FEES OR COSTS RESULTING FROM MISINFORMATION OR FAILURES IN COMMUNICATION; (III) AND ANY ACCIDENTS OR UNEXPECTED EVENTS OTHERWISE, WHETHER BASED IN TORT, CONTRACT OR OTHER LEGAL THEORY, EVEN IF COMPANY IS EXPRESSLY ADVISED OF THE POSSIBILITY OF SUCH DAMAGES. EXCEPT AS SPECIFICALLY REQUIRED BY LAW, IN NO EVENT WILL COMPANY, ITS OFFICERS OR DIRECTORS BE LIABLE IN THE AGGREGATE FOR ANY DAMAGES INCURRED GREATER THAN FIVE HUNDRED DOLLARS ($500). THESE LIMITATIONS OF LIABILITY SHALL SURVIVE THE TERMINATION OF THIS AGREEMENT.

APPLICABLE LAW MAY NOT ALLOW FOR THE LIMITATION OR EXCLUSION OF LIABILITY OR INCIDENTAL OR CONSEQUENTIAL DAMAGES, SO THE ABOVE LIMITATION OR EXCLUSION MAY NOT APPLY TO YOU. IN SUCH CASES, YOU AGREE THAT BECAUSE SUCH WARRANTY DISCLAIMERS AND LIMITATIONS OF LIABILITY REFLECT A REASONABLE AND FAIR ALLOCATION OF RISK BETWEEN YOU AND COMPANY, AND ARE FUNDAMENTAL ELEMENTS OF THE BASIS OF THE BARGAIN BETWEEN YOU AND COMPANY, COMPANY’S LIABILITY WILL BE LIMITED TO THE MAXIMUM EXTENT PERMITTED BY LAW. THESE LIMITATIONS AND EXCLUSIONS APPLY IN NEW JERSEY. YOU UNDERSTAND AND AGREE THAT COMPANY WOULD NOT BE ABLE TO OFFER THE SERVICE TO YOU ON AN ECONOMICALLY FEASIBLE BASIS WITHOUT THESE LIMITATIONS.

Privacy policy

Effective as of October 20, 2023.

Please click here to view the previous version of our Privacy Policy.

California Notice at Collection: See the California Privacy Rights section below for important information about your rights under the California Consumer Privacy Act (“CCPA”).

Popular Lab Co. and Hugo Insurance Services (“Hugo”, “we”, “us” or “our”) provides personal automobile insurance. This Privacy Policy describes how Hugo processes personal information that we collect through our digital or online properties or services that link to this Privacy Policy (including as applicable, our website, mobile application, and social media pages) as well as our marketing activities and other activities described in this Privacy Policy (collectively, the “Service”)). Hugo may provide additional or supplemental privacy policies to individuals for specific products or services that we offer at the time we collect personal information.

You can download a printable copy of this Privacy Policy here.

Personal information we collect

Information you provide to us. Personal information you may provide to us through the Service or otherwise includes:

Contact data, such as your first and last name, salutation, email address, billing and mailing addresses, and phone number.
Demographic data, such as your city, state, country of residence, postal code, gender, and age.
Profile data, such as the username and password that you may set to establish an online account on the Service, date of birth, marital status, biographical details, employment details, homeownership information, educational records, photograph or picture, preferences, and any other information that you add to your account profile.
Vehicle and insurance data, such as your driving frequency; car make, model, trim, and year; vehicle identification number (VIN), prior insurance information, motor vehicle records, driving history, mileage, usage, garaging address, and other information we need to provide you with an insurance quote, Proof of Insurance, or for underwriting purposes.
Communications data based on our exchanges with you, including when you contact us through the Service, social media, or otherwise.
Transactional data, such as information relating to or needed to complete your orders on or through the Service, including order numbers and transaction history.
Marketing data, such as your preferences for receiving our marketing communications and details about your engagement with them.
Relationship data, such as familial or other relationship to third parties whose personal information you may provide to us.
Government-issued identification number data, such as national identification number (e.g., Social Security Number, tax identification number, passport number), state or local identification number (e.g., driver’s license or state ID number), and an image of the relevant identification card.
Payment data needed to complete transactions, including payment card information or bank account number.
Other data not specifically listed here, which we will use as described in this Privacy Policy or as otherwise disclosed at the time of collection.

