PRIVACY POLICY

Active Protective Technologies, Inc.

Last updated June 25, 2019

Active Protective Technologies, Inc. serves to enable mobility & safety of our users. We use cloud-based technology to enable communication of alerts in times of need. We also capture, analyze and store motion data collected to offer insight on mobility. We respect the privacy of our users. This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you visit our website, mobile application, and desktop application (the website, mobile and desktop applications are collectively referred to herein as the “Application”).   Please read this Privacy Policy carefully.  IF YOU DO NOT AGREE WITH THE TERMS OF THIS PRIVACY POLICY, PLEASE DO NOT ACCESS THE APPLICATION. Unless otherwise defined in this Privacy Policy, terms used in this Privacy Policy have the same meanings as in the TERMS OF USE.

This Privacy Policy applies only to Active Protective Technologies, Inc.’s Application. This Privacy Policy does not apply to any websites managed, maintained, and/or hosted by third parties not directly affiliated with Active Protective Technologies, Inc. that you may visit, e.g., via a link provided through the Application or on a website maintained by any third party, including the third-party online/mobile store from which you install the Application or make payments, which may also collect and use data about you.  We are not responsible for any of the data collected by any such third party. Active Protective Technologies, Inc. does not control the privacy policies of other websites to which we may provide hyperlinks.  We encourage you to learn more about the online privacy and data security policies of third party websites directly from such third parties, as their policies may differ from ours.  

I.             COLLECTION OF YOUR INFORMATION

We may collect information about you in a variety of ways.  The information we may collect via the Application depends on the content and materials you use, and includes: 

A.           Personal Data

This refers to information about you that can be used to contact or identify you (“Personal Data”).  Personal Data includes, but is not limited to, full name, date of birth, current address, mailing address, email, phone number and any other information that could be used to personally identify you.  

We also collect other information that you provide as part of registration and the administration and personalization of your account with us that does not identify you (“Non-Identifying Information”).  Non-Identifying Information includes, but is not limited to, your zip code (on its own) and individual preferences.  Certain Non-Identifying Information would be considered a part of your Personal Data if it were combined with other identifiers (for example, combining your zip code with your mailing address) in a way that enables you to be identified.  But the same pieces of information are considered Non-Identifying Information when they are taken alone or combined only with other non-identifying information (for example, your gender only or your viewing preferences).  

We use your Personal Information (in some cases, in conjunction with your Non-Identifying Information) mainly to provide the Application, which includes sending alerts/notifications on your behalf, and respond to correspondence from you. We may also use your Personal Information to facilitate and complete transactions for you, and contact you with newsletters, marketing or promotional materials and other information that may be of interest to you.  If you decide at any time that you no longer wish to receive such communications from us, please follow the unsubscribe instructions provided in any of the communications or update your account information.  

We may also combine your Personal Information with Non-Identifying Information and aggregate it with information collected from other users to attempt to provide you with a better experience, to improve the quality and value of the Application, and to analyze and understand how the Application is used.

B.            Communication Data 

In order to allow for communication to your support network when needed, we will ask for the telephone numbers & email addresses of the individuals you would like belt alerts to notify in the case assistance is needed. We may also send you communication via email, text, phone regarding updates about our services. If you are in a facility or otherwise working with a clinical care team, we will ask the clinical care team member whether he/she has obtained appropriate consent from you to contact these individuals, and will rely on, and not separately confirm, their representation.  

C.           Other Data

The motion sensors in the belt will be able to measure data as to when and how the belt is being worn, charged and is moving around. Active Protective Technologies, Inc. will have access to this information for its own internal purposes of: 1) determining belt utilization and performance at the individual or customer account level, 2) analyzing motions to extract clinically relevant metrics, such as (but not limited to) step count and balance, for the purposes of informing the user or their care team, 3) continually improving algorithms within the belt which are responsible for features such as fall detection, impact detection, improper belt usage, etc. and 4) troubleshooting and resolving technical issues related to a user profile or account, such as a forgotten username or password.  In addition, if you are in a facility or otherwise working with a clinical care team, the facility and clinical care team will have access to this information. Also, if you have designated a facility as the recipient of your information, Active Protective Technologies, Inc. is not responsible for any use or disclosure of information made by the facility or clinical care team or responsible for the privacy of any information once it has been received by the facility or clinical care team. You should contact your facility or clinical care team with any questions regarding uses, disclosure or privacy of your information.   

