SafeON™ Website and Mobile Application Privacy Policy

Last Updated: January 2, 2017

Thank you for accessing the SafeON™ mobile application (“App”) and/or the SafeON™ website located at www.getsafeon.com (the “Site”).  The App and Site are owned, operated and made available by SafeON Products, LLC (“SafeON™,” “we,” “our” or “us”).  Capitalized terms not defined herein shall have the meaning set forth in the SafeON™ Mobile App End-User License Agreement and Website Terms and Conditions (“EULA”). 

This SafeON™ Website and Mobile Application Privacy Policy (“Privacy Policy”) covers our treatment of personal information and other information that we collect when End-Users: (a) access the Site; (b) download (or attempt to download) and/or utilize the App; (c) access the Content; (d) register as: (i) paid members (“Full Users”) of the SafeON™ community platform (collectively, with all the associated services, the “Platform”); and/or (ii) emergency contacts of a given Full User (or all Full Users) (each, a “Safeguard,” and together with the Full Users, the “Users”)™; (e) access the API; (f) access links to SafeON’s™ social media pages/accounts on third party social media websites (collectively, “Social Media Pages”), such as Facebook®, LinkedIn™ and Twitter™ (collectively, “Social Media Websites”); and (g) access certain message boards, comments sections, messaging functionality and other interactive features of the App and Site (collectively, “Interactive Services”).  The Platform shall: (i) enable Full Users to send to Safeguards, and enable Safeguards to receive, certain predesignated emergency messages and notices via the App, telephone, SMS text message and/or other available methods (each, a “SafeON™ Alert”); and (ii) enable Full Users to access the SafeON Routes™ functionality which shall, with the Full Users’ permission: (A) track and optimize frequently travelled routes (or specific routes requested by Full Users); (B) provide notice of potential safety concerns associated with a given route, to the extent same are detected and available through the Platform; (C) provide notice of available Safeguards on a given route; and (D) potentially offer alternative route options (collectively, the “SafeON Routes™ Service,” and together with the Site, App, Content, Platform, API, Social Media Pages, Interactive Services, and SafeON™ Alerts, the “SafeON™ Offerings”).  IF YOU DO NOT AGREE TO THIS PRIVACY POLICY IN ITS ENTIRETY, YOU MAY NOT ACCESS, DOWNLOAD OR OTHERWISE USE THE SAFEON™ OFFERINGS, AS APPLICABLE.

Your California Privacy Rights

If you are a resident of the State of California and would like to learn how your “personal information” (as defined in the Shine the Light Law, Cal. Civ. Code § 1798.83) is shared with third parties, what categories of personal information that we have shared with third parties in the preceding year, as well as the names and addresses of those third parties, please email us as at: customerservice@getsafeon.com; or call us at: 310-376-6266.

Personally Identifiable Information Collected

SafeON™ collects certain personally identifiable information from End-Users, as applicable, when an End-User registers as a User, downloads the App and/or utilizes the Interactive Services.  Such information shall include, without limitation: (a) the End-User’s full name; (b) the End-User’s user name and password; (c) the End-User’s e-mail address; (d) the End-User’s full mailing address; (e) the End-User’s credit card information, including billing address (where paying for a Full User account with a credit card  account); and/or (f) any other information requested by SafeON™ on the Form.  Where an End-User accesses certain of the SafeON™ Offerings using her/his Facebook® account, SafeON™ may collect some additional information associated with that End-User’s Facebook® account, depending on the End-User’s Facebook® account settings (and the discretion of Facebook®), including, but not limited to, the End-User’s e-mail address.  We may also collect certain portions of your personal information when you otherwise agree to the terms of this Privacy Policy, but do not complete the applicable registration process in full.

In addition to the foregoing, when a SafeON™ Alert is delivered, the App will automatically activate the video and audio recording features of that Full User’s Mobile Device in order to help document the event in question (collectively, “Recordings”).

