Prepared Emergency System | Privacy Policy

PREPARED Privacy Policy

Revised July 2023

PREPARED’S COMMITMENT TO PRIVACY‍

Invictus Apps, Inc. d/b/a PREPARED (“PREPARED,” sometimes referred to as “we”, “us” or “our”) respects the privacy of every visitor to our websites and every user of our mobile apps and desktop apps. Your privacy is a priority, and we go to great lengths to protect it. This Privacy Policy describes how we collect and use information about our online visitors. We know you care about your information and we want you to be fully informed about our practices.

This Privacy Policy (“Privacy Policy”) applies to our data collection practices, including when you use our Prepared Live Emergency Communications Service (“Prepared Live”), use and engage with our mobile apps and desktop apps, and when you visit our website (“Site”), inquire about our products or services, subscribe to our mailing lists, or when you engage with us via email or on social media.

This Privacy Policy may be changed or updated from time to time. By visiting PREPARED at one of our websites or using one of our apps or services, you accept the practices described in this Privacy Policy. California, Colorado, Connecticut and Virginia state laws confer certain rights relating to personal information to their residents. If you are a resident of these states, please also see the applicable privacy sections below:

— California
— Colorado
— Connecticut
— Virginia

Please review this Privacy Policy periodically. Whenever you submit personal information to us, you consent to the collection, use, disclosure, transfer, and storage of that information in accordance with this Privacy Policy.

All personal information may be used for the purposes stated in this Privacy Policy. We may make full use of all information that is de-identified, aggregated, or otherwise not in personally identifiable form. We may also make full use of all user-generated content you submit to us, in accordance with our Terms of Use.

‍THE DATA WE COLLECT‍

Our websites, mobile apps and desktop apps provide convenient ways for you to access our services and learn important information about PREPARED and our services. To a see a complete list of what we collect, and how we use this data, please see our Annex 1. We collect information about our online visitors both directly from our visitors and indirectly from other companies and/or government agencies that provide data to us. When you use our websites or apps to pay for a service, register as a user, configure your settings, monitor activity, send emergency alerts or communications, or do various other functions, we may ask you for your name, address, phone number(s), and other information relevant to the transaction or function.

We may obtain information about our online visitors from other sources as well. For example, we may engage with third party sources, including our public agency partners that may provide contact information, location services, and other data. We use this data to help us improve our services and to engage with customers who may benefit from PREPARED’s activities or services. We also collect information about you through your browser, computer hardware and
software. This information can include your IP address, device ID, browser type, domain names, access times and dates, number of clicks, pages viewed, one or more cookies (as described below) that may uniquely identify your browser, and referring website addresses. This information is used by PREPARED for the improvement of our Site.

We also collect non-personal information about our online visitors using “cookies,” pixels, web beacons, and other technologies that operate automatically when you visit our website. We use this information to give our website visitors a more relevant online experience and to help us make website improvements. The information helps us understand which parts of our websites are the most popular, where our online visitors are going, and how long they spend there. If you
do not want us to collect information using cookies, you can disable this function in your browser. If you block cookies from us, however, you may not be able to see personalized content and our website may not function optimally.

We may combine data collected from third party sources, including our public agency partners.

Sensitive Personal Information

‍PREPARED collects sensitive personal information as set forth in Annex 1, including:
— Biometric information, including photographic and video images of you;
— Recordings of your voice as you speak to 911 professionals
— Precise geolocation.

HOW WE SECURE YOUR DATA
We use a variety of security measures to protect your data. We maintain physical, electronic and procedural safeguards to help prevent unauthorized access to and improper use of personally identifiable information.
No website or electronic data can ever be completely secure, but we are always working to maintain up-to-date and appropriate security mechanisms.

HOW WE USE YOUR INFORMATION‍

If you consent to PREPARED’s Prepared Live Emergency Communications Services (“Prepared Live”), we are provided with your personal information and location, text messages and images that you send to 911 professionals, and access your audio and camera feed for the limited purpose of helping public safety agencies aid you in an emergency.

