Full Privacy Policy

My Safety Circle PRIVACY POLICY

This Privacy Policy was last modified on January 12, 2021

Welcome

AB WEB Solutions Pty Ltd,(“My Safety Circle”, “we”, “our”, or “us”) is committed to protecting and respecting your privacy.
My Safety Circle operates a service delivered through our app and website https://www.MySafetyCircle.com that allows the sending of an emergency call, to  transmit  and receive text, images and location information with other users who are preselected by the user of the service in advance –  your “MySafety Circle” (the “Service“).
This Privacy Policy explains our practices regarding the collection, use, disclosure, and protection of information that is collected through our Service, as well as your choices regarding the collection and use of information.
Our Service is available in many different countries, which may have different standards,  requirements and restrictions in respect of the information we provide in the Privacy Policy and how we use personal information.
This Privacy Policy is therefore made up of two parts: Part 1 sets out information applicable to users outside the European Economic Area or Switzerland, and Part 2 sets out information applicable to users in the European Economic Area or Switzerland.
Before accessing or using our Service, please ensure that you have read and understood how we collect, store, use and disclose your personal information as described in the part of this Privacy Policy that applies to you.

Part 1 – Privacy Policy for non-EEA users

This Part 1 of our Privacy Policy explains how we collect, use, disclose and protect information that is collected through our Service from users outside the European Economic Area or Switzerland, as well as your choices regarding the collection and use of information.
This Part 1 of the Privacy Policy was last modified on January 12, 2021.
1. HOW WE COLLECT AND USE INFORMATION
Capitalized terms that are not defined in this Privacy Policy have the meaning given to them in our Terms of Use as varied from time to time.
We collect the following types of information about you:

• Registration and Profile Information. When you create an account, we may collect your personal information such as your username, first and last name, email address, mobile phone number and a photo, if you chose to have a photo associated with your account. If you want to add another person’s name to your account, we collect that other person’s name, email address, and mobile phone number. We may also collect billing information when you sign up for the advanced features.
• Data collected through use of the Service. After you set up your account, we may ask for other profile and demographic information, such as personal emergency instructions and information, and/or nickname etc. You may also customize your map by labeling locations, such as “work” and “home,” to make it easy to spot your favorite Places.
• Geolocation. We collect your location information through your device IP address, WiFi, Bluetooth, and GPS coordinates available through your mobile device. We may also gather information about your location using other technologies and sensors which may provide us with information about nearby devices, WiFi access points and networks, and nearby cell towers. We collect and maintain location data to provide you the features and functionality of the Service. We may also share location information with third parties for advertising, research, analytic and other purposes. If you want to opt-out of the collection of your location data, please adjust your settings in your mobile device to limit the app’s access to your location data. Please see “Your Choices About Your Information” below to learn more.
• Messages and User Content. We collect information when you message other members of your Safety Circle through use of the Service. We may also retain any messages you send to us. We use this information to operate, maintain, and provide to you the features and functionality of the Service and to communicate directly with you, such as to send you alerts on the movements of your Family members, crime alerts in your neighborhood, etc.
• Social Media. When you interact with our site through various social media, such as when you Like us on Facebook or post a comment to our Facebook page, we may receive information from the social network such as your profile information, profile picture, gender, user name, user ID associated with your social media account, age range, language, country, friends list, and any other information you permit the social network to share with third parties. The data we receive is dependent upon your privacy settings with the social network. You should always review, and if necessary, adjust your privacy settings on third-party websites and services before linking or connecting them to My Safety Circle’s website or Service.
• Information we collect automatically through the use of technology. When you visit our website, use our mobile app, read our emails or otherwise engage with us, we and our business partners may automatically collect certain information about your computer or device through a variety of tracking technologies, including cookies, web beacons, log files, embedded scripts, location-identifying technologies, or other tracking/recording tools (collectively, “tracking technologies”), and we may combine this information with other personal information we collect about you. We use these tracking technologies to collect usage and device information, such as:
  • Information about how you access the Service, for example, referral/exit pages, how frequently you access the Service, whether you open emails or click the links contained in emails, whether you access the Service from multiple devices, and other actions you take on the Service.
  • Information about how you use the Service, for example, the features you use, the links you click, the ads you view and click on, purchase transaction information, your location when you access or interact with our Service, and other similar actions.
  • Information about the computer, tablet, smartphone or other device you use, such as your IP address, browser type, Internet service provider, platform type, device type/ model/ manufacturer, operating system, phone number, mobile carrier, date and time stamp, a unique ID that allows us to uniquely identify your browser, mobile device or your account (including, for example, a UDID, IDFA, Google Ad ID, Windows Advertising ID or other persistent device identifier or Ad ID), battery life, and other such information. With your permission, we may also access your photo or camera roll.
• We may collect analytics data, or use third-party analytics tools such as Google Analytics, to help us measure traffic and usage trends for the Service and to understand more about the demographics of our users. You can learn more about Google’s practices at http://www.google.com/policies/privacy/partners, and view its currently available opt-out options at https://tools.google.com/dlpage/gaoptout.
• We use this information to do the following:
  1. remember information so that you will not have to re-enter it during your visit or the next time you visit the Service;
  2. provide custom, personalized content and information, including targeted content and advertising;
  3. track your location and movements;
  4. identify and contact you across multiple devices;
  5. provide and monitor the effectiveness of our Service and our marketing campaigns;
  6. monitor aggregate metrics such as total number of visitors, users, traffic, and demographic patterns;
  7. diagnose or fix technology problems reported by our Users or engineers that are associated with certain IP addresses or User IDs; and
  8. detect or prevent fraud or other harmful activities;
  9. automatically update our mobile application on your system and related devices; and
  10. otherwise plan for and enhance our Service.
• If you would prefer not to accept cookies, most browsers will allow you to:
  1. change your browser settings to notify you when you receive a cookie, which lets you choose whether or not to accept it;
  2. disable existing cookies; or
  3. set your browser to automatically reject cookies.
• Please note that doing so may negatively impact your experience using the Service, as some features and services on our Service may not work properly. Depending on your mobile device and operating system, you may not be able to delete or block all cookies. These browser settings that block cookies may have no effect on non-cookie technologies. You may also set your e-mail options to prevent the automatic downloading of images that may contain technologies that would allow us to know whether you have accessed our e-mail and performed certain functions with it. Although we do our best to honor the privacy preferences of our Users, we are not able to respond to Do Not Track signals from your browser at this time.
• We and our third party partners may also use information collected through tracking technologies for advertising purposes. Please see “Third Party Tracking and Online Advertising” below to learn more.

