This privacy notice describes how and why we might collect, store, use, and/or share (“process”) your information when you use our services (“Services”), such as when you:
- Download and use TrustNet, or any other application of ours that links to this privacy notice
- Engage with us in other related ways, including any sales, marketing, or events
Questions or concerns? Reading this privacy notice will help you understand your privacy rights and choices. If you do not agree with our policies and practices, please do not use our Services. If you still have any questions or concerns, please contact us at support@cuesoft.org.
SUMMARY OF KEY POINTS
This summary provides key points from our privacy notice.
What personal information do we process? Your name, your email address, and location points recorded by your device. We do not collect anything else about you.
How is your location recorded? Your device records a single location point when it registers that you have meaningfully moved. TrustNet does not stream your location continuously and does not record every step you take.
Do we process any sensitive personal information? Yes. Precise geolocation is treated as sensitive personal information under several privacy laws, including the California Consumer Privacy Act. We process it only to provide the Services described in this notice. We do not use or disclose it to infer characteristics about you, and we do not use it for advertising or profiling of any kind.
How long do we keep your location? Only the most recent 3 days. Older location records are deleted automatically.
Do we receive any information from third parties? No.
In what situations and with which parties do we share personal information? We do not sell or share your information with third parties for their own purposes, ever. We release your location records in exactly one situation: when a trusted contact you designated requests them, after we verify their email address, and after we notify you that the request was made.
How do we keep your information safe? Your location records are encrypted before they are stored, and they are stored separately from your device. We have organizational and technical processes in place to protect your personal information. However, no electronic transmission over the internet or information storage technology can be guaranteed to be 100% secure, so we cannot promise or guarantee that hackers, cybercriminals, or other unauthorized third parties will not be able to defeat our security and improperly collect, access, steal, or modify your information.
What are your rights? You have the right to request removal of your entire account, including all records of your email address and any location records we hold. You can do this from within the app and it takes effect immediately.
How do you exercise your rights? The easiest way is by removing your account from within the app. If you encounter any problems you can always contact us.
1. WHAT INFORMATION DO WE COLLECT?
Personal information you disclose to us
In Short: We only collect personal information that you provide to us.
We collect personal information that you voluntarily provide to us when you register on the Services, express an interest in obtaining information about us or our products and Services, when you participate in activities on the Services, or otherwise when you contact us.
Personal Information Provided by You. The personal information we collect may include the following:
- Name
- Email address
- Email addresses of the trusted contacts you choose to designate
Application data
If you use our application, we also collect the following information if you choose to provide us with access or permission:
- Location points. With your permission, TrustNet records a location point when your device registers a significant change in your location. This is not a continuous stream and it is not a record of every movement you make. These points are encrypted before being stored, and they are stored separately from your device. Location may be recorded while the app is in the background, including when the app is not open. If you wish to change our access or permissions, you may do so in your device’s settings.
- Push notifications. We may request to send you push notifications regarding your account or certain features of the application, including notifying you when a trusted contact requests your location records. If you wish to opt out of these communications, you may turn them off in your device’s settings. Please note that turning off notifications means you will not be alerted when someone requests your records.
If you decline location permission, the core function of the Services will not work.
Information automatically collected
In Short: Some technical information is collected automatically when you use our Services.
We automatically collect certain information when you visit, use, or navigate the Services. This information does not reveal your specific identity but may include device and usage information, such as your IP address, device characteristics, operating system, language preferences, device name, country, and information about how and when you use our Services. This information is primarily needed to maintain the security and operation of our Services, and for our internal analytics and reporting purposes.
2. HOW DO WE PROCESS YOUR INFORMATION?
In Short: We process your information to operate the Services, to communicate with you, for security, and to comply with law.
We process your personal information for the following reasons:
- To create and manage your account. So you can create and log in to your account and keep it in working order.
- To maintain your location records so that they are available if you go missing.
- To show your trusted contacts that your device is still reporting. Your trusted contacts see your name and how recently your location was updated. They do not see where you are.
- To fulfil a verified request from a trusted contact, and to notify you that the request was made.
- To deliver an SOS alert that you send from within the app to the contacts you designated.
- To save or protect an individual’s vital interest, such as to prevent harm.
- To comply with our legal obligations.
We do not use your information for advertising, profiling, or automated decision-making.
3. WHAT LEGAL BASES DO WE RELY ON TO PROCESS YOUR INFORMATION?
In Short: We only process your personal information when we have a valid legal reason to do so.
Where the EU or UK General Data Protection Regulation applies, we rely on the following legal bases: your consent, which you may withdraw at any time; the performance of a contract with you, to provide the Services you signed up for; our legitimate interests, in keeping the Services secure and functioning; vital interests, where processing is necessary to protect someone’s life; and compliance with legal obligations.
