Last updated: January 1, 2020
Note about Children: As required by applicable law and our Terms of Service, children under the age of 13 may only use the App with the express prior consent of a parent or legal guardian. If you are a Teacher or Administrator, you must obtain all necessary parental consent before allowing students to create an account or use the App.
Information We Collect and Use
“Personal Information” means any information that identifies, relates to, or describes, directly or indirectly, an individual or household. Personal Information may include some or all of the following: identifiers such as a name, an identification number, location data, device identifiers, and 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.
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
- 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 receive 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 an 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’ location information calculated by GPS in the phone that provides an estimated location. 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 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 estimate 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 in 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.
Information Collected When You Log In Through Social Media – 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 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.
Pseudonymization and Anonymization – We may pseudonymize 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.
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.
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 services that you choose to use.
Where Information is Processed
We operate 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 email@example.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 firstname.lastname@example.org.
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 email@example.com.
Your California Privacy Rights
We do not share personal information (as defined by California Civil Code § 1798.83) with other people or non-affiliated businesses for their direct marketing purposes.
Under the California Consumer Privacy Act of 2018 (“CCPA”), California consumers have the right to request:
- the deletion of the Personal Information we have about them
- additional information about whether and how we have collected, used, disclosed, and sold Personal Information about them
- the specific pieces of Personal Information we have about them
California consumers also have the right not to receive discriminatory treatment if they exercise the rights listed above. We have not sold Personal Information since January 1, 2020, the effective date of the CCPA.
When you make a request, we may require that you provide information and follow procedures so that we can verify the request and your jurisdiction before responding to it. The verification steps we take may differ depending on the request you make. We will match the information that you provide in your request to information we already have on file to verify your identity. If we are able to verify your request, we will process it. If we cannot verify your request, we may ask you for additional information to help us verify your request.
Consumers will be required to submit their first and last name and email address and may also be asked to provide their telephone number so that we can verify the request. Please provide as much of the requested information as possible to help us verify the request. We will only use the information received in a request for the purposes of responding to the request.
California law permits California consumers to use an authorized agent to make privacy rights requests. We require the authorized agent to provide us with proof of the California consumer’s written permission (for example, a power of attorney) that shows the authorized agent has the authority to submit a request for the California consumer. An authorized agent must follow the process described below to make a request. The authorized agent must also verify his/her own identity. We will confirm the agent’s authority with the California consumer about whom the request was made.
Submitting CCPA requests: If you are a user of the LiveSafe app and it is provided by your employer, college/university or other organization, please submit your CCPA access or deletion request to that organization. If you are a LiveSafe app user that is not associated with any organization, you may submit a Personal Information access or deletion request by using one of the methods listed below.
You may submit a CCPA rights request to us by:
- Visiting the following website: https://help.livesafemobile.com/hc/en-us/requests/new
- Sending us an email at firstname.lastname@example.org.
Protecting the privacy of young children is especially important to LiveSafe. For that reason, we created certain features designed to help protect Personal Information relating to children who are less than 13 years of age, or higher age if required by applicable law (“Child Users”).
LiveSafe does not knowingly permit Child Users to use the App without prior, express consent from a parent or legal guardian, except through agreements with schools or districts or as otherwise permitted under the Children’s Online Privacy Protection Rule (COPPA) and the Family Educational Rights and Privacy Act (FERPA). If we learn that Personal Information of a Child User has been collected on the App without applicable prior parental consent, then we will take appropriate steps to delete this information. If you are a parent or guardian (“Parent”) and discover that your child under the age of 13 has a registered account with without your consent, please contact your child’s school (if applicable) and alert LiveSafe at email@example.com and request that we delete that child’s personal information from our systems.
What Children’s Information Is Visible To Others?
No user’s profile is made available or visible to the public through the App.
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.
Attn: Privacy Compliance/Legal Department
1400 Key Blvd., Suite 100
Arlington, VA 22209