2. SHARING OF YOUR INFORMATION
Personal Information: We share your personal information with third parties outside My Safety Circle and its controlled subsidiaries and affiliates in some circumstances, as follows:
 

• We share your personal information, including name, email, location and driving event data, with others within your My Safety Circle Family and other My Safety Circle circles.
• We may share your personal information, including your precise location data, unique identifiers or AD IDs and other data with third parties for their marketing and business purposes, including without limitation, to inform and improve third-party advertising or for marketing, research and attribution purposes. These third party partners may use this information according to their own privacy policies. Please see “Your Choices About Your Information” to learn how you may be able to limit some third-party data sharing.
• Any information or content that you voluntarily post to the website or to our Facebook page will automatically be available to the public. We may publicly post your reviews and comments online on our website or mobile app, or link your reviews to third party websites.

 
Other instances in which we may share your information: We may also share your information for business purposes, as follows:
 

• We may share your personal information with our third-party business partners, vendors and consultants who perform services on our behalf or who help us provide our Services, such as accounting, managerial, technical, marketing or analytic services.
• We may at any time buy or sell/divest the company, or any combination of its products, services, assets and/or businesses. Personal 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 share, transfer or assign such information in the course of corporate divestitures, mergers, acquisitions, bankruptcies, dissolutions or similar transactions or proceedings.
• We may disclose personal information to third parties (including law enforcement, other government entity, or civil litigant; excluding our subcontractors) when required to do so by law or subpoena or if in our sole discretion, we determine it is necessary to (a) conform to the law, comply with legal process, or investigate, prevent, or take action regarding suspected or actual illegal activities; (b) to enforce our Terms of Use [https://www.MySafetyCircle.com/terms-of-use/], take precautions against liability, to investigate and defend ourselves against any claims or allegations, or to protect the security or integrity of our site; and/or (c) to exercise or protect the rights, property, or personal safety of My Safety Circle, our Users or others.

 
De-Identified Information: We share your information with third parties in a form that does not reasonably identify you directly. These third parties may use the de-identified information for any purpose.
3. HOW WE PROTECT YOUR INFORMATION

My Safety Circle cares about the security of your information and uses commercially reasonable physical, administrative, and technological safeguards to preserve the integrity and security of all information we collect and that we share with our service providers. However, no security system is impenetrable and we cannot guarantee the security of our systems 100%. In the event that any information under our control is compromised as a result of a breach of security, we will take reasonable steps to investigate the situation and where appropriate, notify those individuals whose information may have been compromised and take other steps, in accordance with any applicable laws and regulations.

