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Progressive uses IP address geolocation technology to identify the general geographic location of website visitors in order to display state- or city-specific content, and the document states that this process does not collect personal information.
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
This provision discloses the use of IP-based geolocation for content personalization and asserts that the process does not constitute collection of personal information, though the classification of IP addresses as personal information under applicable privacy statutes varies by jurisdiction.
Interpretive note: The classification of IP addresses as non-personal information is contested under CCPA and GDPR, which may define IP addresses as personal data or personal information subject to regulatory requirements.
The agreement discloses that Progressive identifies the general geographic location of website visitors using IP address geolocation; the document states this does not constitute receipt of personal information, though applicable law in certain jurisdictions may classify IP addresses differently.
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"When you visit our Web site, you may see messages tailored to your specific state or city. We are able to identify your general geographic location using a system that recognizes and pinpoints the location of publicly routed IP addresses - the unique numbers computers use to communicate with other devices on computer networks. Though we can identify your geographic location, we do not receive your personal information. We identify your location only to provide a more tailored experience for you.Excerpt from Progressive's Terms of Use
1. REGULATORY LANDSCAPE: The characterization of IP address geolocation as not constituting collection of personal information may require evaluation under the CCPA, which broadly defines personal information to include IP addresses and inferences drawn from them. GDPR classifies IP addresses as personal data in most circumstances. The FTC Act and applicable state privacy statutes may also engage depending on how this data is retained, linked, or used. 2. GOVERNANCE EXPOSURE: Medium. The document's assertion that geographic identification does not involve receipt of personal information is a legal characterization that may not align with CCPA or GDPR definitions. If IP addresses are logged or retained in connection with site visits, the assertion may require review against the company's data mapping and privacy notice obligations. 3. JURISDICTION FLAGS: California residents are afforded broad personal information rights under the CCPA, and the CCPA's definition of personal information likely encompasses IP addresses. EU and EEA users are protected by GDPR, which treats IP addresses as personal data, and the document's assertion to the contrary would require evaluation under GDPR's lawful basis and transparency requirements. 4. CONTRACT AND VENDOR IMPLICATIONS: If the IP geolocation system is operated by a third-party vendor, the vendor relationship should be reviewed to confirm data processing agreements and data retention practices are consistent with CCPA, GDPR, and applicable state privacy frameworks. 5. COMPLIANCE CONSIDERATIONS: The full scope of IP address data practices should be documented in the company's Privacy and Security Policy referenced separately, and legal teams should confirm that the characterization of IP geolocation as non-personal-information is consistent with the company's privacy notice obligations under applicable state and federal law.
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This provision discloses the use of IP-based geolocation for content personalization and asserts that the process does not constitute collection of personal information, though the classification of IP addresses as personal information under applicable privacy statutes varies by jurisdiction.
The agreement discloses that Progressive identifies the general geographic location of website visitors using IP address geolocation; the document states this does not constitute receipt of personal information, though applicable law in certain jurisdictions may classify IP addresses differently.
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