Full Privacy Policy

Safe Control App Privacy Policy

 

This Privacy Policy was last modified on 29/03/2019

 

WELCOME

 

Singulart Systems LLC ("Singulart Systems","we", "our",or "us") is committed to protecting and respecting your privacy.

Singulart Systems operates a service that allows you to speak to and share your location with other users of the app, which you connect to your account, which we make available through our apps (the "Service").

 

This Privacy Policy explains our practices regarding the collection,use, disclosure, and protection of information that is collected through our Service, as well as your choices regarding the collection and use of information.

 

Our Service is available in many different countries, which may have different standards and requirements in respect of the information we provide in the Privacy Policy and how we use personal information.

 

This Privacy Policy is therefore made up of two parts: Part 1 sets out information applicable to users outside the European Economic Area or Switzerland, and Part 2 sets out information applicable to users in the European Economic Area or Switzerland.

Before accessing or using our Service, please ensure that you have read and understood how we collect, store, use and disclose your personal information as described in the part of this Privacy Policy that is relevant to you.

 

Part 1 – Privacy Policy for non-EEA users

This Part 1 of our Privacy Policy explains how we collect, use,disclose and protect information that is collected through our Service from users outside the European Economic Area or Switzerland, as well as your choices regarding the collection and use of information.

This Part 1 of the Privacy Policy was last modified on 10/22/2018

 

1.          HOW WE COLLECT AND USE INFORMATION

 

Capitalized terms that are not defined in this Privacy Policy have the meaning given them in our Terms of Use.

 

We collect the following types of information about you:

 

Registration and Profile Information. When you create an account, we may collect your personal information such as your username, email address and a photo, if you chose to have a photo associated with your account. We may also collect billing information when you sign up for Premium service.

 

Data collected through use of the Service. After you set up your account,we may ask for other profile and demographic information, such as personal emergency instructions and information, and nickname. You may also customize your map by labeling locations, such as “work” and “home,” to make it easy to spot your favorite Places and to provide alerts when family members leave and arrive.

 

Geolocation. We collect your location information through your device IP address, WiFi, Bluetooth, and GPS coordinates (e.g.,latitude/longitude) available through your mobile device. We may also gather information about your location using other technologies and sensors which may provide us with information about nearby devices, WiFi access points and networks, and nearby cell towers. We collect and maintain location data to provide you the features and functionality of the Service. We may also share location information with third parties for advertising, research, analytic and other purposes.If you want to opt-out of the collection of your location data, please adjust your settings in your mobile device to limit the app’s access to your location data. Please see “Your Choices About Your Information” below to learn more.

 

We use this information to operate, maintain, and provide to you the features and functionality of the Service and to communicate directly with you,such as to send you alerts on the movements of your members, etc.

 

Social Media. When you interact with our site through various social media,such as when you Like us on Facebook or post a comment to our Facebook page, we may receive information from the social network such as your profile information, profile picture, gender, user name, user ID associated with your social media account, age range, language, country, friends list, and any other information you permit the social network to share with third parties. The data we receive is dependent upon your privacy settings with the social network. You should always review, and if necessary, adjust your privacy settings on third-party websites and services before linking or connecting them to Singulart Systems’s website or Service.

 

Information we collect automatically through the use of technology. When you visit our website, use our mobile app, read our emails or otherwise engage with us, we and our business partners may automatically collect certain information about your computer or device through a variety of tracking technologies, including cookies, web beacons, log files, embedded scripts, location-identifying technologies, or other tracking/recording tools(collectively, “tracking technologies”), and we may combine this information with other personal information we collect about you. We use these tracking technologies to collect usage and device information, such as:

 

   Information about how you access the Service, for example, referral/exit pages, how frequently you access the Service, whether you open emails or click the links contained in emails, whether you access the Service from multiple devices, and other actions you take on the Service.



   Information about how you use the Service, for example, the features you use, the links you click, the ads you view and click on, purchase transaction information, your location when you access or interact with our Service, and other similar actions.



