LifeAssist Privacy Policy

Effective: January 1, 2017

LifeAssist Technologies, Inc. (“LifeAssist” or “we”) provides this Privacy Policy to inform you of our policies and procedures regarding the collection, use and disclosure of Personal Information. This Privacy Policy applies to your access to and use of our subscription service (“LifeAssist Services”), accessible at app.circura.com (the “Site”) and accessible through our mobile applications, (collectively, “LifeAssist App”) and our in-home care device (“Rosie”.) By choosing to use them, you consent to the collection, transfer, processing, storage, disclosure and other uses of your information described in this Privacy Policy.

The LifeAssist Services and LifeAssist App may be provided to you under a different name by a customer of LifeAssist, such as a Home Care Agency or Senior Residential Living organization (“Third-Party Care Organizations”.) This policy covers the use, collection and disclosure of Personal Information through the LifeAssist Services and LifeAssist App, under either the LifeAssist name or the name provided by the Third-Party Care Organization.

A “Care Circle” is a group of users of LifeAssist Services who are invited use LifeAssist Services. The invitations to start the Care Circle must come from an employee or consultant of the Third-Party Care Organization on behalf of a customer of the Third-Party Care Organization (the “Care Recipient”.) The customer of the Third-Party Care Organization, or a person responsible for the customer’s care, can extend the Care Circle by in turn inviting friends, family members, health professionals or acquaintances of the customer of the Third-Party.

As used below, the term “Personal Information” is used to indicate any piece of information or data that can be used to identify any individual. Personal Information may relate to you as a user of LifeAssist Services or it may relate to a friend, family member or other individual with whom you share a Care Circle.

As used in this policy, the terms “using” and “processing” information include using cookies on a computer, subjecting the information to statistical or other analysis and using or handling information in any way, including, but not limited to collecting, storing, evaluating, modifying, deleting, using, combining, disclosing and transferring information within our organization or among our affiliates within the United States or internationally.

Any other defined term that is not defined in this Privacy Policy has the meaning given that term in the LifeAssist Terms of Service.

MODIFICATIONS

LifeAssist reserves the right, at its sole discretion, to modify this Privacy Policy, at any time and without prior notice. If we modify this Privacy Policy, we will post the modified Privacy Policy and alert you to the modified Privacy Policy on the Site or the LifeAssist App or will otherwise provide you with notice of the modification. We will also update the “Effective Date” at the top of this Privacy Policy. By continuing to access or use the Site, the LifeAssist App or the LifeAssist Services after we have posted a modified Privacy Policy or have provided you with notice of a modification, you are indicating that you agree to be bound by the modified Privacy Policy. If the modified Privacy Policy is not acceptable to you, your only recourse is to cease using the Site, LifeAssist App and LifeAssist Services. Information we collect under the old Privacy Policy will remain subject to the old Privacy Policy unless and until you consent to the application of any modified Privacy Policy to such information.

THE INFORMATION WE COLLECT

Personal Information

You may download the LifeAssist App without expressly providing us any Personal Information that expressly identifies you, however, to make full use of the LifeAssist Services as made available via the Site, Rosie and/or the LifeAssist App, you will need to be invited by an existing user and you will be required to register with us. When you register with us to complete an account, we will ask you for certain Personal Information. In order to set up your account, you need to provide your email address or mobile phone number and you will need to select a password and/or an access PIN. If you elect to add any other Personal Information to your Account, we will collect that information and use it and share it as set forth below.

As a member of a Care Circle, if you are not yourself the Care Recipient, you may also enter information about the Care Recipient. We will collect and store any Information that you may elect to provide to us in the LifeAssist Service, which may include but is not limited to medication information, gender, date of birth, personal contacts, photographs and files, notes on symptoms and other journal information, medical treatment instructions, medical appointments. In the event that you are entering information that relates to someone other than yourself, you are solely responsible for ensuring that you have any and all consents and permissions to share that Personal Information with us and to use that information as part of the LifeAssist Services. We will not ask you for to confirm that you have those consents and permissions.

As part of inviting other individuals to a Care Circle, we will ask you for the invited individual’s name, phone number and email address. We will send the individual emails on your behalf inviting him or her to register for the LifeAssist Services. We store this information for the sole purpose of sending this one-time email. The Third-Party may contact us at support@lat.care to request that we remove this information from our database. We cannot control whether such Third-Party will elect to register for the LifeAssist Services.

Non-Personal Information

We also collect the following information any time you visit our Site or the LifeAssist App, as applicable. This information may not necessarily identify you, but if we have your Personal Information, or you otherwise set up an account with us, we may link any of the below non-personal information with your Personal Information in our records.

Browser Log Data. When you visit the Site, whether as a Member or a non-registered user just browsing the Site, our servers automatically record information that your browser sends whenever you visit a website [Accurate?] (“Browser Log Data”). This Browser Log Data may include information such as your computer’s Internet Protocol (“IP”) address, browser type, operating system or the webpage you were visiting before you came to our Site, pages of our Site that you visit, the time spent on those pages, access times and dates, and other statistics. We use this information to monitor and analyze use of the Site and for the Site’s technical administration, to increase our Site’s functionality and user-friendliness, and to better tailor it to our visitors’ needs. For example, we use this information to verify that visitors to the Site meet the criteria required to process their requests. We do not treat Browser Log Data as Personal Information or use it in association with other Personal Information, though we may aggregate, analyze and evaluate such information for the same purposes as stated above regarding other Non-Identifying information.

