Risk Band LLC (hereafter “RiskBand,” “we,” or “us”) is a business to business provider of two-way emergency response communications systems (hereafter the “Services”) serving a variety of industries from banking to healthcare and utilities. The Services include the ARIES Platform software, and wearable devices that communicate with the software.  Our clients, who license our devices and software products, either directly input or authorize individuals to input your data into our system, and our clients control all data we handle. Our relationship to your information,  therefore, is as a data processor, and as such we depend on the direction of our clients to dictate our treatment of any of your personal data we may handle.

We have a small subset of information that we handle for our own employees and/or data that we have directly collected for marketing purposes from our website at www.riskband.com (the “Site”); and we are the data controller for that information.

1. RiskBand Services:
2. What information is collected, and who collects it

When you complete a user profile on the ARIES Platform, or a RiskBand client with whom you are associated creates a user profile on your behalf, you are required to provide your contact information (login name, first name, last name, and organization affiliation).  It is optional for you, your authorized representative, or the authorized administrator at our client, to provide additional information (such as health, medical, life-saving and activity information, email address, phone number, gender, citizenship, date of birth, physical address, and photos of you) and unique identifiers. Some RiskBand clients may opt to create anonymous user profiles that will not contain any personal identifying information.  Please contact our client with whom you are associated to understand which types of data they maintain in their user profiles.  RiskBand requires you and our clients to take reasonable steps to ensure that information that you or our clients provide to us is reliable for its intended use, accurate, complete, and current.

Additional note:  Please refer to Section III.i. regarding product support and marketing to users of our Services.

1. How the information is used

RiskBand will use information only in ways that are compatible with the Services for which it was collected. We utilize the information to fulfill the terms of any agreement you or our client has with us, and operate our business.  When you use our device, and press the emergency button to initiate an emergency alert, the device and the ARIES Platform collects your precise location data using GPS and cellular signals.  Your associated organization’s ARIES Platform administrator, as determined by our client, uses the Services to obtain or retrieve information that is relevant to your then-current location. This information is used to identify you as a user of a specific device and to support emergency response services provided to you by either RiskBand partners or our client. We are the ARIES Platform Administrator for our small subset of employees using RiskBand.

International Transfer of Data:  Because RiskBand may provide Services in various locations throughout the world, it may be necessary to transfer your information internationally. In particular, your information will be transferred to and processed in the United States and wherever you access our Services based on the type of license our client has procured, either Domestic (United States), International Sets (specific countries), or International Global (global service). By using our Services, you acknowledge that the data protection and other laws of other countries may provide a less comprehensive or protective standard of protection than those in your country or the country you are in while using our Services.

We may use aggregated data to inform potential clients of the robustness of our product and service offerings. For example, we may report that we have a certain number of device users or that we have processed a certain number of emergencies in particular jurisdictions.

RiskBand may disclose aggregated data to facilitate the financing, securitization, insuring, merger, sale, assignment, bankruptcy, or other disposal of all or part of our business or assets.

RiskBand may use and disclose information as it believes reasonably necessary: to comply with applicable law or respond to legal process (for example, a court order, search warrant, or subpoena); in response to lawful requests by public authorities (such as to meet national security or law enforcement requirements); to investigate, prevent, or take action regarding illegal activities, suspected fraud, violations of our Terms and Conditions, or in other circumstances in which RiskBand has a good faith belief that its products or Services are being used in the commission of a crime or that there is an emergency that poses a threat to the safety of you or another person; or to protect our rights and property.

• With whom the information may be shared

When you provide, or authorize others to provide, any personal information, RiskBand in turn has permission to provide the information to emergency response services, to RiskBand partners, and to our client, in support of the delivery of Services.  These companies are authorized to use your information only as necessary to provide the Services to you.

1. Retention of data

We will retain information we process on behalf of our clients for as long as needed to provide Services to our client. We will also retain this information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.

1. The choices available to users regarding collection, use, and distribution of information

Our client may elect to enable your Device to receive Urgent Messages and Emergency Action Messages. If you wish to opt-out of these messages, your request should go to your employer, our client. If you are using the product as a RiskBand employee, you should see the contact information at the end of this policy.

1. RiskBand Site
2. What information is collected, and who collects it

We and our service providers collect information when you access the Site from a browser or a mobile device. This may include your computer or mobile device operating system,  browser type, screen resolution, operating system name and version, device manufacturer and model, language, your Internet service provider, your domain name, your general geographic location, the website that you visited before the Site, the webpage visited, the content accessed, the time spent on the webpage, and the link you used to leave the Site. 

Additional note:  Please refer to Section III.i. regarding product support and marketing to users of our Site.

1. How the information is used

This information is used to analyze trends, administer the Site, track users’ movements around the Site, and to gather demographic information about our visitors to the Site. 

