Techpilot project (telematics pilot for new drivers)
Participant terms and conditions and consent to participate
These Terms and Conditions and Consent to Participate in the Techpilot project include:
- Section 1: Introduction
- Section 2: About the Pilot
- Section 3 Privacy
- Section 4 Terminating Participation
- Section 5 Disclaimers, Limitation of Liability and Trademarks
- Section 6: Consent/Agreement
“Augeo” means Augeo Affinity Marketing, Inc., a rewards platform provider used to redeem participation incentives and driving behaviour rewards.
“Application” or “Digital Driver Mobile Application” means the smartphone application used for collection of driver data and for providing feedback to drivers.
“Distracted Driving Score” means the score that is produced based on mobile phone usage while driving the vehicle. The score is generated by Octo’s proprietary algorithm.
“DriveAbility® Score” or “Score” means the score that is produced based on driving behaviour including acceleration, speeding, hard braking, distance driven, and driving environment including time of day, road type, traffic, and weather. The score is generated by Octo’s proprietary algorithm.
“Graduated Licensing Program” or “GLP” means the step program in which Learner and Novice drivers achieve driving proficiency.
“ICBC” means the Insurance Corporation of British Columbia, a provincial Crown corporation
“Novice driver” means someone who holds a class 7N Novice BC driver’s licence.
“Octo” means Octo Telematics North America, LLC (Octo), a telematics service provider.
“Participant” means a participant in the Pilot.
“Participant Information” means information that is collected about the participant’s driving behaviours by the telematics instrumentation including Trip and driving information (such as location as recorded by the GPS, distance, speed, acceleration, hard braking, time of day), the participant scores for the Trips and challenges the participant completes, the participant’s interactions with the Application, and the Participant’s PI.
“Personal Information” or “PI” means personal information collected in accordance with the Freedom of Information and Privacy Act (FIPPA). PI is recorded information about an identifiable individual, other than contact information.
“Pilot” or “Techpilot” means the Telematics Pilot for New Drivers.
“Smart Tag” or “Sensor” means a telematics sensor used in the Pilot.
“Trip” means a period of travel no less than one kilometer.
“Vehicle” means the vehicle identified as the one that will be used by the Participant for the Pilot. Participants will only be associated with one vehicle during the pilot. Data will only be collected when the Participant is driving the Vehicle.
Participation in the Pilot is contingent on the express acceptance of these Terms and Conditions.
Participants must accept the terms and conditions, in their entirety, as set out in this document, to be eligible to participate in the Pilot.
We reserve the right to modify these Terms and Conditions for minor, non-substantive changes. Significant changes to the Terms and Conditions will only be made with Participants’ consent and Participants will be notified in advance.
BC provincial law prohibits drivers from using a mobile device in any manner while driving if they are in the GLP program (holders of N licenses). While BC provincial law allows for some limited hands free use for fully licensed drivers, for the Participant’s own safety and the safety of everyone else on the road, ICBC strongly encourages all drivers to avoid using their mobile device or the Application while driving.
2. The pilot
2.1 About the pilot
ICBC is implementing the Pilot for drivers with less than four years of driving experience from the first date of issue of their Novice driver’s licence. The purpose of the pilot is to assist ICBC in understanding the effectiveness of telematics solutions, specifically to assess whether telematics programs would have a positive impact on crash rates through incentivizing driving behaviour improvement. The goals of the Pilot are to understand the potential for telematics to:
- improve driver behaviour and reduce distracted driving resulting in fewer crashes,
- improve the driving competency of Novice drivers (in BC’s Graduated Licensing Program), and
- deliver a positive customer experience that promotes safe driving.
ICBC is working with a third party vendor, Octo, to provide telematics technology and services for this Pilot.
Pilot participants will be randomly split into two groups:
- Group A will have the telematics technology installed but will not have access to Application features and feedback. Feedback will be provided at the end of the Pilot only; and
- Group B will have the telematics technology installed and will have access to the Application features and feedback during the Pilot.
2.2 How the Pilot works
The Pilot monitors driver behaviour through an application installed on the Participant’s smartphone that is paired with the Smart Tag.