   Information about the computer, tablet, smartphone or other device you use, such as your IP address, browser type, Internet service provider, platform type, device type/model/ manufacturer, operating system, phone number, mobile carrier, date and time stamp, a unique ID that allows us to uniquely identify your browser, mobile device or your account (including, for example, a UDID, IDFA, Google Ad ID, Windows Advertising ID or other persistent device identifier or Ad ID), battery life, and other such information. With your permission, we may also access your photo or camera roll.



We may collect analytics data, or use third-party analytics tools such as Google Analytics, to help us measure traffic and usage trends for the Service and to understand more about the demographics of our users. You can learn more about Google’s practices at http://www.google.com/policies/privacy/partners, and view its currently available opt-out options at https://tools.google.com/dlpage/gaoptout.

 

We use this information to

·      remember information so that you will not have to re-enter it during your visit or the next time you visit the Service;

·      provide custom, personalized content and information, including targeted content and advertising;

·      track your location and movements;

·      identify and contact you across multiple devices;

·      provide and monitor the effectiveness of our Service and our marketing campaigns;

·      monitor aggregate metrics such as total number of visitors, users, traffic, and demographic patterns;

·      diagnose or fix technology problems reported by our Users or engineers that are associated with certain IP addresses or User IDs;

·      detect or prevent fraud or other harmful activities;

·      automatically update our mobile application on your system and related devices;

·      otherwise plan for and enhance our Service.

 

We and our third-party partners may also use information collected through tracking technologies for advertising purposes. Please see “Third Party Tracking and Online Advertising” below to learn more.

 

2.          SHARING OF YOUR INFORMATION

 

Personal Information:  We share your personal information with third parties outside the Company and its controlled subsidiaries and affiliates in some circumstances, as follows:

 

        We share your personal information, including name, battery level, location with others within your connected members.



        We may share your personal information, including your location data, unique identifiers or AD IDs and other data with third parties for their marketing and business purposes, including without limitation, to inform and improve third-party advertising. These third-party partners may use this information according to their own privacy policies. Please see “Your Choices About Your Information” to learn how you may be able to limit some third-party data sharing. 



 

Other instances in which we may share your information: We may also share your information for business purposes, as follows:

 

   We may share your personal information with our third-party business partners, vendors and consultants who perform services on our behalf or who help us provide our Services, such as accounting, managerial, technical, marketing or analytic services.



   We may at any time buy or sell/divest the company, or any combination of its products, services, assets and/or businesses. Personal information such as customer names and email addresses, and other user information related to the Service will likely be one of the items transferred in these types of transactions. We may also share, transfer or assign such information in the course of corporate divestitures, mergers, acquisitions, bankruptcies, dissolutions or similar transactions or proceedings.



   We may share your steps of using our Service using Amplitude Inc. service. You may be able to see information about Amplitude Inc. service using link: https://amplitude.com/privacy

   We may disclose personal information to third parties (including law enforcement, other government entity, or civil litigant; excluding our subcontractors) when required to do so by law or subpoena or if in our sole discretion, we determine it is necessary to (a) conform to the law, comply with legal process, or investigate, prevent, or take action regarding suspected or actual illegal activities; (b)to enforce our Terms of Use [https://safecontrol.app/docs/terms_of_use.html], take precautions against liability, to investigate and defend ourselves against any claims or allegations, or to protect the security or integrity of our site; and/or (c) to exercise or protect the rights, property, or personal safety of Singulart Systems, our Users or others.



 

De-Identified, Aggregated, or Otherwise and Anonymized Information:  We share your information with third parties in de-identified, aggregated or otherwise anonymized form that does not reasonably identify you directly as an individual or your device.  These third parties may use the anonymized information for any purpose.

 

3.       HOW WE PROTECT YOUR INFORMATION

 

Singulart Systems cares about the security of your information and uses commercially reasonable physical, administrative, and technological safeguards to preserve the integrity and security of all information we collect and that we share with our service providers. However, no security system is impenetrable and we cannot guarantee the security of our systems 100%. In the event that any information under our control is compromised as a result of a breach of security, we will take reasonable steps to investigate the situation and where appropriate, notify those individuals whose information may have been compromised and take other steps, in accordance with any applicable laws and regulations.

