The Website located at www.mobilehelp.com is operated by MobileHelp, LLC, and (“We/Our/Us”). “You/Your” means one who uses Our Website, mobile site(s) and/or Apps (individually or collectively, “Website” or “Online Platform(s)”), and “User(s)” means any and all users of Our products, Apps or services (collectively, “Products”) and the Online Platforms. This Privacy Policy covers Your use of Our Website and Users' use of the Online Platforms and Our Products. We offer the Website, including all information, tools and Products available from the Website, to You conditioned upon Your acceptance of all the terms, conditions, policies and notices stated here.

WE TAKE PRECAUTIONS WITH YOUR INFORMATION AND PERSONAL DATA. We value Our Users and respect Your privacy. We collect information about You in an effort to process and fulfill orders for Products, process order payment(s), provide information to emergency operations, improve Your experience on the Online Platform(s) and to communicate with You about Our Products and promotions as well as those of trusted third parties. As described in greater detail below, We may share Your information under certain circumstances with businesses with whom We work. This Privacy Policy describes the personal information We collect about You, why We collect it, how We use it, and when We share it with third parties. This Privacy Policy also describes the choices You can make about how We collect and use certain of that information.

By accessing the Website or use of Our Products, You acknowledge this Privacy Policy and agree to be bound by the terms hereof and the Terms of Use set forth on the Website. If there is anything You do not understand, please email any inquiry to privacy@mobilehelp.com . If at any time You do not agree to this Privacy Policy, please do not use the Website or Opt-Out as per section 7.0.

We reserve the right to change or update this Privacy Policy by posting such changes or updates to the Website. Amendments to this Privacy Policy will be posted at this URL and will be effective when posted. It is Your responsibility to review any such changes or updates and check the Website from time to time to be sure You understand all terms and conditions, agreements, and policies of the Website and are in compliance with them. You can tell if the policy has changed by checking the last modified date that appears at the end of this Privacy Policy. Your continued use of the Website or Products following the posting of any amendment, modification or change shall constitute Your acceptance thereof.

We will ask You for certain kinds of personal information, such as Your name, email address, street address, telephone number, and other information that identifies You as an individual (“Personal Information”) to provide the Products You request. All payment information we collect, credit card, debit card, or bank information for ongoing billing of the service, is encrypted.

Your Account Users have the opportunity to create a personal monitoring account at MOBILEHELP CONNECT® with Us. This account allows Users who purchase Our Products and their loved ones who use and access the Online Platform(s) to stay connected with real-time location data via Google maps and other functions including optional email and/or notifications. Using Your User ID / email and password of Your choice, You may access Your account online at any time to add, delete, or change information. In creating and/or accessing this account, You authorize Us to store Your name, address, email address, telephone number and other Personal Information that You may provide. The Personal Information provided by You is not used for any purpose other than as outlined in this Privacy Policy. If You ever use a public computer to access Your Website account, We strongly encourage You to log out at the conclusion of Your session. By doing so, although Your information may still be stored with Us, it will not be accessible to anyone else from that computer.

We currently use Authorize.net for payment processing. Please review the terms of use http://www.authorize.net/company/terms/ and privacy policies http://www.authorize.net/company/privacy/ of this third-party payment processor, as We have no control over these third-parties.

We collect and process your Personal Information for the purposes and on the legal bases identified in the following:

• Providing Our website, equipment, and services: We process Your Personal Information to perform Our contract with You for the use of Our website, equipment, and services and to fulfill Our obligations under applicable terms of use/service; where We have not entered into a contract with You, We base the processing of Your Personal Information on Our legitimate interest to operate and administer Our website and services;
• Promoting the security of our website and services: We process Your Personal Information by tracking use of Our website and services, creating aggregated, non-personal information, verifying accounts and activity, investigating suspicious activity and enforcing Our terms and policies, to the extent this is necessary for Our legitimate interest in promoting the safety and security of the services, systems and applications and in protecting Our rights and the rights of others;
• Providing necessary functionality: We process your Personal Information to perform Our contract with You for the use of Our website and services; where We have not entered into a contract with You, We base the processing of your Personal Information on Our legitimate interest to provide You with the necessary functionality required during Your use of Our website and services;
• In the event of a recall: We process Your Personal Information to advise You whether a recall affects any of the equipment or products We have provided to You as part of our contract with You;
• Managing user interface: If You have subscribed to Our services, We process your Personal Information by managing Your user account for the purpose of performing Our contract with You according to applicable terms of service, including the provision of Your Personal Information to Emergency Services and Operations;
• Handling contact and user support requests: If You send Us a request for support or service, or if You contact Us by other means including via a phone call, We process your Personal information to perform Our contract with You and to the extent it is necessary for Our legitimate interest in fulfilling Your requests and communicating with You;
• Managing promotions: If You register for a promotion, We process your Personal Information to perform Our contract with You. Some promotions have additional information about how We will process your Personal Information;
• Managing payments: If You have provided financial information to Us, We process your Personal Information to verify that information and to collect payments to the extent that doing so is necessary to complete a transaction and perform Our contract with You;
• Developing and improving Our website and services: We process Your Personal Information to analyze trends and to track Your usage of and interactions with Our website and services to the extent it is necessary for Our legitimate interest in developing and improving Our website and services and providing Our users with more relevant service offerings, or where We seek Your valid consent;
• Assessing and improving user experience:We process device and usage data, which in some cases may be associated with Your Personal Information, in order to analyze trends and to assess and improve the overall user experience to the extent it is necessary for Our legitimate interest in developing and improving the service offering, or where We seek Your valid consent;
• Reviewing compliance with applicable usage terms: We process Your Personal Information to review compliance with the applicable usage terms in Our customer’s contract to the extent that it is in Our legitimate interest to ensure adherence to the relevant terms;
• Assessing capacity requirements: We process Your Personal Information to assess the capacity requirements of Our services the extent that it is in Our legitimate interest to ensure that We are meeting the necessary capacity requirements of Our service offering;
• Identifying customer opportunities: We process Your Personal Information to assess new potential customer opportunities to the extent that it is in Our legitimate interest to ensure that We are meeting the demands of Our customers and their user experiences;
• Registering office visitors: We process Your Personal Information for security reasons, to register visitors to Our offices and to manage non-disclosure agreements that visitors may be required to sign, to the extent such processing is necessary for Our legitimate interest in protecting Our offices and Our confidential information against unauthorized access;
• Displaying personalized advertisements and content: We process Your Personal Information to conduct marketing research, advertise to You, provide personalized information about Us on and off Our website and to provide other personalized content based upon Your activities and interests to the extent it is necessary for Our legitimate interest in advertising Our websites or, where necessary, to the extent You have provided Your prior consent;
• Sending marketing communications: We will process Your Personal Information and/or device and usage data, which in some cases may be associated with Your Personal Information, in order to send you marketing information, product recommendations and other non-transactional communications (e.g., marketing newsletters, telemarketing calls, SMS, or push notifications) about Us and Our affiliates and partners, including information about Our products, promotions or services as necessary for our legitimate interest in conducting direct marketing or to the extent You have provided Your prior consent; and
• Complying with legal obligations: We process your Personal Information when cooperating with public and government authorities, courts or regulators in accordance with our legal obligations under applicable laws to the extent this requires the processing or disclosure of Personal Information to protect Our rights or is necessary for Our legitimate interest in protecting against misuse or abuse of Our website, protecting personal property or safety, pursuing remedies available to Us and limiting Our damages, complying with judicial proceedings, court orders or legal processes or to respond to lawful requests.

Where We need to collect and process Personal Information by law, or under a contract We have entered into with You, and You fail to provide the required Personal Information when requested, We may not be able to perform Our contract with You.

3.1 We do not share, sell, or trade Your Personal Information with any third-parties, except with Your consent or as described herein.

3.2 We may disclose Your Personal Information when legally required to do so, to cooperate with law enforcement investigations or other legal proceedings, to protect against misuse or unauthorized use of the Website, to limit Our legal liability and protect Our rights or to protect the rights, property or safety of Users of the Website or the public.

3.3 We may also disclose Your Personal Information to outside individuals and/or companies that help Us bring You the Products We offer and to create, operate, and maintain Our Website. For example, We may work with third parties to: (a) manage a database of customer information; (b) assist Us in distributing emails; (c) assist Us with direct marketing and data collection; (d) provide data storage and analysis; (e) provide fraud prevention; (f) provide customer service; (g) provide product fulfillment and shipping services; and (h) provide other services designed to assist Us in developing and running Our Website and maximizing Our business potential. We require that these outside companies agree to keep all information shared with them confidential and to use the information only to perform their obligations to Us. We authorize certain service providers to utilize for their business purposes and, in accordance with their privacy policies certain aggregated, information derived from data collected when You use the products and services they support on Our behalf to customize their customer base. This aggregated products information does not identify You personally.