4. YOUR CHOICES ABOUT YOUR INFORMATION

You may, of course, decline to submit any personal information through the Service, in which case My Safety Circle may not be able to provide its Services to you.

Modifying Your Account Information and Settings: You may modify your account information, update or amend your personal information, or change your password at any time by logging in to your account. If you have any questions about reviewing or modifying your account information, you can contact us directly at privacy@MySafety Circle.com or http://35.89.149.11/contact-us.

Delete Your Account and Personal Information: We will retain your information for as long as your account is active or as needed to provide you services but reserve the right to delete any or all information without notice to the user at any time. If you wish to cancel your account, please contact us at privacy@MySafety Circle.com or http://35.89.149.11/contact-us.

Emails and Notifications: You can stop receiving promotional email communications from us by clicking on the “unsubscribe” link provided in such communications. We make every effort to promptly process all unsubscribe requests. We may also send you Service-related emails (e.g., account verification, parental consent notification, order confirmations, change or updates to features of the Service, technical and security notices). You may not opt-out of Service-related e-mails or emergency calls.

Third Party Tracking and Advertising: We may share, or we may permit third party ad networks, social media companies, and other third party services to collect, information about your use of our Services over time, including location information, so that they may play or display ads that may be relevant to your interests on our Service as well as on other websites, apps or services, or on other browsers or devices you may use, including computers, mobile devices, and Smart TVs. We may also display targeted advertising to you through social media platforms, such as Facebook, Twitter and others. These third party ad partners may collect information such as click stream information, timestamp, hashed email address, device ID or AdID, your use of third party applications and/or precise geolocation data and other information, and may combine this information with information they collect directly through cookies or that they receive other partners, both online and offline, so that they may recognize you across other browsers or devices you use, including computers, mobile devices and Smart TVs. We and our advertising partners use this information to make the advertisements you see online more relevant to your interests, as well as to provide advertising-related services such as reporting, attribution, analytics, and market research.

To opt-out or control third-party tracking and advertising:

• Interest-based advertising. To learn about interest-based advertising and how you may be able to opt-out of some of this advertising, you may wish to visit the Network Advertising Initiative’s online resources, at http://www.networkadvertising.org/choices, and/or the DAA’s resources at www.aboutads.info/choices. You may also manage certain advertising cookies by visiting the EU-based Your Online Choices at www.youronlinechoices.eu.
• Mobile advertising. You may also be able to limit interest-based advertising through the settings on your mobile device by selecting “limit ad tracking” (iOS) or “opt-out of interest based ads” (Android). You may also be able to opt-out of some – but not all – interest-based ads served by mobile ad networks by visiting http://youradchoices.com/appchoices and downloading the mobile AppChoices app.
• Cross-device linking. Please note that opting-out of receiving interest-based advertising through the NAI’s and DAA’s online resources will only opt-out a user from receiving interest-based ads on that specific browser or device, but the user may still receive interest-based ads on his or her other devices. You must perform the opt-out on each browser or device you use.
• Some of these opt-outs may not be effective unless your browser is set to accept cookies. If you delete cookies, change your browser settings, switch browsers or computers, or use another operating system, you will need to opt-out again.
• Google Analytics and Advertising. We may also utilize certain forms of display advertising and other advanced features through Google Analytics, such as Remarketing with Google Analytics, Google Display Network Impression Reporting, the DoubleClick Campaign Manager Integration, and Google Analytics Demographics and Interest Reporting. These features enable us to use first-party cookies (such as the Google Analytics cookie) and third-party cookies (such as the Doubleclick advertising cookie) or other third party cookies together to inform, optimize, and display ads based on your past visits to the Service. You may control your advertising preferences or opt-out of certain Google advertising products by visiting the Google Ads Preferences Manager, currently available at https://google.com/ads/preferences or by vising NAI’s online resources at http://www.networkadvertising.org/choices.

Third Party Location Sharing: We collect location data to provide the My Safety Circle Services, and may share your personal information, including location data, with other My Safety Circle users in your Safety Circle, and with third parties for advertising or other purposes.

• Limit location collection and sharing. You can opt-out of future sharing of your precise location data with our third party partners by adjusting your settings on your mobile device to prohibit My Safety Circle from collecting your location data. For example, depending on your mobile device, you may be able to “Turn location services ‘off.’ You can also adjust your device settings to withdraw permission for the My Safety Circle app to access location data. We and our third party partners may continue to approximate your location based on other data. Please note that your My Safety Circle app may not be able to provide all of our Services to you if you disable access to location data through your device settings.
• Limit location sharing for advertising purposes. To continue to permit My Safety Circle to access your device location data but to prevent future sharing with third parties for advertising purposes, you can “opt out of Location Sharing for Ads” by clicking www.MySafetyCircle.com/opt-out. My Safety Circle may continue sharing your location data with third party partners for non-advertising purposes unless you turn your location services “off” through your device settings. Please note, some third party advertisers may continue to send you location-based ads based on your previous location or may approximate your location based on other data.