 

4.           YOUR CHOICES ABOUT YOUR INFORMATION

 

You may, of course, decline to submit any personal information through the Service, in which case Singulart Systems may not be able to provide its Services to you.

 

Modifying Your Account Information and Settings: You may modify your account information, update or amend your personal information, or change your password at any time by logging in to your account. If you have any questions about reviewing or modifying your account information, you can contact us directly at support@Safecontrol.app.

 

Delete Your Account and Personal Information: We will retain your information for as long as your account is active or as needed to provide you services. If you wish to cancel your account, please contact us at support@safecontrol.app.

 

Emails and Notifications:  You can control your receipt of email and text alerts by visiting “Settings” and “Alert Options” within the mobile app. You can also stop receiving promotional email communications from us by clicking on the “unsubscribe” link provided in such communications. We make every effort to promptly process all unsubscribe requests.  We may also send you Service-related emails (e.g., account verification, parental consent notification, order confirmations, change or updates to features of the Service, technical and security notices). You may not opt-out of Service-related e-mails.

 

Third Party Tracking and Advertising: We may share, or we may permit third party ad networks, social media companies, and other third party services to collect, information about your use of our Services over time, including location information, so that they may play or display ads that may be relevant to your interests on our Service as well as on other websites, apps or services, or on other devices you may use. We may also display targeted advertising to you through social media platforms, such as Facebook, Twitter, Google+ and others. These third part ad partners may collect information such as click stream information, timestamp, hashed email address, device ID or Ad ID, your use of third party applications and/or precise geolocation data and other information, and may use your unique identifiers to recognize you across various devices you use. We and our advertising partners use this information to make the advertisements you see online more relevant to your interests, as well as to provide advertising-related services such as reporting, attribution, analytics, and market research.

 

To opt-out or control third-party tracking and advertising:  

 

   Interest-based advertising. To learn about interest-based advertising and how you may be able to opt-out of some of this advertising, you may wish to visit the Network Advertising Initiative’s online resources, at http://www.networkadvertising.org/choices, and/or the DAA’s resources at www.aboutads.info/choices. You may also manage certain advertising cookies by visiting the EU-based Your Online Choices at www.youronlinechoices.eu.



   Mobile advertising. You may also be able to limit interest-based advertising through the settings on your mobile device by selecting “limit ad tracking” (iOS) or “opt-out of interest based ads” (Android). You may also be able to opt-out of some – but not all – interest-based ads served by mobile ad networks by visiting 
http://youradchoices.com/appchoices and downloading the mobile AppChoices app.



   Cross-device linking. Please note that opting-out of receiving interest-based advertising through the NAI’s and DAA’s online resources will only opt-out a user from receiving interest-based ads on that specific browser or device, but the user may still receive interest-based ads on his or her other devices. You must perform the opt-out on each browser or device you use.



   Some of these opt-outs may not be effective unless your browser is set to accept cookies.  If you delete cookies, change your browser settings, switch browsers or computers, or use another operating system, you will need to opt-out again.



   Google Analytics and Advertising. We may also utilize certain forms of display advertising and other advanced features through Google Analytics, such as Remarketing with Google Analytics, Google Display Network Impression Reporting, the DoubleClick Campaign Manager Integration, and Google Analytics Demographics and Interest Reporting. These features enable us to use first-party cookies (such as the Google Analytics cookie) and third-party cookies (such as the Doubleclick advertising cookie) or other third party cookies together to inform, optimize, and display ads based on your past visits to the Service. You may control your advertising preferences or opt-out of certain Google advertising products by visiting the Google Ads Preferences Manager, currently available at https://google.com/ads/preferences or by vising NAI’s online resources at http://www.networkadvertising.org/choices.    



 

Third Party Location Sharing: We collect location data to provide the Singulart Systems Services, and may share your personal information, including location data, with other Singulart Systems users in your Family Circle or other Circle you belong to, and with third parties for advertising or other purposes.

 

   Limit location sharing with your users.  You may turn location sharing “OFF” for one or more for your users through your App settings.  If you turn off location sharing for one or more of your users, we will not share your location with such users; however, we will continue to collect your location information in order to provide the Service (for example, to provide our emergency services, or to provide location-based advertising). 



