Privacy Policy

 

Last updated: May 24, 2018

LiveSafe, Inc. and its affiliate and subsidiaries (“LiveSafe,” “we,” “our,” or “us”) know that you value your privacy and security. We do too. This Privacy Policy describes the ways in which we use and disclose Personal Information about you collected through the LiveSafe platform (the “App”). This Privacy Policy does not apply to any other Personal Information you provide or that LiveSafe collects. To access the LiveSafe general website privacy policy, please click here. Through this Privacy Policy and other disclosures we make, we provide you with information about our privacy practices and the choices and rights you may have regarding Personal Information in connection with the App.

About LiveSafe

We provide organizations, our clients, and their users with the App, an online communications platform to help manage safety-related information and incidents. Except as otherwise described below, we act as a service provider to our clients and we collect and process data received from you through the App on behalf of our clients. The data we receive through the App from you will be available to your organization. Therefore, our use and disclosure of Personal Information is limited by our agreements with them. This Privacy Policy does not reflect the privacy practices of our clients, and we are not responsible for our clients’ privacy policies or practices. We do not review, comment upon, or monitor our clients’ privacy policies or their compliance with their respective privacy policies, nor do we review our client’s instructions with respect to our processing of information to determine whether such instructions are in compliance or conflict with the terms of the client’s published privacy policy. This Privacy Policy also does not address how other recipients may use and disclose the information they receive through the App.

If you wish to know about the information practices of the organizations with which you are using the App, such as your employer or school, please contact them directly.

Information We Collect and Use

“Personal Information” means any information that directly or indirectly identifies a natural person, including by reference to an identifier such as a name, an identification number, location data, or an online identifier.

LiveSafe is providing a service to you and your organization, and we use Personal Information received through the App only in connection with the services we provide. For example, we do not show you advertising when you use the App or track your usage so we can provide such advertising.

Generally, we process this Personal Information with your consent, to meet our contractual obligations with our clients, and in conformance with our legitimate business interests (e.g., maintaining the security and integrity of the App, enforcing the terms and conditions associated with the App, monitoring the use and performance of the App, quality assurance of our customer service operations, and product improvement and development) where your interests do not outweigh our interests, and to comply with legal obligations. We retain the Personal Information as described below in this Privacy Policy.

Profile Information You Provide – We collect the Personal Information that you submit when you create or update your App profile. The profile Personal Information includes your name, e-mail address, mobile phone number, your organization’s name, and other registration information.

We use the Personal Information in your profile to provide the App services, including to display on the App and personalize messages, provide the information to your organization and emergency services for safety and security purposes, and to respond to any requests and questions. We use the contact information to facilitate sending you electronic messages and safety and service-related notifications from your organization by email, SMS text message, push notifications, secure live chat, and other methods. By submitting your email address and mobile phone number, you consent to receiving communications from them for the purpose of the App. We use your email address or mobile phone number as a username to allow you to log-in on multiple devices.

The processing of your Personal Information for these purposes is to meet our contractual obligations with our clients.

Information You Submit When Using the App – We collect the information you submit when using the App, such as to report a tip and to submit text, pictures, videos, audio files, or other content to your organization. You may also chat with others you select using the SafeWalk feature, and we receive the information submitted through the App. Some of the information you provide may constitute special categories of data or sensitive Personal Information about you or another person, such as information related to current health status, potential criminal activity, and racial or ethnic origin. This information is used for safety and security purposes, such as to send your organization and emergency personnel the information so they can help you and others. They also support your use of certain App features such as communicating with friends, family, your organization, and others that you choose.

Anonymous Submissions - You may be able to submit certain information, such as tips, anonymously. Unless LiveSafe receives a warrant for anonymous tips, we will only disclose identifying or location information about an anonymous tipster to your organization or emergency personnel in “exigent circumstances.” We define an “exigent circumstance” as a situation in which there is imminent risk of serious bodily injury or death. LiveSafe has the sole authority to decide whether something meets the requirement of being an exigent circumstance.

The processing of your Personal Information for these purposes is to meet our contractual obligations with our clients.

Location Data – Many of our App’s safety and security-related services rely on users’ precise location information. This information helps provide actionable safety and security intelligence to you, your organization, emergency personnel, and other users. For example, your organization may send safety and security messages to any and all App users in a certain geographic area and your last-used location information may be used to target such messages. Your precise location information will not be provided to your organization when targeting these messages. However, your location information may be provided to your organization when you interact with your organization to submit a tip or check-in or on confirmation that you received a broadcast message to users in a certain geographic area. To support these services, the App may use your IP address, GPS, Bluetooth, WiFi hotspot, and cell tower location information, and other technologies to determine the most accurate location information possible. You may adjust your location settings on your mobile device at any time to disable location services by managing your location services preferences or, if available, through the App’s permission settings. If you disable location services on your device or for the App, your use of the App will be significantly impaired. The processing of your Personal Information for these purposes is based on your consent.