5. CHILDREN’S PRIVACY

Our Service allows Parents or Guardians to keep track of their children’s location on mobile devices that the Parent has added to the Family account. The Service is intended to be used by children under 13 only with significant parental involvement and approval.

The child will then be able to participate in the My Safety Circle Service as a member of that Family Account. The child’s personal information, including name, user name, email, and location, will be shared with other members of the Family account and the child user will be permitted to contact, and be contacted by, other members of the Family account through the Service. My Safety Circle may collect, use, disclose, and store the child’s personal information as described in this Privacy Policy. However, we do not use or share personal information collected from the accounts of children under 13 for marketing or advertising purposes, or permit our third party partners to collect and use such information for advertising purposes.

The Parent or Guardians may contact us to review and/or delete any personal information we have collected from the child, or to withdraw permission for My Safety Circle to collect any additional information from the child. Please contact us at privacy@MySafetyCircle.com or http://35.89.149.11/contact-us if you have questions about your child’s account. If you believe that we might have inadvertently collected information from a child under 13 without parental consent, please contact us at privacy@MySafety Circle.com or http://35.89.149.11/contact-us.

6. LINKS TO OTHER WEB SITES AND SERVICES
We are not responsible for the practices employed by websites or services linked to or from the Service, nor the information or content contained therein. Please remember that when you use a link to go from the Service to another website, our Privacy Policy does not apply to third-party websites or services. Your browsing and interaction on any third-party website or service, including those that have a link on our website, are subject to that third party’s own rules and policies. Please read over those rules and policies before proceeding.
7. CHANGES TO OUR PRIVACY POLICY
My Safety Circle may, in its sole discretion, modify or update this Privacy Policy from time to time, and so you should review this page periodically. When we change the policy, we will update the ‘last modified’ date at the top of this page. If there are material changes to this Privacy Policy or in how My Safety Circle will use your personal information, we will notify you either by prominently posting a notice of such changes prior to implementing the change or by directly sending you a notification.
8. YOUR CALIFORNIA PRIVACY RIGHTS

This section applies to you if you are a resident of the state of California. California law requires us to disclose certain information regarding the categories of personal information we collect. For purposes of this section, “personal information” has the meaning provided by the California Consumer Privacy Act (the “CCPA”) and does not include information that is publicly available, that is deidentified or aggregated such that it is not capable of being associated with an identifiable consumer or device.

Collection and use of personal information. We collect personal information from and about you for a variety of purposes explained in this Privacy Policy.

We collect this information directly from you, from our business partners, from your browser or device when you visit our websites, download or use our mobile app, and from third parties that you permit to share information with us.

Disclosure of Personal Information. We share personal information with third parties for business purposes or we may sell your personal information to third parties, subject to your right to opt out of those sales (see Your Rights and Choices below). The categories of third parties to whom we disclose your personal information may include: (i) other users with whom you elect to share such information; (ii) our service providers and advisors, (iii) marketing and strategic partners; (iv) ad networks and advertising partners; (v) analytics providers; and (vi) social networks. To learn more about how we disclose personal information to third parties, please refer to Section 2 of this Privacy Policy.

Your Rights and Choices. As a California resident, you may be able to request to exercise the following rights:

• The Right to Know any or all of the following information relating to your personal information we have collected and disclosed in the last 12 months, upon verification of your identity: (i) the specific pieces of personal information we have collected about you; (ii) the categories of personal information we have collected about you; (iii) the categories of sources of the personal information; (iv) the categories of personal information that we have disclosed to third parties for a business purpose, and the categories of recipients to whom this information was disclosed; (v) the categories of personal information we have sold and the categories of third parties to whom the information was sold; and (vi) the business or commercial purposes for collecting or selling the personal information.
• The Right to Request Deletion of personal information we have collected from you, subject to certain exceptions.
• The Right to Opt Out of Personal Information Sales to third parties now or in the future.

You also have the right to be free of discrimination for exercising these rights. However, please note that if the exercise of these rights limits our ability to process personal information (such as in the case of a deletion request), we may no longer be able to provide you our products and services or engage with you in the same manner.