For the purposes of the Pilot, Participants will be required to attach Octo’s self-powered Smart Tag telematics sensor to the windshield behind the rear-view mirror in the vehicle they will be driving during the Pilot. Participants will also install Octo’s Digital Driver telematics application on their smartphone. The Smart Tag and the Application include instrumentation (a GPS, accelerometer, and gyroscope) which is used to collect telematics data about the Participant’s driving behaviour. Data will be transmitted from the Smart Tag to the Participant’s smartphone via Bluetooth. The telematics data is transmitted to Octo via the Participant’s cellular network. More information on the data collected, transmitted, used, stored and accessed is provided in section 3.
A DriveAbility® Score and a Distracted Driving Score will be generated for each Trip a Participant takes.
Additionally, Octo will generate an overall DriveAbility® Score and an overall Distracted Driving Score that is composed of all Trips a Participant drives. The scores are based on the telematics data augmented with contextual data such as road conditions, weather conditions, and traffic data.
Participants in Group A will not be provided with feedback on driving behaviour during the data collection phase of the Pilot. A summary of driving behaviour as measured by the telematics instrumentation will be provided to Group A participants at the end of the Pilot.
Participants in Group B will be provided their scores and feedback to assist them in understanding and potentially improving their driving behaviour. For a seven day period after each Trip, Group B Participants are able to review the Trip route on the Application map, along with any events such as speeding, distracted driving or acceleration.
Group B will be provided additional engagement features including driver behaviour challenges, an opt-in leaderboard, and driver education.
ICBC will use this information, along with information about the vehicle and its insurance policy, and the participant’s historical and ongoing claims and traffic convictions information, along with Participant’s years of driving experience to analyze the overall effectiveness of the telematics services as a whole.
Please see Section 3 for more details on how personal information is collected and used.
2.3 Pilot participation incentives and driving behaviour rewards
Participants in Group A will be eligible for a participation incentive equivalent to $250 CAD.
Initial participation incentives will be delivered after the Application is activated and paired with the Smart Tag (the “Activation Date”), and subsequent participation incentives will be delivered after three, six, nine, and 12 months following the start of the Pilot and can be claimed in accordance with rules set forth in Section 2.4 Claiming Rewards.
Participants in Group B are able to select and complete challenges to earn diamonds which are the virtual currency. Challenges are tasks the Participant’s complete that are aligned to good driving behaviour such as completing a Trip without speeding.
Participants in Group B will be eligible for a total potential incentive equivalent to $250 CAD (in diamonds) consisting of two parts:
- a participation incentive equivalent to $70 CAD, and
- a driver behaviour reward equivalent of up to $180 CAD.
Initial participation incentives will be delivered after the Activation Date, and subsequent participation incentives will be delivered after six and 12 months following the start of the Pilot and can be claimed in accordance with rules set forth in Section 2.4 Claiming Rewards.
Driver behaviour rewards can be earned throughout the 12-month period.
2.4 Claiming rewards
Diamonds earned will be shared with ICBC, Octo and Augeo to facilitate the provision of rewards.
Augeo will provide a catalogue of digital rewards that can be redeemed at well-known retailers and restaurants. Rewards can be redeemed at any time during the pilot duration and for up to 30 days after the pilot concludes.
PARTICIPANTS MUST REDEEM ALL AWARDS BY DECEMBER 15, 2020. The Application and incentives catalogue will not be available after December 15, 2020.
2.5 Participation eligibility
Participation in the Pilot is voluntary and is at no cost to the Participant, other than phone data usage (the Application consumes an average 50 megabytes of data per month or equivalent to a 30 second YouTube video).
Participants may cease participation at any time, for any reason. However, Participants who withdraw from the program will not be eligible for the participation incentives other than those already received. Unless otherwise requested by the participant, all participant information that has been collected up to the point that consent is withdrawn will remain ICBC property and be analyzed by ICBC as outlined in Section 3.2 of these Terms and Conditions.
Participants must have four years or less of driving experience as of November 15th 2019. Driving experience is defined as time licensed in BC with a Class 7N (Novice) driver’s licence plus time licensed with a Class 5 driver’s licence, plus time licensed out of the province with the equivalent of a Novice or Class 5 driver’s licence.
The Vehicle used for the Pilot must be licensed and insured in BC, and must be insured in one of the following rate classes: 001, 002, 003, 004 or 007. The vehicle must be either private passenger or light commercial type vehicle.