If you provide PREPARED with personal information when you visit our Site, or use our mobile apps or desktop apps, we may use the information in our services and activities. We may enter your information into one of our databases so we can contact you to obtain your input, provide information about our services or products, or provide a more personalized online experience.
We may also use data or information provided to us to communicate with customers, emergency responders and law enforcement, and to support public safety agencies in preparing for, responding to, helping the public in recovering from, and mitigating against all emergency
incidents.

We may also use the sessions obtained during the Prepared Live feed for our business needs and purposes, including to make this service better; to identify other services we can provide to help before, during, and after emergencies; and to improve public safety. Information that we disclose to third parties is to assist public safety agencies as they prepare for, respond to, help the public recover from, and mitigate against all emergency incidents and for developing analytical models to provide better support before, during, and after emergencies (the “business and product
improvement purposes”).

‍HOW WE DISCLOSE YOUR PERSONAL INFORMATION
Service Providers. Information that we disclose to third parties is to assist public safety agencies as they prepare for, respond to, help the public recover from, and mitigate against all emergency incidents and for developing analytical models to provide better support before, during, and after emergencies. PREPARED may share your information with our vendors and other partners that help us with our activities and services. For example, we disclose information with vendors that help us manage data and respond to emergencies. These vendors are bound by confidentiality rules and are permitted to use the information only to support PREPARED operations.‍

Third Party Partners. We may also share data and information from emergency situations with public safety agencies such as 911 centers. We do not sell or share personal data or information to other organizations. These third party partners are contractually subject to confidentiality rules, and are required to maintain reasonable security measures to ensure that your information is protected. PREPARED does not sell, trade, or share our customers’ personally identifiable information with any other entity, except as described below. ‍

Legal Obligations. We also disclose information to outside parties (including, without limitation, governmental agencies) if required to do so by law, regulation or court order; to respond to governmental and/or law enforcement requests; to identify, contact or bring legal action against someone who may be causing injury to or interfering with our (or others’) rights or property; to support any actual or threatened claim, defense or declaration in a case or before any jurisdictional and/or administrative authority, arbitration or mediation panel; or in connection with disciplinary actions/investigations as required by law.‍

Sale or Corporate Restructuring. We may disclose Personal Information to third parties in connection with the sale, assignment or other transfer of the business of our website or the sale, assignment, merger, reorganization or other transfer of our brand or company.

HOW WE USE “COOKIES” AND OTHER TECHNOLOGY ON OUR SITE
As you enter the Site, our server records and monitors your IP address and uses it to develop statistical analysis. These analyses assist us in refining and adapting the content and design of our site. The use of IP addresses also enables us to prevent malicious Internet users from masquerading as other users. Automated technology collects information from your computer or mobile device and includes cookies, web beacons, local shared objects, or other similar
technology. A cookie is a small piece of information sent by a website that is saved on your hard drive by your computer’s browser. A “web beacon” is a small object or image that is embedded into a web page, application, or email and is used to track activity. They are also sometimes
referred to as pixels and tags.
As you access or use our Site, we and/or third parties may collect information using cookies, web beacons, pixels, and navigational and location data collection (clickstream, log files, server logs) for the purposes described in this Policy. Such automated technologies further help us to keep track of your interactions with our website and provide you with a more customized experience.

To find more information about cookies please visit www.allaboutcookies.org. Most browsers are initially set to allow cookies, but also offer the option to restrict cookies or warn you of their use. By disabling cookies, you won’t be able to enjoy the convenience provided by our customization.‍

RETENTION OF PERSONAL INFORMATION
We will retain your Personal Information to the extent required by the Health Insurance Portability and Accountability Act of 1996 (“HIPAA”) or as long as it is necessary and to the extent necessary to comply with our legal obligations, resolve disputes, and enforce our legal agreements and policies, whichever is shorter. For more information regarding retention of personal information see Annex 1.