To Submit your California Consumer Rights Requests. You may submit a request to exercise your California Consumer Rights through one of the mechanisms described below. We will need to verify your identity before processing your request, which may require us to request additional personal information from you or require you to log into your account. In certain circumstances, we may decline or limit your request, particularly where we are unable to verify your identity or locate your information in our systems, or as permitted by law.

• To exercise your Right to Know or your Right to Request Deletion, please send an email to privacy@MySafety Circle.com or leave message at http://35.89.149.11/contact-us and include your account name and mobile telephone number as well as the consumer right you would like to exercise.
• To exercise your Right to Opt Out of Personal Information Sales, please click Do Not Sell My Personal Information link to: www.My Safety Circle.com/do-not-sell-CA . You must log into your account to submit the opt-out request in order for the opt-out to be effective. We do not sell the personal information of non-account holders. If you do not remember your account login, please reset your account to gain access and submit the opt-out request.

Minors. We do not sell the personal information of consumers we know to be less than 16 years of age, unless we receive affirmative authorization from either the minor who is between 13 and 16 years of age, or the parent or guardian of a minor less than 13 years of age. Please contact us at privacy@MySafetyCircle.com or http://35.89.149.11/contact-us to inform us if you, or your minor child, are under the age of 16. If you are under the age of 18 and you want to remove your name or comments from our website or publicly-displayed content, please contact us directly at privacy@MySafetyCircle.com or http://35.89.149.11/contact-us. We may not be able to modify or delete your information in all circumstances.

California’s “Shine the Light” Law. My Safety Circle collects various types of personal information about you both online and offline, as described in this privacy policy. Under California law, My Safety Circle customers who are residents of California may request certain information about our disclosure of personal information during the prior calendar year to third parties for their direct marketing purposes. To make such a request, please write to us at the following address:

My Safety Circle
ATTN: California Privacy Rights
539 Bryant St. Suite 402
San Francisco, CA 94107

 

Alternatively, you may send us an email at privacy@My Safety Circle.com with the words “California Shine the Light” in the subject line.

9. YOUR NEVADA PRIVACY RIGHTS
Chapter 603A of the Nevada Revised Statutes permits a Nevada resident to opt out of future sales of certain covered information that a website operator has collected or will collect about the resident. To submit such a request, please contact us at privacy@MySafetyCircle.com or http://35.89.149.11/contact-us or visit www.MySafetyCircle.com/opt-out.
10. HOW TO CONTACT US

If you have any questions about this Privacy Policy or the Service, please contact us at privacy@MySafetyCircle.com or http://35.89.149.11/contact-us

My Safety Circle
ATTN: Privacy
539 Bryant St. Suite 402
San Francisco, CA 94107

Part 2 – Privacy Policy for EEA and Swiss users

This Part 2 of our Privacy Policy sets out how we collect, store, process, transfer, share and use data that identifies or is associated with you (“personal information”) when you access our Service from the European Economic Area or Switzerland.

This Part 2 of the Privacy Policy was last modified on January 12, 2021.

My Safety Circle, Inc is the data controller of the personal information we hold about you.

1. PERSONAL INFORMATION WE COLLECT ABOUT YOU
1.1 We collect personal information that you voluntarily submit directly to us when you use our Service. This can include information you provide to us when you register for an account and user profile, create or edit your user profile on the Service, update your preferences, check-in at a particular location, correspond with us by phone, SMS, e-mail or otherwise, or use some other feature of our Service. 
1.2 We will indicate to you where the provision of certain personal information is required in order for us to provide you certain features of the Service. If you choose not to provide such personal information, we may not be able to provide the Service to you or respond to your other requests.

1.3 The table at Annex 1 sets out the categories of personal information we collect about you and how we use that information, as well as the legal basis which we rely on to process the personal information.

1.4 We also automatically collect personal information indirectly about how you access and use the Service and information about the device you use to access the Service.

1.5 The table at Annex 2 sets out the categories of personal information we collect about you automatically and how we use that information. The table also lists the legal basis which we rely on to process the personal information.

1.6 We may link or combine the personal information we collect about you and the information we collect automatically. This allows us to provide you with a personalised experience regardless of how you interact with us.

1.7 We may de-identify any of the personal information we collect (so that it does not directly identify you) and use it for purposes that include testing our IT systems, research, data analysis, improving our Service and developing new products and features.

1.8 We will store the personal information we collect about you for no longer than necessary for the purposes set out in Annex 1 and Annex 2 and in accordance with our legal obligations and legitimate business interests.