3.4 We may participate in third-party cooperative databases. Database participants provide customer names and mailing addresses and information about their customers' purchasing history to the database, which allows the database participants to segment and/or obtain access to potentially interested parties to whom or which they may target their promotions.

3.5 In addition, if We go through a business transition, such as a merger, acquisition by another company, or sale of all or a portion of Our assets, Your Personal Information will likely be among the assets transferred.

3.6 Our Website may allow Users to post testimonials and other content to Our Website. Any Personal Information that You post to Our Website will become public information and will be accessible by other users of the Website. In addition, Your user name will be viewable by other users, and We therefore encourage You to use a user name that is not Your actual name. We have no responsibility to maintain the privacy or security of any such Personal Information that You may choose to post to Our Website.

3.7 MobileHelp, LLC may also collect your email address via cookies and pixels on the Website through the use of trusted third party partners. These partners may also combine your email information with other information they have access to such as mailing address so that we may serve relevant marketing offers to you via email and direct mail. If you do not want us to collect information about you, please send an email to privacy@mobilehelp.com to opt out.

4.1 Through Your use of the Website, We may also collect certain non-personally identifiable information from You (“NPII”). NPII is not associated with You as an individual. It is measured anonymously and only in the aggregate.

4.2 The Website may use cookies. A cookie is a small piece of information sent by a Website that is saved on Your hard drive by Your computer's browser. Cookies help Us remember You when You return to the Website. Cookies also hold information to personalize and enhance Your experience and to gather Website statistical data, such as which pages are visited, the Internet provider's domain name and the addresses of the sites You visited immediately before coming to and immediately after leaving the Website. The information in the cookies lets Us trace Your “clickstream” activity (i.e., the paths taken by Users of the Website as they move from page to page) to enable Us to better serve Our Users by revealing which portions of the Website are the most popular. Cookies contain absolutely no Personal Information. You may disable cookies on Your browser. Please review Your browser's instructions for doing so. Additionally, information about opting out of cookie-based Internet advertising can be found via the following links http://optout.networkadvertising.org/ and/or https://www.neustar.biz/privacy/opt-out . However, please keep in mind that these technologies are an important part of how the website works; removing, rejecting or limiting the use of cookies or other similar technologies might affect the availability and functionality of the website.

4.2 We may also use “pixel tags” (sometimes called “Web beacons” or “clear gifs”), which are tiny graphic images, on the Website. Pixel tags help Us analyze Users’ online behavior and measure the effectiveness of the Website and Our advertising and marketing. We may also use other analytical tools to evaluate site performance through the use of aggregated data, which contain no Personal Information. We work with service providers that help Us track, collect, and analyze this information.

4.3 Cookies, pixel tags, and/or other analytical tools that We may use on the Website may collect information about Your visit, including the pages You view, the features You use, the links You click, and other actions You take in connection with the Website. This information may include Your computer's Internet protocol (IP) address, Your browser type, Your operating system, date and time information, and other technical information about Your computer. We may also track certain information about the identity of the Website You visited immediately before coming to the Website. We do not otherwise track any information about Your use of other Websites.

4.4 Cookies, pixel tags, and/or other analytical tools in Our emails may be used to track Your interactions with those messages, such as when You receive, open, or click a link in an email message from Us.

4.5 We may also work with businesses that use tracking technologies to deliver advertisements on Our behalf across the Internet. These companies may collect information about Your visits to the Website and Your interaction with Our advertising and other communications, but no Personal Information is shared with them.

4.6 We may contract with third-party vendors to provide ads to our customers on our behalf via the Internet or to send direct mail to customers whom we think may be interested in our products or services. In order to do so, such vendor may collect anonymous information about your visits to our website using Cookies. Third-party vendors may then pool the anonymous information that they collect from our website with other sources of data, which may include your name and mailing address, for purposes of determining whether you might be interested in receiving direct mail. To opt-out of receiving direct mail, you may send us an email at privacy@mobilehelp.com or call us at (800) 761-6359.

5.1 We strive to keep Your Personal Information private and safe. We take commercially reasonable physical, electronic, and administrative steps to maintain the security of Personal Information collected, including limiting the number of people who have physical access to database servers, as well as employing electronic security systems and password protections that guard against unauthorized access. In addition, it is Our policy never to send Your credit card number via email. Please note that email is not encrypted and is not considered to be a secure means of transmitting credit card information, so please do not send Us Your credit card number by email.