‍CONTACT PREFERENCES; OPT-IN AND OPT-OUT
We would like to keep in touch with you in ways that you find to be beneficial. If you don’t want us to use your contact information to communicate with you for promotional purposes, please tell us that when you provide your contact information. If at any time you would like to unsubscribe from receiving future emails, you can click the unsubscribe link at the bottom of any email. You may also contact us at contact@preparedapp.com. Keep in mind that these preferences regarding promotional contacts do not mean that we might not contact you for other reasons, such as those related to an inquiry you made, a legally required notice and so on.

‍External Links
We may make available third party applications through our Site and social media applications for your use. Links to such applications, any other websites included in this Site or links on our social media accounts operate with privacy policies beyond our control. Unless otherwise indicated, once you have left our Site or our social media account, all use of information you provide is governed by the privacy policy of the other website’s or social media account operators. We are not responsible for any transactions that occur between you and a third-party website or social media account.

‍MISCELLANEOUS
PREPARED is committed to accuracy and precision in processing your information. We have procedures to check for errors, and our systems are periodically audited to make sure we process your information securely and accurately.

‍Contact Us
If you have any questions or concerns about this Privacy Policy, please contact us at contact@preparedapp.com.

CALIFORNIA CONSUMERS ONLY: Your California Privacy Rights

This Privacy Rights Act Notice (“Notice”) provides additional information to California residents whose Personal Information is collected by us pursuant to California law, including the California Consumer Privacy Act (“CCPA”), as amended by the California Privacy Rights Act (“CPRA”). If you are not a California resident, this Notice does not apply to you. Please visit our Privacy Policy Privacy Policy (“Policy”) [Insert link to Privacy Policy above] for more
information. Any capitalized terms undefined in this Notice have the same definition as the Policy.‍

RIGHT TO KNOW ABOUT PERSONAL INFORMATION COLLECTED OR DISCLOSED

Information Collected
In the preceding 12 months, we have collected the categories of personal information about California consumers as described in Annex 1. to this Notice. To review these categories click here: Annex 1.‍

Business-to-Business (“B2B”) Information
If you are a contact person for any of our business partners, vendors, distributors, suppliers, service providers, contractors, or other entities with which we have a business relationship or potential business relationship, we collect the contact information you provide to us, including name, phone number, address, email address and other contact and relationship information consistent with your role in facilitating that business relationship. We use that information for internal purposes, including to contact you, send and receive information, and otherwise facilitate the business relationship. We do not disclose that information outside our business relationship without your consent. See Annex 1 for more details.‍

Information Sold or Shared
We have not sold or shared any personal information for a business or commercial purpose in the preceding 12 months.
We have disclosed the following categories of personal information for a business or commercial purpose in the preceding 12 months:
— Personal Identifiers
— Internet Activity
— Sensitive Information
— Biometric Data
We do not knowingly sell the personal information of individuals under 16 years of age without affirmative authorization.
For details regarding the categories of third parties with whom we have disclosed personal information, please see Annex 1.‍

Requests to Know

You have the right to request that we disclose personal information we collect about you. To make a request for any of the information set forth above (a “Request to Know”), please submit a verifiable consumer request pursuant to the instructions below. You may make a Request to Know twice
within a 12-month period. We will acknowledge your Request to Know within 10 days and will attempt to respond substantively within 45-90 days.
The Request to Know must provide sufficient information to allow us to verify that you are the person about whom the personal information was collected, sold or disclosed and must contain sufficient detail to allow us to properly understand, evaluate and respond to your request. If we cannot verify your identity, we will not be able to respond to your request.
You can make a Request to Know the personal information we have about you in the following ways:

— Enter your request here.
— You may also make a request by phone by contacting us at +1 (201) 608-3829.

Once we receive your Request to Know, we will begin the process to verify that you are the person that is the subject of the request (the “Verification Process”). The Verification Process consists of matching identifying information provided by you with the information we have about you in our records. You will be asked to provide us with two or three pieces of information that will help us to verify your identity.

