This document sets forth Conect Inc.’s (“Conect”, the “Company”, “we” or “us”) privacy notice. It describes the types of personal information that we receive in the course of doing business, how we use that information, third-parties with whom we may share the information, and your choices in modifying or removing the information.

We value the trust you place in Conect Inc.’s services and our privacy practices. We are committed to providing our customers and users with a secure environment, unparalleled customer service, and state of the art technologies to safeguard your personal information. Conect Inc. will adhere to the policies and practices described in this privacy notice, as well as any applicable customer agreement as it pertains to personal information.

Conect Inc. may, from time to time, own and operate one or more websites (each a “Website” and collectively the “Websites”) and/or mobile applications (each an “Mobile App” or “App” and collectively the “Mobile Apps” or “Apps”).  This privacy notice applies to all Conect Inc. Websites and Mobile Apps including the www.Conectinc.com website and Conect Firstmobile application, which is available in the iTunes store.

What Information Does Conect Inc. Collect?

Our privacy practices will vary depending on the circumstances under which we collected your personal information. Conect Inc. collects personal information in the following circumstances:

  • Personal information collected from Customers (as defined herein).
  • Personal information collected through our Websites and surveys.
  • Personal information collected through our mobile applications.

Information Collected from Users and Customers

Conect Inc. provides a critical event management and public service awareness platform that empowers our individual users (“Users”) and law enforcement and public safety institutions (“Customers”) to better communicate and share information to manage law enforcement and public safety notifications, activities and emergencies in addition to other services (each a “Service” and collectively the “Services”). Part of this capability involves Conect Inc.’s software enabling our Customers to broadcast notifications to targeted Users. To broadcast a notification, the Customer will have uploaded into the Conect Inc. system the User’s name and basic contact information (such as mobile number, work telephone, and e-mail address), and then the Customer will use the Conect Inc. system to send out the notification.

Conect Inc. has no direct relationship with the Users whose personal information it processes from Customers. In this instance our may be the individual’s employer, or a local or state government agency with jurisdiction over the area where the individual resides.

Information collected through our Websites

When you visit and use one or more of our Websites, we may collect, retain and use two kinds of information:

  • Information you provide to us, which may include:
    • Information that you provide by filling in forms on our Websites when registering for Services, white papers, marketing, events or webinars, requesting further information about our solutions, when you report a problem with our Websites or when you otherwise communicate with us. This includes personal information such as name, email address and phone number. The personal information that you are asked to provide, and the reasons why you are asked to provide it, will be made clear to you at the point we ask you to provide your personal information and, if you do not provide this information, we may not be able to provide you with the relevant service, information or communication.
    • Records and copies of your correspondence if you contact us.
    • Your responses to surveys that we might ask you to complete for research purposes.
    • Your search queries on the Websites.
    • Information you provide through our Anonymous Tipping service.
    • Information you provide when signing up for Conect Services, such as your cell phone number or email address.
    • We may also collect the following information from you:
      • Personal information about you.
      • Information about your business, such as organization and industry.
      • Demographic information, such as geographic location.
    • Information collected through automatic data collection technologies.

As is true of most websites, we gather certain information automatically and store it in log files. This information includes internet protocol (IP) addresses, browser type, internet service provider (ISP), referring/exit pages, operating system, date/time stamp, and clickstream data.

We link this automatically collected data to other information we collect about you. We do this to improve our offered services, marketing, analytics, and site functionality.

Please note that Conect Inc. does not attempt to collect any sensitive information, such as personal financial information, social security or driver’s license numbers, or personal health information, on our Websites.

Some of our pages utilize framing techniques to serve content to and from our partners while preserving the look and feel of our Websites. Please be aware that you are providing your personal information to these third parties and not to us.

Our Websites also may include social media features, such as Facebook and Twitter buttons and widgets, and the “Share This” button. These features may collect your IP address, identify which page you are visiting on the Website you are visiting, and may set a cookie to enable the feature to function properly.