The Pilot is intended for those who expect to drive the Vehicle on a regular basis and it is expected participants will drive the Vehicle a minimum of 1,000 kilometers during the Pilot. If participants do not reach the minimum 1,000 kilometers within the duration of the Pilot, they will not be eligible for the final incentives installment or to redeem any rewards balance after the Pilot concludes.
Participants will be required to participate in one short survey before the Pilot commences, and in a second one after the Pilot is complete. The surveys are intended to provide ICBC with information on Participant experience.
Participants who have been enrolled in the Pilot will receive an email with further Pilot details, and with instructions on Application activation.
2.6 Smart Tag Sensor
The Smart Tag on-board sensor unit is a piece of electronic equipment which records and transmits vehicle acceleration data.
The vehicle must have the Smart Tag attached to the windshield in the manner described in the Installation Guide. The Smart Tag must be calibrated with the Application in the manner described in the Installation guide.
The Smart Tag sensor is owned by ICBC for the duration of a Participant’s participation in the Pilot. A Participant should not remove, alter, damage or destroy the Sensor until the Pilot is complete. If the Smart Tag is removed, altered, damaged or destroyed, Participants must contact ICBC for a replacement; if ICBC is not advised and no replacement is issued, then the participant will be removed from the Pilot and will not be eligible for further rewards.
Participants should contact ICBC in the following situations to have a replacement Smart Tag mailed at no cost:
- If the vehicle is replaced (i.e. sold, turned in if a leased vehicle, or is otherwise no longer used for the Pilot) and the participant wishes to continue participating in the Pilot with a replacement vehicle.
- If the windshield of the vehicle is replaced.
- If the Smart Tag sensor is faulty when it’s received, or if the Sensor appears to become faulty during the Pilot.
After the completion of the Pilot, the Participant is not required to return the Smart Tag.
Participants will only be associated to one vehicle for the purposes of the Pilot and therefore only one Smart Tag sensor may be active for each Participant at any given time. If multiple Participants are using the same vehicle, each Participant will require a Sensor.
2.7 Smartphone Requirements
All participants must have a smartphone (iPhone with iOS 10 or higher, or Android phone with version 6.0 or higher) which is compatible with the most-recent version of the Application (iOS or Android).
Participants must maintain a data plan at all times for the duration of their participation in the Pilot, allowing for data to be collected and transferred to Octo.
The Application uses a certain amount of power from the smartphone battery. Care should be
taken to ensure the smartphone is always charged and turned on when driving to record the telematics information.
The smartphone’s location services (GPS) should be enabled in the App at all times to provide for accurate data collection. iPhone users also must have fitness monitoring enabled, so the phone’s accelerometer and gyroscope capabilities are enabled.
Bluetooth must be enabled to allow the Smart Tag to communicate with the Application while the participant is driving the vehicle.
The Application will not interfere with other smartphone features such as Do Not Disturb While Driving.
Note that the Application should be downloaded onto only one smartphone per Participant. Participants may transfer the Application to another Smartphone if required. Participants must first sign out of the Application on their initial smartphone, then download the Application onto their new smartphone and log in to the Application.
The Application is free and can be downloaded via Wi-Fi or using cellular data from the App Store (iPhone) or Google Play (Android).
The Application itself will use cellular data to transfer telematics data to Octo and then to ICBC. Participants are responsible for assuming all roaming fees, data fees (including any overage), plan fees and any other fees their mobile service provider may charge as a result of the download and use of the Application. Please note that while roaming, unless data is turned off on the smartphone, telematics data will continue to be transferred. Participants are not required to have data roaming enabled for the Pilot and therefore may wish to review their smartphone’s settings to ensure data does not transfer while roaming.
The area where a Participant lives or uses their vehicle must have cellular coverage available to sufficiently transmit telematics data. The Application will not transmit data relating to a Participant’s driving behaviour where cellular coverage is insufficient or non-existent.
2.8 The Application
Installation and Activation
Participants will receive an email with Application installation and activation instructions (iPhone and Android).
Once installed and activated, the Application must be running at all times that the Participant is driving the Vehicle. The smartphone with the Application installed must be in the Vehicle when the Participant is operating the Vehicle so the Application can detect and record the telematics data from each Trip. The Application may require periodic updates and updating the Application from time to time is the Participant’s responsibility. Participants must ensure the most recent version of the Application is installed at all times.
The Application will identify all Trips as Trips with the Participant as the driver of the Vehicle.