• With whom the information may be shared

We do not share this information with anyone other than the service providers, such as Google Analytics and web hosting services, which help us collect the information.  Your data is not sold to third parties. 

1. Use of Cookies

The Site uses the services of Google Analytics, a web analytics service provided by Google Inc.  Cookies and similar technologies are used on the Site to analyze Site usage. For more information about Google Analytics, or to opt-out of Google Analytics, please go to: https://tools.google.com/dlpage/gaoptout.

1. The choices available to users regarding collection, use, and distribution of information

You may manage your location sharing preferences on your mobile device at any time with the iOS and Android platforms by changing the Location Services settings.

• RiskBand Product Support & Marketing

1. What information is collected, and who collects it

This section is relevant to authorized administrators and device users as part of our Services, and to visitors of our Site.  If you have a user profile in the ARIES Platform, then your information may be utilized to provide you with relevant marketing, offers, product updates, customer support, and other services to you. Information collected for product support and marketing purposes includes name, address, email address, client organization name, job title, and phone number(s).

RiskBand also collects information for marketing purposes when you register for access to content in any form, or when you contact us.  The information may be collected offline, when you attend one of our events, when you attend industry conferences, during phone calls with sales representatives, or when you contact our customer service.

In order to enhance our ability to provide relevant marketing, offers, and services to you, we may obtain information about you from other sources, such as public databases, joint marketing partners, social media platforms, as well as from other third parties.

1. How the information is used

We use the information to provide you with content, products, and services that you request.

We use the information you provide to respond to your requests, request feedback or handle customer service questions or issues, or notify you of important changes or updates to the Services.

We use the information to send newsletters and promotional communications (which we send on an opt-in basis where required by law) regarding our current, new, or improved products, Services, and features, and other information that we believe may interest you. Although we hope that you will find our promotional communications useful, you may opt-out of receiving them by following the “unsubscribe” instructions included at the bottom of each email message.

• The choices available to users regarding collection, use, and distribution of information

You may request that we remove content or information that you post on our Site that personally identifies you. To obtain removal of such content or information, please send an email with a detailed description of the specific content or information you would like removed to privacy@riskband.com. Please be aware that such a request does not ensure complete or comprehensive removal of the content or information you have posted, since the content or information may remain in our database, may remain visible in a manner that does not identify you, or may have been re-posted by another user. For residents of the United States, there may be other circumstances in which applicable laws do not require or allow removal even if requested.

You may also ‘opt-out’ of receiving non-essential or promotional communications directly from RiskBand. If you no longer wish to receive our non-service-related mailings, you may opt-out of receiving these communications by following unsubscribe instructions at the bottom of each communication, replying to the email and placing “unsubscribe” in the subject line of the email, or emailing us at privacy@riskband.com.

1. RiskBand Employee Information
   1. What information is collected, and who collects it

RiskBand collects information when you apply for employment, on our Site or by some other method, and when you are employed by RiskBand.  Information collected may include name, address, bank information for payroll purposes, email address, job title, phone or fax number, and emergency contact information.  In some cases, we may collect information from or through a third party in order to provide you risk management or emergency services. In those circumstances, the collection, use, and disclosure of your information is subject to the privacy policy of the third party website or service, and not this Privacy Policy.

1. ii) How the information is used

We use information collected to fulfill our legal obligations as an employer, including performance evaluation, tax reporting, payroll data, and employee benefit services.

1. How to contact us with questions or issues
2. The choices available to users regarding collection, use, and distribution of information

You always have the ability to modify or remove information you provide to us, by sending an email to privacy@riskband.com.

In the event of a complaint, we may receive information about you from other users or third parties who may communicate information to us about you in relation to that complaint.

1. Other considerations
2. Privacy Protections for Children

RiskBand’s Services, including the Site, are provided for adults only. The Site and the Services are not directed to children under the age of 13, and we do not knowingly collect information from children under the age of 13 through the Site or other Services.

1. Procedures used to secure information under our control from loss, misuse, or alteration

RiskBand takes commercially reasonable administrative, technical, and physical precautions to protect our users’ information against loss, misuse and unauthorized access, disclosure, alteration, or destruction. However, no system is 100% secure and, therefore, we cannot guarantee the absolute security of the information that we collect.

We may retain your information for as long as your account is active or as needed to provide you Services, comply with our legal obligations, resolve disputes, and enforce our agreements, consistent with applicable law.

• For European Union, United Kingdom, and Swiss Individuals

In connection with your use of our Site and Services for your benefit, RiskBand may receive information about you directly from our client. For individuals residing in the European Union, Switzerland, and/or the United Kingdom, we act as a data processor on behalf of our client.  If our client has given RiskBand any information about you in connection with its license of a RiskBand product or Service for your benefit, our client and not RiskBand will be responsible for determining the method and means by which you will receive notice and the ability to consent to RiskBand’s receipt and use of such information.

