Progressive

"Once downloaded, the App will run in the background and collect and analyze driving and phone sensor data ('Accident Response Data'), which will be uploaded to Progressive. Accident Response Data includes vehicle speed and location using GPS, time and date information, phone usage and settings, data from the phone's sensors."

The app runs in the background continuously collecting GPS location, vehicle speed, and sensor data, uploading it to Progressive. This applies to both the Snapshot and Accident Response features.

"Mobile phone information includes Wi-Fi status, whether your screen is locked, whether you are calling or otherwise using your phone, motion activity or activity recognition, whether the phone is connected to a Bluetooth® device, date/time stamp, and operating system data available to the App. Driving data includes data from the phone's sensors such as magnetometer, gyroscope, barometer, proximity, and accelerometer."

The app accesses a wide range of device sensors (magnetometer, gyroscope, barometer, proximity, accelerometer) plus monitors phone call activity, Wi-Fi status, Bluetooth connections, and screen lock state — well beyond basic insurance functionality.

"We may work with third parties to install cookies, web beacons, tags, scripts, software development kits (SDK), and other similar technologies within the App. The data collected through these technologies include your device time zone, device operating system, device model and carrier, screen size, processor cores, total and remaining disk space, device and advertising identifiers and device opt-out settings. Some of these third parties may be able to associate the data collected through these technologies with other information they already have about you."

Third-party SDKs embedded in the app collect device identifiers, hardware specs, and advertising IDs, and can link this data with other information they already have about users to serve personalized ads.

"This includes Cross-Context Behavioral Advertising purposes such as compensation for leads and analysis of advertising effectiveness. 'Cross-Context Behavioral Advertising' means targeting advertising to a Consumer based on the Consumer's Personal Information obtained from that person's activity across businesses, distinctly-branded websites, applications, or services, other than the business, distinctly-branded website, application, or service with which the person intentionally interacts."

Progressive explicitly engages in cross-context behavioral advertising, tracking users across different businesses, websites, and services to target ads based on activity outside of Progressive's own platforms.

"The minimum length of time for which we will retain the Personal Information we collect varies based on applicable statutes of limitations and whether we think we might need the information for court or other official proceedings. When you are no longer our customer, we continue to share your information as described in this notice."

Progressive provides no specific retention period, keeping data as long as they think they might need it for legal proceedings, and continues sharing data even after the customer relationship ends.

"Please note: If you are a new customer, we can begin sharing your information 30 days from the date we provided this notice. When you are no longer our customer, we continue to share your information as described in this notice. However, you can contact us at any time to limit our sharing."

Progressive can begin sharing new customers' data after 30 days with no opt-in required, and continues sharing data even after the customer relationship ends, with the burden on the consumer to actively opt out.