Privacy Policy

Effective: October 28th, 2020

 

This privacy policy (this “Privacy Policy”) explains what information Secure Internet Solutions LLC, a Wyoming limited liability company, d/b/a Watch Our Own (“Watch Our Own”, “we”, “our” or “us”) collects and saves from you when you use our website, applications and services as described herein (the “Services”) and in connection with Groups as described in Section I below. By using the Services, you agree to all the terms and conditions stated in this Privacy Policy. Please take a moment to review this information.

 

    I. Background

 

Watch Our Own offers Services designed to enable you and the members of the group you create or accept membership in (“Group(s)”), to assist in the support of someone you care about. All the information in Group is managed by you or the administrator of your Group, and such individual decides who and when to share information with and when to remove that access. A Group may also share information during a live event and via remote access to first responder dispatch.

 

For example, a member of the Group may need to lookup medical information to provide to a first responder or medical service. The individual in charge of a Group may also initiate an “Emergency Code” to allow first responder dispatch to access it via the https://www.watchourown.com/first-responder site.

 

    II. How We Protect Your Information

 

We take reasonable measures to protect your personally identifiable information (“Personal Information”) to prevent against unauthorized use, access and disclosure. Your name and e-mail address, along with other information described in greater detail in Section III below, that can be used to identify you, constitute your Personal Information. Please be aware that, security measures are not impenetrable, and we cannot guarantee against misuse.

 

    III. What Information We Collect

 

    a). Contact Information

 

If you choose to contact us through the Services, we will collect your contact information, such as your name, telephone number, home address, and email address (collectively, “Contact Information”), in order for us to communicate with you, including for billing statements as well as notification of Group activities. If you write a message, we may store the message so we can reference it to tailor our responses to you. We may occasionally collect additional Personal Information that you voluntarily submit to us through the Services for other purposes, including information needed to open an account if you choose to do so.

 

    b). Services Visitor Data

 

Directly or through the use of third-party data analytics services, we may collect visitor information, including your IP address and server log data (the address of the web page you visited before using the Services, your browser type and settings, the date and time of your use of the Services, language preferences). We may gather your information about the device you are using to access our Services, including what type of device it is, what operating system you are using, device settings, application identifications, location, unique device identifiers, and crash data. Other data which may be collected, includes data generated by your use of the Services and links you interact with.

 

    c). Information You Provide to Us

 

           i. In connection with the Services, you may publish, display or transmit the information to us or third parties, including, but not limited to:

 

          ii. Health and Medical Information (including medical conditions, symptoms, prescription schedule, and vitals such as heart rate);

 

          iii. Photos;

 

          iv. Documents;

 

          v. Videos;

 

          vi. Event Information and Historical Data;

 

          vii. Prescription Schedule;

 

          viii. Location Information;

 

          ix. Location Schedule;

 

          x. Caregiver Coverage Schedule; and

          xi. Chat Data.

 

 

    IV. How We Use Your Information

 

  • We use information in connection with the Groups as described in Section I above.

  • We use your information to operate, manage, and improve our Services, and for marketing and administrative purposes.

  • We may send you newsletters and marketing information, until you decide to opt out. We may also send you notifications, updates, and changes about our Services, and contact you to provide customer service and support.

  • We may use your Personal Information, including any information you share with us, to improve our programs and Services.

  • We may use your information to comply with legal or regulatory requirements, to respond to lawful requests, court orders and legal process, to enforce our rights, enforce the Terms of Use, protect our intellectual property, to prevent fraud, and to protect the security of the Services and for safety.

  • We may use your IP address and location data to analyze usage, administer our Services, and gather demographic information for aggregate use.

  • With your consent, we may use your Personal Information in other ways.

  • For the following types of information you publish, display or transmit the information to us or third parties in connection with the Services, we use such information in the following ways:

 

          i. Health and Medical Information – We provide you with a Service to manage health and medical information in connection with the Groups.

 

          ii. Photos - All photos (e.g., avatar, front, side and obstructed photos) which you post are yours or a Group’s to manage and share. It is your        responsibility to maintain recent photos of your care recipients on the Service.

 

          iii. Documents – Currently, we provide you with the option to store a “living will” and “do not resuscitate” documents on the Service.