Third-party sources. We may combine personal information we receive from you with personal information falling within one of the categories identified above that we obtain from other sources, such as:

Public sources, such as government agencies, public records (including the Bureau of Automotive Repair), social media platforms, and other publicly available sources.
Data providers, such as information services and data licensors.
Consumer reporting and motor vehicle records partners, in order to gather information such as your credit report, driving record, and claims history with other insurers. These agencies keep your information and only disclose it to us as permitted by the Fair Credit Reporting Act (FCRA) and/or pursuant to their agreements with us. By submitting an application for insurance coverage, you authorize Hugo to request your consumer report both before and after you finalize your application. You are entitled to receive a free copy of your consumer report directly from the consumer reporting agency we utilize. To receive your report, contact them at: Samba Safety Consumer Support, LexisNexis Consumer Report, or as otherwise directed.
Partners, such as marketing partners, lead aggregators, and event co-sponsors.
Service providers that provide services on our behalf or help us operate the Service or our business.
Third-party services, such as social media services, that you use to log into, or otherwise link to, your Service account. This data may include your username, profile picture and other information associated with your account on that third-party service that is made available to us based on your account settings on that service (such as Google) that you use to log into, or otherwise link to, your Service account. This data may include your Google username, profile picture and other information associated with your Google account on that third-party service that is made available to us based on your account settings on that service. Our use and disclosure of information received from Google’s APIs will adhere to the Google API Services User Data Policy, including the Limited Use requirements.

Automatic data collection. We, our service providers, and our business partners may automatically log information about you, your computer or mobile device, and your interaction over time with the Service, our communications and other online services, such as:

Device data, such as your computer or mobile device’s operating system type and version, manufacturer and model, browser type, screen resolution, RAM and disk size, CPU usage, device type (e.g., phone, tablet), IP address, unique identifiers (including identifiers used for advertising purposes), language settings, mobile device carrier, radio/network information (e.g., Wi-Fi, LTE, 3G), and general location information such as city, state or geographic area.
Online activity data, such as pages or screens you viewed, how long you spent on a page or screen, the website you visited before browsing to the Service, navigation paths between pages or screens, information about your activity on a page or screen, access times and duration of access, and whether you have opened our emails or clicked links within them.
Precise geolocation data when you authorize the Service to access your device’s location.
Communication interaction data such as your interactions with our email, text or other communications (e.g., whether you open and/or forward emails) – we may do this through use of pixel tags (which are also known as clear GIFs), which may be embedded invisibly in our emails.

For more information concerning our automatic collection of data, please see the Tracking technologies section below.

Data about others. We may offer features that help users invite their friends or contacts to use the Service, and we may collect contact details about these invitees so we can deliver their invitations. Please do not refer someone to us or share their contact details with us unless you have their permission to do so.

Tracking technologies

Cookies and similar technologies. Some of our automatic data collection is facilitated by cookies and similar technologies as outlined below. We will also store a record of your preferences in respect of the use of these technologies in connection with the Service.

