This policy is effective January 22, 2018.

This online privacy policy applies to all Popular Lab Co. and / or Hugo Insurance Services (“Hugo”) websites and online resources that link to our websites. Hugo is aware of our users’ concerns about their privacy when visiting our website and using online and mobile resources (the “Services”). This policy explains what information we collect about users, how we collect that information, what we use the information for, who we disclose information to, and how users can limit the uses we make of Personally Identifiable Information.

Please read this entire policy before using or submitting information to Us Us through our Services. By using our website, you are agreeing to the terms of this policy, and any information you submit to Hugo through a website or online resource will be collected, processed, used, and disclosed in accordance with these terms.

What Data Do We Collect and How Do We Use It?

Personally Identifiable Information. Hugo websites may collect Personally Identifiable Information, which is information that either directly identifies you or could reasonably be used in combination with other publicly available information to identify you. Examples of Personally Identifiable Information include your name, contact information, email address, and other information in combination with such identifiers. For example, we may use applicants’ Vehicle Identification Numbers (VINs) to access the latest SMOG check through the Bureau of Automotive Repair, which enables us to understand more about our applicants’ vehicles for research purposes.

Certain areas of our Services allow you to submit your Personally Identifiable Information to us. For example, you may submit information to receive an online quote. We may use the information you provide to send you requested information, respond to your inquiry, improve our websites, verify your relationship with Hugo, and take other actions that may be necessary to respond to your request.

Where permitted by law, we may combine Personally Identifiable Information you provide through the use of our Services with other information you’ve provided to Hugo online or offline. We may also combine Personally Identifiable Information collected through our Services with Hugo’s offline records and information provided to us by third parties, where legally permissible. We use this consolidated information to improve our Services, enhance our marketing activities, better design our offerings, and facilitate other business functions.

Here are some examples of the information we collect:

Application and Communications. Through your use of the Service we gather information such as your name, address, garaging address, phone number, email address, residential information, drivers’ license number, gender, date of birth, prior insurance information, vehicle information, vehicle ID number, marital status, and driving history, as well as other information that you may provide through other communication features of the Service.

Consumer Report. Through consumer reporting agencies we may gather information such as your 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. By submitting an application for insurance coverage, you authorize Company 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

Transactions. Through your transactions with us, we gather information such as insurance coverage, payments and claims history, payment instrument information (such as credit card information), and cell phone usage information.

Driving Data. We may have access to and gather your mileage, speed, acceleration, braking, and drive session information from an OBD 2 device or through an application on your phone, but only if you decide to plug it into your vehicle or install the application (the device or application will be provided to you when you explicitly elect use such a device/application and begin Service with us).

Other Information. Our Services also collect other basic information about you which does not directly identify you but which may correspond with you or a particular device. We use this information to learn more about how our Services are used and to otherwise improve and administer the site. We also use this information to enable us to deliver information tailored to your interests and preferences, based on your use of the site. For example, we may collect the Internet Protocol Address assigned to your computer by your internet service provider. This address may change each time you connect to the internet (a “dynamic” IP address), or it may remain the same (a “static” IP address). If you choose to use a referral opportunity to tell a friend about our site, we may ask you for your friend’s name and email address. We will automatically send your friend a one-time invitation email to visit the site, and we may send subsequent reminder emails. Hugo stores this information for the sole purpose of sending the invitation and reminder emails, and for tracking the success of our referral program. Your friend may contact us at support@withhugo.com to request that we remove this information from our database.

To collect certain basic information, we may also use the techniques described below:

Cookies and LSOs. Our websites may use a tracking technology called a “cookie.” A cookie is a small data file that a website can place on your computer’s hard drive, where your internet browser files are kept. Cookies enable us to recognize when a computer has previously visited a Hugo website or online resource. Cookies can also be used to enable a site to “remember” the information a visitor has previously inputted. Cookies may be placed on your computer both by us and by third parties with whom we have a relationship, such as web analytic services and advertising network services. Further information concerning the use of third-party cookies on our site can be found below, in the section titled Our Policy on Cookies and Other Tracking Technologies. We and third parties with whom we partner to provide certain features on our site or to display advertising based upon your web browsing activity use LSOs such as HTML 5 to collect and store information. Various browsers may offer their own management tools for removing HTML5 LSOs.

Web Beacons. On certain web pages or in emails we send to you, we may utilize a technology called a “web beacon” (also known as an “action tag” or “clear GIF technology”). We may use web beacons to help determine which email messages sent by us were opened and whether a message was acted upon. Web beacons also help analyze the effectiveness of websites by measuring the number of visitors to a site or how many visitors clicked on key elements of a site.

Social Plugins. This site may use social plugins (e.g., the Facebook “Like” button) to enable you to easily share information with others. When you visit our site, the operator of the social plugin may be able to place a cookie on your computer, enabling that operator to recognize individuals who have previously visited our site. If you have previously logged into the associated social media website (e.g., Facebook) before browsing on our website, the social plugin allows that social media website to receive information about your visit to particular pages on our website. The social plugin may collect this information for any such visitors who have logged into social networks, whether or not they specifically interact with the plugin on our websites (e.g., by clicking “Like” or “Share”). The social plugin may also allow the social media website to share information about your activities on our websites with other users of their social media website. For further details about the information shared via a particular social media plugin, you should refer to that social media site’s privacy statement.