In order for the Application to generate the most accurate results, Group B participants should exclude Trips on the Application where they were not the driver of the Vehicle, such as a Trip where they were a passenger. Any exclusions must be completed within five days of the Trip or it will be deemed a Trip attributable to the participant as the driver.
All Trips that are not removed within the five day post-Trip period will be used in the calculation of the DriveAbility® and Distracted Driving Scores.
Group B participants will have access to a number of Application features, but are not required to use any of the features that are provided as part of the Pilot.
ICBC is committed to protecting Participants’ privacy and safeguarding Participants’ personal information in accordance with the BC Freedom of Information and Protection of Privacy Act (“FIPPA”). A more detailed description of the Participant Information that may be collected during the Pilot is provided below.
During the Pilot, ICBC will collect various types of personal information from Participants including data about their driving behaviours, driving locations, their scores, and other telematics data (collectively, “Participant Information”). The collection, use of, storage and access to, and destruction of the data that is collected and generated in the Pilot is described below.
3.1 Collection of participant information
To facilitate the delivery of telematics services to Participants, ICBC will collect the following information from Participants:
- first and last name
- valid email address
- mailing address
- mobile phone number
- confirmation the Participant has a smartphone with a data plan
- telematics data*
- incentives/rewards data**
- driver training history
- Vehicle licence plate number
- Vehicle make
The Octo Smart Tag sensor and mobile Application will collect data from the Participant as they are driving, which is the telematics data. This information will only be collected while the smartphone and app are paired. The telematics data includes:
- geographic location and coordinates (i.e. identified through the GPS)
- Note that geographic location data is used solely for the purpose of analyzing driving behaviour and providing Participants with detailed event mapping. GPS data is anonymized after seven days at which point it is no longer personally identifiable.
- speed of travel and average speed
- accelerometer and gyroscope data including average acceleration, deceleration and cornering
- when Trips occur including both starting and stopping (date and time of day)
- amount of time travelled
- distance driven in kilometers
- distraction events (including hands free calls and phone handling; but not the applications or content accessed while distracted driving)
- whether a Participant has indicated that they were NOT the driver of a Trip that was recorded
- interactions with the telematics mobile Application
To facilitate providing Participants with incentives and rewards, ICBC, Octo and Augeo will have record of incentives data, including:
- Rewards and pilot participation points (experience points (XP) and diamonds)
- Purchase history of the rewards redemption catalogue
3.2 Use and Disclosure of Participant Information
Logistics and Support
ICBC will provide Octo with the following Participant Information: name, email address, phone number, and mailing address. This information will be used by Octo for program administration, logistics and support during the Pilot, including but not limited to:
- sending Participants the Smart Tag sensor that they need to place in the Vehicle
- providing Participants access to the telematics Application
- assisting Participants with any problems with the technology during the Pilot
- sending Participants information via email
A DriveAbility® Score and a Distracted Driving score are generated for each Trip Participants take. Participants in Group B are able to access the individual Trip information and view scores and the events that triggered them on a Trip map through the Application smartphone. Additionally, Octo will generate an overall DriveAbility® Score and an overall Distracted Driving Score that is based on the aggregate of all Trips driven.
The Application will automatically provide drivers with tips or hints based on the individual driving patterns and scores.
Virtual Currency and Leaderboard
Participants in Group B will be able to select and complete driving behaviour challenges to earn virtual currency (i.e. diamonds). Diamonds earned will be shared with Augeo to facilitate the provision of rewards or incentives. Octo will maintain a record of the challenges Participants have completed.
Participants may choose to display how they are performing relative to other Pilot Participants through the Pilot leaderboard. The leaderboard will show relative ranking amongst all opted-in Participants. Participants who opt-in will have their scores and display name shared with all other Participants as well as with ICBC.
Incentives and rewards
Octo has subcontracted with Augeo, a rewards service provider, to provide Participants with a rewards catalogue. Augeo will provide Participants with a selection of digital gift cards to choose between.
Participants’ name, email address, phone number and the amount of diamonds earned will be provided to Augeo so they can deliver digital gift cards to Participants and handle any customer service matters that are raised.
ICBC Analysis of Participant Information
Any sharing or publication of results of the Pilot will be at an aggregate level only, with no individual data shared or published. This means no information will be released that will enable an individual participant to be identified.
