Last Updated: August 08, 2025

Welcome to Covered by Carl. We respect your privacy and are committed to protecting your personal information. This Privacy Policy outlines how we collect, use, disclose, and safeguard your personal information when you interact with our website, quiz, and services. We do not collect data from individuals under 18.

1. Who We Are

Covered by Carl is a lead generation platform operated by Jeremy Essers, registered in Canada. All services are provided from Canada. We work with licensed auto insurance specialists in Australia. We comply with the Australian Privacy Act 1988, Spam Act 2003, Australian Consumer Law (ACL), Canadian Personal Information Protection and Electronic Documents Act (PIPEDA), Canada’s Anti-Spam Legislation (CASL), and Quebec’s Act respecting the protection of personal information in the private sector. Jeremy Essers is our accountability officer for data protection.

Business Contact Information:

Covered by Carl

6365 Rue Marquette, Montréal, QC, Canada H2G 2Y3

Email: [email protected]

Phone: +1 (613) 252-5972

2. What Information We Collect

We collect only necessary information when you visit our website or complete our quiz:

Personal Information:

• Name
• Mobile phone number (for verification via SMS)
• Email address
• City or postcode
• Answers to quiz questions about your vehicle, driving history, and insurance needs (sensitive data, such as details on accidents or claims, processed with explicit consent)

Device & Usage Data:

• IP address
• Browser type and version
• Pages visited and actions taken
• Time and date of visit
• Cookies and tracking technologies (see Section 6)

3. How We Use Your Information

We use your information to:

• Assess whether you may qualify to be connected with a licensed auto insurance specialist (no insurance advice or recommendations)
• Verify your identity via secure SMS
• Share your contact details with one licensed specialist only if you consent
• Improve our services, website performance, and advertising
• Comply with legal obligations

We may use artificial intelligence (AI) and machine learning (ML) technologies to analyze quiz responses, personalize user experiences, and optimize lead matching processes. This includes using AI models to evaluate eligibility based on provided data, detect patterns for service improvements, and enhance fraud detection. AI processing is conducted securely, with human oversight where necessary, and does not involve automated decision-making that produces legal effects or similarly significant impacts on individuals without your consent. We ensure AI tools comply with privacy laws, including transparency and fairness principles under the Australian Privacy Act 1988.

Legal Basis: Consent for sharing and AI processing; legitimate interest for analytics (balanced with your rights); legal obligations for compliance. For sensitive information (e.g., driving history), we rely on explicit consent.

4. When and How We Share Your Information

We will only share your personal information in these cases:

• With one ASIC-licensed auto insurance specialist (verified via ASIC register) if you are eligible and have provided explicit consent
• With trusted service providers who help us deliver the website and quiz (e.g., hosting, SMS verification, AI/ML tools), bound by contracts ensuring Privacy Act and PIPEDA compliance
• Where required by law or regulators (e.g., Australian Consumer Law, Privacy Act, PIPEDA)
• In connection with the sale or transfer of our business, provided protections are in place

We do not sell your information. We do not share your details with multiple specialists. For international transfers (e.g., to Canada), we use standard contractual clauses and encryption. If sharing involves AI/ML providers, we ensure they adhere to data protection standards and process data only for specified purposes.

5. Legal Basis for Processing

We collect and process your information based on:

• Your explicit consent (checkbox and SMS verification during the quiz)
• Our legitimate interest in providing and improving the service, including AI/ML enhancements
• Our legal obligations (e.g., data protection and regulatory compliance)

For sensitive information and AI/ML processing, we rely on explicit consent.

6. Cookies and Tracking

We use cookies and third-party analytics tools (e.g., Meta Pixel, Google Analytics) to understand how our site is used and improve user experience. We obtain consent via a cookie banner. You can opt out via browser settings or Do Not Track signals.

7. International Data Transfers

Your information may be processed and stored in Canada or other countries outside Australia. Transfers comply with Australian Privacy Principle (APP) 8 (adequate protection via PIPEDA equivalence) and PIPEDA Principle 8. We use AES-256 and TLS encryption and standard contractual clauses for safeguards.

8. How We Protect Your Data

• AES-256 and TLS encryption for data at rest and in transit
• Secure data storage via industry-leading platforms (e.g., Airtable, Make)
• Access controls and logging
• Regular system audits, including AI/ML model reviews for bias and accuracy

In case of a data breach, we notify affected individuals and regulators (OAIC in Australia, OPC in Canada) within 72 hours if harm is likely, per Privacy Act and PIPEDA requirements.

9. Your Rights

You have the right to:

• Request access to the personal information we hold about you, including details on AI/ML processing
• Correct inaccurate or outdated information
• Withdraw your consent at any time (which may limit AI-enhanced services)
• Request deletion of your personal information
• File a complaint with the Office of the Australian Information Commissioner (OAIC, oaic.gov.au) or the Office of the Privacy Commissioner of Canada (OPC, priv.gc.ca)

Requests are processed within 30 days (OAIC/PIPEDA standard). Contact us at [email protected]

10. Data Retention

We retain quiz data for 7 years to comply with legal and audit requirements (e.g., ASIC/ACCC). If you withdraw consent, we delete your data unless retention is legally required (e.g., for record-keeping). AI/ML training data is anonymized where possible and retained only as needed for model improvement.

11. Contact Us

If you have any questions about this Privacy Policy or how we handle your data, including AI/ML usage, please contact:

Covered by Carl

Jeremy Essers

6365 Rue Marquette, Montréal, QC, Canada H2G 2Y3

Email: [email protected]

Phone: +1 (613) 252-5972

For privacy complaints:

• Australia: OAIC (oaic.gov.au)
• Canada: OPC (priv.gc.ca)

12. Changes to This Policy

We may update this Privacy Policy from time to time. The most current version will always be available on our website. Material changes will be emailed to users where possible.

13. External Links

This website may contain links to third-party websites. We are not responsible for the privacy practices or content of those sites.

14. Lead Generation Specifics

We share leads exclusively with one ASIC-licensed auto insurance specialist. No insurance advice or matching guarantees—data is passed based on explicit consent. We do not provide insurance recommendations; results depend on your circumstances.

15. Anti-Spam Compliance

Emails and SMS include opt-out options (e.g., “Reply STOP” for SMS, unsubscribe link for emails). We comply with Australia’s Spam Act 2003 and Canada’s Anti-Spam Legislation (CASL); no unsolicited messages are sent without consent.

16. Governing Law

For Australian users, we comply with the Privacy Act 1988, Spam Act 2003, and Australian Consumer Law (ACL). For Canadian operations, we comply with PIPEDA and CASL. Quebec residents: compliant with the Act respecting the protection of personal information in the private sector.

By using our website or submitting your information through our quiz, you agree to the terms outlined in this Privacy Policy.