Privacy Policy

SENSORCOMM TECHNOLOGIES, INC.

SensorComm Technologies respects your privacy. We appreciate that you trust us with the information that is important to you and want you to understand our commitment to maintaining the privacy of your personal information and how it will be used and kept safe.

Please read this Privacy Policy carefully. It applies to our applications, our software, our websites, our products and our alert and monitoring services (the “Services”). By using our Services, you agree to the terms of this Privacy Policy. If you do not agree to this Privacy Policy, do not use our Services.

TABLE OF CONTENTS

1. The Information You Provide To Us
2. The Information We Receive From Your Use Of Our Services
3. How We Use Your Information
4. When Information Is Shared
5. Your Rights To Access And Control Your Personal Data
6. Data Retention
7. Information Security
8. How To Contact Us
9. Updates

1. THE INFORMATION YOU PROVIDE TO US

ACCOUNT INFORMATION

You may be asked to create an account in order to use some of the Services. You will have to provide your first and last name, gender, height, weight, email address, a username and password, date of birth, and in some cases your mobile and/or landline telephone number in order to create an account with us. You may have the opportunity through your use of the Services to provide other information, all of which will be purely voluntary.

ADDITIONAL INFORMATION

If you contact us, we collect the information you submit such as your name, contact information, and message so that we can validate your identity, address the problem (escalate if necessary) and use the information provided for training purposes.

PAYMENT AND CARD INFORMATION

Some of our Services support payments and transactions with us. When you activate this feature, you must provide certain information for identification and verification, such as your name, address, credit, debit or other card number, card expiration date, and CVV code. This information is encrypted and sent to your card network, which upon approval sends back to your device a token, which is a set of random digits for engaging in transactions without exposing your card number. For your convenience, we store the last four digits of your card number and your card issuer’s name and contact information. You can remove the token from your account using your account settings. We do not store your transaction history.

DATA SHARING SERVICES

You may provide us with the information of a third party that you wish to receive your information and receive your monitoring alerts. If you use this portion of the Services, you are authorizing us to provide the data collected to the parties that you provide.

2 THE INFORMATION WE RECEIVE FROM YOUR USE OF OUR SERVICES

DEVICE INFORMATION

Your device collects data to estimate your body temperature, your blood oxygen level, your blood pressure, and heart rate. When your device syncs with our applications or software, data recorded on your device is transferred from your device to your mobile phone or micro-server and then uploaded to our servers.

GEOLOCATION INFORMATION

The Services include features that use precise geolocation data, including GPS signals, Wi-Fi access points, IP address and cell tower IDs. We collect this type of data if you grant us this access to your location.

USAGE INFORMATION

When you access the Services, we receive certain usage or network activity information. This includes information about your interaction with the Services, for example, when you view your alerts or graph, download and install applications or software, log into your account, pair your device to your account, or open or interact with an application on your device.

We also collect data about the devices and computers you use to access the Services, including IP addresses, browser type, language, operating system, mobile device information (including device and application identifiers), the referring web page, pages visited, location (depending on whether you have granted permission), and cookie information.

INFORMATION WE RECEIVE FROM THIRD PARTIES

If you choose to connect your account on our Services to your account on another service, we may receive information from the other service. You can stop sharing the information from the other service with us by removing our access to that other service.

We may partner with third parties, such as schools, employers and insurance companies that offer our Services to their employees, students and customers. In most cases, the employers will maintain the database of employee identifiers and the MAC address issued. When there is an alert, you and the entity partnering with us or anyone else you may have included in their profile to provide you with the Services will receive the alert.

3. HOW WE USE YOUR INFORMATION

PROVIDE THE SERVICES

Using the information we collect we are able to deliver the Services to you. For example, we need to use your information to provide you with your dashboard tracking your temperature, to send alerts in cases of anomalies and to provide you with customer support. We may also use your information where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.

IMPROVE, PERSONALIZE, AND DEVELOP THE SERVICES

We use the information we collect to improve the Services. For example, we use the information to troubleshoot and protect against reporting errors, perform data analytics and testing and conduct research optimization for additional insights. We will also use your information to personalize your experience and to develop new features and services.

COMMUNICATE WITH YOU

We use your information to send you notifications and respond to you when you contact us.

PROMOTE SAFETY AND SECURITY

We also use the information we collect to promote the safety and security of our services, our users, and other parties. For example, we may use the information to authenticate users, facilitate secure payments, protect against fraud and abuse, respond to a legal request or claim, conduct audits, and enforce our terms and policies.

We may use cookies and similar technologies for the purposes described above as well.

MARKETING

We may also use your information to promote new features or products that we think you might be interested in. You have the right to stop us from contacting you for marketing purposes. If you do not want us to contact you for marketing purposes, please notify us by sending an email to privacy@sensorcommtech.com.