Address Book Contacts – Certain App functions, like SafeWalk, permit you to communicate through the platform with individuals in your mobile device’s address book. To connect you with an individual contact in your address book, the App may access your device’s address book with your permission and receive the name and contact information of only those individuals that you submit. By submitting contact information of another person to the App, you represent that all such contacts have consented to receive SMS texts from you through the App. The processing of this Personal Information for these purposes is with your consent and your organization will not have access to your address book information or the name or contact information of users with whom you have participated on a SafeWalk.

Single Sign-On – We may request the username you use with your organization so that the App can connect with your organization’s user authentication service and permit you to gain access to your organization’s communities using your organization’s single sign-on capabilities. The processing of your Personal Information for these purposes is to meet our contractual obligations with our clients.

Information Obtained From Other Sources – We may receive information about you from your organization if it provides you with access to the App, and we combine that information with the information we collect from and about you through the App. The processing of your Personal Information for these purposes is to meet our contractual obligations with our clients. You may also choose to log into your LiveSafe account using social media or other third-party log-in features, such as those provided by Facebook. We receive Personal Information about you from the social media or the third-party service provider, including your name and email address. We use this information for the purposes of creating your profile and connecting you to your organization in the App. The processing of your Personal Information for these purposes is with your consent.

Information We Automatically Collect – We and our third party service providers may automatically collect certain technical information about your software and hardware attributes (including operating system version, device identifiers, and hardware model information), mobile carrier information, device and application IDs, IP address, and information regarding how you use the App (such as the date, time, and duration of use). We use this information to provide and improve the App and the products and services we provide; to personalize the content, messages, and App experience we provide to you; technical support; to detect, prevent, and respond to fraud, intellectual property infringement, violations of our Terms of Use, violations of law, or other misuse of the App; and to support our business operations. The processing of your Personal Information for these purposes is based on our legitimate interests.

Psuedonymization and Anonymization – We may psuedonymize and/or anonymize the information collected through the App and use and disclose it for business purposes, including for improving our products and services, in which case we may use such information without further notice to you. The processing of your Personal Information for this purpose is based on our legitimate interests.

Legal and Other Similar Uses – We may process (including use, disclose, and store) information, including your Personal Information, if we believe doing so is required or appropriate to: comply with law enforcement requests and legal process, such as a court order or subpoena; respond to your requests; comply with the law; enforce our Terms of Use; or protect your, our, or others’ rights, property, or safety.

Information Sharing

We do not disclose Personal Information about you except as described in this Privacy Policy. We do not rent or sell your Personal Information. We do not share your Personal Information with third parties for their direct marketing purposes.

Your Organization – When you connect your profile to an organization, we treat the Personal Information received through your use of the App in connection with an organization as that organization’s information. In other words, we process the information to provide the App services to the organization in compliance with our agreement with it, including by providing access to all Personal Information of the user connected to the organization. Please see above for more information about anonymous tips. The organization accesses, uses, and discloses this information for its business purposes. You may contact your organization to learn about how it uses this information.

Other Users – We will disclose the Personal Information we collect from and about you through the App with other users (including your family and friends) when requested by you.
Emergency Personnel – Your organization may disclose the Personal Information collected from and about you through the App with public safety officials and other government entities on an emergency basis or when requested by you.

Third Party Service Providers and Vendors – We share the Personal Information we collect with our service providers and vendors so they can provide their services to us. For example, we partner with certain service providers to collect diagnostic and usage information as described above and to engage in analysis, auditing, research, and reporting on our behalf. We also work with service providers and vendors to provide the App’s technical infrastructure and send communications, such as email and text messages.

Internally – We may disclose the Personal Information we collect from and about you through the App within LiveSafe (including our worldwide affiliates and subsidiaries) to fulfill obligations to our client organizations and operate the App consistent with the Privacy Policy and applicable data protection law.

Merger, Sale, or Other Asset Transfers – To the extent permitted by applicable law, if we are involved in a merger, acquisition, financing due diligence, reorganization, bankruptcy, receivership, sale of company assets, or transition of service to another provider, your information may be disclosed in connection with the negotiation of such transaction, and/or sold or transferred as part of such a transaction as permitted by law and/or contract.

Third-Party Links and Features

The App also may contain third-party links or features. We are not responsible for the collection and use of your Personal Information by such third parties that are not under our control. We encourage you to review the privacy policies applicable to third-party websites or features.

For example, we provide you with the ability to log into your account using social media or other third-party login features, such as those provided by Facebook. We do not control these third-party services, your profiles on social media services, or determine how your Personal Information will be used by these third-party services. We are not responsible for any acts or omissions by any social media service or other third-party service that you choose to use.