2. RECIPIENTS OF PERSONAL INFORMATION

2.1 We may share your personal information with the following:

 

1. Others in your My Safety Circle Family or other My Safety Circle Circle: we may share your personal information, including your name, location and driving event data, with other users of our Service at your request and in accordance with your preferences.
2. Third parties for their marketing and related purposes with your consent. Where you have provided consent for us to do so, we may sell your personal information (specifically, your location data, driving sensor data, information about your device, and unique identifiers or AdIDs) to third parties for their marketing and market research purposes.
3. Service providers, business partners and advisors: we may share your personal information with third party vendors and other service providers that perform services for us or on our behalf, which may include providing payment, email or chat services, fraud prevention, web hosting, or providing analytic services.
4. Purchasers and third parties in connection with a business transaction: your personal information may be disclosed to third parties in connection with a transaction, such as a merger, sale of assets or shares, reorganisation, financing, change of control or acquisition of all or a portion of our business.
5. Law enforcement, regulators and other parties for legal reasons: we may share your personal information with third parties as required by law or if we reasonably believe that such action is necessary to
   1. comply with the law and the reasonable requests of law enforcement;
   2. detect and investigate illegal activities and breaches of agreements, including our Terms of Service; and/or
   3. exercise or protect the rights, property, or personal safety of My Safety Circle, its users or others.

2.2 Annex 1 and Annex 2 contain further information about some of the parties with which we may share your personal information.

3. YOUR LOCATION

3.1 We collect information about your location in order to provide you certain functionalities of the Service.

3.2 We will collect your location where it is necessary for the purposes of providing you with the location-based services features of the app as well as for the legitimate interests of My Safety Circle or our business partners, such as for data analytics. Where you have given us your consent to do so, we may also sell your location data to third parties for marketing and research purposes.

3.3 You can share your location with one or more of your Circles or every your Safety contact by switching on the Emergency mode or activating Share my location feature, otherwise your location is not shared with other users. You can opt out of us sharing your location with third parties for advertising purposes by following www.MySafetyCircle.com/opt-out.

3.4 You can also stop sharing your location with us at any time by updating the settings on your mobile device to limit the app’s access to your location information. Please note, however, that we may not be able to provide all of the functionalities of our Services to you if you disable access to location data.

3.5 If you no longer want to continue using the Service, uninstalling the My Safety Circle app or logging out from the Service will also stop us from collecting your location.

4. MARKETING MESSAGES AND NOTIFICATIONS

4.1 From time to time, we may contact you with information about our products and services. Most of the marketing messages we send will be by email or through push notifications on your device.

4.2 We will only send you marketing messages if you have given us your consent to do so. We will ask you if you would like to receive these messages when we first collect your contact details.

4.3 You can change your preferences at a later date by clicking on the unsubscribe link at the bottom of our marketing newsletters.

4.4 Please note that if you do opt-out of or do not grant consent to receiving marketing related messages from us, we may still send you non-marketing messages, such as communications relating to the provision of our Service.

5. TARGETED ADVERTISING

5.1 We may share, or we may permit third party ad networks, social media companies, and other third party services to collect, information about your use of our Services over time, so that they may play or display ads that may be relevant to your interests on our Service as well as on other websites, apps or services, or on other devices you may use. We may also display targeted advertising to you through social media platforms, such as Facebook, Twitter and others. These third party ad partners may collect information such as click stream information, timestamp, hashed email address, device ID or AdID, and information about your use of third party applications. They may also collect and analyse information about your use of our Service in order to recognise you across various devices you use.

5.2 Where you have consented to us doing so, we may also share your precise geolocation data with advertising partners. We and our advertising partners use the information we collect about you to make the advertisements you see online more relevant to your interests, as well as to provide advertising-related services such as reporting, attribution, analytics, and market research.

5.3 To learn about interest-based advertising and how you may be able to opt-out of some of this advertising, you may wish to visit the Network Advertising Initiative’s online resources, at http://www.networkadvertising.org/choices, and/or the DAA’s resources at www.aboutads.info/choices.

5.4 You may also be able to limit interest-based advertising through the settings on your mobile device by selecting “limit ad tracking” (iOS) or “opt-out of interest based ads” (Android). You may also be able to opt-out of some – but not all – interest-based ads served by mobile ad networks by visiting http://youradchoices.com/appchoices and downloading the mobile AppChoices app.

5.5 Please note that opting-out of receiving interest-based advertising through the NAI’s and DAA’s online resources will only opt-out from receiving interest-based ads on that specific device, but you may still receive interest-based ads on your other devices. You must perform the opt-out on each device you use.