Facebook® is a registered trademark of Facebook Inc. (“Facebook”). SafeON™ is not in any way affiliated with Facebook and neither SafeON™nor the SafeON™ Offerings are endorsed or sponsored by Facebook.

Use of Personally Identifiable Information

Other than as set forth in this Privacy Policy, SafeON™ will never share, sell, rent, exchange or barter your personal information to or with any third party for financial gain or marketing purposes.  By making your personal information available to SafeON™, you grant SafeON™ the right, subject to applicable state and federal law, to use that personal information to contact you by telephone, text message and email including, without limitation, to: (a) send you SafeON Alerts where you are a Safeguard; and (b) send you various marketing messages that contain promotional offers from SafeON™, as well as offers from SafeON’s™ third party partners, that SafeON™ believes may be of interest to you.  If you wish to stop receiving future communications from us, please follow the instructions at the end of each such marketing message, or see the “Opt-Out/Unsubscribe” section below. 

Where you submit personal information, we use the personal information that you make available to personalize your experience with the App and/or Site and to facilitate the delivery of the applicable SafeON™ Offerings (including SafeON Alerts) to you, including to respond to any inquiries made by you. 

You also agree that we may contact you at any time with updates and/or any other information that we may deem appropriate for you to receive in connection with your continued use of the SafeON™ Offerings, and to keep you informed of our other products and services.   

We may also employ other companies and individuals to perform certain functions on our behalf.  Examples include sending direct and electronic mail, removing duplicate information from End-User lists, analyzing data and providing marketing analysis.  The agents performing these limited functions on our behalf shall have access to our End-Users’ personal information as needed to perform these functions for us, but we do not permit them to use End-User personal information for other purposes.

We will also use your personal information for customer service, to provide you with information that you may request, to customize your experience with the SafeON™ Offerings and/or to contact you when necessary in connection with your use of the SafeON™ Offerings.  We may also use your personal information for internal business purposes, such as analyzing and managing our service offerings including, without limitation, the SafeON™ Offerings.  We may also combine the information we have gathered about you with information from other sources.   

By submitting your personal information by and through the SafeON™ Offerings, you agree that such act constitutes an inquiry and/or application for purposes of the Amended Telemarketing Sales Rule (16 CFR §310 et seq.), as amended from time to time (the “Rule”) and applicable state do-not-call regulations.  As such, notwithstanding that your telephone number may be listed on the Federal Trade Commission’s Do-Not-Call List, and/or on applicable state do-not-call lists, we retain the right to contact you via telemarketing in accordance with the Rule and applicable state do-not-call regulations.

Where you provide “prior express written consent” within the meaning of the Telephone Consumer Protection Act (47 USC § 227), and its implementing regulations adopted by the Federal Communications Commission (47 CFR § 64.1200), as amended from time-to-time (“TCPA”), you consent to receive telephone calls, including artificial voice calls, pre-recorded messages and/or calls (including SMS text messages) delivered via automated technology, to the telephone number(s) that you provided.  Please note that you are not required to provide this consent in order to obtain access to the SafeON™ Offerings, and your consent simply allows SafeON™ to contact you via these means.  Please be advised that by agreeing to this Privacy Policy, you are obligated to immediately inform us if and when the telephone number that you have previously provided to us changes.  Without limiting the foregoing, if you: (i) have your telephone number reassigned to another person or entity; (ii) give up your telephone number so that it is no longer used by you; (iii) port your telephone number to a landline or vice versa; or (iv) otherwise stop using that telephone number for any reason (collectively “Phone Number Change”), you agree that you shall promptly notify SafeON™ of the Phone Number Change via e-mail at: customerservice@getsafeon.com, or by using one of the methods set forth in the “Contact Us” section below.

