Progressive · Progressive Privacy Policy · View original document ↗

Snapshot Telematics Data Collection

High severity High confidence Explicitdocumentlanguage Unique · 0 of 325 platforms
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Document Record

What it is

If you join the Snapshot program, Progressive continuously monitors your driving behavior including how fast you go, how hard you brake, and when you drive, and uses that data to set your insurance premium.

This analysis describes what Progressive's agreement states, permits, or reserves. It does not constitute a legal determination about enforceability. Regulatory applicability and practical outcomes may vary by jurisdiction, enforcement context, and individual circumstances. Read our methodology

ConductAtlas Analysis

Why it matters (compliance & governance perspective)

This is one of the most expansive data collection practices in consumer insurance: your real-time behavioral and location data is collected continuously and directly tied to how much you pay for coverage.

Consumer impact (what this means for users)

Participating in Snapshot means Progressive collects ongoing data about your driving habits and physical location, which can raise or lower your insurance premium based on how you drive. Withdrawing from the program may not automatically delete historical telematics data already collected.

What you can do

⚠️ These actions may provide transparency or partial mitigation but may not fully address the underlying issue. Effectiveness varies by jurisdiction and individual circumstances.
  • Delete Your Data
    Visit progressive.com/privacy/ and use the data rights request form to request deletion of telematics data collected through the Snapshot program. California residents can submit a CCPA deletion request; availability of deletion for non-California residents may vary.

How other platforms handle this

PlanetScale Medium

When you visit the Careers portion of our websites, we collect the information that you provide to us in connection with your job application. This includes but is not limited to business and personal contact information, professional credentials and skills, educational and work history and other in...

American Airlines Medium

American does not knowingly collect personal information directly from children – persons under the age of 13, or another age if required by applicable law – other than when required to comply with the law or for safety and security reasons. Due to the nature of our Services, we may collect travel i...

GOAT Medium

We may collect information about your location, including precise geolocation information, when you use our Services. We use this information to provide location-based services, such as showing you products available in your area, and for other purposes described in this Privacy Policy.

See all platforms with this clause type →

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▸ View Original Clause Language DOCUMENT RECORD
"
The Snapshot program uses a device or mobile app to collect information about how, how much, and when you drive. This includes information such as speed, braking, time of day, and miles driven. We use this information to calculate your insurance rate.

— Excerpt from Progressive's Progressive Privacy Policy

ConductAtlas Analysis

Institutional analysis (Compliance & governance intelligence)

REGULATORY LANDSCAPE: Continuous collection of location and driving behavior data implicates state-level location privacy statutes and, depending on how the data is processed, may engage the Illinois Biometric Information Privacy Act if any biometric identifiers are associated with driving profiles. The FTC has issued guidance on connected devices and data minimization principles that apply to telematics. State insurance regulators in California, New York, and other jurisdictions have authority over whether telematics-based pricing is actuarially justified and transparently disclosed to consumers. GOVERNANCE EXPOSURE: High. Continuous behavioral and location data collection from policyholders creates heightened exposure under state privacy laws, insurance rating statutes, and emerging connected-vehicle regulations. The scope of data retention and whether telematics data is ever shared with or sold to third parties beyond rate calculation is a material disclosure gap that compliance teams should verify. JURISDICTION FLAGS: California residents have CCPA rights to know what telematics data has been collected and to request deletion; the California Privacy Protection Agency has authority to enforce these rights. Illinois BIPA creates additional exposure if any behavioral data is linked to biometric identifiers. Several states have enacted or are considering location data privacy laws that may require explicit opt-in consent for continuous location tracking. CONTRACT AND VENDOR IMPLICATIONS: If telematics data is processed by a third-party analytics vendor, data processing agreements must include CCPA-compliant service provider restrictions and should address retention limits, deletion obligations, and restrictions on secondary use. Procurement teams should assess whether Snapshot device manufacturers or app partners have access to raw location data and whether those relationships are documented in vendor agreements. COMPLIANCE CONSIDERATIONS: Compliance teams should audit the consent mechanism at Snapshot enrollment to confirm it satisfies opt-in requirements where applicable, and review data retention schedules for telematics data. A data mapping exercise should document what Snapshot data is stored, for how long, and which vendors have access. Progressive's privacy policy should be reviewed to confirm whether telematics data is included in the categories subject to California opt-out rights.

Full compliance analysis

Regulatory citations, enforcement risk, and due diligence action items.

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Applicable agencies

  • FTC
    The FTC has jurisdiction over unfair or deceptive data collection practices involving connected devices and consumer behavioral data, including telematics programs.
    File a complaint →
  • State AG
    State attorneys general, particularly in California, enforce consumer privacy rights related to continuous location and behavioral data collection under the CCPA and state insurance privacy laws.
    File a complaint →

Applicable regulations

CCPA/CPRA
California, USA
Connecticut Data Privacy Act Amendments
US-CT
ePrivacy Directive
European Union
FCRA
United States Federal
FTC Act Section 5
United States Federal
GDPR
European Union
GLBA
United States Federal
Indiana Consumer Data Protection Act
US-IN
Kentucky Consumer Data Protection Act
US-KY
Universal Opt-Out Mechanism Expansion 2026
US

Provision details

Document information
Document
Progressive Privacy Policy
Entity
Progressive
Document last updated
May 5, 2026
Tracking information
First tracked
May 8, 2026
Last verified
May 11, 2026
Record ID
CA-P-010035
Document ID
CA-D-00599
Evidence Provenance
Source URL
Wayback Machine
Content hash (SHA-256)
b8ce3eebdae1d6ebc57bb85684b2402ab308666262264a794a453df2f30860f9
Analysis generated
May 8, 2026 12:35 UTC
Methodology
Evidence
✓ Snapshot stored   ✓ Hash verified
Citation Record
Entity: Progressive
Document: Progressive Privacy Policy
Record ID: CA-P-010035
Captured: 2026-05-08 12:35:51 UTC
SHA-256: b8ce3eebdae1d6eb…
URL: https://conductatlas.com/platform/progressive/progressive-privacy-policy/snapshot-telematics-data-collection/
Accessed: May 13, 2026
Permanent archival reference. Stable identifier suitable for legal filings, compliance documentation, and research citation.
Classification
Severity
High
Categories

Other risks in this policy

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Frequently Asked Questions

What does Progressive's Snapshot Telematics Data Collection clause do?

This is one of the most expansive data collection practices in consumer insurance: your real-time behavioral and location data is collected continuously and directly tied to how much you pay for coverage.

How does this clause affect you?

Participating in Snapshot means Progressive collects ongoing data about your driving habits and physical location, which can raise or lower your insurance premium based on how you drive. Withdrawing from the program may not automatically delete historical telematics data already collected.

Is ConductAtlas affiliated with Progressive?

No. ConductAtlas is an independent monitoring service. We are not affiliated with, endorsed by, or sponsored by Progressive.