D.           Financial Data

We may collect certain financial information, such as data related to your payment method (e.g. valid credit card number, card brand, expiration date) that if you purchase, order, return, or exchange products from Active Protective Technologies, Inc. We store only very limited, if any, financial information that we collect. Otherwise, all financial information is stored by our payment processor, [Amazon Payments,] [Authornize.Net,]  [Braintree Payments,] [Chargify,] [Dwolla,] [Google Checkout,][Paypal,] [SafeCharge,] [Stripe,] [WePay,[2Checkout,] [Shopify,] and you are encouraged to review their privacy policy and contact them directly for responses to your questions.

E.            Geo-Location Information

We may request access or permission to and track location-based information from your mobile device, either continuously or while you are using the Application, to provide location-based services. If you wish to change our access or permissions, you may do so in your device’s settings.

F.            Mobile Device Access

We may request access or permission to certain features from your mobile device, including your mobile device’s Bluetooth, WiFi, calendar, camera, contacts, microphone, reminders, sensors, storage, and other features. If you wish to change our access or permissions, you may do so in your device’s settings.

G.           Mobile Device Data

We may access mobile device information such as your mobile device ID number, model, and manufacturer, version of your operating system, phone number, country, location, and any other data you choose to provide. 

H.           Push Notifications

We may request to send you push notifications regarding your account or the Application. If you wish to opt-out from receiving these types of communications, you may turn them off in your device’s settings.

I.             Third-Party Data

Information from third parties, such as personal information or network friends, if you connect your account to the third party and grant the Application permission to access this information.

 

II.           USE AND DISCLOSURE OF YOUR INFORMATION

The information that Active Protective Technologies, Inc. collects may be used to provide the Application and its functionality to you and may be added to our databases and used for business purposes, including for marketing and promotional purposes, for a statistical analysis of End Users’ behavior, for product development, for content improvement, or to customize the content and layout of the Website.  We may share information we have collected about you in certain situations. 

If you are in a facility or otherwise working with a clinical care team, the facility and clinical care team that you designate will have access to your information. If you have designated a facility as the recipient of your information, Active Protective Technologies, Inc. is not responsible for any use or disclosure of information made by the facility or clinical care team or responsible for the privacy of any information once it has been received by the facility or clinical care team. You should contact your facility or clinical care team with any questions regarding uses, disclosure or privacy of your information.  

Your information may also be disclosed to other third parties as described below. 

We are not responsible for the actions of third parties with whom you share personal or sensitive data, and we have no authority to manage or control third-party solicitations.  If you no longer wish to receive correspondence, emails or other communications from third parties, you are responsible for contacting the third party directly.

A.           By Law or to Protect Rights

If we believe, in our sole discretion, the release of information about you is necessary to respond to legal process, to investigate or remedy potential violations of our policies; to protect the rights, property, and safety of others; or to prevent activity that we believe, in our sole discretion, may be or may become illegal, unethical, or legally actionable, we may share your information as permitted or required by any applicable law, rule, or regulation.  This includes exchanging information with other entities for fraud protection and credit risk reduction.

B.            Third-Party Service Providers

We may share your information with third parties that perform services for us or on our behalf, including payment processing, data analysis, email delivery, hosting services, customer service, etc. We may also share Non-identifying information with research partners for the purposes of studying safety, effectiveness, and utility of the belt.

C.           Sale or Bankruptcy

If we reorganize or sell all or a portion of our assets, undergo a merger, or are acquired by another entity, we may transfer your information to the successor entity.  If we go out of business or enter bankruptcy, your information would be an asset transferred or acquired by a third party.  You acknowledge that such transfers may occur and that the transferee may decline honor commitments we made in this Privacy Policy.