   Limit location collection and sharing.  You can opt-out of future sharing of your precise location data with our third party partners by adjusting your settings on your mobile device to prohibit Safe Control from collecting your location data. For example, depending on your mobile device, you may be able to “Turn location services ‘off.’ You can also adjust your device settings to withdraw permission for the Safe Control app to access location data. We and our third party partners may continue to approximate your location based on other data. Please note that your Singulart Systems app may not be able to provide all of our Services to you if you disable access to location data through your device settings. 



 

5.           CHILDREN'S PRIVACY

 

Our Service allows parents to keep track of their children’s location on mobile devices that the Parent has added to the Family account. The Service is intended to be used by children under 13 only with significant parental involvement and approval. If a Parent wishes to add a User who is under 13 to the Family account, the Parent must first complete the Parental Consent Form and return it via mail, fax or email. The Parental consent form can be found here - https://safecontrol.app/consent.pdf.

 

The child will then be able to participate in the Singulart Systems Service as a member of that Family Account. The child’s personal information, including name, user name, email, and location, will be shared with other members of the Family account and the child user will be permitted to contact, and be contacted by, other members of the Family account through the Service. Singulart Systems may collect, use, disclose, and store the child’s personal information as described in this Privacy Policy. However, we do not use or share personal information collected from the accounts of children under 13 for marketing or advertising purposes, or permit our third party partners to collect and use such information for advertising purposes.

 

The Parent may contact us to review and/or delete any personal information we have collected from the child, or to withdraw permission for Singulart Systems to collect any additional information from the child. Please contact us at support@safecontrolapp.com if you have questions about your child’s account. If you believe that we might have inadvertently collected information from a child under 13 without parental consent, please contact us at support@safecontrolapp.com.

 

6.           LINKS TO OTHER WEB SITES AND SERVICES

 

We are not responsible for the practices employed by websites or services linked to or from the Service, nor the information or content contained therein. Please remember that when you use a link to go from the Service to another website, our Privacy Policy does not apply to third-party websites or services. Your browsing and interaction on any third-party website or service, including those that have a link on our website, are subject to that third party’s own rules and policies. Please read over those rules and policies before proceeding.

 

7.           CHANGES TO OUR PRIVACY POLICY

 

Singulart Systems may, in its sole discretion, modify or update this Privacy Policy from time to time, and so you should review this page periodically. When we change the policy, we will update the ‘last modified’ date at the top of this page. If there are material changes to this Privacy Policy or in how Singulart Systems will use your personal information, we will notify you either by prominently posting a notice of such changes prior to implementing the change or by directly sending you a notification.

 

8.           YOUR CALIFORNIA PRIVACY RIGHTS

 

Singulart Systems collects various types of personal information about you both online and offline, as described in this privacy policy. Under California law, Singulart Systems 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 you may send us an email at support@safecontrol.app with the words “California Privacy Rights” in the subject line.

 

9.           HOW TO CONTACT US

 

If you have any questions about this Privacy Policy or the Service, please contact us at support@safecontrol.app

Singulart Systems LLC

Platonova st. 1B, office 25, BC Victoria Plaza

Minsk, Belarus 220034

Part 2 – Privacy Policy for EEA and Swiss users

 

This Part 2 of our Privacy Policy sets out how we collect, store, process, transfer, share and use data that identifies or is associated with you ("personal information") when you access our Service from the European Economic Area or Switzerland.

 

This Part 2 of the Privacy Policy was last modified on 01/04/2019

 

Singulart Systems LLC is the data controller of the personal information we hold about you.

 

1.           PERSONAL INFORMATION WE COLLECT ABOUT YOU

 

1.1         We collect personal information that you voluntarily submit directly to us when you use our Service. This can include information you provide to us when you register for an account and user profile, create or edit your user profile on the Service, update your preferences, check-in at a particular location, correspond with us by phone, SMS, e-mail or otherwise, or use some other feature of our Service.

 

1.2         We will indicate to you where the provision of certain personal information is required in order for us to provide you certain features of the Service. If you choose not to provide such personal information, we may not be able to provide the Service to you or respond to your other requests.

 

1.3         The table at Annex 1 sets out the categories of personal information we collect about you and how we use that information, as well as the legal basis which we rely on to process the personal information.