Cookies. Cookies are small text files that websites store on user devices and that allow web servers to record users’ web browsing activities and remember their submissions, preferences, and login status as they navigate a site. Cookies used on our sites include both “session cookies” that are deleted when a session ends, “persistent cookies” that remain longer, “first party” cookies that we place and “third party” cookies that our third-party business partners and service providers place.
Browser Web Storage. We may use browser web storage (including via HTML5), also known as locally stored objects (“LSOs”), for similar purposes as cookies. Browser web storage enables the storage of a larger amount of data than cookies. Your web browser may provide functionality to clear your browser web storage.
Flash Technology. We may use Flash cookies (which are also known as Flash Local Shared Object (“Flash LSOs”)) on our Sites to collect and store information about your use of our Sites. Unlike other cookies, Flash cookies cannot be removed or rejected via your browser settings. If you do not want Flash LSOs stored on your computer or mobile device, you can adjust the settings of your Flash player to block Flash LSO storage using the tools contained in the Website Storage Settings Panel. You can also control Flash LSOs by going to the Global Storage Settings Panel and following the instructions. Please note that setting the Flash Player to restrict or limit acceptance of Flash LSOs may reduce or impede the functionality of some Flash applications, including, potentially, Flash applications used in connection with our Sites.
Web Beacons. We may also use web beacons (which are also known as pixel tags and clear GIFs) on our Sites and in our HTML formatted emails to track the actions of users on our Sites and interactions with our emails. Unlike cookies, which are stored on the hard drive of your computer or mobile device by a website, pixel tags are embedded invisibly on webpages or within HTML formatted emails. Pixel tags are used to demonstrate that a webpage was accessed or that certain content was viewed, typically to measure the success of our marketing campaigns or engagement with our emails and to compile statistics about usage of the Sites, so that we can manage our content more effectively.
Session-replay technologies. We may use products and services provided by Segment, Fullstory, and Logrocket that employ software code to record users’ interactions with the Services in a manner that allows us to watch DVR-like replays of those user sessions. The replays include users’ clicks, mobile app touches, mouse movements, scrolls and keystrokes/key touches during those sessions. These replays help us diagnose usability problems, identify areas for improvement, and maintain records of acceptance of our Service’s terms. You can learn more about Segment at https://www.twilio.com/en-us/legal/privacy. You can learn more about Fullstory at https://www.fullstory.com/legal/privacy-policy. You can learn more about Logrocket at https://logrocket.com/privacy/.

How we use your personal information

We may use your personal information for the following purposes or as otherwise described at the time of collection:

Service delivery and operations. We may use your personal information to:

provide the Service;
enable security features of the Service;
establish and maintain your user profile on the Service;
communicate with you about the Service, including by sending Service-related announcements, updates, security alerts, and support and administrative messages; and
provide support for the Service, and respond to your requests, questions and feedback.

Service personalization, which may include using your personal information to:

understand your needs and interests;
personalize your experience with the Service and our Service-related communications; and
remember your selections and preferences as you navigate webpages.

Service improvement and analytics. We may use your personal information to analyze your usage of the Service, improve the Service, improve the rest of our business, help us understand user activity on the Service, including which pages are most and least visited and how visitors move around the Service, as well as user interactions with our emails, and to develop new products and services.

Marketing and advertising. We, our service providers and our third-party advertising partners may collect and use your personal information for marketing and advertising purposes:

Direct marketing. We may send you direct marketing communications and may personalize these messages based on your needs and interests. You may opt-out of our marketing communications as described in the Opt-out of communications section below.
Interest-based advertising. We and our third-party advertising partners may use cookies and similar technologies to collect information about your interaction (including the data described in the Tracking technologies section above) with the Service, our communications and other online services over time, and use that information to serve online ads that they think will interest you. This is called interest-based advertising. We may also share information about our users with these companies to facilitate interest-based advertising to those or similar users on other online platforms. You can learn more about your choices for limiting interest-based advertising in the Your choices section.

Compliance and protection. We may use your personal information to:

comply with applicable laws, lawful requests, and legal process, such as to respond to subpoenas, investigations or requests from government authorities;
protect our, your or others’ rights, privacy, safety or property (including by making and defending legal claims);
audit our internal processes for compliance with legal and contractual requirements or our internal policies;
enforce the terms and conditions that govern the Service; and
prevent, identify, investigate and deter fraudulent, harmful, unauthorized, unethical or illegal activity, including cyberattacks and identity theft.

Data sharing in the context of corporate events, we may share certain personal information in the context of actual or prospective corporate events – for more information, see How we share your personal information, below.

To create aggregated, de-identified and/or anonymized data. We may create aggregated, de-identified and/or anonymized data from your personal information and other individuals whose personal information we collect. We make personal information into de-identified and/or anonymized data by removing information that makes the data identifiable to you. We may use this aggregated, de-identified and/or anonymized data and share it with third parties for our lawful business purposes, including to analyze and improve the Service and promote our business.

Cookies and similar technologies. In addition to the other uses included in this section, we may use the Cookies and similar technologies described above for the following purposes:

Technical operation. To allow the technical operation of the Service, such as by remembering your selections and preferences as you navigate the site, and whether you are logged in when you visit password protected areas of the Service.
Functionality. To enhance the performance and functionality of our services.
Advertising. To help our third-party advertising partners collect information about how you use the Service and other online services over time, which they use to show you ads on other online services they believe will interest you and measure how the ads perform.
Analytics. To help us understand user activity on the Service, including which pages are most and least visited and how visitors move around the Service, as well as user interactions with our emails. For example, we use Segment and Heap for this purpose. You can learn more about Segment at https://www.twilio.com/en-us/legal/privacy, and Heap at https://www.heap.io/privacy.