ICBC will use the Participant Information, along with policy and vehicle information, participant crash history, chargeable claims and traffic convictions history, to understand the effectiveness of telematics solutions, specifically to assess whether telematics programs would have a positive impact on crash rates through incentivizing driving behaviour improvement.
Octo will provide ICBC with Participant Information, Incentives and Rewards Data, Telematics Data, logistics and support data, DriveAbility® Scores and its components (Trips, acceleration, speeding, hard barking, distance driven), and Distracted Driving Scores. ICBC will pair this with information about the Vehicle and its insurance policy, along with a Participant’s years of driving experience and historical and ongoing claims and traffic convictions information. This information will then be aggregated to the Participant’s Group for comparison.
ICBC will compare the differences between Group A and Group B in their exposure, crash frequency, crash attributes, Driveability® Score, Distracted Driving Score, Driveability® score components, and various other behavioural metrics such as frequency of distracted driving, average speed and average event count.
Customer engagement analysis will seek to understand Participant use of the App including the extent to which Participants engage with the App, use feedback to inform driving behaviour, and access App resources such as tips or videos to help improve driving behaviour. Additional analysis will seek to understand the impact of gamification on sustaining engagement.
ICBC will assess the extent to which Participants access the customer support center, how that access changes over time, the types of support accessed, and customer satisfaction with support.
ICBC will conduct additional road safety research to derive insight into the behaviours that lead to crashes, the prevalence of the behaviours, the sequence of behaviors that lead to crashes and the relationship between behaviours (for example, the relationship between distracted driving events and hard braking events). This analysis will inform future public education campaigns.
ICBC will retain Participant Information for an eight year period after the end of the Pilot for further customer experience and road safety research (See Section 3.4 for further information on data storage, access and deletion). No geolocation data will be provided to ICBC at any point by Octo. Octo will systematically anonymize geolocation data seven days after each Trip.
Only authorized ICBC staff will have access to Participant Information to assess and analyze driving behaviour in accordance with the Pilot objectives.
3.3 Disclosure compelled by law
ICBC will collect, disclose, and use Participant Information only for the Pilot, unless otherwise required by law. For example, in the event of a crash, police investigation, or litigation, other parties may seek the crash information collected by the telematics Smart Tag and/or Application and request it from ICBC. ICBC may be required by law to provide this information in response to a court order.
ICBC will not use Participant Information to adjust an ICBC claim in the event of a claim involving the Vehicle, unless required to do so by law.
3.4 How Participant Information will NOT be used
ICBC will not disclose Participant Information to any person other than authorized ICBC staff, Octo or its authorized sub-contractors, and then only on an as-required basis for the purpose of the Pilot. For example, this means ICBC will NOT disclose any of Participant Information to:
- a parent/guardian of the Participant, even if the Participant is a minor,
- the registered owner of the Vehicle if the Participant is not the registered owner,
- authorities such as the RCMP or local police, for the purposes of issuing a driving violation, or
- another agency of government for additional research.
However, a Participant may choose to share their Participant Information with others if they choose to do so.
Participant Information will have no bearing on a Participant’s standing in or graduation from the Graduated Licensing Program (“GLP”).
3.5 Storage and Access of Participant Information
All policy, claims, vehicle, driver licensing, and traffic convictions data used by ICBC within the Pilot will be stored on ICBC servers in Canada.
ICBC will retain Participant data including events, Trips, and scores on ICBC servers in Canada.
Octo will store and access Participant Information on servers located in Canada, the United States of America, and the European Union (Italy, France & Ireland). Augeo will store and access Participant Information on servers located in the United States of America.
ICBC requires Octo and Augeo to protect Participant Information in a manner that is legally compliant with FIPPA requirements.
Deletion of Data
A Participant’s personal information will be completely deleted from Octo and Augeo servers within three months of Pilot completion. Octo will certify that all data has been removed from Octo and Augeo servers.
ICBC will retain Participant Information for eight years from the date of Pilot completion:
- Participant Information will be personally identifiable for the first five years.
- Participant Information will be de-identified for the subsequent three years.
ICBC will not be provided or retain any Participant GPS data.
After the eight year retention period is complete, all Participant Information will be destroyed.
Personal Information is collected pursuant to sections 26(c) & (e) of FIPPA for the purposes of conducting the Pilot. Personal Information will be stored, used and disclosed as authorized under FIPPA.