Where Information is Processed

We operate the services in the United States. Therefore, if you provide us with Personal Information during your use of the Services, we collect, process, and store that information in the United States. We may also transfer that information to our affiliates and subsidiaries or to other third parties, across borders to other countries or jurisdictions around the world. If you are visiting from the European Economic Area or other regions with laws governing data collection and use that may differ from U.S. law, please note that you may be transferring your Personal Information to the United States, which does not have the same data protection laws as the EU or other countries.

We maintain appropriate safeguards to properly protect Personal Information concerning you when it is transferred to the United States, such as agreeing with our clients to comply with the EU Standard Contractual Clauses. For more information about our data transfer safeguards, please send a request to legal@livesafemobile.com.

How Information is Stored and Secured

We maintain appropriate organizational and technical measures for the protection of the security, the confidentiality, and integrity of Personal Information from unauthorized or unlawful access, accidental loss, destruction, damage, misuse, disclosure and alteration. However, no information system can be 100% secure, so we cannot guarantee the absolute security of your Personal Information. Moreover, we are not responsible for the security of Personal Information that you transmit to the App over networks that we do not control, including the Internet and wireless networks. You do so at your own risk. If LiveSafe learns of a security system’s breach, we will comply with all applicable law to notify you about the breach so that you can take protective steps.

How Long We Keep Information

We consider several factors to determine how long we keep Personal Information. We consider the amount, nature, and sensitivity of the Personal Information, the potential risk of harm from unauthorized use or disclosure of your Personal Information, the purposes for which we process your Personal Information and whether we can achieve those purposes through other means, the contractual requirements with our client organizations, and the applicable legal requirements. Once we no longer have a need for your Personal Information, we will securely destroy it in accordance with our standards and applicable laws and regulations.

Your Choices and Rights

You choose whether to report tips, use emergency features, communicate with your chosen organization, friends, family and others, or invite a third party to participate in a SafeWalk or share in other App features. In connection with some features, you may be able to submit certain information anonymously. Within the App, you can access your profile to update your name and contact information, manage the organizations with which you are connected, and view your App activity. If you cannot find the information you are looking for or make the changes you want to make in the App, please contact your organization. If you believe your information has been submitted to the App and you are not associated with an organization using the App, please contact us at legal@livesafemobile.com.

While we take various steps to ensure the accuracy and completeness of your Personal Information, we rely upon you to provide accurate and complete Personal Information when interacting with the App. All persons in the scope of the General Data Protection Regulation whose Personal Information is being processed by LiveSafe have the legal right to request from its organization: (i) access, (ii) rectification (iii) erasure, (iv) restriction of processing, (v) object to processing, and/or (vi) data portability of their Personal Information. We may help your organization respond to such requests. If you are unable to use the App features to complete your request, please contact your organization. If you believe your information has been submitted to the App and you are not associated with an organization using the App, please contact us at legal@livesafemobile.com.

If you are in the EU, you also have the right to lodge a complaint with an EU supervisory authority. However, if you have a complaint regarding the processing of your Personal Information, we kindly request that you first contact us directly as indicated in the Contact Us section of this Privacy Policy, and we will reply promptly.

Children’s Information

The App is not directed to, nor do we knowingly collect information from, children under the age of 13. If you become aware that your child or any child under your care has provided us with information without your consent, please contact us at the contact information listed below.

Enforcement and More Information

When we receive formal written inquiries or complaints, we will contact the individual regarding his/her concerns. LiveSafe will cooperate with the appropriate regulatory authorities, including local data protection authorities, to resolve any complaints regarding the handling of Personal Information that cannot be resolved between LiveSafe and an individual.

Changes to this Privacy Policy

Without prejudice to your rights under applicable law, we reserve the right to amend this Privacy Policy at any time to reflect changes in the law, our data collection and use practices, the features of our App and products, or advances in technology. We will make the revised policy accessible through the App, so we encourage you to review the policy periodically. We also may alert you to changes by sending you notice via the email address you have provided or through the App itself. If we make a material change to this Privacy Policy, you will be provided with appropriate notice, and we will seek your consent to the updated policy in accordance with legal requirements. If you do not agree to the changes to this Privacy Policy, you should request deletion of your Personal Information by contacting us at legal@livesafemobile.com.

Contact Us

The Data Controller for the App is the organization listed below. If you have any questions, comments, or concerns about this Privacy Policy or about our use or disclosure of your Personal Information collected through the App, please send us an e-mail at legal@livesafemobile.com or write to us at:

LiveSafe, Inc.
Attn: Privacy Compliance
1400 Key Blvd., Suite 100
Arlington, VA 22209