We self-certify compliance with U.S. and EU Safe Harbor

INTRODUCTION

Wearsafe receives and processes Information (in paper and electronic form) for the purpose of providing a mobile personal safety service.  At Wearsafe, we recognize the importance of privacy to the customers of our service and we strive to safeguard any Information we receive and may need to use in support of our customers.

Wearsafe adheres to the set of data protection principles developed in consultation by the United States Department of Commerce (DOC), in collaboration with the European Commission and the Federal Data Protection and Information Commissioner of Switzerland, producing the U.S. - European Union Safe Harbor Framework Documents and U.S. - Swiss Safe Harbor Framework Documents. The privacy principles in this policy are based on these Safe Harbor Principles “(Principles”).  To view our certificate or to learn more about the Safe Harbor program please visit http://www.export.gov/safeharbor/

Wearsafe’s privacy policy outlines our general policy and practices for implementing the Principles, including the types of information we gather, how we use it and the notice and choice affected individuals have regarding our use of and their ability to correct that information. This Safe Harbor policy applies to all personal information received by Wearsafe whether in electronic, paper or verbal format. Wearsafe privacy policy can be viewed online at privacy policy.

This Safe Harbor Privacy Policy (“Policy”) sets out the privacy principles to which Wearsafe adheres, as it relates to Information transferred from the European Union (“EU”) and/or Switzerland to the United States (“U.S.”).

SCOPE

This Policy applies to all Information received by Wearsafe from the EU and/or Switzerland. In most cases, the Information we receive will be in electronic form and relates to our users.  Wearsafe collects Information during transactions and communications with its customers including, without limitation, when customers purchase, register, use, update or request support for, Wearsafe services or participate in surveys. Customer Information is transferred from the EU to the United States for the purposes of marketing, providing services, facilitating transactions, security, customer support, customer communications, creating, developing, operating, delivering, and improving products, services, content and advertising, verification of identity and determination of appropriate services, the provision of data services to third party Agents including services that provide computing and various information processing or development services, auditing, data analysis and data storage. This Information is collected and processed primarily in the U.S. in accordance with Wearsafe’s privacy policy pertaining to such Information. The Information is primarily transferred and accessed electronically. Information accessible in the United States is stored on secured servers located inside and outside the United States.

DEFINITIONS

  1. Collectively, “Information” means “Personal Information” that (1) is transferred from the EU or Switzerland to the United States; (2) is recorded in any form; (3) is about, or pertains to a specific individual; and (4) can be linked to that individual; and/or “Sensitive Personal Information” that reveals race, ethnic origin, sexual orientation, political opinions, religious or philosophical beliefs, trade union membership, or that concerns an individual’s health.
  2. “Agent” is any third party that collects, uses, or stores Information at Wearsafe’s direction in support of Wearsafe engagements.

SAFE HARBOR PRINCIPLES

The practices to which Wearsafe is committed are based on the EU and Swiss Safe Harbor Principles negotiated between their respective government agencies and the United States Department of Commerce. Adherence by Wearsafe to these Safe Harbor Principles provides the necessary level of protection required by the EU/Swiss Directives for the transfer of Information outside the EU/Switzerland.  Wearsafe’s execution of these principles may be limited in certain circumstances, in particular:

  • where there is a conflicting or overriding legal obligation; or
  • to the extent expressly permitted by any applicable law, rule or regulation.

How Personal Information is Collected

Web Visitors.  Wearsafe collects Information about a visitor to our Web site when the visitor chooses to provide such information. We may use this information for three general purposes: to customize the content you see, to fulfill your requests for certain services and information, and to contact you.

Web Site / Cookies. In order to improve the content and format of our site, Wearsafe may at times use Web site tracking software to automatically capture technical information that is then stored in our server’s log files. This information may include, but is not limited to, user domain, the type of Internet browser being used, which of our Web pages is visited, and the amount of time spent on our site. Wearsafe’s web server log files and click path tracking do not contain any personally identifiable information.

In addition, some of Wearsafe’s Web pages may contain “cookies.” A cookie is a small amount of data which our Web site stores on your computer, and which we can later retrieve. The cookie cannot be read by a site other than ours. We use cookies for a number of administrative purposes; for example, to store your preferences for certain kinds of information. No cookie will contain information that will allow anyone to contact you via telephone, e-mail, or any other means. You can monitor our use of cookies on your computer by setting your Web browser to inform you when cookies are set, or you can prevent the cookies from being set entirely. The “help” portion of the toolbar on most browsers will tell you how to prevent your browser from accepting new cookies, how to have the browser notify you when you receive a new cookie, or how to disable cookies altogether. Please understand that if you disable the use of cookies on your computer, you may be unable to access certain portions or services on our Web sites.

Customers.  Wearsafe may collect certain Information, including Sensitive Personal Information, from our customers who use our service. The Information may be collected through our software applications, mobile applications, or web-based solution, or by members of our support team who provide support to customers. The type of Information collected varies based on the type of interactions the customer is having with the software applications, mobile applications, or SaaS solution.