Such social media features and widgets are either hosted by a third-party website or hosted directly on our Websites. Your interactions with these third-party features are governed by the privacy notice of the company providing the third-party features.

Surveys

We may provide you the opportunity to participate in surveys on our Websites. If you participate, we will request certain personal information from you. Participation in these surveys is completely voluntary and therefore you have the option whether to disclose this information. The requested information typically includes contact information (such as name and email address) and demographic information (such as zip code).

We may use this information to better understand our market and customer needs, and to continue to enhance our applications.

We may use a third-party service provider to conduct these surveys; that company will be prohibited from using your personal information for any other purpose. We will not share the personal information you provide through a survey with other third parties unless we give you prior notice and the choice to opt-out.

Testimonials

We may display personal testimonials of satisfied customers on our Websites in addition to other endorsements. With your consent we may post your testimonial on one or more Websites along with your name. If you wish to update or delete your testimonial, you can contact us at [email protected].

Information Collected through our Mobile Applications

Conect Inc. offers one or more Mobile Apps. Please note that when you download and use a Conect Inc. Mobile App, you do so voluntarily. Our Mobile Apps may collect the following types of information:

  • Usage Details. Certain details of your access to and use of the Mobile App, including traffic data, logs and other communication data, and the resources that you access and use on or through the Mobile App. We use mobile analytics software to allow us to better understand the functionality of our Mobile App on your phone. This software may record information such as: how often you use the application, the events that occur within the application, aggregated usage, performance data, and where the application was downloaded from. We do not link the information we store within the analytics software to any personal information you submit within the mobile app.
  • 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.
  • Digital Media. Only after you have downloaded a Mobile App and subsequently provided consent, may a Mobile App access metadata, as well as content that you choose to upload, from your device. This content may include photographs that you upload, contact information provided when you ask the Mobile App to access your address book to send invites, or the number of residents in your neighborhood or location also using the Mobile App (but not their identity or contact information).
  • Location Information. We may ask you for your location when you use our Mobile App, or when you opt-in to Conect Inc. Services in connection with sending or receiving messages from our Customers. You will have the option to include your location which will only be used to assist our Customers (for example, a local fire department) to provide better communication in the event of an emergency or other incident. You may opt-out of location-based services at any time by editing the setting at the device level.

We use this information to monitor, analyze and improve our Mobile Apps. 

How Does Conect Inc. Use Information We Collect?

  • User Data. We use User data only as necessary to deliver the Conect Inc. Services that a User has agreed to under the Conect Inc. Terms of Service Agreement (“Terms of Service”), which include, but are not limited to, the provision of our notification services, customer support, and notification of new features and services. We may also use Customer data to contact you regarding administrative notices, to resolve disputes, troubleshoot problems and enforce the Terms of Service. Conect Inc. will retain personal information (including geo-location data) provided by our Users for as long as is needed to provide services to our Users and in accordance with the Terms of Service. In addition to this privacy notice, usage of User data is subject to and covered by the applicable Terms of Service.
  • Customer Data. We use Customer data only as necessary to deliver the Conect Inc. Services that a Customer has agreed to use under the Conect Inc. Customer Services Agreement (the “Customer Services Agreement”), which include, but are not limited to, the provision of our notification services, customer support, and notification of new features and services. We may also use Customer data to contact you regarding administrative notices, to resolve disputes, troubleshoot problems and enforce the Customer Services Agreement. Conect Inc. will retain personal information (including geo-location data) provided by our Customers for as long as is needed to provide services to our Customers and in accordance with the Customer’s Services Agreement. In addition to this privacy notice, usage of Customer data is subject to and covered by the applicable Customer Services Agreement.
  • Anonymous Tipping. Our Anonymous Tipping service will allow you to anonymously report information about a crime or suspicious activity. In connection with an SMS tip submission, Conect Inc. will store your number to allow for two-way communication. If you are affiliated with a Conect Customer, a name will be associated with that number. However, your name and phone number will not be displayed to enforcement agencies, public safety agencies or other third parties except where required by law. In addition, Conect Inc. uses industry standard encryption and other safeguards to provide security and anonymity of the information being submitted. Although such encryption and safeguards are utilized, due to the nature of Internet and mobile SMS delivery networks, we cannot and do not guarantee 100% security, or timely delivery or receipt of the information you submit. Neither Conect Inc., nor any third party, makes any representation as to if, how, or when any information you submit may be acted upon by law enforcement or public safety agencies or law enforcement or public safety officials. In addition, Conect Inc. cannot guarantee how often any such agency or official will review and monitor submitted tips. Under no circumstances should you rely on the anonymous tip service to report issues of an emergency nature or for conditions requiring an immediate response. If your issue is an emergency, please dial 911 or your local emergency responder. Conect services are only available in the United States.
  • Disclosure of Your Information for Third-Party Advertising. We do not share your personal information with unaffiliated or non-agent third parties for promotional purposes, except for customers sending business or promotional notifications to which you have specifically consented, including through opt-in.