We rely on your consent to process your precise location. You may withdraw it at any time in your device settings or by deleting your account.
4. WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?
In Short: We release your location records only to a trusted contact you designated, after verifying them, and after telling you.
We do not sell your personal information, and we do not share it with third parties for their own purposes.
We will share your location records and name in the following situation, and only this one:
- Trusted contact request. A person you have saved as a trusted contact may request your location records. We verify their identity by validating their email address before releasing anything, and we notify you that the request was made. If you have not designated anyone as a trusted contact, no one can request your records.
We may need to disclose your personal information in the following additional situations:
- Legal obligations. We may disclose your information where we are legally required to do so in order to comply with applicable law, governmental requests, a judicial proceeding, court order, or legal process.
- Business transfers. We may share or transfer your information in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company. Because we hold no more than 3 days of location records at any time, the location data involved in any such transfer would be limited to that window.
- Service providers. We may share information with service providers who process it on our behalf under a written contract requiring them to protect it and to use it only for the purposes we specify.
5. HOW LONG DO WE KEEP YOUR INFORMATION?
In Short: Location records are kept for 3 days. Account information is kept until you delete your account.
Location records: 3 days
We keep only the most recent 3 days of your location records. Anything older is deleted automatically. It is not archived, and it is not retained in a reduced or anonymized form.
We chose a short window deliberately. Three days is enough to help find someone who has gone missing. It is not enough to build a picture of where you live, work, worship, or spend your time, and we do not want to hold that picture.
Account information
We keep your name, email address, and the email addresses of your trusted contacts for as long as you have an account with us. When you delete your account, this information is deleted from our active systems immediately.
Backups
Deleted information may persist in encrypted backup archives for up to [X days] before those backups are cycled out. During that period the information is isolated from any further processing.
6. HOW DO WE KEEP YOUR INFORMATION SAFE?
In Short: We aim to protect your personal information through a system of organizational and technical security measures.
Your location records are encrypted before they are stored, and they are stored separately from your device. We have implemented appropriate and reasonable technical and organizational security measures designed to protect the security of any personal information we process.
However, despite our safeguards and efforts to secure your information, no electronic transmission over the Internet or information storage technology can be guaranteed to be 100% secure, so we cannot promise or guarantee that hackers, cybercriminals, or other unauthorized third parties will not be able to defeat our security and improperly collect, access, steal, or modify your information. Although we will do our best to protect your personal information, transmission of personal information to and from our Services is at your own risk. You should only access the Services within a secure environment.
7. WHERE IS YOUR INFORMATION STORED?
Your information is stored on servers located in [COUNTRY / REGION]. If you are located outside that region, please be aware that your information will be transferred to, stored, and processed there. Where required by applicable law, we put in place appropriate safeguards for such transfers.
8. DO WE COLLECT INFORMATION FROM MINORS?
In Short: We do not knowingly collect data from or market to children under 13 years of age without parental consent.
TrustNet may be set up for a child by a parent or guardian. Where an account is created for a user under 13, it must be created and consented to by a parent or legal guardian, who is responsible for that account and may delete it at any time.
We do not knowingly solicit data from or market to children under 13 years of age without verifiable parental consent. If we learn that personal information from users less than 13 years of age has been collected without such consent, we will deactivate the account and take reasonable measures to promptly delete the data from our records. If you become aware of any data we may have collected from children under age 13, please contact us at support@cuesoft.org.
9. WHAT ARE YOUR PRIVACY RIGHTS?
In Short: You may review, change, or delete your account at any time, from inside the app.
In some regions (like the EEA, UK, Switzerland, and Canada), you have certain rights under applicable data protection laws. These may include the right (i) to request access and obtain a copy of your personal information, (ii) to request rectification or erasure, (iii) to restrict the processing of your personal information, (iv) if applicable, to data portability, and (v) not to be subject to automated decision-making. In certain circumstances, you may also have the right to object to the processing of your personal information. You can make such a request by contacting us using the contact details provided below.
We will consider and act upon any request in accordance with applicable data protection laws.
If you are located in the EEA or UK and you believe we are unlawfully processing your personal information, you also have the right to complain to your local data protection supervisory authority.
Withdrawing your consent. If we are relying on your consent to process your personal information, you have the right to withdraw that consent at any time. You may withdraw consent for location processing in your device’s settings, or by deleting your account from within the app. Withdrawing consent will not affect the lawfulness of processing carried out before its withdrawal, nor processing conducted in reliance on lawful grounds other than consent.