 

1.4         We also automatically collect personal information indirectly about how you access and use the Service and information about the device you use to access the Service.

 

1.5         The table at Annex 2 sets out the categories of personal information we collect about you automatically and how we use that information. The table also lists the legal basis which we rely on to process the personal information.

 

1.6         We may link or combine the personal information we collect about you and the information we collect automatically. This allows us to provide you with a personalised experience regardless of how you interact with us.

 

1.7         We may anonymise and aggregate any of the personal information we collect (so that it does not directly identify you). We may use anonymised information for purposes that include testing our IT systems, research, data analysis, improving our Service and developing new products and features. We may also share such anonymised information with others.

 

1.8         We will store the personal information we collect about you for no longer than necessary for the purposes set out in Annex 1 and Annex 2 and in accordance with our legal obligations and legitimate business interests.

 

2.           RECIPIENTS OF PERSONAL INFORMATION

 

2.1         We may share your personal information with the following:

 

(a)          Others in your Safe Control connections: we may share your personal information, including your name, location, with other users of our Service at your request and in accordance with your preferences.

 

(b)          Service providers, business partners and advisors: we may share your personal information with third party vendors and other service providers that perform services for us or on our behalf, which may include providing payment, email or chat services, fraud prevention, web hosting, or providing analytic services.

 

(c)          Purchasers and third parties in connection with a business transaction: your personal information may be disclosed to third parties in connection with a transaction, such as a merger, sale of assets or shares, reorganisation, financing, change of control or acquisition of all or a portion of our business.

 

(d)          Law enforcement, regulators and other parties for legal reasons: we may share your personal information with third parties as required by law or if we reasonably believe that such action is necessary to(i) comply with the law and the reasonable requests of law enforcement; (ii)detect and investigate illegal activities and breaches of agreements, including our Terms of Service; and/or (iii) exercise or protect the rights, property, or personal safety of Singulart Systems, its users or others.

 

2.2         Annex 1 and Annex 2 contain further information about some of the parties with which we may share your personal information.

 

 

3.           YOUR LOCATION

 

3.1      We collect information about your location in order to provide you certain functionalities of the Service.

 

3.2         We will only collect your location where it is necessary for the purposes of providing you with the location-based services features of the app.  You can turn off location sharing for your connected users – if you do so, we will continue to collect your location information in order to provide you the Service. If you would like to opt out of the collection of your location information altogether, please adjust the settings on your mobile device to limit the app's access to your location information.

 

3.3         If you no longer want to continue using the Service, uninstalling the Singulart Systems app or logging out from the Service will also stop us from collecting your location.

 

4.           MARKETING AND ADVERTISING

 

4.1         From time to time, we may contact you with information about our products and services. Most of the marketing messages we send will be by email or through push notifications on your device.

 

4.2         We will only send you marketing messages if you have given us your consent to do so. We will ask you if you would like to receive these messages when we first collect your contact details. 

4.3         You can change your preferences at a later date by clicking on the unsubscribe link at the bottom of our marketing newsletters.

 

5.           STORING AND TRANSFERRING YOUR PERSONAL INFORMATION

 

5.1         Security. We implement appropriate, commercially reasonable technical and organisational measures to protect your personal information against accidental or unlawful destruction, loss, change or damage. However, no security system is impenetrable and we cannot guarantee the security of our systems 100%. We will never send you unsolicited emails or contact you by phone requesting your account ID, password, credit or debit card information or national identification numbers.

 

5.2         International Transfers of your Personal Information. As we are located in the USA, any information we collect from you will initially be collected and stored in the USA. If you are in the EU or EEA, this may mean that your personal information will be stored in a jurisdiction that offers a level of protection that may, in certain instances, be less protective of your personal information than the jurisdiction you are typically resident in. We will take reasonable steps to ensure that your personal information is treated securely and in accordance with applicable law and this privacy policy.

