RiskBand Privacy Policy

Effective Date: April 26, 2019

Risk Band LLC and its affiliates (hereafter “RiskBand,” “we,” or “us”) respect individual privacy and value the confidences of our clients, employees, business partners, and others. We strive to collect, use, and disclose personal and other information in a manner consistent with applicable laws, and pride ourselves in upholding the highest ethical standards in our business practices. This Privacy Policy describes how RiskBand collects, uses, and shares information in connection with: our website at www.riskband.com (the “Site”); our RiskBand ARIES Device (the “Device”); our RiskBand ARIES Manager Software Platform (the “Platform”); and emails that we send to our clients. The Site, Devices, Platform, and emails are sometimes collectively referred to as the “Services.” This Privacy Policy also describes choices available to users regarding Personal Information.

What information is collected?

Who collects the information?

How the information is used.

Information we collect on behalf of our clients.

With whom the information may be shared.

Privacy protections for children.

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

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

Information for European Union users.

International transfer of data.

How to contact us with questions or issues.

Dispute resolution.

Changes to this privacy policy.

What Information is Collected

RiskBand Services

RiskBand collects both Personal Information and Other Information when you register for or use the Services. “Personal Information” is any information or set of information relating to an identified person or a person who can be identified, directly or indirectly, by reference to an identifier, such as an identification number, location data, an online identifier or one or more factors specific to physical, physiological, genetic, biometric, mental, economic, cultural, or social identity. For example, Personal Information includes name, address, email address, employer’s name, job title, phone or fax number, employee ID, emergency contact information, and, if requested by a client, other identifying factors. “Sensitive Personal Information” means Personal Information that reveals race, ethnic origin, sexual orientation, political opinions, religious or philosophical beliefs, or trade union membership, that concerns an individual’s health or sex life, criminal proceedings, or that is designated in writing by a third party as Sensitive Personal Information.

“Other Information” is any information that is not Personal Information or Sensitive Personal Information. For purposes of this Privacy Policy, Personal Information does not include information that is anonymized, pseudonymous, or publicly available information that has not been combined with Personal Information or Sensitive Personal Information. If we combine Other Information with Personal Information, we will treat the combined information as Personal Information in accordance with this Privacy Policy.

  • For individuals residing in the European Union, if RiskBand collects Personal Information directly from you, we will inform you about the types of Personal Information collected, the purposes for which we collect and use the Personal Information, the types of non-agent third parties to whom RiskBand discloses or may disclose that information, and the choices and means, if any, RiskBand offers individuals for limiting the use and disclosure of their Personal Information. Under these circumstances, notice will be provided in clear and conspicuous language when you are first asked to provide Personal Information to RiskBand, or as soon as practicable thereafter, and in any event before RiskBand uses or discloses the information for a purpose other than that for which it was originally collected or discloses it for the first time to a third party. For example, we may receive Personal Information from your authorized representatives, or authorized administrators of our Client, for use in connection with our provision of Services.

We collect Personal Information for the RiskBand Services in the following circumstances:

  • You provide certain Personal Information to us when you: (a) register to use the Services, (b) use the Services, and (c) send email messages, submit forms, or send other information to us.
  • RiskBand may obtain Personal Information about you from third parties.
  • When you complete a User Profile on the 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 (such as login name, first name, last name, and organization affiliation). In the event that a Device is alerted, this information is used to identify you as a user of a specific Device and to support emergency response services provided by either RiskBand partners or our Client. It is optional for you, your authorized representative, or the authorized administrator at our Client, to provide additional Personal 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. Please understand that by providing, or by authorizing others to provide, any such additional Personal Information permits RiskBand to provide the information to emergency response services, RiskBand partners and our Client.

If you use our Device, RiskBand may collect information about the precise location of your Device using GPS or cellular network signals. In particular, our Devices and Platform collect precise location data when you use the emergency button or when you or our Client’s RiskBand Manager administrator use the Services to obtain or retrieve information that is relevant to your then-current location. If you would like RiskBand to stop collecting precise location data from your Device, please follow the instructions in the section below titled “Your choices regarding collection, use, and distribution of Personal Information and Other 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, RiskBand’s Client.
  • In the event of a complaint, we may receive Personal Information about you from other users or third parties who may communicate information to us about you in relation to that complaint.
  • We may collect Personal Information from you at other times that you use our Services, in which event, you will be advised that Personal Information is being collected.