Further uses, in some cases, we may use your personal information for further uses, in which case we will ask for your consent to use of your personal information for those further purposes if they are not compatible with the initial purpose for which information was collected.

We may share your personal information with the following parties and as otherwise described in this Privacy Policy, in other applicable notices, or at the time of collection.

Affiliates. Our corporate parent, subsidiaries, and affiliates.

Service providers. Third parties that provide services on our behalf or help us operate the Service or our business (such as hosting, information technology, data providers, customer support, email delivery, marketing, consumer research and website analytics).

Payment processors. Any payment card information you use to make a purchase on the Service is collected and processed directly by our payment processors, such as Stripe. Stripe may use your payment data in accordance with its privacy policy, https://stripe.com/privacy.

Consumer reporting and motor vehicle records partners. As outlined above, we may disclose your personal information to our partners in order to gather information such as your driving record and claims history with other insurers for use in connection with your application for insurance coverage.

Advertising partners. Third-party advertising companies for the interest-based advertising purposes described above.

Third parties designated by you. We may share your personal information with third parties where you have instructed us or provided your consent to do so, including for example, to facilities that can make repairs on your vehicle following an accident.

Linked third-party services. If you log into the Service with, or otherwise link your Service account to, a social media or other third-party service, we may share your personal information with that third-party service. The third party’s use of the shared information will be governed by its privacy policy and the settings associated with your account with the third-party service.

Claims representatives. We may disclose personal information in order to initiate the claim process and so that the claims representative may contact you with additional questions.

Insurance partners. We may share your personal information with our insurance partners to provide you with a policy. If we have difficulties placing a policy for you, we may, at your direction, share your personal information with additional insurance partners to assist in finding you a policy.

Professional advisors. Professional advisors, such as lawyers, auditors, bankers and insurers, where necessary in the course of the professional services that they render to us.

Authorities and others. Law enforcement, government authorities, and private parties, as we believe in good faith to be necessary or appropriate for the Compliance and protection purposes described above.

Business transferees. We may disclose personal information in the context of actual or prospective business transactions (e.g., investments in Hugo, financing of Hugo, public stock offerings, or the sale, transfer or merger of all or part of our business, assets or shares), for example, we may need to share certain personal information with prospective counterparties and their advisers. We may also disclose your personal information to an acquirer, successor, or assignee of Hugo as part of any merger, acquisition, sale of assets, or similar transaction, and/or in the event of an insolvency, bankruptcy, or receivership in which personal information is transferred to one or more third parties as one of our business assets.

Your choices

In this section, we describe the rights and choices available to all users. Users who are located in California can find additional information about their rights below.

Access or update your information. If you have registered for an account with us through the Service, you may review and update certain account information by logging into the account at app.withhugo.com and navigating to “My Info”.

Opt-out of communications. You may opt-out of marketing-related emails by following the opt-out or unsubscribe instructions at the bottom of the email, or by contacting us. Please note that if you choose to opt-out of marketing-related emails, you may continue to receive service-related and other non-marketing emails.

If you receive text messages from us, you may opt out of receiving further text messages from us by replying UNSUBSCRIBE to our message.

Cookies. Most browsers let you remove or reject cookies. To do this, follow the instructions in your browser settings. Many browsers accept cookies by default until you change your settings. Please note that if you set your browser to disable cookies, the Sites may not work properly. For more information about cookies, including how to see what cookies have been set on your device and how to manage and delete them, visit www.allaboutcookies.org. If you do not accept our cookies, you may experience some inconvenience in your use of our Sites. For example, we may not be able to recognize your computer or mobile device and you may need to log in every time you visit our Sites.

Blocking images/clear gifs: Most browsers and devices allow you to configure your device to prevent images from loading. To do this, follow the instructions in your particular browser or device settings.

Mobile location data. You can disable our access to your device’s precise geolocation in your mobile device settings.