 

6.           USERS' RIGHTS IN RESPECT OF THEIR PERSONAL INFORMATION

 

6.1         In accordance with applicable privacy law, you have the following rights in respect of your personal information that we hold:

 

(a)          Right of access. You have the right to obtain:

 

(i)           confirmation of whether, and where, we are processing your personal information;

 

(ii)          information about the categories of personal information we are processing, the purposes for which we process your personal information and information as to how we determine applicable retention periods;

 

(iii)         information about the categories of recipients with whom we may share your personal information; and

 

(iv)         a copy of the personal information we hold about you.

 

(b)          Right of portability. You have the right, in certain circumstances, to receive a copy of the personal information you have provided to us in a structured, commonly used, machine-readable format that supports re-use, or to request the transfer of your personal data to another person.

 

(c)          Right to rectification. You have the right to obtain rectification of any inaccurate or incomplete personal information we hold about you without undue delay.

 

(d)          Right to erasure. You have the right, in some circumstances, to require us to erase your personal information without undue delay if the continued processing of that personal information is not justified.

 

(e)          Right to restriction. You have the right, in some circumstances, to require us to limit the purposes for which we process your personal information if the continued processing of the personal information in this way is not justified, such as where the accuracy of the personal information is contested by you.

 

(f)           Right to object. You have a right to object to any processing based on our legitimate interests where there are grounds relating to your particular situation. There may be compelling reasons for continuing to process your personal information, and we will assess and inform you if that is the case.  You can object to marketing activities for any reason.

 

6.2         If you wish to exercise one of these rights, please contact us using the contact details at the end of this privacy policy.

 

6.3         You may also review and edit your contact and profile information by logging into your account on the app, and opt out of certain processing activities, such as the collection sharing movement data, by updating your preferences contacting us support@safecontrol.app . Please note that we may not be able to provide some functionalities of our Services to you if you opt-out of the collection and/or sharing of motion data.

 

6.4         You also have the right to lodge a complaint to your national data protection authority. Further information about how to contact your local data protection authority is available at http://ec.europa.eu/justice/data-protection/bodies/authorities/index_en.htm.

 

8.           LINKS TO THIRD PARTY SITES

 

Our Service may, from time to time, contain links to and from third party websites, including those of other users, our partner networks, advertisers, partner merchants, news publications, retailers and affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for their policies. Please check the individual policies before you submit any information to those websites.

 

9.           OUR POLICY TOWARDS CHILDREN

 

9.1         The Service may only be used by children with the consent of a parent or person with parental responsibility over the child. The child's device may only be joined to your account connection created on our Service by, or otherwise associated with the account of the person granting consent.

 

9.2         The age at which children need parental consent varies between EEA Countries. Please refer to Annex 3 to verify the minimum age at which children no longer need consent to use our Service (the "Minimum Age").

 

9.3         If you would like to grant your child access to the Service, you must complete the consent form available at https://safecontrol.app/consent.pdf and return it to us by mail, email using the contact details at the end of this policy.

 

9.4         We will use the personal information of users under the relevant Minimum Age as set out in this privacy policy. We do not, however, use or share personal information collected from accounts of children under the Minimum Age for marketing or advertising purposes, or permit our third party partners to collect and use such information for advertising purposes. We also do not contact, or permit third parties to contact any children under the Minimum Age who access or use our Service.

 

9.5         If you become aware that your child has provided us with personal information, without your consent, then please contact us using the details below so that we can take steps to remove such information and terminate any account your child has created with us.

 

9.6         If you would like to review or delete any personal information we have collected from the child,or to withdraw permission for us to collect any information from the child,please contact us support@safecontrol.app.

 

10.         CHANGES TO THIS POLICY

 

We may update this privacy policy from time to time and so you should review this page periodically. When we change this privacy policy in a material way, we will update the "last modified" date at the end of this privacy policy. Changes to this privacy policy are effective when they are posted on this page.

 

11.         NOTICE TO YOU

 

If we need to provide you with information about something, whether for legal, marketing or other business-related purposes, we will select what we believe is the best way to get in contact with you. We will usually do this through email or by placing a notice on our Service. The fact that we may send notices to you will not stop you from being able to opt out of certain types of contact as described in this privacy policy.

 

12.         CONTACTING US

 

12.1        Please contact support@safecontrol.app if you have any questions, comments and requests regarding this Privacy Policy.