PRIVACY POLICY

This is the privacy policy (“Privacy Policy”) that governs how we, Alerteenz Ltd.  (“Caring”
“CaringApp”, “The caring app”, “we”, & “our” or “us”), use Personal Information (defined below) that we
collect, receive and store about individuals in connection with the use of CaringApp application and
any other service that we operate (“application”, “application”, “service”). This Privacy Policy
supplements the Terms of Use of Caring (the "Terms"), available
onhttps://www.thecaring.app/terms-of-use
 
We do not ourselves host the application. All hosting is done by third party service providers that we
engage. This means that data you provide us or that we collect from you (including any Personal
Information, as defined below), as further described in this Privacy Policy, is hosted with such third
party service providers on servers that they own or control. Regardless of where such third party
service providers are located (and some are located in the United States or in the EU), their servers
may be located anywhere in the world (including the United States and EU). Your data may even be
replicated across multiple servers located in multiple countries. By using and accessing the
Application you are consenting to your data being transferred to various third party service providers
around the world (including the United States and EU). We try to process the information under
arrangements aimed at providing an adequate level of data protection, which includes EU decisions
recognizing the adequacy of those countries and model contract clauses. However, in certain cases
the laws in some of these countries may nevertheless provide a lesser degree of data protection
than the laws of your own country. You agree to the transfer of your information to such other
countries for the purpose of processing as described in this Policy, including through cloud services.
 
 
1. Introduction. We have implemented this Privacy Policy because your privacy, and the privacy of
other users, is important to us. This Privacy Policy explains our online information practices and the
choices you can make about the way your Personal Information is collected and used in connection
with the application. “Personal Information” means any information that may be used, either alone or
in combination with other information, to personally identify an individual, including, but not limited to,
a first and last name, a mobile number, an email address, location data, a home or other physical address, or other contact information.
 
2. Consent and Modification. You are not legally obligated to provide us Personal Information, and
you hereby confirm that providing us Personal Information is at your own free will. By using the
Application, you consent to the terms of this Privacy Policy and to our collection, processing and
sharing of Personal Information for the purposes set forth herein. If you do not agree to this Privacy
Policy, please do not access or otherwise use the Application. We reserve the right, at our
discretion, to change this Privacy Policy at any time. Such change will be effective ten (10) days
following posting of the revised Privacy Policy on the Application, and your continued use of the
Application thereafter means that you accept those changes.
 
3. What Personal Information We Collect and How We Collect It. We do not currently require you to
provide Personal Information in order to have access to general information available on the
Application. But, we do receive and/or collect Personal Information from you in the following ways:
 
3.1 Account. In order to use certain services that we offer via the Application, you may be required to
create an account (“Account”), by one of the following methods (for types of Accounts in the
application please see the Terms):
 
(a) You may create an account by completing a form on the Application.  If you create an Account
you will be required to provide us with certain information, such as your name, email address, as
well as a password that you will use for your Account.

 
(b) You may also choose to create an Account by logging in with your Facebook account which you
may do by clicking on a Facebook ‘connect’ or ‘sign-in’ button that we may display on the Application
(“Facebook Account”). Doing so will enable you to link your Caring Account and your Facebook
Account. If you choose this option, then you will be required to approve the connection as well as the
types of information (which may include Personal Information) that we may obtain from Facebook,
including your name, Facebook identification (ID) number, your profile picture, your gender, age
range, locale and time zone, and e-mail address. You may disable or withdraw certain Permissions
in the settings section of your Facebook Account (on Facebook), but doing so may cause certain
features of the Application to become unavailable to you. In addition to the use of data described
here, we may also use such data as described in Sections 4 (The Way We Use Personal
Information) and 5 (Use of Anonymous Information) below. YOU ACKNOWLEDGE AND AGREE
THAT WE MAY KEEP DATA WE OBTAIN FROM FACEBOOK AS DESCRIBED ABOVE EVEN
AFTER WE CEASE USING THE FACEBOOK PLATFORM OR OFFER FACEBOOK
FUNCTIONALITY SUCH AS FACEBOOK CONNECT OR LOGIN ON THE APPLICATION. 
 