Advertising choices. You may be able to limit use of your information for interest-based advertising through the following settings/options/tools:

Browser settings. Changing your internet web browser settings to block third-party cookies.
Privacy browsers/plug-ins. Using privacy browsers and/or ad-blocking browser plug-ins that let you block tracking technologies.
Platform settings. Certain platforms offer opt-out features that let you opt-out of use of your information for interest-based advertising. For example, you may be able to exercise that option for Google and Facebook, respectively, at the following websites:
- Google: https://adssettings.google.com/
- Facebook: https://www.facebook.com/about/ads
Ad industry tools. Opting out of interest-based ads from companies that participate in the following industry opt-out programs:
- Network Advertising Initiative: http://www.networkadvertising.org/managing/opt_out.asp
- Digital Advertising Alliance: https://optout.aboutads.info
- AppChoices mobile app, available at https://www.youradchoices.com/appchoices, which will allow you to opt-out of interest-based ads in mobile apps served by participating members of the Digital Advertising Alliance.
Mobile settings. Using your mobile device settings to limit use of the advertising ID associated with your mobile device for interest-based advertising purposes.

You will need to apply these opt-out settings on each device and browser from which you wish to limit the use of your information for interest-based advertising purposes.

We cannot offer any assurances as to whether the companies we work with participate in the opt-out programs described above.

Do Not Track. Some Internet browsers may be configured to send “Do Not Track” signals to the online services that you visit. We currently do not respond to “Do Not Track” signals. To find out more about “Do Not Track,” please visit http://www.allaboutdnt.com.

Linked third-party platforms. If you choose to connect to the Service through your social media account or other third-party platform, you may be able to use your settings in your account with that platform to limit the information we receive from it. If you revoke our ability to access information from a third-party platform, that choice will not apply to information that we have already received from that third party.

Declining to provide information. We need to collect personal information to provide certain services. If you do not provide the information we identify as required or mandatory, we may not be able to provide those services.

Delete your content or close your account. You can choose to delete certain content through your account.

Other sites and services

The Service may contain links to websites, mobile applications, and other online services operated by third parties. In addition, our content may be integrated into web pages or other online services that are not associated with us. These links and integrations are not an endorsement of, or representation that we are affiliated with, any third party. We do not control websites, mobile applications or online services operated by third parties, and we are not responsible for their actions. We encourage you to read the privacy policies of the other websites, mobile applications and online services you use.

Security

We employ a number of technical, organizational and physical safeguards designed to protect the personal information we collect. However, security risk is inherent in all internet and information technologies and we cannot guarantee the security of your personal information.

International data transfer

We are headquartered in the United States and may use service providers that operate in other countries. Your personal information may be transferred to the United States or other locations where privacy laws may not be as protective as those in your state, province, or country.

Children

The Service is not intended for use by anyone under 13 years of age. If you are a parent or guardian of a child from whom you believe we have collected personal information in a manner prohibited by law, please contact us. If we learn that we have collected personal information through the Service from a child without the consent of the child’s parent or guardian as required by law, we will comply with applicable legal requirements to delete the information.

Changes to this Privacy Policy

We reserve the right to modify this Privacy Policy at any time. If we make material changes to this Privacy Policy, we will notify you by updating the date of this Privacy Policy and posting it on the Service or other appropriate means. Any modifications to this Privacy Policy will be effective upon our posting the modified version (or as otherwise indicated at the time of posting). In all cases, your use of the Service after the effective date of any modified Privacy Policy indicates your acknowledging that the modified Privacy Policy applies to your interactions with the Service and our business.

How to contact us

Email: support@withhugo.com

Important information for California residents

This section applies only to California residents. It describes how we collect, use, disclose, and share Personal Information of California residents in operating our business, and their rights with respect to that Personal Information. The Privacy Notice describes the personal information that we collect, the sources from which we collect it, the purposes for which we use it, the limited circumstances under which we disclose personal information, and with whom we disclose it. For purposes of this section, “Personal Information” and “Sensitive Personal Information” have the meanings given in the California Consumer Privacy Act of 2018, as amended by the California Privacy Rights Act of 2020 (collectively, “CCPA”) and do not include information exempted from the scope of the CCPA.