5.2 Unfortunately, despite Our best efforts, the transmission of data over the Internet cannot be guaranteed to be 100% secure. While We will use every reasonable means to ensure the security of information You transmit through the Website, We cannot guarantee that such information will not be intercepted by third-parties. We will, however, prosecute any unauthorized or fraudulent transactions to the fullest extent permitted by law.

6.1 While visiting the Website, You may link to Websites operated by third-parties, or You may have come to the Website using a link found in another Website. Such other Websites are independent from Us, and We have no control over, or responsibility for, their information, products or activities.

6.2 In addition, We currently use third-parties for payment processing of Your order(s). Such payment processors are independent from us, and We have no control over or responsibility for their information, products, or activities.

You may opt-out from Us by clicking on DSAR Form and completing the form as instructed. Please allow Us (10) business days from when the request was received to complete the removal, as some of Our promotions may already have been in process before You submitted Your request.

A common Internet scam is known as “spoofing” or “phishing.” This occurs when You receive an email from what appears to be a legitimate source requesting Personal Information from You. Please be aware that We will not send You any emails requesting You to verify credit card, bank information, or any other Personal Information. If You ever receive an email that appears to be from Us requesting such information from You, DO NOT respond to it, and DO NOT click on any links appearing in the email. Instead, please forward the email to Us at privacy@mobilehelp.com , as We will investigate instances of possible Internet fraud.

The Website is not meant for children, and We will not knowingly collect any Personal Information from children under the age of 13 without verified parental consent. If You believe we have collected any Personal Information from a minor child, and You are the parent or guardian of that minor child, please contact US as shown in Section 7.0 and provide the information to US that will allow us to investigate. We will remove from Our files any Personal Information of anyone We discover to be under thirteen (13) years old.

10.1 Under California Civil Code sections 1798.83-1798.84, California residents are entitled to ask Us for a notice describing what categories of Personal Information We share with third parties or corporate affiliates for those third parties or corporate affiliates' direct marketing purposes. That notice will identify the categories of information shared and will include a list of the third parties and affiliates with which it was shared, along with their names and addresses. If You are a California resident and would like a copy of this notice, please submit a written request to the following address: privacy@mobilehelp.com. Please allow thirty (30) calendar days for a response.

10.2 California Privacy Rights. We collect various types of Personal Information about You as described in this Policy. Under California law, including the California Consumer Privacy Act (“CCPA”), Our 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 contact Us as shown in Section 7.0.

10.2.1 You have specific rights under the CCPA, including:

• The Right to Opt Out of a sale of Personal Information to third-parties. As stated in Section 3.1, We do not sell Your Personal Information. If this Policy ever changes, we will amend this Privacy Policy to include instructions and a link to the “Do Not Sell My Personal Information” section in Our Privacy Policy; and

• The Right To Be Forgotten. For information on how we will delete your information, please request to be “Forgotten” using the links in Section 7.0.

• The Right to Know. We disclose to You, at or before the point of collection, in this Privacy Policy, the following: The categories of personal information to be collected about You and the purposes for which the information will be used; and, the categories of Your Personal Information that were actually collected in the preceding twelve (12) months and sold or disclosed for business purposes in the preceding twelve (12) months.

Specifically, We collect the following types of Personal Information:

1. 1. Name, address, personal identifier, IP address, email address, account name.
2. 2. Personal Information under California’s records destruction law (Cal. Civ. Code § 1798.80(e)), which additionally includes signature, physical characteristics or description, telephone number, insurance policy number, education, employment, employment history, or financial account information.
3. 3. Characteristics of protected classifications under California or federal law.
4. 4. Biometric information.
5. 5. Internet or other electronic network activity, such as browsing history, search history, and information regarding a consumer’s interaction with a website, application, or advertisement.
6. 6. Geolocation data.
7. 7. Audio, electronic, visual, thermal, olfactory, or similar information.
8. 8. Education information that is not publicly available personally identifiable information, as defined in the Family Educational Rights and Privacy Act (20 USC § 1232(g), 34 CFR Part 99).
9. 9. Inferences drawn from any of the information listed above to create a profile about a consumer reflecting the consumer’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.

