Last Updated: November 1, 2018
- The ATHENA device (the (“Product”) and any other wearable devices that connect to our Mobile Apps (defined below)(our “Devices”);
- The ROAR Personal Safety App and any other mobile applications we make available for download through the Sites (defined below), the Apple® App Store, other cell phone service provider locations or other locations we indicate or that may be accessed through computers or mobile devices (each a “Mobile App” and collectively the “Mobile Apps”); and
- the types of information we may collect or you may provide when you purchase, download, install, register with, access or use any ROAR for Good Products and Services;
- our practices for collecting, using and sharing your information; and
- the security approaches we use to protect your information.
Governing Privacy Law
The ROAR for Good Products and Services are only intended for use in the United States. We make no representations that the ROAR for Good Products and Services are appropriate or available for use outside the United States. Those who access or use the ROAR for Good Products and Services from other countries do so at their own volition and risk and are entirely responsible for compliance with all applicable laws and regulations, and agree to be bound by United States privacy laws, which may be less restrictive than the privacy laws of their home jurisdiction. By using any ROAR for Good Products and Services, you consent to the transfer of any of your information to the United States.
What Information Do We Collect?
We collect information from and about all visitors, users, and others who access the ROAR for Good Products and Services (“User(s)”):
- directly from you when you provide it to us;
- automatically when you use the ROAR for Good Products and Services. and
- from other Users.
We may collect real-time information about the location of your mobile device using its GPS and other technologies, which we will treat as personally identifiable information. If you activate the emergency feature of the ROAR for Good Products and Services, we will attempt to determine your location as precisely as possible. We may utilize this information in the event that you activate the emergency features to communicate your location to emergency responders and/or your preprogrammed emergency contacts. We may track your location and associate/store such location with any messages, data, or incidents you transmit through the ROAR for Good Products and Services.
Information You Provide to Us
When you download, register with or use the ROAR for Good Products and Services, we may ask you to provide the following types of information:
- If you are an Athena Device owner or are using the ROAR for Good Products and Services, we may collect your personally identifiable information, such as name, postal address, email address, user name, telephone numbers, photos, gender, and age/date of birth;
- If you are an Athena Device owner or are using the ROAR for Good Products and Services, we may collect information about your precise geographic location, information about emergencies and incidents, and contact details of your emergency contacts and Designated Recipients;
- If you are an Athena Device owner or are using the ROAR for Good Products and Services, the name and mobile phone number of your emergency contacts;
- If you purchase a ROAR for Good Product or Service from us, we may collect your credit card or other payment information for payments.
Before you provide information to us about third parties, including non-public emergency contacts and Designated Recipients, you should obtain their permission to reveal such information to us.
Information We Collect When You Use The ROAR for Good Products and Services
When you download, access and use the ROAR for Good Products and Services, such ROAR for Good Products and Services may use technology to automatically collect:
- Usage Details: When you access and use the ROAR for Good Products and Services, we may automatically collect certain details of your access to and use of the ROAR for Good Products and Services, including precise geolocation data, logs and other communication data and the resources that you access and use on or through the ROAR for Good Products and Services.
- Device Information: We may collect information about your mobile device and Internet connection, including the device’s unique device identifier, IP address, operating system, browser type, mobile network information and the device’s telephone number.
- Stored Information and Files: We also may access files and other information stored on your device. This may include, for example, photographs, audio and video clips, personal contacts and address book information if you activate the emergency features of the ROAR for Good Products and Services.
Information Collected From Other Users
How Do We Collect Information?
The technologies we use for automatic information collection may include:
- Web Beacons: Pages of the Mobile Apps and Sites and our e-mails may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags and single-pixel gifs) that permit Company, for example, to count Users who have visited those pages or opened an e-mail and for other related ROAR for Good Products and Services statistics (for example, recording the popularity of certain ROAR for Good Products and Services content and verifying system and server integrity).
How Do We Use Your Information?