 

III.         TRACKING TECHNOLOGIES

Active Protective Technologies, Inc. may use a number of different techniques and technologies to collect the information described above.  For example, Active Protective Technologies, Inc. may use cookies, web beacons, website analytics and/or other technology used to monitor your use of the Application.  

A.           Cookies and Web Beacons

We may use cookies, web beacons, tracking pixels, and other tracking technologies on the Application to help customize the Application and improve your experience. When you access the Application, your personal information is not collected through the use of tracking technology. 

Most browsers are set to accept cookies by default. A cookie is a small amount of data that is sent to and stored on your device from our server. Cookies may, for example, allow a user to enter a password less frequently or remember a user’s preferences during an online session.  You can remove or reject cookies, but be aware that such action could affect the availability and functionality of the Application. 

You may not decline web beacons. However, they can be rendered ineffective by declining all cookies or by modifying your web browser’s settings to notify you each time a cookie is tendered, permitting you to accept or decline cookies on an individual basis.

B.            Forms

We request certain information from you through the use of forms when you send us correspondence through the Application.

C.           Website Analytics

We may also partner with selected third-party vendors, such as [Adobe Analytics,] [Clicktale,] [Clicky,] [Cloudfare,] [Crazy Egg,] [Flurry Analytics,] [Google Analytics,] [Heap Analytics,] [Inspectlet,] [Kissmetrics,][Mixpanel,] [Piwik,] and others, to allow tracking technologies and remarketing services on the Application through the use of first party cookies and third-party cookies, to, among other things, analyze and track users’ use of the Application, determine the popularity of certain content, and better understand online activity. By accessing the Application, you consent to the collection and use of your information by these third-party vendors. You are encouraged to review their privacy policy and contact them directly for responses to your questions. We do not transfer personal information to these third-party vendors. However, if you do not want any information to be collected and used by tracking technologies, you can install and/or update your settings for one of the following:

[Adobe Privacy Choices Page]

[Clicktale Opt-Out Feature]

[Crazy Egg Opt-Out Feature]

[Digital Advertising Alliance Opt-Out Tool]

[Flurry Analytics Yahoo Opt-Out Manager]

[Google Analytics Opt-Out Plugin]  

[Google Ads Settings Page]

[Inspectlet Opt-Out Cookie]

[Kissmetrics Opt-Out Feature]

[Mixpanel Opt-Out Cookie]

[Network Advertising Initiative Opt-Out Tool

You should be aware that getting a new computer, installing a new browser, upgrading an existing browser, or erasing or otherwise altering your browser’s cookies files may also clear certain opt-out cookies, plug-ins, or settings.

D.           Tracking

We may collect certain data automatically by the Application’s servers and software.  For example, because the Application automatically collects usage data for all End Users that visit the Application, your Application session will be tracked. You agree that we may collect and use technical data and related information, including technical information about your device, system and application software, and peripherals, to maintain and support the Application generally.  

Most web browsers and some mobile operating systems, including our mobile Applications include a Do-Not-Track (“DNT”) feature or setting you can activate to signal your privacy preference not to have data about your online browsing activities monitored and collected.  No uniform technology standard for recognizing and implementing DNT signals has been finalized. As such, we do not currently respond to DNT browser signals or any other mechanism that automatically communicates your choice not to be tracked online.  If a standard for online tracking is adopted that we must follow in the future, we will inform you about that practice in a revised version of this Privacy Policy. 

 

IV.         THIRD-PARTY WEBSITES

The Application may contain links to third-party websites and applications of interest, including advertisements and external services, that are not affiliated with us. Once you have used these links to leave the Application, any information you provide to these third parties is not covered by this Privacy Policy, and we cannot guarantee the safety and privacy of your information. Before visiting and providing any information to any third-party websites, you should inform yourself of the privacy policies and practices (if any) of the third party responsible for that website, and should take those steps necessary to, in your discretion, protect the privacy of your information. We are not responsible for the content or privacy and security practices and policies of any third parties, including other sites, services or applications that may be linked to or from the Application.