We reserve the right to release current or past personal information (including Recordings): (A) in the event that we believe that the SafeON™ Offerings are being or have been used in violation of the Terms and Conditions or to commit unlawful acts; (B) if the information is subpoenaed, requested pursuant to a court order or in connection with an ongoing law enforcement investigation; provided, however, that, where permitted by applicable law, we shall provide you with e-mail notice, and opportunity to challenge the subpoena, prior to disclosure of any personal information pursuant to a subpoena; or (C) if we are sold, merge with a third party, are acquired or are the subject of bankruptcy proceedings; provided, however, that if SafeON™ is involved in a bankruptcy proceeding, merger, acquisition or sale of all or a portion of its assets, you will be notified via email and/or a prominent notice in the App and on the Site of any change in ownership or uses of your personal information, as well as any choices that you may have regarding your personal information. 

You hereby consent to the disclosure of any record or communication to any third-party when we, in our sole discretion, determine the disclosure to be appropriate including, without limitation, sharing your e-mail address with third-parties for suppression purposes in compliance with applicable law, including the CAN-SPAM Act of 2003, as amended from time to time.  End-Users should also be aware that courts of equity, such as U.S. Bankruptcy Courts, might have the authority under certain circumstances to permit personal information to be shared or transferred to third parties without permission. 

Credit Card Transactions

SafeON™ utilizes third party service providers to provide credit card payment processing services.  If you choose to obtain a Full User Account or otherwise make a purchase in connection with the SafeON™ Offerings, the credit card information provided will either be collected directly by such third party service provider, or we will share that payment information with our contracted third party service provider(s).  SafeON™ requires that its third party payment processing service provider(s) has/have in place privacy policies and practices consistent with this Privacy Policy; provided, however, that we cannot guarantee the privacy practices of our third party payment processing service provider(s).

Social Media Websites/Interactive Services

If you engage in any interaction with SafeON™, other End-Users or any third party on any Social Media Pages or via the Interactive Services, you should be aware that: (a) the personal information that you submit by and through such Social Media Pages and/or Interactive Services, as applicable, can be read, collected and/or used by other users of these websites/services (depending on your privacy settings associated with your accounts with the applicable Social Media Websites), and could be used to send you unsolicited messages or otherwise to contact you without your consent or desire; and (b) where SafeON™ responds to any interaction on such Social Media Pages, your account name/handle may be viewable by any and all members/users of SafeON’s™ social media accounts. 

We are not responsible for the personal information that you choose to submit on any Social Media Websites or via the Interactive Services.  The Social Media Websites operate independently from SafeON™, and we are not responsible for such Social Media Websites’ interfaces or privacy or security practices.  We encourage you to review the privacy policies and settings of the Social Media Websites with which you interact to help you understand those Social Media Websites’ privacy practices.  If you have questions about the security and privacy settings of any Social Media Websites that you use, please refer to their applicable privacy notices or policies. 

Non-Personal Information Collection and Use

Aggregate Data

SafeON™ reserves the right to share your personal information with third party advertisers and marketers on an aggregate, non-personally identifiable basis.  Such information will include broad demographic categories about End-Users, their preferences, activities, location and other information; provided, however, that such aggregate information will never be linked to any personally identifiable information.

Mobile Device, Geolocation and App Usage Information

We may collect certain non-personally identifiable information about you and your mobile device (“Mobile Device”) when you access the App and/or visit certain App pages.  This non-personally identifiable information includes, without limitation, the following information pertaining to your Mobile Device and your use of the App: Mobile Device platform type; Mobile Device identifier; SDK version; API key (identifier for the App); App version; iOS Identifier for Advertising (if applicable); iOS Identifier for Vendors (if applicable); Media Access Control (MAC) address; International Mobile Equipment Identity (IMEI); the model type, manufacture and iOS version and/or Android version of the Mobile. We use the non-personally identifiable information identified in this paragraph to improve the design and content of the SafeON™ Offerings and to enable us to personalize your App experience.  We also may use this information in the aggregate to analyze SafeON™ Offerings usage, and to alter existing SafeON™ Offerings, or develop new or different SafeON™ Offerings.