We use information that we collect about you or that you provide to us, including any personal information, to:
- Provide you with the ROAR for Good Products and Services and their contents, and any other information, products or services that you request from us. The information collected by the ROAR for Good Products and Services is primarily designed to help you in the event of an emergency or incident including assisting others in assessing the event, responding, managing and coordinating responses, and reporting during and following emergencies and incidents. Information you provide to the ROAR for Good Products and Services will be used, made available to others, and otherwise handled for these purposes. Please note, however, that the ROAR for Good Products and Services are NOT a replacement for 911 or similar emergency response system. If you are in immediate danger, are suffering a medical emergency or are the victim of a crime, CALL 911 and/or the appropriate authorities and do not rely on the ROAR for Good Products and Services.
- Give you notices about your account, including expiration and renewal notices.
- Notify you of ROAR for Good Products and Services updates, and of changes to any products or services we offer or provide though the ROAR for Good Products and Services.
The usage information we collect helps us to improve the ROAR for Good Products and Services and to deliver a better and more personalized experience by enabling us to:
- estimate our audience size and usage patterns;
- store information about your preferences, allowing us to customize the ROAR for Good Products and Services according to your individual interests;
- speed up your searches;
- recognize you when you use the ROAR for Good Products and Services; and
- improve the ROAR for Good Products and Services.
We may create aggregated and anonymized data sets from the information we have about our Users (including information they provide and information collected through their use of the ROAR for Good Products and Services, including precise geolocation information) (collectively “Aggregated Data”). We may use the Aggregated Data without restriction. Without limiting the preceding, Aggregated Data may be provided to law enforcement officials, researchers, and universities for research or public safety purposes.
How Do We Disclose Your Information?
- To Emergency Personnel and Law Enforcement: We may disclose identifying and non-identifying information about our Users if you activate the emergency features of the ROAR for Good Products and Services. This information may be provided to emergency responders, police, and other public safety or law enforcement personnel.
- To Family Members and Friends: When you ask us to invite a friend or family member to join ROAR for Good, we may send such person invitation messages on your behalf using your name and contact details. We will also send your information to your designated emergency contacts if you activate the emergency features of the ROAR for Good Products and Services.
- To Third Party Service Providers: We may disclose your personal information to contractors, service providers and other third parties we use to support our business and who are bound by contractual obligations to keep personal information confidential and use it only for the purposes for which we disclose it to them, including web hosting, data services, analytics, and credit card processors or other payment providers. We do not use, or allow third party advertising networks to use, information about web browsing activity or location information collected through the ROAR for Good Products and Services for targeted or behavioral advertising. We support the development and implementation of a standard “Do Not Track” browser feature that provides customers with control over the collection and use of information about their web- browsing activities; however, ROAR for Good Products and Services do not currently respond to a DNT or similar signal. Once a standardized DNT feature is released, we intend to adhere to the browser settings accordingly.
- Promotional Offers: We may contact you with Service-related announcements from time to time. We may use your personal information to provide you with offers about new products or services that we or other businesses may offer. However, in connection with such offers, we will not give another business your name, address, email address, mobile phone number or location information.
- Non-Identifying Information: We may disclose information that does not identify an individual or device, including Aggregated Data, without restriction.
- Security: In the event we become aware that the security of the sites has been compromised or users’ personal information has been disclosed to unrelated third parties as a result of external activity, including, but not limited to, security attacks or fraud, we reserve the right to take reasonably appropriate measures, including, but not limited to, investigation and reporting, as well as notification to and cooperation with data protection and law enforcement authorities.
- Legal Disclosure: We may need to share your data when we believe it’s required by law or to help protect the rights and safety of you, us or others. It is possible that we will need to disclose information about you when required by law, subpoena, or other legal process or if we have a good faith belief that disclosure is reasonably necessary to (1) investigate, prevent, or take action regarding suspected or actual illegal activities or to assist government enforcement agencies; (2) enforce our agreements with you, (3) investigate and defend ourselves against any third-party claims or allegations; or (4) protect the security or integrity of our company. We attempt to notify customers about legal demands for their personal data when appropriate in our judgment, unless prohibited by law or court order, or when the request is an emergency. We may dispute such demands when we believe, in our discretion, that the requests are over-broad, vague or lack proper authority, but we do not promise to challenge every demand.