Cookies We use HTML5 local storage, also called DOM storage, to recognize you, manage access and use of resources, provide personalization and store information prior to committing it to our secure databases. The use of this storage and information contained within is strictly necessary for the operation of the LifeAssist Service or LifeAssist App. You would not be able to use the LifeAssist Service or LifeAssist App if this modern browser feature is not available or is turned off.

App Usage Data. When you use the LifeAssist App, our servers automatically record information that your mobile device sends whenever you use an Internet service. (“App Usage Data”). This App Usage Data may include information such as your computer’s IP address, device model and version, device identifier, operating system, time zone, name of your mobile operator or ISP, application performance measurements, and error conditions. It may also include a record of when specific features of the LifeAssist App or LifeAssist Service are used. We use this information to monitor and analyze use of the LifeAssist App and LifeAssist Service and for their technical administration, to increase their functionality and user-friendliness, and to better tailor them to our visitors’ needs. For example, we use this information to measure the popularity of different features and to more effectively resolve customer issues. We may aggregate, analyze and evaluate such information for the same purposes as stated above regarding other Non-Identifying Information.

Location Information. The App, with your consent, may access your location. LifeAssist will only access your location services while you are using the App and provided you have opted in to activate this feature. You may choose to allow LifeAssist to access your location by granting the App access to your device’s location, when prompted by the App, or through your device’s location services settings.

HOW WE USE YOUR INFORMATION

We will never sell your personal information without your consent.

We may use any Personal Information in your Account as well as information in your Profile to provide the LifeAssist Services, complete your transactions, administer your inquiries, and present you with offers for products and services that we think may be of use or interest to you. We may contact you in various ways including but not limited to, via email, Inbox in the app, telephone, cell phone, and SMS/text messages.

We may aggregate and combine information collected in LifeAssist Service, including, but not limited to, profile information, login times and other system activity events, calendar, medication reminder and notes creation and update times. This aggregate information is rendered anonymous. It is used to improve the operation and user experience of the LifeAssist Service and LifeAssist App.

Third-Party Care Organizations have access and may download information collected in LifeAssist Service for their customers and for members of their customer’s Care Circle. This information includes, but not limited to, profile information, login times and other system activity events, calendar, medication reminder and notes. Third-Party Care Organizations do not have access to information for that does not pertain to their customers. The use of information collected in the LifeAssist Service pertaining to customers of the Third-Party Care Organizations is governed by Privacy Policy’s of Third-Party Care Organizations.

INFORMATION SHARING AND DISCLOSURE

The purpose of LifeAssist Service is to share care information securely among members of the Care Circle. The LifeAssist Service provides mechanisms for restricting what other members of the Care Circle can view (“Sharing Permissions”.) As a member of a Care Circle, information you enter may be visible to other members of the Care Circle, following the Sharing Permissions that you have specified. However, you cannot be certain that other members of the Care Circle will not re-transmit information they have received from you under private or restricted Sharing Permissions to other members of the Circle without your consent.

We cannot control how any authorized user may use or disclose or otherwise exploit any Personal Information or other content that you may elect to make available to such user. You expressly release LifeAssist from any responsibility and liability resulting from any access by a User to any Personal Information or content that you provided to that User through Sharing Permissions. Any information you choose to provide and make available to third parties via the LifeAssist Services should reflect how much you want others to know about you and the individual(s) whose information is the subject of your account.

Certain Users with administrative credentials in the Third-Party Care Organizations may have, in some circumstances, access to information that you have entered even if they are not invited members of the Care Circle. This information may include, but is not limited to, Profile information and content of messages that were exchanged with the Staff of the Third-Party Care Organization.

The LifeAssist software defects team may need to access data stored within the LifeAssist Service databases to troubleshoot issues with the performance of the software. Access to the LifeAssist Service databases is controlled by password and further limited to specific workstations. Each access is the databases is logged.

CALIFORNIA’S SHINE THE LIGHT LAW – Currently, we do not share any of your personal information with third parties for direct marketing. LAT does not consider sharing of information with Third-Party Care Organizations are not considered as covered by “Shine the Light” law because of the nature of the relationships between LAT, Third-Party Care Organizations and the Care Recipients, who are customers of the Third-Party Care Organizations.

California Civil Code Section 1798.83, known as the “Shine the Light” law, permits our users who are California residents to request and obtain from us a list of what personal information (if any) we disclosed to third parties for direct marketing purposes in the preceding calendar year and the names and addresses of those third parties. You may make such a request once per calendar year, and we will provide the information to you free of charge. Please send any requests made pursuant to this section by emailing us at support@lat.care. However, as defined under Section 1798.83, we do not currently share any personal information with third parties for their direct marketing purposes.