6. STORING AND TRANSFERRING YOUR PERSONAL INFORMATION

6.1 Security. We implement appropriate, commercially reasonable technical and organisational measures to protect your personal information against accidental or unlawful destruction, loss, change or damage. However, no security system is impenetrable and we cannot guarantee the security of our systems 100%. We will never send you unsolicited emails or contact you by phone requesting your account ID, password, credit or debit card information or national identification numbers.

6.2 International Transfers of your Personal Information. Any information we collect from you will initially be collected and stored in the USA. If you are in the EU or EEA, this may mean that your personal information will be stored in a jurisdiction that offers a level of protection that may, in certain instances, be less protective of your personal information than the jurisdiction you are typically resident in. We will take reasonable steps to ensure that your personal information is treated securely and in accordance with applicable law and this privacy policy.

6.3 Privacy Shield. We comply with the EU-U.S. Privacy Shield framework and Swiss-U.S. Privacy Shield framework as set forth by the U.S. Department of Commerce regarding the collection, use and retention of personal information from European Union countries (including Lichtenstein, Norway and Iceland) and Switzerland transferred to the United States pursuant to the Privacy Shield (“Privacy Shield“). We have certified that we adhere to the Privacy Principles of notice, choice, accountability for onward transfer, security, data integrity, purpose limitation, access, and recourse, enforcement and liability (“Principles“) with respect to such data. If there is any conflict between the policies in this policy and the Principles, the Principles shall govern. To learn more about Privacy Shield, please visit the U.S. Department of Commerce Privacy Shield website: https://www.privacyshield.gov/. For more information regarding our Privacy Shield certification, please see: https://www.privacyshield.gov/list.

6.4 Onward Transfer. Where we transfer personal information to a third party, will take reasonable and appropriate steps to ensure the third-party processes personal information for limited and specified purposes and in a manner consistent with our Privacy Shield obligations. Where the transfer is to a third-party agent acting on our behalf, we may be liable if such third parties fail to meet those obligations, and we are responsible for the event giving rise to the damage. In certain situations, we may be also required to disclose personal data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.

7. USERS’ RIGHTS IN RESPECT OF THEIR PERSONAL INFORMATION

7.1 In accordance with applicable privacy law, you have the following rights in respect of your personal information that we hold:

1. Right of access. You have the right to obtain:
   1. confirmation of whether, and where, we are processing your personal information;
   2. information about the categories of personal information we are processing, the purposes for which we process your personal information and information as to how we determine applicable retention periods;
   3. information about the categories of recipients with whom we may share your personal information; and
   4. a copy of the personal information we hold about you.
2. Right of portability. You have the right, in certain circumstances, to receive a copy of the personal information you have provided to us in a structured, commonly used, machine-readable format that supports re-use, or to request the transfer of your personal data to another person.
3. Right to rectification. You have the right to obtain rectification of any inaccurate or incomplete personal information we hold about you without undue delay.
4. Right to erasure. You have the right, in some circumstances, to require us to erase your personal information without undue delay if the continued processing of that personal information is not justified.
5. Right to restriction. You have the right, in some circumstances, to require us to limit the purposes for which we process your personal information if the continued processing of the personal information in this way is not justified, such as where the accuracy of the personal information is contested by you.
6. Right to object. You have a right to object to any processing based on our legitimate interests where there are grounds relating to your particular situation. There may be compelling reasons for continuing to process your personal information, and we will assess and inform you if that is the case. You can object to marketing activities for any reason.

7.2 If you wish to exercise one of these rights, please contact us using the contact details at the end of this privacy policy.

7.3 You may also review and edit your contact and profile information by logging into your account on the app, and opt out of certain processing activities, such as the collection and sharing of your location and movement data, by updating your preferences at www.MySafetyCircle.com/opt-out. Please note that we may not be able to provide some functionalities of our Services to you if you opt-out of the collection and/or sharing of location and movement data.

7.4 You also have the right to lodge a complaint to your national data protection authority. Further information about how to contact your local data protection authority is available at http://ec.europa.eu/justice/data-protection/bodies/authorities/index_en.htm.

8. CONSENT

8.1 We are not required to obtain your consent for most of the processing activities that we undertake in respect of your personal information.

 

8.2 We may, however, need your consent for certain processing activities. If we need your consent, we will notify you of the personal information we intend to use and how we intend to use it.

 

8.3 If you have provided consent for certain processing of your personal information, you have the right to withdraw your consent. If you withdraw your consent, this will not affect the lawfulness of our processing of your personal information before your withdrawal.

8.4 Where we share your personal information with your consent with third parties for marketing and related purposes, you may withdraw consent at any time via our in-app Privacy Centre.