Geolocation Tracking

Please be advised that SafeON™ uses geolocation tracking technology (“Location Services”) to verify your location for purposes of facilitating your use of the SafeON™ Offerings, including the  SafeON Routes™ Service, your ability to make contact with other Full Users and/or Safeguards regarding SafeON™ Alerts.  Where you permit SafeON™ to track your location, and depending on the Account settings you select in connection with permitting other Users to view your then-current geolocation, your location may be viewable to other Users.  However: (a) if you are a Full User and you do not permit SafeON™ to verify your location: (i) your Safeguard connections may not be able to locate you in connection with one (1) or more of your SafeON™ Alerts; and (ii) you will not be able to use some or all of the SafeON Routes™ Service features; and (b) if you are a Safeguard and you do not permit SafeON™ to verify your location, your Full User connections may not be able to locate you in connection with one (1) or more of such Full Users’ SafeON™ Alerts.

Other than as set forth in the preceding paragraph, SafeON™ does not track your geolocation, or share or use your geolocation information, for any other purpose.

Behavioral Tracking

Neither SafeON™, nor any third party, uses cookies, pixels or other tracking technology in connection with the App and/or Site for purposes of tracking End-Users’ activities after they leave the App and/or Site, as applicable.  Nevertheless, most Internet browsers contain a “do-not-track” setting.  In general, when a “do-not-track” setting is active, the End-User’s Internet browser notifies other websites that the End-User does not want his/her Information and online behavior to be tracked and used, for example, for behavioral advertising.

Cookies

When an End-User visits the Site and/or activates the App, we may send one (1) or more cookies and/or gif files (collectively, “Cookies”) to assign an anonymous, unique identifier to that End-User’s computer and/or Mobile Device, as applicable.  Cookies have many benefits to enhance your experience with the SafeON™ Offerings.  To find out more about Cookies, please visit www.cookiecentral.com.  We use Cookies to improve the quality of the SafeON™ Offerings, including for storing End-User preferences, improving ad selection and tracking End-User trends (such as Site pages opened and App session length).

Most computers and mobile devices are initially set up to accept Cookies, but you can reset your Internet browser and/or Mobile Device to refuse all Cookies or to indicate when a Cookie is being sent. To disable and reject certain Cookies, follow the instructions associated with the Internet browser installed on your computer and/or Mobile Device, as applicable.  Even in the case where an End-User rejects a Cookie, she/he may still use the SafeON™ Offerings; provided, however, that the End-User’s ability to utilize certain features of the SafeON™ Offerings may be impaired.  We reserve the right to retain Cookie data indefinitely.

Third Party Links

The SafeON™ Offerings may contain links to other third-party owned and/or operated websites including, without limitation, the Download Venues and Social Media Websites.  SafeON™ is not responsible for the privacy practices or the content of such websites.  In some cases, you may be required to provide certain information to register or complete a transaction at such website.  These third-party websites have separate privacy and data collection practices and SafeON™ has no responsibility or liability relating to them.  We do not endorse, nor are we responsible for the accuracy of, the privacy policies and/or terms and conditions of such websites.  These third party entities are independent third parties and are not affiliated with us.

Security

We endeavor to safeguard and protect our End-Users’ personal information.  When End-Users make personal information available to us, their personal information is protected both online and offline (to the extent that we maintain any personal information offline).  Where our registration/application process prompts End-Users to enter Sensitive Information (such as credit card or bank account information), and when we store and transmit such Sensitive Information, that information is encrypted with advanced TLS (Transport Layer Security).

Access to your personal information is strictly limited, and we take reasonable measures to ensure that your personal information is not accessible to the public.  All of our End-Users’ personal information is restricted in our offices, as well as the offices of our third party service providers.  Only employees or third party agents who need End-User personal information to perform a specific job are granted access to End-User personal information.  Our employees are dedicated to ensuring the security and privacy of all End-User personal information.  Employees not adhering to our firm policies are subject to disciplinary action.  The servers that we store End-User personal information on are kept in a secure physical environment.  We also have security measures in place to protect the loss, misuse and alteration of personal information under our control. 