 

V.           SECURITY OF YOUR INFORMATION

We use administrative, technical, and physical security measures to help protect your personal information.  While we have taken reasonable steps to secure the personal information you provide to us, please be aware that despite our efforts, no security measures are perfect or impenetrable, and no method of data transmission can be guaranteed against any interception or other type of misuse.  Any information disclosed online is vulnerable to interception and misuse by unauthorized parties.  Therefore, we cannot guarantee complete security if you provide personal information.

 

VI.         POLICY FOR CHILDREN

We do not knowingly solicit information from or market to children under the age of 13. If you become aware of any data we have collected from children under age 13, please contact us using the contact information provided below.

Any access to or use of the Application by anyone under the age of thirteen (13) is unauthorized, unlicensed, and in violation of the Agreement.  By using the Application, you represent and warrant that you are thirteen (13) years of age or older and that you agree to and agree to abide by all of the terms and conditions of the Agreement.  If Active Protective Technologies, Inc. believes that you are under the age of thirteen (13) or that you are not old enough to consent to and be legally bound by the Agreement, Active Protective Technologies, Inc. may, at any time, in its sole discretion, and with or without notice: (i) terminate your access to or use of the Application (or any portion, aspect, or feature of them), or (ii) delete any content or information that you have posted through the Application.

 

VII.       OPTIONS REGARDING YOUR INFORMATION

Account Information

You may at any time review or change the information in your account or terminate your account by:

1.    Logging into your account settings and updating your account; or

2.    Contacting us using the contact information provided below: 

support@activeprotective.com

Upon your request to terminate your account, we will deactivate or delete your account and information from our active databases. However, some information may be retained in our files to prevent fraud, troubleshoot problems, assist with any investigations, enforce our Terms of Use and/or comply with legal requirements.

 

VIII.    CALIFORNIA PRIVACY RIGHTS

California Civil Code Section 1798.83, also known as the “Shine The Light” law, permits our users who are California residents to request and obtain from us, once a year and free of charge, information about categories of personal information (if any) we disclosed to third parties for direct marketing purposes and the names and addresses of all third parties with which we shared personal information in the immediately preceding calendar year. If you are a California resident and would like to make such a request, please submit your request in writing to us using the contact information provided below.

California residents who have an established business relationship with Active Protective Technologies, Inc. may choose to opt out of Active Protective Technologies, Inc.’s disclosing personal information about them to third parties for marketing purposes.  If you do not want us to share your personal information with such third parties, please send us your name, email address, street address and phone number to support@activeprotective.com. Your opt out request will be processed within 30 days of the date it was received. 

If you are under 18 years of age, reside in California, and have a registered account with the Application, you have the right to request removal of unwanted data that you publicly post on the Application. To request removal of such data, please contact us using the contact information provided below, and include the email address associated with your account and a statement that you reside in California.  We will make sure the data is not publicly displayed on the Application, but please be aware that the data may not be completely or comprehensively removed from our systems.

 

IX.         CHANGES TO THIS POLICY

We reserve the right to make changes to this Privacy Policy at any time and for any reason.  We will alert you about any changes by updating the “Last updated” date of this Privacy Policy.  You are encouraged to periodically review this Privacy Policy to stay informed of updates. You will be deemed to have been made aware of, will be subject to, and will be deemed to have accepted the changes in any revised Privacy Policy by your continued use of the Application after the date such revised Privacy Policy is posted. The information Active Protective Technologies, Inc. gathers is and will be subject to the Privacy Policy in effect at the time the information is gathered. 

 

X.           CONTACT US

If you have questions or comments about this Privacy Policy, please contact us at:

Active Protective Technologies, Inc
580 Virginia Dr Suite 230
Fort Washington, PA 19034
support@activeprotective.com