CHOICE

Use of Your Personal Information. We use your Information to provide you with the services which Wearsafe is contractually obligated to provide to you, or to assist you in completing a transaction, or communicate with you about our products or services. We use Information from Web site visitors to respond to any inquiries such visitors make to our Web site and to provide you with related information of interest to you. We will not rent or sell your Information to third parties outside of Wearsafe Labs Inc. and its subsidiaries and affiliates without your consent, except as noted herein or in our Privacy Policy.

Onward Transfers

Sharing of Your Personal Information

We may disclose Information, to first responders, safety personnel, law enforcement, governmental agencies, or authorized third-parties, in response to: (1) an alert notification message that is sent by, or initiated in connection with, the App and the Service (a “Wearsafe Alert”); or (2) a verified request relating to a criminal investigation, investigation of fraud, alleged illegal activity or any other activity that may expose us, you, or any other User or person to physical harm or legal liability.  In such events, we will disclose information relevant and necessary to the emergency response, investigation or inquiry, such as name, city, state, ZIP code, telephone number, email address, User ID history, IP address, payment history, and anything else we may deem relevant to the emergency response or investigation.  Without limiting the above, in an effort to respect your privacy and our ability to keep the Wearsafe community free from bad actors, we will not otherwise disclose your Information to law enforcement, other government officials, or other third parties after an alert without a subpoena, court order or substantially similar legal procedure, except when we believe in good faith that the disclosure of information is necessary to protect the rights, property, or personal safety of our users, our company or others.

We may contract with third party companies to perform services on our behalf, including but not limited to accounting, managerial, technical, marketing, operations, message delivery, hosting services, customer service and data analysis.

We may at any time buy or sell/divest the company, or any combination of its products, services, assets and/or businesses. Information such as customer names and email addresses, and other user information related to the service will likely be one of the items transferred in these types of transactions. We may also transfer or assign such information in the course of corporate divestitures, mergers, acquisitions, bankruptcies, dissolutions or similar transactions or proceedings.

Links to Non-Wearsafe Web Sites and Third Parties

Wearsafe’s mobile applications and web sites may contain links to third-party sites for your convenience and/or information. If you access those links, you will be re-directed to a third-party site. Wearsafe does not control those sites or the privacy practices of those third-party sites, which may differ from Wearsafe’s privacy practices. We do not endorse or make any representations about third-party Web sites, and the personal data you choose to provide to third-party Web sites is not covered by our Privacy Policy. We encourage you to review the privacy policy of any Web site or company before submitting your Personal Information to them.

Access. 

Wearsafe will take reasonable steps to ensure that your Personal Information is accurate, complete, and current, to its intended use. We provide individuals with reasonable access to the Information that they provide to us, as well as the ability to review and correct such information.

To protect your privacy and security, we also take reasonable steps to verify your identity, before granting access to your Information. In addition, we may limit or deny access to Information where providing such access would be unreasonably burdensome or expensive in the circumstances, or as otherwise permitted by the Safe Harbor Frameworks.

Security

To prevent unauthorized access or disclosure, to maintain data accuracy, and to allow only the appropriate use of your Information, we utilize physical, technical, and administrative controls and procedures to safeguard the information we collect.

To protect the confidentiality, integrity, and availability of your Personal Information, Wearsafe utilizes a variety of physical and logical access controls, firewalls, network and database monitoring, anti-virus, and backup systems. We limit access to your Information and data to those persons who have a specific business purpose for maintaining and processing such information. Wearsafe’s employees who have been granted physical access to your Personal Information will be made aware of their responsibilities to protect the confidentiality, integrity, and availability of that information and have been provided training and instruction on how to do so.

Data Integrity

Wearsafe will take reasonable steps to ensure that Information is accurate, complete, and current, to its intended use. Wearsafe will only use Information in ways that are compatible with the purposes for which it was collected or subsequently authorized by the individual.

Enforcement and Verification

Wearsafe will conduct periodic assessments to validate its continued adherence to this Policy. Where Wearsafe has knowledge that one of Wearsafe’s employees or third parties is using or disclosing Information in a manner contrary to this Policy, Wearsafe will take reasonable steps to prevent or stop the use or disclosure. Wearsafe holds its employees and agents accountable for maintaining the trust that our customers place in our company.

Changes to This Privacy Policy

Wearsafe reserves the right to modify or amend this Policy at any time consistent with the requirements of the Safe Harbor Frameworks. Updates will be posted to this site.

Recourse for Safe Harbor privacy complaints

Privacy Complaints by U.S. and European Union Citizens

In compliance with the Safe Harbor Principles, Wearsafe, commits to resolve complaints about your privacy and our collection or use of your personal information. U.S. and European Union citizens with inquiries or complaints regarding this privacy policy should first contact Wearsafe at:

Wearsafe Labs
Wearsafe Privacy Department
1429 Park Street, Suite 205
Hartford, CT 06106

Or by sending an email to: [email protected]
Dispute Resolution

Wearsafe will investigate and attempt to resolve complaints and disputes regarding the use and disclosure of Personal Information in accordance with the principles contained in this Policy. For complaints that cannot be resolved between Wearsafe and the complainant, Wearsafe has agreed to participate in the dispute resolution procedures of the panel established by the EU Data Protection Authorities (DPAs) to resolve disputes pursuant to the Safe Harbor Privacy Principles, as well as to cooperate and comply with the Federal Data Protection and Information Commissioner of Switzerland.

Effective date: May 23, 2016