Does Hugo Disclose Your Information to Third Parties?

We do not sell, share, or otherwise disclose the information we collect through our Services, except as provided in this policy. We may disclose information to third parties who provide us with various business services, including monitoring and maintaining the websites and preparing newsletters and mailings. We may also share Personally Identifiable Information with third parties with whom we are working to provide you with services or information.

We may also disclose information we collect in special cases, including when we have a reason to believe that such disclosure is necessary to identify, contact, or bring a legal action against someone who may be causing injury to or interference with our rights and property or those of any other person. We may also disclose information when we believe the law requires it and in any situation that involves threats to any person’s physical safety.

If all or part of Hugo is merged into another entity, the information we have about you may be transferred to a third party as part of that transaction. We will try to assure that no Personally Identifiable Information that is transferred will be used or shared in a manner inconsistent with this policy without your consent. Your information may also be included among the assets affected by financing agreements undertaken by Hugo. Your continued use of this website would, however, signify your agreement to be bound by the privacy statement and other applicable terms of the subsequent owner or operator.

We may disclose your information to claims representatives, consumer reporting agencies, insurance agents, law enforcement agencies, courts and government agencies. These parties may disclose information to other parties as permitted by law. For example:

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

• A consumer reporting agency may disclose transaction information received from us to other insurance companies with which you do business.

• We disclose information to appropriate entities that make necessary repairs to your vehicle when you are involved in an incident.

Is this Website Intended for Children?

Our Services are not intended for children. We do not knowingly collect any Personally Identifiable Information from children under 13-years old. However, if the parent or the guardian of a child under 13 years old believes that the child has provided Us us with Personally Identifiable Information, the parent or guardian of that child should contact Us us at support@withhugo.com to request the information’s deletion.

How Can You Control and Update Your Information with Hugo?

Hugo wants to keep only accurate information about you. To update or correct your contact information, please email us at support@withhugo.com. Policyholders may call the customer service phone number listed in their coverage information. At any time, you may also email us at support@withhugo.com to ask that we remove your name, contact information, and email address from our lists we use to send our marketing mailings. We use to send our marketing mailings. We may retain a copy of your Personally Identifiable Information, however, for our record-keeping purposes.

Upon request, Hugo will provide you with information about whether we hold any of your personal information. As a consumer, you have the right to review the information we have about you and update, change or delete your information if needed. We will respond to your request within a reasonable timeframe.

We will retain your information for as long as your account is active or as needed to provide you with the Services. We will retain and use your information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.

We can provide consumers with the names of all entities that Hugo has disclosed certain of your personal information to within two years, in accordance with applicable law. We also provide you with information on how to obtain a copy of your credit report (see prior section entitled What Data Do We Collect and How Do We Use It?).

With respect to cookie-based advertising, please be aware that the Digital Advertising Alliance maintains a website where consumers can opt out from receiving interest-based advertising from some or all of the network advertising companies participating in the program (www.AboutAds.info/choices/).

In addition, most internet browsers allow you to change your browser settings to notify you when you receive a cookie, which lets you choose whether or not to accept it, or to automatically refuse all cookies. Please be aware that some functionality on some of our Services relies on the use of cookies and may not be available should you choose to refuse all cookies.

How Does Hugo Keep Your Information Secure?

Hugo takes certain steps to protect your information from unauthorized access. However, no internet or telephone transmission is ever completely secure or error free. In particular, email sent or forms submitted using this website or another online resource may not be secure. You should take special care before deciding to send us information via electronic means. If you create an account with Hugo on our site or other Services, it is your responsibility to protect your access credentials from unauthorized access or use.

Is Hugo Responsible for the Websites It Links to?

We are not. We do not endorse and are not responsible for the content of third-party websites or resources, and our privacy policy does not apply to any sites that are not affiliated with Hugo, even if you access them via a link on our site. You should review the privacy policies of any third-party site before providing any information.

How Can You Contact Us About this Policy?

Questions about this policy may be directed to support@withhugo.com

Your California Privacy Rights: California Civil Code Section 1798.83 permits California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please follow the instructions above (see section entitled How Can You Control and Update Your Information with Hugo), or write to the address provided above. Be sure to include your name and address. If you would like a response via email, please include an email address. Otherwise, we will respond to mailed requests by postal mail within the time required by law.

How Does Our Site Respond to Web Browser “Do Not Track” Signals?

Certain web browsers and other programs may be used to signal your preferences to Hugo about how or whether Hugo or third parties may collect information about your online activities. Currently, our Services do not respond to such signals.

What Else Do You Need to Know?

Hugo reserves the right to amend this policy at our discretion. When changes are made, we will post the updated policy and the date of its revision.