RIGHT TO KNOW AND LIMIT SENSITIVE PERSONAL INFORMATION COLLECTED

We collect and use your Sensitive Personal Information as described in Annex 1. Under certain laws, you have the right to limit the use of your Sensitive Personal Information for purposes other than those set forth in Regulation Section 7027(m). You can submit a request to limit the use of your Sensitive Personal Information in certain circumstances by clicking here [webform to opt out]

RIGHT TO REQUEST DELETION OF PERSONAL INFORMATION‍

You have the right to request the deletion of your personal information collected or maintained by us (“Request to Delete”), subject to certain exceptions permitted by law.

To make a Request to Delete, please submit a verifiable consumer request pursuant to the instructions below. You may make a verifiable consumer Request to Delete twice within a 12-month period. We will acknowledge your Request to Delete within 10 days and will attempt to respond substantively within 45-90 days.

The Request to Delete must provide sufficient information to allow us to verify that you are the person about whom the personal information was collected, sold or disclosed and must contain sufficient detail to allow us to properly understand, evaluate and respond to your request. If we cannot verify your identity, we will not be able to respond to your request. Additionally, as permitted by law, if the information requested to be deleted is necessary for us to maintain, we will
not be able to comply with your request. We will notify you if this is the case.

You can make a Request to Delete in the following ways:
— Enter your request here here.
— You may also make a request by phone by contacting us at +1 (201) 608-3829.
Once we receive your initial request to delete and your separate confirmation to delete, we will need to verify that you are the person that is the subject of the request (the “Verification Process”). The Verification Process consists of matching identifying information provided by you with the information we have about you in our records. You will be asked to provide us with two or three pieces of information that will help us to verify your identity.

We will retain correspondence, documents and information related to any Request to Know, Request to Delete, or Request to Opt-Out for 24 months as required by law.

Cookies
As explained in our “How We Use ‘Cookies’ and Other Technology on Our Site” section, you can opt out of cookies using your browser. You may also exercise your right to opt-out of cookies using our Cookie Preference Center.
Please Note:
— Opt-outs are device and browser based. You must opt out on each device and each browser where you want your choice to apply.
— Opt-outs maybe stored via cookies. If you clear cookies, your opt-out may no longer be valid and you must opt out again where you want your choices to apply.
— We may still share your information with our service providers that help us perform functions that are necessary for our business such as vendors that host our website, credit card processors, analytics processors. These entities are contractually obligated to keep this information confidential and not use it for any purpose other than for the services they provide to our business.
— You may still receive ads from us that are not tailored to your interests.

RIGHT TO CORRECT

You have the right to request that we rectify inaccurate information about you.‍

Requests to Correct‍

To make a Request to Correct, please submit a verifiable consumer request pursuant to the instructions below. We will acknowledge your Request to Correct within 10 business days and we will attempt to respond substantively within 45-90 days.

You can make a Request to Correct in the following ways:
— Enter your request here.
— You may also make a request by phone by contacting us at +1 (201) 608-3829.

Once we receive your request to correct, we will need to verify that you are the person that is the subject of the request through the Verification Process.

We will review all information provided by you to us, to determine whether the information is inaccurate. We reserve the right to delete the information instead of correcting if such deletion does not impact you or you consent to the deletion.

We will inform you of our decision to deny or grant your request.

We will retain correspondence, documents and information related to any Request to Correct for 24 months as required by law.

RIGHT TO ACCESS INFORMATION ABOUT AUTOMATED DECISION MAKING AND THE RIGHT TO OPT-OUT OF AUTOMATED DECISION MAKING‍

We do not engage in automated decisionmaking with respect to your personal information.‍

RIGHT TO NON-DISCRIMINATION FOR EXERCISING CONSUMER PRIVACY RIGHTS

You have the right not to receive discriminatory treatment for exercising your privacy rights conferred by the California Consumer Privacy Act, including by exercising the rights specified herein.

RETENTION OF PERSONAL INFORMATION‍

We will retain your Personal Information to the extent required by the Health Insurance Portability and Accountability Act of 1996 (“HIPAA”) or as long as it is necessary and to the extent necessary to comply with our legal obligations, resolve disputes, and enforce our legal agreements and policies, whichever is shorter. For more information regarding retention of personal information see Annex 1.