Account information. If you would at any time like to review, change, or delete your account, you can do so from within the app. Deleting your account removes your email address and all of your location records immediately. We may retain limited information where necessary to prevent fraud, assist with investigations, enforce our legal terms, or comply with applicable legal requirements.
If you have questions or comments about your privacy rights, you may email us at support@cuesoft.org.
10. CONTROLS FOR DO-NOT-TRACK FEATURES
Most web browsers and some mobile operating systems and 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. At this stage 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 notice.
11. DO UNITED STATES RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS?
In Short: Yes. If you are a resident of California and certain other states, you have specific rights regarding access to and deletion of your personal information.
How do we use and share your personal information?
More information about our data collection and sharing practices can be found in this privacy notice. You may contact us by email at support@cuesoft.org, or by referring to the contact details at the bottom of this document.
If you are using an authorized agent to exercise your rights, we may deny a request if the authorized agent does not submit proof that they have been validly authorized to act on your behalf.
Will your information be shared with anyone else?
We may disclose your personal information to our service providers pursuant to a written contract between us and each service provider. Each service provider processes the information on our behalf, following the same strict privacy protection obligations mandated by applicable law.
We may use your personal information for our own business purposes, such as undertaking internal research for technological development and demonstration. This is not considered to be “selling” of your personal information.
Cuesoft has not disclosed, sold, or shared any personal information to third parties for a business or commercial purpose in the preceding twelve (12) months. Cuesoft will not sell or share personal information belonging to website visitors, users, or other consumers in the future.
Your rights with respect to your personal data
Right to request deletion of the data. You can ask for the deletion of your personal information, and you can do it yourself from within the app. If you ask us to delete your personal information, we will respect your request and delete it, subject to certain exceptions provided by law.
Right to be informed. Depending on the circumstances, you have a right to know:
- whether we collect and use your personal information;
- the categories of personal information that we collect;
- the purposes for which the collected personal information is used;
- whether we sell or share personal information to third parties;
- the categories of personal information that we sold, shared, or disclosed for a business purpose;
- the categories of third parties to whom the personal information was sold, shared, or disclosed for a business purpose;
- the business or commercial purpose for collecting, selling, or sharing personal information; and
- the specific pieces of personal information we collected about you.
In accordance with applicable law, we are not obligated to provide or delete consumer information that is de-identified in response to a consumer request, or to re-identify individual data to verify a consumer request.
Right to Non-Discrimination for the Exercise of a Consumer’s Privacy Rights. We will not discriminate against you if you exercise your privacy rights.
Right to Limit Use and Disclosure of Sensitive Personal Information. We collect precise geolocation, which is classified as sensitive personal information under the California Consumer Privacy Act. We use it only to provide the Services described in this notice: to maintain your location records so that a trusted contact can request them if you go missing, and to deliver an SOS alert that you send. We do not use or disclose sensitive personal information to infer characteristics about you, for advertising, or for any purpose that would give rise to a right to limit its use under applicable law. You may stop this processing at any time by revoking location permission in your device settings or by deleting your account.
Verification process. Upon receiving your request, we will need to verify your identity to determine that you are the same person about whom we have information in our system. These verification efforts require us to ask you to provide information so that we can match it with information you have previously provided. We will only use personal information provided in your request to verify your identity or authority to make the request, and we will delete any additionally provided information as soon as we finish verifying you.
Other rights. You may object to the processing of your personal information; request correction of your personal data if it is incorrect or no longer relevant; designate an authorized agent to make a request on your behalf; and request to opt out from any future selling or sharing of your personal information. Upon receiving an opt-out request, we will act upon it as soon as feasibly possible and no later than fifteen (15) days from the date of submission.
To exercise these rights, contact us by email at support@cuesoft.org. If you have a complaint about how we handle your data, we would like to hear from you.
12. DO WE MAKE UPDATES TO THIS NOTICE?
In Short: Yes, we will update this notice as necessary to stay compliant with relevant laws.
We may update this privacy notice from time to time. The updated version will be indicated by an updated “Last updated” date and will be effective as soon as it is accessible. If we make material changes, we will notify you either by prominently posting a notice of such changes or by sending you a notification directly. We encourage you to review this privacy notice regularly.
13. HOW CAN YOU CONTACT US ABOUT THIS NOTICE?
If you have questions or comments about this notice, you may email us at support@cuesoft.org, or write to us at:
[LEGAL ENTITY NAME] [POSTAL ADDRESS]
14. HOW CAN YOU REVIEW, UPDATE, OR DELETE THE DATA WE COLLECT FROM YOU?
You can review, update, and delete your account and all of your location records from within the app, and deletion takes effect immediately. Based on the applicable laws of your country, you may also have the right to request access to the personal information we collect from you, change that information, or delete it by contacting us at support@cuesoft.org.