Regardless of whether you create an Account through a form on the Application or by using your
Facebook Account, you may also choose to provide additional Personal Information as part of the
Account registration process and in connection with your ongoing use of your Account. We may
send you a text message to your mobile phone or an e-mail to the e-mail address you submit to
confirm your registration. If you choose not to create an Account, you may not be able to access or
use certain features of the Application.
 
(c) You may also choose to create an Account by logging in with your Google account which you
may do by clicking on a Google or ‘sign-in’ button that we may display on the Application (“Google
Account”). Doing so will enable you to link your Caring Account and your Google Account. If you
choose this option, then you will be required to approve the connection as well as the types of
information (which may include Personal Information) that we may obtain from Google, including but
not limited to your name, your profile picture, your gender, age range, locale and time zone, and e-
mail address. You may disable or withdraw certain Permissions in the settings section of your
Google Account (on Google), but doing so may cause certain features of the Application to become
unavailable to you. In addition to the use of data described here, we may also use such data as
described in Sections ‎4 (The Way We Use Personal Information) and 5 (Use of Anonymous
Information) below. YOU ACKNOWLEDGE AND AGREE THAT WE MAY KEEP DATA WE OBTAIN
FROM GOOGLE AS DESCRIBED ABOVE EVEN AFTER WE CEASE USING THE GOOGLE
PLATFORM OR OFFER GOOLGE FUNCTIONALITY SUCH AS GOOGLE CONNECT OR LOGIN
ON THE APPLICATION.
 
Regardless of whether you create an Account through a form on the Application or by using your
Google Account, you may also choose to provide additional Personal Information as part of the
Account registration process and in connection with your ongoing use of your Account. We may
send you a text message to your mobile phone or an e-mail to the e-mail address you submit to
confirm your registration. If you choose not to create an Account, you may not be able to access or
use certain features of the Application.
 
3.2 Add elder device. In order to add a monitored elder device, you may be required to provide
certain information, such as the name of the elder, birthdate, gender, phone number and e-mail
address. You may also provide additional information such as a profile picture for the elder.
 
3.3 ‘Contact Us’ Information. If you send us a “Contact Us” request, whether by submitting an online
form that we make available or by sending an email to an email address that we display, you may be
required to provide us with certain information such as your name and email address.
 

3.4 Invite Friends Service. The Application may enable you to invite your friends to use our
Application by sending them an invitation email or message through a third-party service such as
Facebook or Twitter. If you send an invitation to a friend, we may obtain your e-mail address or the
username and ID for your third-party service account.
 
3.5 Cookies and Other Tracking Technologies. Our Application may utilize “cookies”, anonymous
identifiers and other tracking technologies in order to for us to provide our Application and present
you with information that is customized for you. A “cookie” is a small text file that may be used, for
example, to collect information about activity on the Application. Certain cookies and other
technologies may serve to recall Personal Information, such as an IP address, previously indicated
by a user. Most browsers allow you to control cookies, including whether or not to accept them and
how to remove them. You may set most browsers to notify you if you receive a cookie, or you may
choose to block cookies with your browser.
 
3.6 Analytics Tools.  We may use tools to collect and analyse information about use of the
Application (“Analytics Tools”), such as “Google Analytics” or “Mixpanel.” Analytics Tools collect
information such as how often users visit this application, what pages they visit when they do so, and
what other applications they used prior to coming to this Application. We use the information we get
from these Analytics Tools to maintain and improve the Application and our products and services.
We do not combine the information collected through the use of Google Analytics with personally
identifiable information. Google’s ability to use and share information collected by Google Analytics
about your visits to this Application is restricted by the Google Analytics Terms of Service, available
athttp://www.google.com/analytics/terms/us.html, and the Google Privacy Policy, available
at http://www.google.com/policies/privacy/. You may learn more about how Google collects and
processes data specifically in connection with Google Analytics
athttp://www.google.com/policies/privacy/partners/. You may prevent your data from being used by
Google Analytics by downloading and installing the Google Analytics Opt-out Browser Add-on,
available at https://tools.google.com/dlpage/gaoptout/. Mixpanel’s use of information collected
through Mixpanel is set forth in the “Privacy Policy” section of its Terms of Use available
athttps://mixpanel.com/terms/. You may opt-out of Mixpanel’s automatic retention of data
at https://mixpanel.com/optout/.
 