AUTHORIZED AGENT INFORMATION‍

You may designate an authorized agent to make a request on your behalf under the California Consumer Privacy Act.

In order to allow an authorized agent to make a request on your behalf, please email us at contact@PreparedApp.com to provide your written request and consent to an authorized agent. When your authorized agent makes a request related to your personal information, we will require the agent to provide the above written permission. We may also require that you verify your own identity directly with us at the time such a request is made.

California Do Not Track Notice: Because there are not yet common, industry accepted “do not track” standards and systems, our website does not respond to Do Not Track signals. In addition, we may allow third-parties to collect personal information from your activity on our website, as described in the “Information Collection and Use” section above.

California Shine The Light Disclosure Information‍

Although we do not disclose to any third-parties for their marketing purposes any personal information, California residents are entitled to receive the following disclosure information under California law:

Under California Law, California residents have the right to request in writing from businesses with which they have an established business relationship, (1) a list of the categories of personal information, such as name, address, email address, and the type of services provided to the customer, that a business has disclosed to third-parties (including affiliates that are separate legal entities) during the immediately preceding calendar year for the third-parties' direct marketing purposes, and (2) the names and addresses of all such third-parties. We will respond to such written requests within 30 days following receipt at the email or mailing address specified below under “Contact Us”. If we receive your request at a different email or mailing address, we will respond within a reasonable period of time, but not to exceed 150 days from the date received.

Please note that we are required to respond to each customer only once per calendar year.

Changes to This Privacy Policy‍

This Privacy Policy may be revised from time to time for any reason. If this Privacy Policy changes, the revised policy will include a new effective date, and we will notify you of such changes by posting the revised policy on this page. Be sure to check the Privacy Policy whenever you submit personal information to us.‍

CONTACT FOR MORE INFORMATION‍

For information and questions about the use of your personal information or this California Consumer Privacy Section or your rights under California law, you may contact us at contact@preparedapp.com.

COLORADO, CONNECTICUT AND VIRGINIA CONSUMERS ONLY: COLORADO, CONNECTICUT AND VIRGINIA PRIVACY ACT NOTICES

This Notice provides additional information to Colorado, Connecticut, and Virginia residents whose Personal Information is collected pursuant to the Colorado Privacy Act (“CPA”), Connecticut Data Privacy Act (“CTDPA”), and Virginia Consumer Data Protection Act
(“VCDPA”).

The Notice below applies only to Connecticut, Colorado, and Virginia residents. Please visit our Privacy Policy (“Privacy Policy”) for more information. Any capitalized terms undefined in this Notice have the same definition as the Privacy Policy.

RIGHT TO CONFIRM, ACCESS AND DATA PORTABILITY
You have the right to confirm whether or not we are processing your personal data and to access such personal data in a portable and, to the extent technically feasible, readily usable format that allows you to transmit the data to another controller without hindrance, where the processing is carried out by automated means. We will respond to your request within 45 days of receipt, unless we request an extension for an additional 45 days to respond.

You can exercise this right in the following ways:

— You may make a request here.
— You may make a request here: contact@preparedapp.com
— You may also make a request by phone by contacting us at +1 (201) 608-3829

Once we receive your request, we will begin the process to verify your identity to confirm that you are the person that is the subject of the request (the “Verification Process”). The Verification Process consists of matching identifying information provided by you with the information we have about you in our records. Upon making a request, you should be prepared to provide us with information that will help us to verify your identification. If we cannot verify your identity, we will not be able to respond to your request.

RIGHT TO REQUEST DELETION OF PERSONAL DATA‍

You have the right to request the deletion of your personal data provided by or obtained about you (“Request to Delete”), subject to certain exceptions permitted by law.

To make a Request to Delete, please submit a verifiable consumer request pursuant to the instructions below. We will respond to your request within 45 days of receipt, unless we request an extension for an additional 45 days to respond.‍

Requests to Delete
You can make a Request to Delete in the following ways:

— You may make a request here.
— You may make a request here: contact@preparedapp.com.
— You may also make a request by phone by contacting us at +1 (201) 608-3829

RIGHT TO CORRECT
You have the right to request that we rectify inaccurate information about you. To make a Request to Correct, please submit a verifiable consumer request pursuant to the instructions below. We will attempt to respond substantively within 45-90 days.