Your California privacy rights. As a California resident, you may have the rights listed below. However, these rights are not absolute, and in certain cases we may decline your request as permitted by law. We have no actual knowledge that we have sold or shared the personal information of California residents under 16 years of age in the past twelve months. We also do not use or disclose Sensitive Personal Information for purposes that California residents have a right to limit under the CCPA, nor do we engage in automated decision making or profiling, as defined under the CCPA.

Information. You can request the following information about how we have collected and used your Personal Information during the past 12 months:

The categories of Personal Information that we have collected.
The categories of sources from which we collected Personal Information.
The business or commercial purpose for collecting and/or selling Personal Information.
The categories of third parties with whom we share Personal Information.
Whether we have disclosed your Personal Information for a business purpose, and if so, the categories of Personal Information received by each category of third-party recipient.
Whether we’ve sold or shared your Personal Information, and if so, the categories of Personal Information received by each category of third-party recipient.

Access. You can request a copy of the Personal Information that we have collected about you.
Correction. You can ask us to correct inaccurate Personal Information that we have collected about you.
Opt-out of Sharing. You can opt-out of certain processing of personal information for targeted advertising purposes.
- You may also have the right to opt-out of other sales of your Personal Information; however, we do not sell your Personal Information for monetary consideration.
Deletion. You can ask us to delete certain Personal Information that we have collected from you.
Nondiscrimination. You are entitled to exercise the rights described above free from discrimination in the form of legally prohibited increases in the price or decreases in the quality of our Service.

How to exercise your rights

You may exercise your California privacy rights described above as follows:

Right to information, access, correct and deletion. You can request to exercise your information, access, correct and deletion rights by visiting form for collecting rights requests.

Verification of Identity or Authorized agents. We reserve the right to confirm your California residence to process your requests and will need to confirm your identity to process your requests to exercise your information, access or deletion rights. As part of this process, government identification may be required. Consistent with California law, you may designate an authorized agent to make a request on your behalf. In order to designate an authorized agent to make a request on your behalf, you must provide a valid power of attorney, the requester’s valid government-issued identification, and the authorized agent’s valid government issued identification. We cannot process your request if you do not provide us with sufficient detail to allow us to understand and respond to it.

Retention. The criteria for deciding how long to retain Personal Information is generally based on whether such period is sufficient to fulfill the purposes for which we collected it as described in this notice, including complying with our legal obligations.

Personal information that we collect, use, disclose and share.

We have summarized the Personal Information we collect and may disclose to third parties by reference below to both the categories defined in the “Personal information we collect” section of this Privacy Policy above and the categories of Personal Information specified in the CCPA (Cal. Civ. Code §1798.140(v)) and describes our practices currently and during the 12 months preceding the effective date of this Privacy Policy.

Information you voluntarily provide to us, such as in free-form webforms, may contain other categories of Personal Information not described below.