4. The Way We Use Personal Information (as defined in clause 1). If you submit or we collect Personal Information through the Application, then we may use such Personal Information in the following ways, via any applicable communication channel, including e-mail, SMS, etc.:

 

4.1 We will use your location data to enable your caregiver and/or emergency contacts to locate you in case of an emergency whether the app is in use or not.

 

4.2 We will use your Personal Information to provide and improve our Application, to send you
marketing/advertisement communications that we believe may be of interest to you, to contact you in
connection with the Application and certain programs or offerings that you may have registered for,
and to identify and authenticate your access to the parts of the Application that you are authorized to
access.

 
4.3 We may use your designated email address to: (i) send you updates or news regarding the
Application and our products; and/or (ii) respond to a “Contact Us” or administrative request (for
example, to change your password).
 
4.4 If you choose to send your friend an invitation email or message, we will use the contact
information that you provide, or make available, to automatically send your friend a message by the
method you have chosen with the invitation or the shared content (as applicable). Your name and
email address may be included in the message.
 
4.5 We may transfer your Personal Information to our local or foreign subsidiaries or affiliated
companies for the purpose of storing or processing such information on our behalf. Such information

may be transferred to other countries. We require that these parties agree to process such
information in compliance with our Privacy Policy.
 
4.6 We may share your Personal Information with our third party service providers and partners, but
only to assist us with our business operations and to provide our Application to you and other users.
Such information may be transferred to other countries. We use commercially reasonable efforts to
only engage or interact with third party service providers and partners that post a privacy policy
governing their processing of Personal Information.
 
4.7 We may disclose your Personal Information or any information you submitted via the Application
if we have a good faith belief that disclosure of such information is helpful or reasonably necessary
to: (i) comply with any applicable law, regulation, legal process or governmental request; (ii) enforce
our Terms, including investigations of potential violations thereof; (iii) detect, prevent, or otherwise
address fraud or security issues; or (iv) protect against harm to the rights, property or safety of the
Caring app, our users, yourself or the public.
 
4.8 We will collect user's device installed application usage data, and use it to analyze user's social
activity. Collected data will not be shared with any other parties

 
5. Use of Anonymous Information. We may use Anonymous or de-identified  Information (as defined
below) or disclose it to third party service providers in order to improve our Application and enhance
your experience with the Application. We may also disclose Anonymous Information (with or without
compensation) to third parties, including advertisers and partners. “Anonymous Information” means
information which does not enable identification of an individual user, such as user-level information
about the use of our Application. You acknowledge and agree that even if you request that we delete
personal information obtained from Facebook in connection with your Facebook Account, we may
nevertheless retain Anonymous Information which was based on that information and use such
information as described in this Section ‎5.
 
 
6. legal basis for processing your data
We are the data controller with respect to the personal data collected and processed within the
scope of the service provided via the application. Only we collect and maintain personal information
through the application. In this capacity, we process your personal data pursuant to the following:
1. Your informed consent to this Policy. Note that you may withdraw your consent at any time, without
affecting the lawfulness of data processing we carried out based on your consent before such
withdrawal.
2. As necessary for the performance of the Terms which are a contract that you and the Company
have entered for the provision of the Service.
 
 
7. Accessing, Updating or Deleting your Personal Information and Obtaining a Copy of it
If the law grants you such rights, you may ask to review the personal information about you and your
elder parent that is stored in our systems. You may also ask for our confirmation as to whether or not
we process personal information concerning you or your elder parent.
You may request that we delete the information we have about you or your elder parent. If you do
so, we will also terminate the provision of the service to you.
Subject to the limitations in law, you may request that we update or correct inaccurate or outdated
personal information.
Subject to law, you may also be entitled to obtain from us the personal data that you directly
provided to us (excluding data we obtained from other sources) in a structured, commonly used and
machine-readable format, in order to transmit such data to third party.