9. COOKIES AND SIMILAR TECHNOLOGIES

9.1 Our websites use cookies to distinguish you from other users of our website. This helps us to provide you with a good experience when you browse our website or access any of our other websites and also allows us to improve our websites.

9.2 Please see our Cookie Policy [https://www.MySafetyCircle.com/cookie-policy] for more information about the cookies we use on our website, and how to manage cookies.

9.3 Deleting or blocking cookies may not be effective for all types of tracking technologies, such as Local Storage Objects (LSOs) like HTML5.

10. JURISDICTION AND ENFORCEMENT

10.1 As part of our participation in the Privacy Shield, we are subject to the investigatory and enforcement powers of the US Federal Trade Commission (FTC).

10.2 You also have the right to lodge a complaint to your local data protection authority. Further information about how to contact your local data protection authority is available at http://ec.europa.eu/justice/data-protection/bodies/authorities/index_en.htm.

11. CONTACT My Safety Circle AND RECOURSE

11.1 In compliance with the EU-US and Swiss-US Privacy Shield Principles, we commit to resolve complaints about your privacy and our collection or use of your personal information transferred to the United States pursuant to the Privacy Shield. European Union or Swiss individuals with inquiries or complaints regarding this privacy policy should first contact us at privacy@MySafetyCircle.com or http://35.89.149.11/contact-us.

11.2 In the event that you are concerned about how personal information you have provided to My Safety Circle has been used, please address your inquiry or complaint first to us at the address listed above. My Safety Circle takes all concerns about privacy and use of personal information very seriously, and shall endeavour to reply to you within 45 days of receiving a complaint.

11.3 We have further committed to refer unresolved privacy complaints under the Privacy Shield Principles to an independent dispute resolution mechanism provided by JAMS. If you do not receive timely acknowledgement of your complaint, or if your complaint is not satisfactorily addressed, please visit https://www.jamsadr.com/file-an-eu-us-privacy-shield-claim for more information and to file a complaint. This service is provided free of charge to you.

11.4 If your Privacy Shield complaint cannot be resolved through the above channels, under certain conditions specified by the Principles, you may also be able to invoke binding arbitration to resolve your complaint. If you do not receive timely acknowledgment of your complaint, or if your complaint is not satisfactorily addressed, please visit http://go.adr.org/privacyshieldfiling.html for more information and to file a complaint.

12. LINKS TO THIRD PARTY SITES
Our Service may, from time to time, contain links to and from third party websites, including those of other users, our partner networks, advertisers, partner merchants, news publications, retailers and affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for their policies. Please check the individual policies before you submit any information to those websites.
13. OUR POLICY TOWARDS CHILDREN

13.1 The Service may only be used by children with the consent of a parent or person with parental responsibility over the child. The child’s device may only be joined to a “Family” or “Circle” created on our Service by, or otherwise associated with the account of the person granting consent.

13.2 The age at which children need parental consent varies between EEA Countries. Please refer to Annex 3 to verify the minimum age at which children no longer need consent to use our Service (the “Minimum Age”).

13.3 If you would like to grant your child access to the Service, you must complete the consent form available at https://www.My Safety Circle.com/pdf/consent.pdf and return it to us by mail, fax or email using the contact details at the end of this policy.

13.4 We will use the personal information of users under the relevant Minimum Age as set out in this privacy policy. We do not, however, use or share personal information collected from accounts of children under the Minimum Age for marketing or advertising purposes, or permit our third party partners to collect and use such information for advertising purposes. We also do not contact, or permit third parties to contact any children under the Minimum Age who access or use our Service.

13.5 If you become aware that your child has provided us with personal information, without your consent, then please contact us using the details below so that we can take steps to remove such information and terminate any account your child has created with us.

13.6 If you would like to review or delete any personal information we have collected from the child, or to withdraw permission for us to collect any information from the child, please contact us at privacy@MySafetyCircle.com or http://35.89.149.11/contact-us.

14. CHANGES TO THIS POLICY
We may update this privacy policy from time to time and so you should review this page periodically. When we change this privacy policy in a material way, we will update the “last modified” date at the end of this privacy policy. Changes to this privacy policy are effective when they are posted on this page.
15. NOTICE TO YOU
If we need to provide you with information about something, whether for legal, marketing or other business related purposes, we will select what we believe is the best way to get in contact with you. We will usually do this through email or by placing a notice on our Service. The fact that we may send notices to you will not stop you from being able to opt out of certain types of contact as described in this privacy policy.
16. CONTACTING US

16.1 Please contact privacy@MySafetyCircle.com or http://35.89.149.11/contact-us if you have any questions, comments and requests regarding this Privacy Policy.