Service Providers. We will disclose Personal Information to the Third-Party service providers that we engage to assist us in making the Site, LifeAssist App and LifeAssist Services available. These service providers consist of our datacenter provider, storage provider, customer support system provider, email service providers, and software development contractors. These third parties have access to your Personal Information only to perform these tasks on our behalf and are obligated not to disclose or use it for any other purpose.

Compliance with Laws and Law Enforcement. While LifeAssist maintains information regarding your health or your loved one’s health on your or his or her behalf, LifeAssist is not a covered entity under the Health Insurance Portability and Accountability Act (HIPAA). Nevertheless, we take the protection of such private health information very seriously. In the event that we receive any subpoena or similar request from a court, government or law enforcement official, we will only disclose any Personal Information or other information in our custody or control as we, in our sole discretion, believe legally necessary or appropriate to respond to claims and legal process.

Business Transfers. LifeAssist may sell, transfer or otherwise share some or all of its assets, including your Personal Information and related account content, in connection with a merger, acquisition, reorganization or sale of assets or in the event of bankruptcy.

CHANGING OR DELETING YOUR INFORMATION

All registered users may review, update, correct or delete their account information and any associated Personal Information by contacting us. If you would like to close your account or delete any information from your account, please contact us at support@lat.care. We will use commercially reasonable efforts to honor your request. We will retain an archived copy of your records as set forth below

California law requires us to honor all requests by minors who are registered users of our Site to remove Personal Information and content provided to our Site. In order to remove such information and content, please e-mail us at support@lat.care and tell us that you are a minor who wishes to remove Personal Information you’ve provided to our Site. Let us know what type of information you wish to remove, and we will assist in removing or deleting such information.

OUR POLICY TOWARD CHILDREN

If you have created a Profile for a minor under the age of 18, you represent and warrant to us at LifeAssist that you are the parent or legal guardian for that minor with a right to provide us the Personal Information of that minor. The LifeAssist Site and LifeAssist Apps are not directed to children under 13. We do not knowingly collect Personal Information from children under 13. If a parent or guardian becomes aware that his or her child has provided us with Personal Information without their consent, he or she should contact us at support@lat.care. If we become aware that we have been provided with Personal Information regarding a child under 13, we will delete such information from our files.

DATA RETENTION

We will retain the information you provide via our Site or the LifeAssist App for as long as your account is active or as needed to provide you or the Third-Party Care Organization with the LifeAssist Services. We will also retain and use the information you provide via our Site or LifeAssist App as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements. If you delete your account, any Personal Information associated with the same is moved out of our active databases, but will still be retained in our systems pursuant to our data backup and retention policies.

DO NOT TRACK SIGNALS AND AD NETWORKS

Our site does not have the capability to respond to “Do Not Track” signals received from various web browsers.

SECURITY – HOW WE PROTECT YOUR DATA

All communications between you and the Site, and between the App and the Site, are encrypted using the highest-level encryption supported by your device. Data stored in the LifeAssist Service is encrypted at rest using industry-standard AES encryption.

IDENTITY THEFT

Identity theft is of great concern to LifeAssist. Safeguarding information to help protect you from identity theft is a top priority. We do not and will not, at any time, request your credit card information, your login information, or national identification numbers in a non-secure or unsolicited e-mail or telephone communication.

For more information about identity theft, visit the Federal Trade Commission’s website at www.ftc.gov.

SECURITY BREACH

The LifeAssist App and LifeAssist Services rely on the Internet and mobile networks, which are not always secure. We use commercially reasonable efforts to maintain the confidentiality, availability and integrity of any information we collect, but we cannot guarantee that the use of the LifeAssist App or LifeAssist Services are secure or that your Personal Information or any other data that we may have will be secure. In the event we become aware of a security incident, we will provide notice to you as required by law.

REPORTING A PROBLEM

If you feel your account may have been compromised, or you discover abuse or misuse of LifeAssist Services, the Site or the LifeAssist App, please report it immediately to support@lat.care and we’ll investigate.

INTERNATIONAL TRANSFER

Your information may be transferred to — and maintained on — computers located outside of your state, province, country or other governmental jurisdiction where the privacy laws may not be as protective as those in your jurisdiction. If you are located outside the United States and choose to provide information to us, LifeAssist transfers Personal Information to the United States and processes it there. Your consent to this Privacy Policy followed by your submission of such information represents your agreement to that transfer.


LINKS TO OTHER WEBSITES

Our Site may contain links to other websites. If you choose to click on a Third-Party link, you will be directed to that Third-Party’s website. The fact that we link to a website is not an endorsement, authorization or representation of our affiliation with that Third-Party, nor is it an endorsement of their privacy or information security policies or practices. We do not exercise control over Third-Party websites. These other websites may place their own cookies or other files on your computer, collect data or solicit personal information from you. Other websites follow different rules regarding the use or disclosure of the personal information you submit to them. We encourage you to read the privacy policies or statements of the other websites you visit.

CONTACTING LIFEASSIST

If you have any questions about this Privacy Policy, please contact LifeAssist at support@lat.care