If you wish to exercise any of these rights, contact us at: privacy@thecaring.app When handling
these requests, we may ask for additional information to confirm your identity and your request.
 
8. Opting Out. You may choose not to receive future promotional, advertising, or other Application-
related emails from us by selecting an unsubscribe link at the bottom of each email that we send.
Please note that even if you opt out of receiving the foregoing emails, we may still send you a
response to any “Contact Us” request as well as administrative emails (for example, in connection
with a password reset request) that are necessary to facilitate your use of the Application.
 
9. Choice. At all times, you may choose whether or not to provide or disclose Personal Information. If
you choose not to provide mandatory Personal Information, you may still visit parts of the
Application, but you may be unable to access certain options, programs, offers, and services that
involve our interaction with you.
 
10. Access/Accuracy. To the extent that you do provide us with Personal Information, we wish to
maintain accurate Personal Information. If you would like to delete or correct any of your other
Personal Information that we may be storing, you may use the tools that we may make available on
the Application or you may submit an access request by sending an email to privacy@thecaring.app.
Your email should include adequate details of your request.
 
11. Security. The security of Personal Information is important to us. We follow generally accepted
industry standards, including the use of appropriate administrative, physical and technical
safeguards, to protect the Personal Information submitted to us. However, no method of
transmission over the Internet, or method of electronic storage, is 100% secure. Therefore, while we
strive to use reasonable acceptable means to protect your Personal Information, we cannot
guarantee its absolute security or confidentiality. If you have any questions about security on the
Service, you can contact us at contact@thecaring.app.
 
12.  Data retention
We retain the personal data we collect for as long as needed in order to provide the Service to you.
We then either delete from our systems or anonymize it, so long as we are not otherwise legally
required to retain the data or require it in order to establish, exercise or defend against legal claims.
If you withdraw your consent to us processing you and your elderly parents' information, we will
erase the information from our systems so long as we are not otherwise required to retain the data
or need it in order to establish, exercise or defend against legal claims.
 
 
13. Merger, Sale or Bankruptcy. In the event that we are acquired by or merged with a third party
entity, or in the event of bankruptcy or a comparable event, we reserve the right to transfer or assign
Personal Information in connection with the foregoing events.
 
12. California Privacy Rights. California Civil Code Section 1798.83 permits our customers who are
California residents to request certain information regarding our disclosure of Personal Information to
third parties for their direct marketing purposes. To make such a request, please send an email
to privacy@thecaring.app. Please note that we are only required to respond to one request per
customer each year.
 
13. Our California Do Not Track Notice. We do not track consumers over time and across third party
web applications and therefore do not respond to Do Not Track signals. We do not allow third parties
to collect personally identifiable information about an individual consumer’s online activities over time
and across different web applications when a consumer uses the Application.
 

14. Deletion of Content from California Residents.  If you are a California resident under the age of
18 and a registered user, California Business and Professions Code Section 22581 permits you to
remove content or Personal Information you have publicly posted.  If you wish to remove such
content or Personal Information and you specify which content or Personal Information you wish to
be removed, we will do so in accordance with applicable law.  Please be aware that after removal
you will not be able to restore removed content. In addition, such removal does not ensure complete
or comprehensive removal of the content or Personal Information you have posted and that there
may be circumstances in which the law does not require us to enable removal of content.
 
15. Commitment. We are committed to protecting your privacy. Protecting your privacy online is an
evolving area, and we are constantly evolving our Service to meet these demands. If you have any
comments or questions regarding our Privacy Policy, or your Personal Information that we may be
storing and using, , including any concern you may have regarding the violation of your privacy
please contact us at privacy@thecaring.app.
 
Last updated: June 21, 2020

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