We and our service providers may also collect Other Information when you use the Services. This may include your computer or Device operating system and browser type, 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 or the Platform.

RiskBand and our partners may collect this Other Information automatically through the use of cookies or similar technologies, such as JavaScript, to analyze trends, administer the Site, track users’ movements around the Site or the Platform, and to gather demographic information about our user base as a whole.

RiskBand Marketing

RiskBand collects both Personal Information and Other Information for marketing purposes when you register for access to content in any form or you contact us. Personal Information collected for marketing purposes includes name, address, email address, employer’s company name, job title, phone number or fax number. We do not request any “Sensitive Personal Information” for marketing purposes.

We collect Personal Information for marketing purposes in a variety of ways including:

  • Offline: When you attend one of our events, during phone calls with sales representatives, or when you contact our customer service.
  • Through You: Information that you voluntarily provide through forms or access requests. Note that there is no legal obligation for you to provide us with Personal Information and any information collected by us will be provided by you at your own election and with your consent. We may also collect Personal Information from you at other times that you use our Services, and you will be advised that Personal Information is being collected. You always have the ability to modify or remove information you provide to us, either in the form or through an email to privacy@riskband.com.
  • Information from Other Sources: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.

We and our service providers may collect Other Information for marketing purposes in the following ways, including:

  • Through Your Browser or Device: Certain information is collected by most browsers or automatically through your device, such as a computer(Windows or Macintosh), screen resolution, operating system name and version, device manufacturer and model, language, Internet browser type and version, and the name and version of the Site (such as the Services) you are using.
  • Through Cookies and Similar Technologies: RiskBand and our partners use cookies and similar technologies to analyze trends, administer the Site, track users’ movement around the Site, and to gather demographic information about our user base as a whole. In particular, cookies and other technologies are used by our web analytics services which currently is Google Analytics, a web analytics service provided by Google Inc. Google Analytics uses cookies and similar technologies to analyze how users use the Site. For more information about Google Analytics, or to opt-out of Google Analytics, please go to: https://tools.google.com/dlpage/gaoptout.

Employee Information

RiskBand collects both Personal Information and Other Information when you apply on our Site or by some other method and when you are employed by RiskBand. Personal Information collected may include name, address, bank information for payroll purposes, email address, job title, phone or fax number, and emergency contact information. RiskBand does not store, nor does it allow its Clients to store, passport numbers, national registration numbers, or Social Security numbers.

Who Collects the Information

Risk Band LLC is the company that collects Personal Information and Other Information through our Services. Our mailing address is:

1036B eWall St.

Mount Pleasant, SC 29464

Our customer service email address is privacy@riskband.com.

In some cases, as part of our Services, 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.

How the Information is Used

For individuals residing in the European Union, RiskBand will use Personal Information only in ways that are compatible with the purposes for which it was collected or subsequently authorized by the individual or directed by our Client that has licensed RiskBand Services on behalf of its employees or service providers. RiskBand will take reasonable steps to ensure that Personal Information that you provide to us is reliable for its intended use, accurate, complete, and current.

Services

We use Personal Information and Other Information as part of our Services to:

  • Provide you with content, products, and services that you request, fulfill the terms of any agreement you or our Client has with us, and operate our business.
  • Register you for the Services and tailor the Services specifically to the profile you provide.
  • Send administrative communications about the Services, provide relevant Emergency Action Messages and Urgent Messages, if you elect to receive them, respond to your requests, request feedback or handle customer service questions or issues, or notify you of important changes or updates to the Services.
  • Provide location-based services to you. For example, our Device, when active, collects information about your current location, and sends a signal with your current location during an emergency, including incident information collected from the Device such as precise location, images, and User Profile data. In some cases, the Device may allow your precise location to be monitored on a near real-time, continuous basis.
  • Operate our Services, enhance our Services, and deliver messages.
  • Provide certain information to potential clients on an aggregated basis. 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.