Requests to Correct
You can make a Request to Correct in the following ways:

— You may make a request here.
— You may make a request here: contact@preparedapp.com.
— You may also make a request by phone by contacting us at +1 (201) 608-3829

Once we receive your request, we will begin the process to verify your identity to confirm that you are the person that is the subject of the request (the “Verification Process”). The Verification Process consists of matching identifying information provided by you with the information we have about you in our records. Upon making a request, you should be prepared to provide us with information that will help us to verify your identification. If we cannot verify
your identity, we will not be able to respond to your request.

We will retain correspondence, documents and information related to any Request to Correct for 24 months as required by law.‍

RIGHT TO NON-DISCRIMINATION FOR EXERCISING CONSUMER PRIVACY RIGHTS‍

You have the right not to receive discriminatory treatment for exercising your privacy rights , including by exercising the rights specified herein. As the Right to Non-Discrimination is effective across the board, there is no specific “request” that you need to make in order to exercise this right.

RIGHT TO OPT OUT OF PROFILING
You have the right to opt out of the processing of your personal data for purposes of profiling in furtherance of decisions that produce legal or similarly significant effects (“Request to Opt Out of Profiling”).

Requests to Opt Out of Profiling
You can make a Request to Opt Out of Profiling in the following ways:

— You may make a request here.
— You may make a request here: contact@preparedapp.com
— You may also make a request by phone by contacting us at +1 (201) 608-3829

Authorized Agent
You may designate an authorized agent to make a request on your behalf to opt out of the sale of personal information.

Authorized agents may make requests under the CTDPA, CPA, and VCDPA on behalf of consumers by emailing contact@preparedapp.com. We will require authorized agents to provide proof of the consumer’s consent to and designation of the authorized agent for purpose of making the request, and will require authorized agents to provide information necessary to verify the identity of the consumer who is the subject of the request. We may also require that a consumer verify his or her own identity directly with us before we respond to an authorized agent’s request.

RIGHT TO APPEAL
You have the right to appeal our decision to deny any of your privacy rights requests above. Within 60 days of receipt of your appeal (45 days for Colorado residents), we will inform you in writing of any action taken or not taken in response to the appeal, including a written explanation of the reasons for the decisions.

Colorado residents, if your appeal is denied, you may submit a complaint to the Colorado Attorney General at https://coag.gov/office-sections/consumer-protection.

Connecticut residents, if your appeal is denied, you may submit a complaint to the Connecticut Attorney General at https://portal.ct.gov/AG/Common/Complaint-Form-Landing-page

Virginia residents, if your appeal is denied, you may submit a complaint to the Virginia Attorney General at https://www.oag.state.va.us/consumer-protection/index.php/file-a-complaint.

‍Making an Appeal

‍You can make an appeal in the following ways:
— Enter your appeal here.
— You may also make an appeal by phone by contacting us at +1 (201) 608-3829.

We reserve the right to deny appeals in certain circumstances, such as where we have a reasonable belief that the request is fraudulent.

RETENTION OF PERSONAL INFORMATION
We will retain your Personal Information for 10 years as required by the Health Insurance Portability and Accountability Act of 1996 (“HIPAA”) or as long as it is necessary and to the extent necessary to comply with our legal obligations, resolve disputes, and enforce our legal agreements and policies, whichever is shorter. For more information regarding retention of personal information see Annex 1.

OTHER DISCLOSURE INFORMATION

Do Not Track Notice‍

Because there are not yet common, industry-accepted “do not track” standards and systems, the Site does not currently respond to Do Not Track signals. In addition, we may allow third parties to collect Personal Information from your activity on our website, as described in the “Information Collection and Use” section above and described in Annex 1 below.

ANNEX 1

Notice of Collection, Use, and Disclosure
See our full Privacy Policy here
See California Privacy Rights here
See Colorado, Connecticut and Virginia Privacy Rights here