In general, we will use any of the personal information we collect from you only for the purposes described in this privacy notice or for purposes that we explain to you at the time we collect such information.  However, we may also use your personal information for other purposes that are not incompatible with the purposes we have disclosed to you (such as statistical purposes) if and where this is permitted by applicable data protection laws.

What About Other Websites Linked to the Conect Inc. Websites?

Except as otherwise discussed in this privacy notice, this document only addresses the use and disclosure of information we collect from you. We are not responsible for the practices employed by websites linked to, or from, Conect Inc. Websites, nor the information or content contained therein. Other sites accessible through our Websites have their own privacy policies and data collection, use and disclosure practices. Please consult each third-party website’s privacy notice rules before proceeding.

Third-Parties with Whom We May Share Your Information

We may disclose personal information about you as described in this privacy notice, including:

  • To our third-party service providers on a need to know basis to assist us e.g. operating our website, conducting our business, or providing services to you.
  • To our subsidiaries and affiliates to provide support to you in connection with our Websites or Conect Inc. Services.
  • To fulfil the purpose for which you provide it. For example, if you give us an e-mail address to use the “e-mail a friend” feature of our Website, we will transmit the contents of that e-mail and your e-mail address to the recipients. Or if you opt-in to text-based notifications, we will use your mobile number to send those notifications to you.
  • As required by law, such as to comply with any court order, subpoena, or similar legal process, including responding to any government or regulatory request, as well as lawful requests by public authorities to meet law enforcement requirements.
  • To enforce or apply Conect Inc.’s Terms of Service or our Customer Services Agreement (as applicable) and other agreements.
  • If we believe in good faith that disclosure is necessary or appropriate to protect the rights, property, or safety of Conect Inc., our Users, Customers or others, or to investigate fraud. However, all such disclosure shall comply with any applicable data protection law.
  • In the context of a sale, assignment or other transfer of all or part of the business.
  • To any other person with your consent.

It may be necessary to share our customer data with third-parties in order for Conect Inc. to provide the Services requested by our Customers. For example, we will need to transmit an individual Users cell-phone number to a telecommunications provider in order to deliver a Customer-initiated notification designated for that individual User and others. Under such circumstances we will only transmit the information needed to fulfil the obligations described in our Customer’s Services Agreement. These third-parties are also bound by contractual obligations to keep personal User and Customer information confidential and use it only for the purposes for which we disclose it to them. Transfers to these third-parties are covered by the provisions in this privacy notice regarding notice and choice, as well as applicable contractual agreements.

We do not sell, trade, or rent customer or user data to others.

Legal Basis for Processing your Personal Information (EEA Individuals Only)

If you are a visitor from the European Economic Area (EEA), our legal basis for processing your personal information will depend on the personal information concerned and the specific context in which we collect it.