Marketing

We use Personal Information and Other Information collected for marketing purposes to:

  • Respond to any requests for information you submit.
  • Send newsletters and promotional communications (which we send on an opt-in basis where required by law) regarding our current products, Services, and features; our new or improved products, services, or 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.
  • Understand and analyze how the Services are being used, create new products and services, and deliver messages.
  • Provide lists of prospects from tradeshows with partners (on an opt-in basis where required by law).
  • Provide certain information to potential clients on an aggregated basis. 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.

Employee

We use Personal Information and Other Information collected for Employment Purposes to:

  • Fulfill our legal obligations as an employer, including performance evaluation, tax reporting, payroll data, and employee benefit services.

Information We Collect on Behalf of Our Clients

The use of information collected through our Service shall be limited to the purpose of providing the Service for which the Client has engaged RiskBand.

RiskBand collects information under the direction of its Clients and has no direct relationship with the individuals whose personal data it processes. If you are a customer of one of our Clients and would no longer like to be contacted by one of our Clients that use our Service, please contact the Client that you interact with directly. We may transfer Personal Information to companies that help us provide our Service, such as our emergency response partners or other monitoring services designated by our Clients. Transfers to subsequent third parties are covered by the service agreements with our Clients and may include emergency response agencies.

In connection with your use of RiskBand products or Services for your benefit, RiskBand may receive Personal Information about you directly from our Client. For individuals residing in the European Union, if our Client has given RiskBand any Personal 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.

An individual who seeks access, or who seeks to correct, amend, or delete inaccurate data should direct his or her query to the Client (the data controller). If we are requested to remove data, we will respond within a reasonable timeframe.

We will retain Personal Information we process on behalf of our Clients for as long as needed to provide Services to our Client. RiskBand will retain this Personal Information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.

With Whom the Information may be Shared

We disclose information to third parties in the following circumstances:

  • RiskBand may share Personal Information and Other Information we collect with our contractors and third party service providers, including companies that send email and other messages on our behalf to you, companies that store such information for these uses, and companies that perform analytics services for us, on a need-to-know basis in order to provide and maintain our Services. These companies are authorized to use your Personal Information only as necessary to provide these services to us. For consumers residing in the European Union, RiskBand will obligate such service providers to safeguard such information in a manner consistent with this Privacy Policy and the consent provided by you, and to provide the same level of protection as the Privacy Shield Principles. RiskBand will remain liable under the Privacy Shield Principles if the service provider processes information in a manner inconsistent with the Principles, unless RiskBand proves that it is not responsible for the event giving rise to the damage, if any.
  • Our Site may allow third parties (such as Google) to collect information through cookies, pixel tags, and mobile advertising identifiers, such as Apple’s IDFA or Android’s Advertising ID, for use in online, interest-based advertising. For more information about behavioral advertising practices, visit the Network Advertising Initiative, the Digital Advertising Alliance or the European Digital Advertising Alliance. You may opt-out of our third party service providers’ interest-based advertising practices in web browsers and mobile apps by clicking http://preferences-mgr.truste.com or if located in the European Union by clicking http://www.youronlinechoices.eu. Please note you will continue to receive generic ads. Although our Site currently does not respond to “do not track” browser headers, you can limit tracking by taking the steps discussed above. Please note that the use of online tracking mechanisms by third parties is subject to those third parties’ own privacy policies and not our Privacy Policy.
  • If a RiskBand product or Service is licensed by our Client on behalf of an individual, RiskBand may transfer Personal Information and Other Information, including precise location, to the Client for its legitimate business purposes, including, without limitation, for purposes of risk management and/or emergency response.
  • When you contribute to a public area or feature of our Site, the information that you submit will be made available to other users, and sometimes to the general public. For this reason, we recommend that you do not submit any Personal Information, including your full name, home address, phone number, other information that would enable other users to locate you, or financial or medical information on these areas of our Site. If you are a California resident under the age of 18 and a registered user of our Services, you may request that we remove content or information that you post on our Services 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. There may be other circumstances in which applicable laws do not require or allow removal even if requested.
  • In addition, RiskBand may use and disclose Personal Information and Other 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.
  • RiskBand may disclose Personal Information and Other Information to facilitate the financing, securitization, insuring, merger, sale, assignment, bankruptcy, or other disposal of all or part of our business or assets.

We may also disclose aggregated, de-identified information about users of the Services for any purpose, such as by publishing a report on trends in the usage of RiskBand Services..

