Progressive Privacy Policy

This document is Progressive Insurance's consumer-facing privacy policy, governing the collection, use, storage, and sharing of personal information obtained through its website, mobile applications, and insurance products, with its stated basis being compliance with applicable insurance regulations and voluntary disclosure to customers. The policy states that Progressive collects a broad range of data including name, address, Social Security number, driving history, vehicle telematics, financial information, and browsing behavior, and the terms authorize sharing this information with affiliated companies, service providers, marketing partners, and in some cases non-affiliated third parties for joint marketing purposes. Notably, the policy describes the Snapshot telematics program, which the terms authorize to collect real-time driving behavior data including speed, braking, time of day, and location, representing an operationally distinct data collection practice that goes beyond standard insurance application data; the policy also asserts rights to use customer data for marketing and analytics purposes, though applicable state insurance privacy regulations and the California Consumer Privacy Act may constrain some of these asserted rights in practice. The policy engages the Gramm-Leach-Bliley Act's privacy notice requirements, California's CCPA and CPRA frameworks, and state insurance department privacy regulations enforced by state insurance commissioners; California residents in particular are granted specific opt-out and deletion rights under CCPA that are referenced in the policy. Material compliance considerations include the adequacy of consent mechanisms for telematics data collection, the scope of third-party data sharing disclosures, and alignment of marketing data use with state insurance privacy statutes that may impose restrictions beyond what the policy describes.