10.2.2 If you choose to exercise your rights under the CCPA, We will not discriminate against You in any way. We will not:

• Deny goods or services to You;
• Charge You a different price for Our goods and services including through the use of discounts or other benefits;
• Impose penalties on You, including providing You with a different level of quality or service; and,
• Suggest to You that You will receive a different price or rate or different level of quality of goods or services.

10.3 In addition, please note the following:

(a) Users can visit Our Website anonymously;

(b) We have provided a link to this Privacy Policy on Our home page, or at a minimum, on the first significant page after entering Our Website;

(c) Our Privacy Policy link includes the word “Privacy” and can be easily found on the page specified above;

(d) Users will be notified of any privacy policy changes on Our Privacy Policy page;

(e) Users are able to change their Personal Information by emailing Us or by calling Us;

(f) We take reasonable steps to honor “do-not-track” signals and do-not-track, plant cookies, or use advertising when a Do Not Track browser mechanism is in place, but some features of our website may not function correctly if you have elected to use your “do-not-track” mechanism; and

(g) We allow the collection of Users' behavioral tracking (but not Personal Information) by third parties. We do not authorize the collection of Personal Information on the Website by third parties.

10.3 The Website uses the Google AdWords remarketing service to advertise on third party websites (including Google) to previous visitors to Our Website. It could mean that We advertise to past visitors who haven't completed a task on Our site, for example, using the contact form to make an inquiry. This could be in the form of an advertisement on the Google search results page or a site in the Google Display Network. Third-party vendors, including Google, use cookies to serve ads based on someone's past visits to the MobileHelp Website. Of course, any data collected will be used in accordance with Our own Privacy Policy and Google's privacy policy. You can set preferences for how Google advertises to You using the Google Ad Preferences page, and if You want to You can opt-out of interest-based advertising entirely by cookie settings or permanently using a browser plugin.

You hereby authorize Us to disclose any of Your Personal Information pursuant to judicial and administrative proceedings and to law enforcement or government agencies if We believe the disclosure is necessary or appropriate. You also authorize Us to disclose Personal Information if We believe the disclosure is necessary or appropriate in the event of an investigation of improper or illegal conduct in connection with the Website, such as fraud, misrepresentation, intellectual property infringement, or other activity that may put Us at risk for liability.

We do not want You to send Us any confidential or proprietary information through email or otherwise. Any information, materials, suggestions, ideas or comments sent to Us will be considered non-confidential, and by submitting the same to Us, You are giving Us the absolute right to use, modify, reproduce, transmit, display and distribute the information for any purpose whatsoever, with no payment or other compensation to You. However, We will not use Your name unless We are required by law to identify the source of the materials, information, suggestions, ideas, or comments, or unless We first obtain Your permission.

We may freely assign this Privacy Policy or any of Our rights and/or obligations hereunder.

The Health Insurance Portability and Accountability Act (“HIPAA”) sets forth privacy and security standards for any entity that uses or discloses protected health information. For information on HIPAA, visit the U.S. Department of Health and Human Services Website at www.hhs.gov.

HIPAA compliance is an organization-wide obligation requiring procedural standards and business practices that protect the privacy and security of patient/client information. As part of these obligations, the business must ensure it only utilizes software that has adequate safeguards to protect patient/client information. Our system incorporates such technological and procedural safeguards, as detailed below.

We employ the following technological safeguards to facilitate compliance with HIPAA: patient/client information is transferred using 168-bit SSL encryption; accounts require secure login with minimum password length enforcement; the production environment is protected by stand-alone firewalls with access limited to authorized personnel via encrypted channels; and, offsite backups are made daily and stored in an encrypted state. Further, We require all personnel with access to patient/client information to be trained in the privacy requirements of HIPAA. We do not share, sell, disclose or provide patient/client information to third parties unless required by law.

We also provide numerous settings and features, including user-specific login, multiple user access levels, and the ability to easily add and remove users to facilitate procedural standards that enable Us to maintain overall HIPAA compliance.

If You have any questions about Your privacy or security at the Website, please send an email to privacy@mobilehelp.com and include Your first and last name, phone number, and email address in the message. If You do not receive a response from Us to any emails You send to Us within 7 business days, please send Us another email as Your original email may not have been received.

This Privacy Policy is effective as of the date appearing below; for any data collected prior to that date, Your information and personal data were subject to a different, then-effective privacy policy. If You would like to receive a copy of the privacy policy in effect prior to December 17, 2019, please email privacy@mobilehelp.com to request a copy and include Your contact information and We will respond as provided in this Contact section.

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