However, we will normally collect personal information from you only where we have your consent to do so, where we need the personal information to perform a contract with you, or where the processing is in our legitimate interests and not overridden by your data protection interests or fundamental rights and freedoms.  In some cases, we may also have a legal obligation to process personal information about you to protect your vital interests or those of another person.

If we collect and use your personal information in reliance on our legitimate interests (or those of any third party), this interest will normally be to operate our Websites and/or Mobile Apps and communicate with you as necessary to provide our products and services to you and for our legitimate commercial interest. These legitimate interests include, for example, responding to your queries, improving our platform, undertaking marketing, or detecting or preventing illegal activities.  We may have other legitimate interests and if appropriate we will make clear to you at the relevant time what those legitimate interests are.

If you have questions about or need further information concerning the legal basis on which we collect and use your personal information, please contact us using the contact details provided under the “Contacting Us” heading below.

Cookies

We use cookies and similar tracking technology (collectively, “Cookies”) to collect and use personal information about you.  For further information about the types of Cookies we use, why we use Cookies, and how you can control Cookies, please see our Cookie Notice as applicable.

Data Transfers and Privacy Shield

Your personal information may be transferred to, and processed in, countries other than the country in which you are resident. These countries may have data protection laws that are different from the laws of your country (and, in some cases, may not be as protective).

We have taken appropriate safeguards to require that your personal information will remain protected in accordance with this privacy notice.

Conect Inc. complies with the EU-U.S. Privacy Shield Framework and the Swiss – U.S. Privacy Shield Framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information transferred from the European Union (EU) and Switzerland to the United States, respectively. Conect Inc. has certified to the Department of Commerce that it adheres to the Privacy Shield Principles and commits to comply with the Privacy Shield Principles as they apply to the personal data of EU and Swiss residents. If there is any conflict between the terms in this privacy notice and the Privacy Shield Principles, the Privacy Shield Principles shall govern. To learn more about the Privacy Shield program, and to view our certification, please visit https://www.privacyshield.gov/.

Resolution of Disputes and Complaint Mechanism

Conect Inc. commits to resolve complaints about our collection or use of your personal information in accordance with the Privacy Shield Principles. Users in the EU or Switzerland may submit queries related to the processing of personal information under the Privacy Shield framework by contacting us directly at [email protected].

Conect Inc. has further committed to cooperate with the European data protection authorities (the “DPAs”) and/or the Swiss Federal Data Protection and Information Commissioner (the “Commissioner”), as applicable. If we have not been able to successfully resolve your query or complaint and you are based in the EEA or Switzerland, you may raise your query or complaint directly to the DPA or Commissioner. The services of the DPAs and Commissioner are provided at no cost to you. You can find details of the relevant DPA at http://ec.europa.eu/justice/data-protection/article-29/structure/data-protection-authorities/index_en.htm. Conect Inc. will comply with any advice given by the DPAs and/or Commissioner and take necessary actions to remediate any non-compliance with the Privacy Shield Principles.

If your inquiry still has not been satisfactorily resolved, you may have other recourse mechanisms such as invoking binding arbitration by the Privacy Shield Panel.

Enforcement

Conect Inc. privacy practices are subject to the jurisdiction of the United States Federal Trade Commission (FTC), and as such Conect Inc. is subject to the investigatory and enforcement powers of the FTC.

Onward Transfer

If Conect Inc. is going to transfer personal data to a third-party that is acting as an agent, it will enter into a written agreement with such third-party requiring that the third-party provide at least the same level of privacy protection as is required by the Privacy Shield Principles. In the context of such onward transfer to third-parties of data of EU or Swiss individuals received pursuant to Privacy Shield, Conect Inc. is potentially liable if we process such personal information in a manner inconsistent with the Privacy Shield Principles.