Your Choices About Our Collection, Use and Disclosure of Your Information
We strive to provide you with options regarding the personal information you provide to us. You may modify the personal information on your account at any time. However, such modifications or deletions will only affect reports after the date of such modifications; any data associated with prior usage of the ROAR for Good Products and Services will remain unmodified. This section describes mechanisms we provide for you to control certain uses and disclosures over your information.
- Location Information: You can choose whether or not to allow the ROAR for Good Products and Services to collect and use real-time information about your device’s location through the device’s privacy settings. However, if you block the use of location information, many parts of the ROAR for Good Products and Services may then be inaccessible or not function properly.
Accessing and Correcting Your Personal Information
You can review and change your personal information by logging into the Mobile App and visiting your account profile page. You may also send us an e-mail at email@example.com to request access to, correct or delete any personal information that you have provided to us. We reserve the right to decline requests that are excessive or would be disproportionately burdensome or expensive. We cannot delete your personal information except by also deleting your user account. We may not accommodate a request to change information if we believe the change would violate any law or legal requirement or cause the information to be incorrect.
Deactivating your ROAR for Good Account
You can deactivate your ROAR for Good account by contacting us at firstname.lastname@example.org. When you do, data that can identify you and that is associated with your account will be removed from the ROAR for Good Products and Services. Backup copies of this data will be removed from our server based upon an automated schedule, which means it may persist in our archive for a short period. ROAR for Good may continue to use your non-identifiable data and any Aggregated Data after you deactivate your account.
Any sensitive information, in our sole and reasonable discretion, will be encrypted in transit using SSL technology.
The safety and security of your information also depends on you. Where we have given you (or where you have chosen) a password for access to certain parts of the ROAR for Good Products and Services, you are responsible for keeping this password confidential. You may not share your password with anyone. Be careful about giving out information in public areas of the ROAR for Good Products and Services. The information you share in public areas may be viewed by any User of the ROAR for Good Products and Services.
Unfortunately, the transmission of information via the internet and mobile platforms is not completely secure. We cannot guarantee the security of your personal information transmitted through the ROAR for Good Products and Services. Any transmission of personal information is at your own risk. If you send an email directly to us from your own email account, the contents will not be encrypted. Do not send sensitive information (like a credit card number) to us via unencrypted email. We are not responsible for disclosure resulting from your privacy settings or from circumvention of any security measures we provide.
ROAR for Good Products and Services are not intended for use by anyone under the age of 13. If you are under 13, please do not attempt to create an account or send any information about yourself to us, including your name, address, telephone number or email address. No one under the age of 13 may provide any personal information to us. We do not knowingly collect personal information from children under 13. If we learn we have collected or received personal information from a child under 13 without verification of parental consent, we will delete that information from our applicable database. If you believe we have any information from or about a child under 13, or if you are aware of a user under the age of 13 using the ROAR for Good Products and Services directly, rather than through a parent or guardian, please contact us at please contact us at email@example.com.
Adults With Guardians, Conservators or Other Legal Supervision
No person who lacks the legal competence to enter into a contract may directly use the ROAR for Good Products and Services. A legal guardian, conservator or other person with the legal right to do so may subscribe to the ROAR for Good Products and Services to assist in the provision of care for such a person. Such legal guardian, conservator or other person with legal right shall be responsible for ensuring that the use of the ROAR for Good Products and Services is by such legal guardian, conservator or other person with legal right, and not by the person who lacks legal competence.
Your California Privacy Rights
Under California’s “Shine the Light” law, California residents who provide personal information in obtaining products or services for personal, family or household use are entitled to request and obtain from us once per calendar year information about the customer information we shared, if any, with other businesses for their own direct marketing uses. If applicable, this information would include the categories of customer information and the names and addresses of those businesses with which we shared customer information for the immediately prior calendar year (e.g. requests made in 2016 will receive information regarding 2015 sharing activities).
To obtain this information from the Company please send an email message to firstname.lastname@example.org with “Request for California Privacy Information” on the subject line and in the body of the message. We will provide the requested information to you at your e-mail address in response. Not all information sharing is covered by the “Shine the Light” requirements and only information on covered sharing will be included in our response.