3.7 For more information
If there are any questions about the collection of Personal Information for the Pilot, Participants may contact ICBC’s Privacy Manager at firstname.lastname@example.org.
4. Terminating Participation
Participants may decide to opt out of the Pilot at any time. If a Participant withdraws from the Pilot they will not be eligible to receive further rewards or incentives other than those already earned.
A Participant may withdraw from the Pilot by contacting our support center by phone at 604-982-1319 or 1-844-982-1319.
Additionally, if a registered owner or lessee of the Vehicle withdraws consent for the Vehicle to be used in the Pilot and ICBC is not notified of a replacement vehicle, the Participant’s status in the Pilot will become inactive. In either case, a Participant will no longer be eligible to receive further incentives. The Vehicle owner may withdraw consent for the Vehicle for the Vehicle to be used in the Pilot by contacting the Pilot support center by phone at 604-982-1319 or 1-844-982-1319, or by removing the Smart Tag.
ICBC reserves the right, at our sole discretion, to terminate a Participant’s enrollment in the Pilot if we are unable to obtain an accurate assessment of driving behaviours. If this occurs, ICBC will notify the Participant and propose to terminate participation in the Pilot unless a satisfactory solution can be resolved with the Participant within 30 days of our notice. If no successful solution is concluded within 30 days of our notice, the Participant’s status in the Pilot will become inactive and they will not be eligible for any further incentives. Reasons a Participant’s enrollment could be terminated by ICBC include (but are not limited to):
- more than 50 per cent of a Participant’s Trips were excluded because they were not the driver
- the inability of their smartphone to collect and transfer data
- the lack of cellular coverage and/or network in the area where they live or use the Vehicle
- failure to activate the Application within thirty (30) days of the date we send the email to the Participant confirming enrolment in the Pilot
- any misuse of the Application
- removing the Application
All Participant Information that has been collected up to the point that consent has been withdrawn, or enrollment is terminated, will remain ICBC property and be analyzed by ICBC as outlined in Section 3.2 of these Terms and Conditions.
5. Disclaimers, Limitation of Liability and Trademarks
The Application is made available “as-is”, “with all faults” and “as available” and it is used at the Participant’s own risk. ICBC makes no warranties or guarantees of any kind, express or implied, including but not limited to any implied warranties of merchantability, fitness for a particular purpose, title and non-infringement.
Other than as expressly set out in these Terms and Conditions, ICBC and its appointed service provider, Octo, and (where applicable) Augeo, expressly do not warrant that the Application and its operation will be uninterrupted or error or defect-free, that any errors or defects in the Application will be corrected, that data will not be lost or damaged, or that the Application or server(s) that make it available are free from viruses, disabling code or other contaminants.
ICBC and its affiliates and suppliers shall not be liable for any direct, indirect, special, incidental, exemplary, punitive, or consequential losses or damages resulting from, arising out of, related to or in connection with, the use of, participation in or access to the Pilot or the Application, these Terms and Conditions or any related services whether provided by ICBC or its affiliates or suppliers.
The rights to use the Application developed and maintained by Octo are protected by the Copyright Act of Canada, and its content cannot be altered without infringing on the owner’s copyright and his/her moral rights. Certain names, words, titles, expressions, phrases, logos, icons, graphics or designs or other content in the Application are, as the case may be, also trade-names or trade-marks of Octo, which may not be used without the owner’s consent
I have read and understand the above information. My consent is effective from the date of submission of my application to participate.
By checking the checkboxes, I
a) consent and agree to:
- my participation in the Pilot;
- these Terms and Conditions as they apply to me;
- the collection, storage and use by the Insurance Corporation of British Columbia of my personal information in accordance with the purpose(s) set out in this form;
- the disclosure, storage, and access of my personal information in the following jurisdiction(s) (Canada, the United States of America, and the European Union) as set out in this form; and
b) certify that:
- if under 18 years of age, I have the consent of a parent or (legal) guardian to participate in the Pilot;
- if I am not the registered owner, or lessee if a leased vehicle, of the Vehicle identified, I have the consent of the registered owner or lessee to use their Vehicle in the Pilot;
- if I am not the owner of the smartphone or its data plan, I have the consent of the owner of the smartphone and its data plan for use in the Pilot.