4. WHEN INFORMATION IS SHARED

We do not share your personal information except in the limited circumstances described below.

WHEN YOU AGREE OR DIRECT US TO SHARE

You may direct us to disclose your information to others.

You may also direct us to share your information in other ways, for example, when you give a third-party application access to your account, or give your employer access to information when you choose to participate in an employee sponsored program. You can revoke your consent to share with third-party applications or employee wellness programs by emailing sensorcommtech (at) gmail (dot) com.

FOR EXTERNAL PROCESSING

We transfer information to our corporate affiliates, service providers, and other partners who process information for us, based on our instructions, and in compliance with this policy and any other appropriate confidentiality and security measures. These partners provide us with services globally, including for customer support, information technology, payments, sales, marketing, data analysis, research, and surveys.

FOR LEGAL REASONS

We may preserve or disclose information about you to comply with a law, regulation, legal process, or governmental request, or to assert legal rights or defend against legal claims, or to prevent, detect, or investigate illegal activity, fraud, abuse, violations of our terms, or threats to the security of the services or the physical safety of any person.

COOKIES AND OTHER TECHNOLOGIES

If you request Services from us, we may then attempt to set cookies on your computer and later access those cookies. Additionally, third-party widgets such as YouTube or Facebook may install cookies depending on their configuration. You can normally refuse cookies by setting preferences in your browser. You do not need to accept cookies in order to use the website or the Services.

A cookie is a small amount of data which often includes a unique identifier that is sent to your browser from a website’s computers and then stored on your computer’s hard drive. A cookie cannot obtain information from your hard drive, destroy files, or transmit viruses.

Each website can send its own cookie to your browser, if your browser’s preferences allow it. To protect your privacy, your browser normally only permits a website to access cookies that it has previously sent to you, but not cookies sent to you by other sites.

NON-PERSONAL INFORMATION

We may share non-personal information that is aggregated or de-identified so that it cannot reasonably be used to identify an individual. We may disclose such information publicly and to third parties.

MERGER, ACQUISITION OR ASSET SALE

In exceptional circumstances, if we are involved in a merger, acquisition or sale of assets, we may also disclose your information, however any

such third party will have to protect your information in the same way we do.

5. YOUR RIGHTS TO ACCESS AND CONTROL YOUR PERSONAL DATA

We give you account settings and tools to access and control your personal data, as described below, regardless of where you live. If you live in certain jurisdictions, you may have legal rights with respect to your information, which your account settings and tools allow you to exercise, as outlined below.

Accessing and Exporting Data. By logging into your account, you can access much of your personal information, including your dashboard with your daily temperature profile and statistics. Using your account settings, you can also download information in a commonly used file format.

Editing and Deleting Data. By logging into your account and using your account settings, you can change and delete your personal information. For instance, you can edit or delete the profile data you provide and delete your account if you wish.

If you choose to delete your account, please note that while most of your information will be deleted within 30 days, it may take up to 90 days to delete all of your information in backup systems. This is due to the size and complexity of the systems we use to store data. We may also preserve data for legal reasons. If you delete your account, we will, however, continue to maintain your device data, but it will no longer have any identifying information.

6. DATA RETENTION

We keep your account information, for as long as your account is in existence. We keep other information until you use your account settings or tools to delete the data or your account because we use this data to provide you with our Services. We also keep information about you and your use of the Services for as long as necessary for our legitimate business interests, for legal reasons, and to prevent harm. The individual temperature, blood oxygen level, blood pressure, heart rate and other data gathered from your device will be stored for three (3 days) before it is overwritten.

7. INFORMATION SECURITY

We work hard to keep your data safe. We use a combination of technical, administrative, and physical controls to maintain the security of your data and protect it from accidental loss and unauthorized access. This includes encrypting many of our services and use of firewalls. No method of transmitting or storing data is completely secure, however. If you have a security-related concern, please contact privacy@sensorcommtech.com.The safety and security of your information also depends on you. Where we have given you (or where you have chosen) a password for access to certain parts of our Mobile Application and Website, you are responsible for keeping this password confidential. We ask you not to share your password with anyone. We urge you to be careful about giving out information in public areas of the Website like message boards. The information you share in public areas may be viewed by any user of the Website.

Unfortunately, the transmission of information via the internet is not completely secure. Although we do our best to protect your personal information, we cannot guarantee the security of your personal information transmitted to our Website or Mobile Application. Any transmission of personal information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on the Website.

OUR INTERNATIONAL OPERATIONS AND DATA TRANSFERS

We operate internationally and transfer information to the United States and other countries for the purposes described in this policy.