Personal Information (“PI”) we collect	CCPA statutory category	Categories of third parties to whom we “disclose” PI for a business purpose	Categories of third parties to whom we “sell” or “share” PI
Contact data	Identifiers (online) Identifiers (other) Commercial information California customer records	Affiliates Service providers Payment processors Consumer reporting and motor vehicle records partners Third parties designated by you Claims Representatives Insurance partners Professional advisors Authorities and others Business transferees Business and marketing partners	Advertising partners (to facilitate online advertising) Business and marketing partners
Demographic data	Identifiers (online) Identifiers (other) California customer records	Affiliates Service providers Payment processors Consumer reporting and motor vehicle records partners Third parties designated by you Claims representatives Insurance partners Professional advisors Authorities and others Business transferees Business and marketing partners	Advertising partners (to facilitate online advertising) Business and marketing partners
Profile data	Identifiers (online) Identifiers (other) Commercial information California customer records	Affiliates Service providers Payment processors Consumer reporting and motor vehicle records partners Third parties designated by you Claims representatives Insurance partners Professional advisors Authorities and others Business transferees Business and marketing partners	Advertising partners (to facilitate online advertising) Business and marketing partners
Vehicle and insurance data	Identifiers (online) Identifiers (other) Commercial information California consumer records	Affiliates Service providers Payment processors Consumer reporting and motor vehicle records partners Third parties designated by you Claims representatives Insurance partners Professional advisors Authorities and others Business transferees Business and marketing partners	Advertising partners (to facilitate online advertising) Business and marketing partners
Communications data	Identifiers (online) Identifiers (other) Commercial information California consumer records Internet or Network Information	Affiliates Service providers Payment processors Third parties designated by you Claims representatives Insurance partners Professional advisors Authorities and others Business transferees Business and marketing partners	Advertising partners (to facilitate online advertising) Business and marketing partners
Transactional data	Commercial information California consumer records Financial information	Affiliates Service providers Payment processors Third parties designated by you Claims representatives Insurance partners Professional advisors Authorities and others Business transferees Business and marketing partners	Advertising partners (to facilitate online advertising) Business and marketing partners
Marketing data	Identifiers (online) Identifiers (other) Commercial information California customer records Internet or Network Information	Affiliates Payment processors Claims representatives Insurance partners Professional advisors Authorities and others Business transferees	Advertising partners (to facilitate online advertising) Business and marketing partners
Relationship data	Identifiers (online) Identifiers (other) California customer records	Affiliates Service providers Payment processors Third parties designated by you Claims representatives Insurance partners Professional advisors Authorities and others Business transferees Business and marketing partners	Advertising partners (to facilitate online advertising) Business and marketing partners
Government-issued identification number data	Identifiers (online) California customer records	Affiliates Service providers Payment processors Consumer reporting and motor vehicle records partners Third parties designated by you Claims representatives Insurance partners Professional advisors Authorities and others Business transferees Business and marketing partners	Business and marketing partners N/A
Payment data	Commercial information Financial information California consumer records	Affiliates Service providers Payment processors Third parties designated by you Claims representatives Insurance partners Professional advisors Authorities and others Business transferees Business and marketing partners	N/A
Data about others	Identifiers (online) Identifiers (other) California consumer records	Affiliates Service providers Payment processors Consumer reporting and motor vehicle records partners Third parties designated by you Claims representatives Insurance partners Professional advisors Authorities and others Business transferees Business and marketing partners	Advertising partners (to facilitate online advertising) Business and marketing partners
Device data	Identifiers (other) Internet or Network Information	Affiliates Service providers Payment processors Third parties designated by you Claims representatives Insurance partners Professional advisors Authorities and others Business transferees Business and marketing partners	N/A
Online activity data	Identifiers (other) Commercial information Internet or Network Information	Affiliates Service providers Payment processors Third parties designated by you Claims representatives Insurance partners Professional advisors Authorities and others Business transferees Business and marketing partners	N/A
Precise geolocation data	Geolocation data	Affiliates Service providers Third parties designated by you Claims representatives Insurance partners Professional advisors Authorities and others Business transferees Business and marketing partners	N/A
Communication interaction data	Identifiers (online) Identifiers (other) Commercial information California consumer records Internet or Network Information	Affiliates Service providers Payment processors Third parties designated by you Claims representatives Insurance partners Professional advisors Authorities and others Business transferees Business and marketing partners	N/A
Data derived from the above	Inferences	Affiliates Service providers Claims representatives Insurance providers Authorities and others Business transferees Business and marketing partners	N/A
Other Sensitive Personal Information We do not intentionally collect this information, but it may be revealed in identity data or other information we collect	Protected Classification Characteristics	N/A	N/A

Additional information for California residents.

Sensitive personal information. We do not use or disclose sensitive personal information for purposes that California residents have a right to limit under the California Consumer Privacy Act.
Shine the light law. Under California’s Shine the Light law (California Civil Code Section 1798.83), California residents may ask companies with whom they have formed a business relationship primarily for personal, family or household purposes to provide the names of third parties to which they have disclosed certain personal information (as defined under the Shine the Light law) during the preceding calendar year for their own direct marketing purposes, and the categories of personal information disclosed. You may send us requests for this information to support@withhugo.com. In your request, you must include the statement “Shine the Light Request,” and provide your first and last name and mailing address and certify that you are a California resident. We reserve the right to require additional information to confirm your identity and California residency. Please note that we will not accept requests via telephone, mail, or facsimile, and we are not responsible for notices that are not labeled or sent properly, or that do not have complete information.

Contact Us. If you have questions or concerns about our privacy policies or information practices, please contact us using the contact details set forth in the How to contact us section, above.