 

          iv. Videos - During an event, you may send or receive a video stream in connection with a Group. Our Service does not currently save the video.

          v. Event Information and Historical Data – We provide access to previous events in connection with Groups, excluding any video.

          vi. Prescription Schedule - If you include yours or your care recipient’s prescription information, you can setup reminders with event level escalation via a schedule provided in the Service. There are three levels of notification (low, medium and high) based on the number of individuals who receive notifications related to prescriptions.

 

          vii. Location Information – We use your location data to enable you and the members of your Group to find your care recipient and care givers. We also provide (if your mobile coverage allows) the ability to find and map nearby sites such as police, and medical facilities as well as EMS/fire near you via location services.

 

         viii. Location Schedule - When you setup a location schedule for yourself or your care recipient, you will setup and adjust the geo-fence as well as the time and dates the person is supposed to be at that location.

For example, you may indicate that 9am-5pm on Monday through Friday an individual is at “school” by including the school address and adjusting the geo-fence to where such individual is located.

Please note that depending on how good your mobile coverage is, you may get false alerts if the mobile cannot find its location or access our Service due to weak signal coverage or if your phone is turned off.

 

         ix. Caregiver Coverage Schedule - This schedule is mainly for you to organize when (i.e., date and time) you want to have a particular care giver watching over your care recipient. As with any notification, it depends on your mobile coverage.

 

         x. Chat Data - During an event we provide the ability to chat with members in a Group that you have provided access to. That data may also persistent in the historical event.

 

     V. How We Share Your Information

 

We do not knowingly sell, trade or otherwise share your Personal Information with any third parties without your consent, except: (i) as described above for Groups; (ii) as required by law, (iii) when we reasonably believe it is necessary to prevent or take action regarding illegal activities, suspected fraud or to protect the safety of any person, (iv) in connection with a merger, acquisition or sale of our assets, and/or (v) as otherwise disclosed in this Privacy Policy. We may share location information with Google Maps a web mapping service developed by Google, LLC for purposes of providing maps to you.

 

    VI. Cookies and Other Technologies

 

           i. What are cookies?

 

A cookie is a small file that can be placed on your computer's hard disk or on a server. Cookies do not retrieve information stored on your hard drive and do not corrupt or damage your computer or computer files. For those using our Services, we may link cookie information to your email address so as to maintain and recall your preferences within the Services.

 

           ii. Why we use cookies

 

We may use cookies and similar tracking technologies to improve or administer the Services, analyze trends, track users’ movements around the Services, support security features on the Services, and to gather demographic information about our user base.

 

   VII. Opt-in/Opt-out of Communications

 

By using our Services, you expressly allow us to contact you and use your information as set forth in this Privacy Policy. You may opt-out of receiving marketing emails anytime by clicking the “unsubscribe” button in the email that contains the marketing communication.

 

   VIII. Links

 

This Service may contain links to other third-party Services. Please be aware that we are not responsible for the privacy practices of third-parties and their other Services. This Privacy Policy applies only to the information we collect on this Services. We encourage you to read the privacy policies of other Services you link to from our Services or otherwise visit.

 

    IX. Your Choice to Access, Edit, or Delete Information

 

We strive to provide you with as many choices and as much control as possible regarding your Personal Information. You have the right to access and change your Personal Information. Please contact us as noted at the bottom of this Privacy Policy to find out how. We will, upon receiving your request, make reasonable efforts to correct, delete, and/or block your Personal Information from further use to the extent it remains in our possession, except to the extent not permitted by law.

 

   X. Minors

 

Our Services is not directed at nor intended for use by individuals under 13. If you are under the age of 13, please do not attempt to register with the Services or send any information about yourself to us, including your name or e-mail address. If you learn that a child under 13 has provided us with Personal Information, please contact us. If we become aware that a child under 13 has provided us with his or her Personal Information, we will promptly delete such data.

 

   XI. Business Transactions

 

In the event we go through a business transition, including without limitation any merger, acquisition, partnership, business reorganization, debt finance, or sale of association assets, or in the event of an insolvency, bankruptcy, or receivership (together a “Business Transition”), we may use information collected in accordance with this Privacy Policy and subject to its restrictions, as part of any such Business Transition. In such instances, your information can be part of the assets transferred.