Please be advised, however, that while we take every reasonable precaution available to protect your data, no storage facility, technology, software, security protocols or data transmission over the Internet or via wireless networks can be guaranteed to be 100% secure.  Computer hackers that circumvent our security measures may gain access to certain portions of your personal information, and technological bugs, errors and glitches may cause inadvertent disclosures of your personal information; provided, however, that any attempt to breach the security of the network, our servers, databases or other hardware or software may constitute a crime punishable by law.  For the reasons mentioned above, we cannot warrant that your personal information will be absolutely secure.  Any transmission of data at or through the Site, other SafeON™ Offerings or otherwise via the Internet or wireless network, is done at your own risk.

In compliance with applicable federal and state laws, we shall notify you and any applicable regulatory agencies in the event that we learn of an information security breach with respect to your personal information.  You will be notified via e-mail in the event of such a breach.  Please be advised that notice may be delayed in order to address the needs of law enforcement, determine the scope of network damage, and to engage in remedial measures.

Minors

Visitors under eighteen (18) years of age (or the applicable age of majority, if greater than eighteen (18) years of age) are not permitted to use and/or submit their personal information at the Site and/or through the App.  We do not knowingly solicit or collect information from visitors under eighteen (18) years of age (or the applicable age of majority, if greater than eighteen (18) years of age).  We encourage parents and guardians to spend time online with their children and to participate and monitor the interactive activities of their children.

Opt-Out/Unsubscribe

To opt-out of receiving marketing and other communications from us, you can follow the instructions at the end of the applicable marketing message or e-mail us at: customerservice@getsafeon.com.

Notwithstanding the foregoing, we may continue to contact you for purposes of communicating information relating to your request for and use of SafeON™ Offerings, as well as to respond to any inquiry or request made by you.  To opt-out of receiving SafeON™ Offerings-related and inquiry response-related messages from SafeON™, you must cease requesting and/or utilizing the SafeON™ Offerings and cease submitting inquiries to SafeON™, as applicable.

Deleting, Modifying and Updating Your Information

At your request, we will: (a) inform you of what personal information we have on file for you; (b) amend the personal information that we have on file for you; and/or (c) remove personal information that you have provided to us, or that we have collected.  You may do so by e-mailing us at: customerservice@getsafeon.com. We ask individual End-Users to identify themselves and the information requested to be accessed, corrected or removed before processing such requests and, to the extent permitted by applicable law, we may decline to process requests that are unreasonably repetitive or systematic, require disproportionate technical effort, jeopardize the privacy of others or would be extremely impractical (for instance, requests concerning information residing on backup tapes).

Please be advised that deleting your personal information may terminate your access to certain of the SafeON™ Offerings.  If you wish to continue using the full complement of SafeON™ Offerings, you may not be able to delete all of the personal information that we have on file for you.

Please be further advised that, after you delete your personal information, residual copies may take a period of time before they are deleted from our active servers and may remain in our backup systems. In addition, this deletion will not change or delete personal information which may have already been shared with third parties, all as provided above in this Privacy Policy.  You will need to contact the third parties that contact you directly to change your preferences regarding their use of your personal information.

Changes to this Privacy Policy

SafeON™ reserves the right to change or update this Privacy Policy at any time by posting a notice on the Site and/or in the App interface that we are changing our Privacy Policy.  If the manner in which we use personal information changes, SafeON™ will notify End-Users by: (a) sending the modified policy to our End-Users via email; and/or (b) by any other reasonable means acceptable under applicable state and federal law.  You will have a choice as to whether or not we use your information in this different manner and we will only use your information in this different manner where you opt-in to such use.  

Contact Us

If you have any questions about this Privacy Policy, please e-mail us at: customerservice@getsafeon.com; or call us at: 310-376-6266

Filing a Complaint with the Federal Trade Commission

To file a complaint regarding our privacy practices, please Click Here. https://www.ftccomplaintassistant.gov/FTC_Wizard.aspx?Lang=en