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 Personal Information from children under the age of 13 through the Site or other Services.

The Choices Available to Users Regarding Collection, Use, and Distribution of Personal Information and Other Information

You can control the collection, use, and sharing of your information by following the instructions stated below. Please note that if you provide any information to parties who provide services to our Site or Platform or to any other sites or application you encounter on the Internet or otherwise (even if these sites are branded with our branding), different rules may apply to their use or disclosure of any Personal Information you disclose to them. We encourage you to investigate and ask questions before disclosing any Personal Information to third parties.

  • You have the right to access, amend, or delete Personal Information we hold about you, and in some cases, to object to the processing of your Personal Information, or request your Personal Information to be provided to you in a portable form. For example, if your Personal Information changes, you would like to review or correct your Personal Information, or if you no longer desire our Services, you may correct, update, or remove your Personal Information at the member information page or by emailing our Customer Support at privacy@riskband.com. Upon request, we will provide you with information about whether we hold any of your Personal Information. We will respond to your request within a reasonable timeframe.
  • You are given the opportunity to ‘opt-in’ to having your Personal Information used for purposes not directly related to our Services at the point where we ask for the information. For example, RiskBand might want to use your information as part of future marketing campaigns.
  • 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.

RiskBand may collect location information if you use a RiskBand application on your mobile device. The iOS and Android (OS 6.0+) platforms will alert you the first time a RiskBand app wants permission to access certain types of data and will let you consent (or not consent) to that request. You may subsequently manage your location sharing preferences at any time with the iOS and Android (OS 6.0+) platforms by changing the Location Services settings on your mobile device. Android devices (OS 5.1.1 and earlier) will notify you of the permissions that a RiskBand app seeks before you first use the app, and your use of the app constitutes your consent.

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.

Information for European Union Users

RiskBand will participate in and certify its compliance with the EU-U.S. Privacy Shield Framework and the Swiss-U.S. Privacy Shield Framework. RiskBand is committed to subjecting all personal data received from European Union (EU) member countries and Switzerland, respectively, in reliance on each Privacy Shield Framework, to the Framework’s applicable Principles. To learn more about the Privacy Shield Framework, visit the U.S. Department of Commerce’s Privacy Shield List at https://www.privacyshield.gov/list.

RiskBand is responsible for the processing of personal data it receives, under each Privacy Shield Framework, and subsequently transfers to a third party acting as an agent on its behalf. RiskBand complies with the Privacy Shield Principles for all onward transfers of personal data from the EU and Switzerland, including the onward transfer liability provisions.

With respect to personal data received or transferred pursuant to the Privacy Shield Frameworks, RiskBand will be subject to the regulatory enforcement powers of the U.S. Federal Trade Commission. In certain situations, RiskBand may be required to disclose personal data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.

 

International Transfer of Data

Because RiskBand may provide Services in various locations throughout the world, it may be necessary to transfer your Personal Information internationally. In particular, your Personal 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.

How to Contact Us with Questions or Issues

Users are encouraged to contact RiskBand if they have a Privacy Shield-related complaint. Questions, comments, or complaints regarding the use or disclosure of Personal Information and this Policy should be sent by email to privacy@riskband.com or submitted to the following person by mail as follows:

Risk Band LLC

Attn: Privacy Office

1036B eWall St.

Mount Pleasant, SC 29464

Our data protection officer can be contacted as follows:

Risk Band LLC

Attn: Director – Enterprise Security Programs

1036B eWall St.

Mount Pleasant, SC 29464
privacy@riskband.com

Dispute Resolution

RiskBand will investigate and attempt to resolve complaints and disputes regarding use and disclosure of Personal Information in accordance with the Privacy Shield Principles contained in this Policy. If you have an unresolved privacy or data use concern that we have not addressed satisfactorily, please contact our U.S.-based third party dispute resolution provider (free of charge) at https://feedback-form.truste.com/watchdog/request.

Under certain conditions, more fully described on the Privacy Shield website at https://www.privacyshield.gov/article?id=How-to-Submit-a-Complaint, you may be entitled to invoke binding arbitration when other dispute resolution procedures have been exhausted.

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. If we make a material change to this Privacy Policy, we will provide you with appropriate notice on our Site prior to the change becoming effective.

Do you have a question about RiskBand?

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