 

   XII. Do-Not-Track

 

You may have implemented a “do-not-track” signal through your browser. We currently do not respond to do-not-track signals from your web browser.

 

   XIII. Data Retention and Destruction

 

We will retain Personal Information for as long as necessary to accomplish our purposes for such data as set forth in this Privacy Policy. You can request that your information be deleted by contacting us at the address provided at the bottom of this Privacy Policy. At the time your information is deleted, we will destroy your Personal Information using reasonable data destruction practices. We may, however, retain certain information to comply with legal or contract obligations or to facilitate law enforcement requests.

 

   XIV. Changes

 

We may revise this Privacy Policy from time to time. If we decide to change our Privacy Policy, we will post the revised statement here. If changes are significant and materially affect your rights under this Privacy Policy, we may provide a more prominent notice on the Services. In certain cases, we may also provide email notification of the revised Privacy Policy. However, as we may make changes at any time without notifying you, we suggest that you periodically consult this Privacy Policy. Please note that our rights to use any information collected will be based on the Privacy Policy in effect at the time the information is used.

 

   XV. Contact Us

 

If you have any questions about the Privacy Policy, please contact us by one of the following means:

 

 

PRIVACY NOTICE FOR CALIFORNIA RESIDENTS (CCPA)

In addition to our Privacy Policy, this Privacy Notice for California Residents supplements the information contained in our Privacy Policy above and applies solely to all visitors, users, and others who reside in the State of California (“consumers” or “you”). We have provided this notice in compliance with the California Consumer Privacy Act of 2018 (CCPA) and any terms defined in the CCPA have the same meaning when used in this notice.

Information We Collect (CCPA)

Within the last twelve (12) months, our Services have collected the following categories of personal information from consumers:

(Note: in this table, Yes indicates that a given category of data was collected, and No indicates that a given category of data was not collected.)

Category and Examples

A: Identifiers

A real name, Internet Protocol address, email address, or other similar identifiers.

B: Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e))

A name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver’s license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information. Some personal information included in this category may overlap with other categories.

C: Protected classification characteristics under California or federal law

Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information).

D. Commercial information

Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.

E. Biometric information

Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as, fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data.

F. Internet or other similar network activity

Browsing history, search history, information on a consumer’s interaction with a website, application, or advertisement.

G. Geolocation data

Physical location or movements.

H. Sensory data

Audio, electronic, visual, thermal, olfactory, or similar information.

I. Professional or employment-related information

Current or past job history or performance evaluations.

J. Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)).

Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records.

K. Inferences drawn from other personal information.

Profile reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.

Collected by the Service?
Yes
Yes
Yes
No
Yes
No
Yes
No
No
No
No

To summarize the above, we collect personal information about consumers to our Service as further described in the Privacy Policy.

 

Note that “personal information” does not include:

  • Publicly available information from government records.

  • De-identified or aggregated consumer information.

  • Information excluded from the CCPA’s scope, including:

    • Health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and the California Confidentiality of Medical Information Act (CMIA) or clinical trial data;

    • Personal information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FRCA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver’s Privacy Protection Act of 1994.

 

We obtain the categories of personal information listed above from the following categories of sources:

  • Directly from our customers or their agents. For example, from documents that our customers provide to us related to the Service for which they engage us.

  • Indirectly from our customers or their agents through their use of our Service.

  • Directly and indirectly from activity on our Services.

Use of personal information (CCPA)

We may use or disclose the personal information we collect for one or more of the following business purposes:

  • To fulfill or meet the reason for which the information is provided.

  • To provide you with information, products or services that you request from us.

  • To provide customers with information regarding you and products or services of customer.

  • To provide you with email alerts, event registrations and other notices concerning our products or services, or events or news, that may be of interest to you.

  • To carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collections.

  • To improve our Services and present their contents to you.

  • For testing, research, analysis and product development.

  • As necessary or appropriate to protect the rights, property or safety of us, our customers or others.

  • To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.

  • As described to you when collecting your personal information or as otherwise set forth in the CCPA.

  • To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our or a customer’s assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by us or a customer is among the assets transferred.

 

We will not collect additional categories of personal information or use the personal information we collected for materially different, unrelated, or incompatible purposes without updating this notice.