Third Party Web Links
The ROAR for Good Products and Services or content contained therein may contain links to other websites, services or resources on the Internet. When you access third party websites, services or resources, you do so at your own risk. Such websites and services are not under our control, and you acknowledge that Company is not responsible or liable for the content, functions, accuracy, legality, appropriateness or any other aspect of such websites, services, or resources. The inclusion of any such link does not imply endorsement by Company or any association with its operators. You further acknowledge and agree that Company shall not be responsible or liable, directly or indirectly, for any damage or loss caused or alleged to be caused by or in connection with the use of or reliance on any content, goods or services available on or through any such third party website or resource. If you follow a link to any of these websites, services, or resources, please note that these websites, services, or resources may have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any personal data to these websites
We provide many choices about the collection, use and sharing of your data, from deleting or correcting data you include in your profile to advertising opt-outs and communication controls.
For personal information that we have about you, your principal rights under data protection law are:
(a) the right to access;
(b) the right to rectification;
(c) the right to erasure;
(d) the right to restrict processing;
(e) the right to object to processing;
(f) the right to data portability;
(g) the right to complain to a supervisory authority; and
(h) the right to withdraw consent.
You have the right to confirmation as to whether or not we process your personal data and, where we do, access to the personal data, together with certain additional information. That additional information includes details of the purposes of the processing, the categories of personal data concerned and the recipients of the personal data. Providing the rights and freedoms of others are not affected, we will supply to you a copy of your personal data. You have the right to have any inaccurate personal data about you rectified and, taking into account the purposes of the processing, to have any incomplete personal data about you completed.
In some circumstances you have the right to the erasure of your personal data without undue delay. Those circumstances include: the personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed; you withdraw consent to consent-based processing; you object to the processing under certain rules of applicable data protection law; the processing is for direct marketing purposes; and the personal data have been unlawfully processed.
In some circumstances you have the right to restrict the processing of your personal data. Those circumstances are: you contest the accuracy of the personal data; processing is unlawful but you oppose erasure; we no longer need the personal data for the purposes of our processing, but you require personal data for the establishment, exercise or defense of legal claims; and you have objected to processing, pending the verification of that objection. Where processing has been restricted on this basis, we may continue to store your personal data. However, we will only otherwise process it: with your consent; for the establishment, exercise or defence of legal claims; for the protection of the rights of another natural or legal person; or for reasons of important public interest.
You have the right to object to our processing of your personal data on grounds relating to your particular situation, but only to the extent that the legal basis for the processing is that the processing is necessary for: the performance of a task carried out in the public interest or in the exercise of any official authority vested in us; or the purposes of the legitimate interests pursued by us or by a third party. If you make such an objection, we will cease to process the personal information unless we can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms, or the processing is for the establishment, exercise or defense of legal claims.
You have the right to object to our processing of your personal data for direct marketing purposes (including profiling for direct marketing purposes). If you make such an objection, we will cease to process your personal data for this purpose.
You have the right to object to our processing of your personal data for scientific or historical research purposes or statistical purposes on grounds relating to your particular situation, unless the processing is necessary for the performance of a task carried out for reasons of public interest.
To the extent that the legal basis for our processing of your personal data is:
(a) consent; or
(b) that the processing is necessary for the performance of a contract to which you are party or in order to take steps at your request prior to entering into a contract,
and such processing is carried out by automated means, you have the right to receive your personal data from us in a structured, commonly used and machine-readable format. However, this right does not apply where it would adversely affect the rights and freedoms of others.
If you consider that our processing of your personal information infringes data protection laws, you have a legal right to lodge a complaint with a supervisory authority responsible for data protection. You may do so in the EU member state of your habitual residence, your place of work or the place of the alleged infringement.
To the extent that the legal basis for our processing of your personal information is consent, you have the right to withdraw that consent at any time. Withdrawal will not affect the lawfulness of processing before the withdrawal.
ROAR for Good for Good, LLC
1339 Chestnut Street, STE 1500, Philadelphia, PA 19107