1. Dispute resolution

An individual who seeks to view, correct, amend, or delete inaccurate data should direct his or her query to the client (the data controller). If our client authorizes us to correct, amend, or delete the data, then we will respond within a reasonable timeframe.

1. Affirmative commitment to comply with the Privacy Shield Framework 

Risk Band LLC complies 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 transferred from the European Union, the United Kingdom and Switzerland to the United States.  Risk Band LLC has certified to the Department of Commerce that it adheres to the Privacy Shield Principles.  If there is any conflict between the terms in this Privacy Policy and the Privacy Shield Principles, the Privacy Shield Principles shall govern.  To learn more about the Privacy Shield program, and to view our certification, please visit https://www.privacyshield.gov/

RiskBand LLC is subject to the jurisdiction and enforcement authority of the United States Federal Trade Commission.

Pursuant to the Privacy Shield Frameworks, we affirm the following:

• EU, UK and Swiss individuals have the right to access their personal information which we hold and to update, amend or delete it if it has been handled in a manner inconsistent with the Privacy Shield Principles.. Understand, however, that if your data is being controlled by one of our clients who retains control over that information, we may have to refer any requests to that entity.  If we are a data controller for your information, you can access your data by contacting us at privacy@riskband.com.
• We may be required to release data in response to lawful requests by public authorities including to meet national security and law enforcement requirements
• We will provide an individual opt-out choice, or opt-in for sensitive data, before we share your data with third parties other than our clients or agents, or before we use it for a purpose other than for which it was originally collected or subsequently authorized. You may also ‘opt-out’ of receiving non-essential or promotional communications directly from RiskBand. If you no longer wish to receive our non-service-related mailings, you may opt-out of receiving these communications by following unsubscribe instructions at the bottom of each communication, replying to the email and placing “unsubscribe” in the subject line of the email, or emailing us at privacy@riskband.com.
• Sharing data: For our Services, when you use our device, and press the emergency button to initiate an emergency alert, the device and the ARIES Platform collects your precise location data using GPS and cellular signals.  Your associated organization’s ARIES Platform administrator, as determined by our client, uses the Services to obtain or retrieve information that is relevant to your then-current location. This information is used to identify you as a user of a specific device and to support emergency response services to you, provided by either RiskBand partners or our client. For our Site, we do not share your information with anyone other than the service providers, such as Google Analytics and web hosting services, which help us collect the information.  For marketing, we use the information to provide you with content, products, and services that you request.  We use the information you provide to respond to your requests, request feedback, handle customer service questions or issues, or notify you of important changes or updates to the Services.  We also use the information to send newsletters and promotional communications. 
• Non-agent Sharing: We do not sell your data to third parties, or allow third parties beyond those described above to view or use your data.  If our practice changes, we will update this privacy notice and provide individuals with opt-in choice prior to sharing their data. 
• We remain liable for the onward transfer of personal data to third parties acting as our agents unless we can prove we were not a party giving rise to the damages.

In compliance with the Privacy Shield Principles, RiskBand LLC commits to resolve complaints about our collection or use of your personal information.  EU, UK and Swiss individuals with inquiries or complaints regarding our Privacy Shield policy should first contact RiskBand LLC at the contact information at the end of this Policy. 

RiskBand LLC has further committed to refer unresolved privacy complaints under the Privacy Shield Principles to an independent dispute resolution mechanism, the BBB EU PRIVACY SHIELD. If you do not receive timely acknowledgment of your complaint, or if your complaint is not satisfactorily addressed, please visit www.bbb.org/EU-privacy-shield/for-eu-consumers  for more information and to file a complaint. This service is provided free of charge to you. 

If your Privacy Shield complaint cannot be resolved through the above channels, under certain conditions, you may invoke binding arbitration for some residual claims not resolved by other redress mechanisms.  See Privacy Shield Annex 1 at https://www.privacyshield.gov/article?id=ANNEX-I-introduction

How to Contact Us with Questions or Issues

Users are encouraged to contact RiskBand if they have a complaint. Questions, comments, or complaints regarding the use or disclosure of information and this Policy should be sent by email to privacy@riskband.com, or submitted to the following person by mail as follows.  In compliance with the Privacy Shield Principles, (your organization name) commits to resolve complaints about our collection or use of your personal information.  EU, UK and Swiss individuals with inquiries or complaints regarding our Privacy Shield Policy should first contact (your organization name) at: 

Risk Band LLC

Attn: Privacy Office

1036B eWall St.

Mount Pleasant, SC 29464

Changes to This Privacy Policy

This Privacy Policy may be amended from time to time, consistent with changing legal, regulatory, or client

requirements. We will post any changes to this Privacy Policy on our Site and on the ARIES Platform. If we make a material change to this Privacy Policy, we will provide you with appropriate notice on our Site and on the ARIES Platform prior to the change becoming effective.