 

Sharing personal information (CCPA)

We may disclose your personal information to a third party for a business purpose. When we disclose personal information for a business purpose, we enter a contract that describes the purpose and requires the recipient to both keep that personal information confidential and not use it for any purpose except performing the contract.

In the preceding twelve (12) months, we have disclosed the following categories of personal information for a business purpose:

  • location information for Google Maps to Google, LLC.

We disclose your personal information for a business purpose to the following categories of third parties:

  • Third parties to whom you or your agents authorize us to disclose your personal information in connection with Groups as further described in Section I. 

 

In the preceding twelve (12) months, we have not sold any personal information.

 

Your Rights and Choices (CCPA)

The CCPA provides California residents with specific rights regarding their personal information. This section describes your CCPA rights and explains how to exercise those rights.

 

Access to Specific Information and Data Portability Rights (CCPA)

You have the right to request that we disclose certain information to you about our collection and use of your personal information over the past 12 months. Once we receive and verify your request, we will disclose to you:

  • The categories of personal information we collected about you.

  • The categories of sources for the personal information we collected about you.

  • Our business or commercial purpose for collecting that personal information.

  • The categories of third parties with whom we share that personal information.

  • The specific pieces of personal information we collected about you (also called a data portability request).

  • (Applicable if we sell or disclose your personal information for a business purpose) Two separate lists disclosing:

    • Sales, identifying the personal information categories that each category of recipient purchased; and

    • Disclosures for a business purpose, identifying the personal information categories that each category of recipient obtained.

 

Deletion Request Rights (CCPA)

You have the right to request that we delete any of your personal information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request, we will delete (and direct our service providers to delete) your personal information from our records, unless an exception applies.

We may deny your deletion request if retaining the information is necessary for us or our service providers to:

  • Complete the transaction for which we collected the personal information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you.

  • Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.

  • Debug products to identify and repair errors that impair existing intended functionality.

  • Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.

  • Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 seq.).

  • Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information’s deletion may likely render impossible or seriously impair the research’s achievement, if you previously provided informed consent.

  • Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.

  • Comply with a legal obligation.

  • Make other internal and lawful uses of that information that are compatible with the context in which you provided it.

 

Exercising Access, Data Portability, and Deletion Rights (CCPA)

To exercise the access, data portability, and deletion rights described above, please submit a verifiable consumer request to us by:

Only you or a person registered with the California Secretary of State that you authorize to act on your behalf, may make a verifiable consumer request related to your personal information. You may also make a verifiable consumer request on behalf of your minor child.

You may only make a verifiable consumer request for access or data portability twice within a 12-month period. The verifiable consumer request must:

  • Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative.

  • Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

 

We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you. Making a verifiable consumer request does not require you to create an account with us. We will only use personal information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.

 

Response Timing and Format (CCPA)

We endeavor to respond to a verifiable consumer request within 45 days of its receipt. If we require more time (up to 90 days), we will inform you of the reason and extension period in writing. If you have an account with us, we will deliver our written response to that account. If you do not have an account with us, we will deliver our written response by mail or electronically, at your option. Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request’s receipt. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your personal information that is readily usable and should allow you to transmit the information from one entity to another entity without hindrance.

We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.

 

Non-Discrimination (CCPA)

We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not:

  • Deny you goods or services.

  • Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.

  • Provide you a different level or quality of goods or services. Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.

 

Changes to This Privacy Notice (CCPA)

We may revise this privacy notice from time to time in our sole and absolute discretion. If we decide to change our privacy notice, we will post the revised statement on our Services. If changes are significant and materially affect your rights under this privacy notice, we may provide a more prominent notice on our Services. As we may make changes at any time without notifying you, we suggest that you periodically consult this privacy notice. Please note that our rights to use any information collected will be based on the privacy notice in effect at the time the information is used.

 

Contact Information (CCPA)

If you have any questions, comments or concerns about the privacy notice or would like to request additional information regarding our privacy practices, please contact us at:

 

 

PRIVACY NOTICE FOR VERMONT RESIDENTS

If you are a Vermont resident who we collect information about, we will only share such information with third parties, to the extent permissible under Vermont law, including to process your transactions, maintain your account and as you otherwise authorize.