We rely on multiple legal bases to lawfully transfer personal data around the world. These include your consent and other approved model contractual clauses, which require certain privacy and security protections. You may obtain copies of the model contractual clauses by contacting us at privacy@sensorcommtech.com.

Please note that the countries where we operate may have privacy and data protection laws that differ from, and are potentially less protective than, the laws of your country. You agree to this risk when you create an account and click “I agree” to data transfers, irrespective of which country you live in. If you later wish to withdraw your consent, you can delete your account.

EUROPEAN PRIVACY DISCLOSURES

If you live in the European Economic Area (EEA), United Kingdom (UK), or Switzerland, please review these additional privacy disclosures under the European Union’s General Data Protection Regulation (“GDPR”).

HEALTH AND OTHER SPECIAL CATEGORIES OF PERSONAL DATA

To the extent that information we collect is health data or another special category of personal data subject to the GDPR, we ask for your explicit consent to process the data. We obtain this consent separately when you take actions leading to our obtaining the data, for example, when you pair your device to your account, grant us access to your exercise or activity data from another service. You can use your account settings and tools to withdraw your consent at any time, including by stopping use of a feature, removing our access to a third-party service, unpairing your device, or deleting your data or your account.

OUR LEGAL BASES FOR PROCESSING PERSONAL DATA

For personal data subject to the GDPR, we rely on several legal bases to process the data, including:

When you have given your consent, which you may withdraw at any time using your account settings and other tools
When the processing is necessary to perform a contract with you, like the Terms of Service and our legitimate business interests, such as in improving, personalizing, and developing the services, marketing new features or products that may be of interest, and promoting safety and security.

HOW TO EXERCISE YOUR LEGAL RIGHTS

In order to exercise your rights under the GDPR to access and control your personal data you must log into your account on our website and go to the account settings section. There you can limit the use of your personal data and marketing communications.

In addition to the various controls, in certain circumstances, you can seek to restrict our processing of your data, or object to our processing of your data based on our legitimate interests, including as described in the How We Use Information section. Under the GDPR, you have a general right to object to the use of your information for direct marketing purposes. Please note that you can always delete your account at any time.

If you need further assistance regarding your rights, please contact us at privacy@sensorcommtech.com, and we will consider your request in accordance with applicable laws. You also have a right to lodge a complaint with your local data protection authority.

CALIFORNIA PRIVACY DISCLOSURES

If you are a California resident, note that under California law, as of January 1, 2020, you are entitled to ask if we have records of your personal information, what that information may be, and to have it deleted from our records. Please email us at privacy@sensorcommtech.com.

HOW TO EXERCISE YOUR LEGAL RIGHTS

You have the right to understand how we collect, use, and disclose your personal information, to access your information, to request that we delete certain information, and to not be discriminated against for exercising your privacy rights.

If you need further assistance regarding your rights, please contact us at privacy@sensorcommtech.com, and we will consider your request in accordance with applicable laws.

CATEGORIES OF INFORMATION WE COLLECT, USE, AND DISCLOSE FOR BUSINESS PURPOSES

As described in the Information We Collect section, we collect the categories of personal information listed below. We receive this information from you, your device, your use of the services, third parties (like the other services you have connected to your account, or your employer or insurance company if they offer you services as an employee or customer), and as otherwise described in this policy. We use and disclose these categories of information for the business purposes described in the How We Use Information and How Information Is Shared sections, respectively. The categories are:

Identifiers: like your name or username, email address, mailing address, phone number, IP address, account ID, device ID, cookie ID, and other similar identifiers.
Demographic information: such as your gender, age, health information, and physical characteristics or description, which may be protected by law.
Commercial information: including your payment information and records of the Services or devices you purchased.
Biometric information: such as your temperature, heart rate, and any similar information to which you grant us access from another service.
Internet or other electronic network activity information: such as the usage data we receive when you access or use our Services. This includes information about your interactions with the services and about the devices and computers you use to access the Services, including MAC addresses.
Geolocation data: including GPS signals, device sensors, Wi-Fi access points, and cell tower IDs, if you have granted us access to that information.
Professional or employment related information, including any information (like your name, email address, or similar information) that your employer provides to us so that we can invite you to participate in or determine your eligibility for Services that they offer to their employees.
Other information that you provide,
Inferences drawn from any of the above.

CHANGES TO THIS POLICY

We may update this Privacy Policy at any time. Our most current and applicable privacy policy will be posted on our website and in our application. We encourage you to periodically check our website and applications in order to review our current privacy policy as it may change from time to time.

8. CONTACT INFORMATION

If you need further assistance regarding your rights, please contact us at privacy@sensorcommtech.com.

9. LAST UPDATED: December 20, 2023

DISCLAIMER

FORWARD LOOKING

Use of this website signifies your acceptance of each of these policies.

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