Data Security

We have implemented measures designed to secure your personal information from accidental loss and from unauthorized access, use, alteration and disclosure. The security of your personal information and our Customers’ information is extremely important to us. When you enter sensitive information and/or geo-location data, we encrypt the transmission of that information using up-to-date security 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 our Websites, you are responsible for keeping this password confidential. We ask you not to share your password with anyone. We urge you to be careful about giving out information in public areas of the Websites.

Unfortunately, the transmission of information via the Internet is not completely secure. Although we do our best to protect your personal information, we cannot guarantee the security of your personal information transmitted to our Websites. Any transmission of personal information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on the Websites. If you have any questions about security on our Websites, you may contact us at [email protected].

Data retention

We retain personal information we collect from you where we have an ongoing legitimate business need to do so (for example, to provide you with a service you have requested or to comply with applicable legal, tax or accounting requirements).

When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymize it or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.

Choices About How We Use and Disclose Your Information

We strive to provide you with choices regarding your personal information. We have created mechanisms to provide you with the following control over your information:

  • User Data.If you are accessing Conect Inc. services as an individual User, and you wish to make any changes to your contact information, you will need to do so through your profile settings on either the Website or Mobile App you have registered on. If you would no longer like to receive communications from Conect Inc., please delete your account from the Website or Mobile App.
  • Customer Data.If you are accessing Conect Inc. services as an employee, resident or other designee of one of our Customers, and you wish to make any changes to your contact information, you will need to do so through that Customer. If you would no longer like to receive communications from the Customer, please contact the Customer that you interact with directly. If the Customer requests Conect Inc. to remove the data, we will respond to their request promptly, within a reasonable period of time.
  • Promotional Offers from Us.If you do not wish to receive information about our products or services, you can opt-out by going to [email protected] requesting to “opt-out” of the promotional e-mails we send you. If we have sent you a promotional e-mail, you may send us a return e-mail asking to be omitted from future e-mail distributions.
  • Push Notifications.We may occasionally send you push notifications through our Mobile Apps to send you updates and other service related notifications that may be of importance to you. You may opt-out from receiving these types of communications, at any time, by contacting our support team at [email protected].

Rights of individuals in the EEA

If you are a resident of the EEA, you also have the following data protection rights:

  • If you wish to access, correct, update or request deletion of your personal information, you can do so at any time by contacting us using the contact details provided under the “Contacting Us” heading below.
  • In addition, you can object to processing of your personal information, ask us to restrict processing of your personal information or request portability of your personal information. Again, you can exercise these rights by contacting us using the contact details provided under the “Contacting Us” heading below.
  • If we have collected and process your personal information with your consent, then you can withdraw your consent at any time. Withdrawing your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, nor will it affect processing of your personal information conducted in reliance on lawful processing grounds other than consent.
  • You have the right to complain to a data protection authority about our collection and use of your personal information. For more information, please contact your local data protection authority (the contact details for data protection authorities in the EEA, Switzerland and certain non-European countries are available here).

We respond to all requests we receive from individuals wishing to exercise their data protection rights in accordance with applicable data protection laws. Also, for general users on our website, you can fill out a new form to access, update or request deletion of your information, or email us at [email protected].

Your California Privacy Rights

California Civil Code Section § 1798.83 permits users of our Websites whom 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 e-mail to [email protected].

Future Business Transactions

As we continue to develop our business, we might undergo a change of ownership such as a merger and/or a sale of all or substantially all our stock or assets. In such transactions, user information, including customer data, generally is one of the transferred business assets. By submitting information on the Websites, Mobile Apps, through data import, or any other means, you acknowledge that such data may be transferred to such parties in these circumstances. However, any party purchasing our assets will be subject to an obligation to maintain the integrity of your information. You will be notified via email and/or a prominent notice on our website of any change in ownership or uses of user information, as well as any choices you may have regarding your information.

Changes to this Privacy Notice

We may update this privacy notice to reflect changes to our information practices. We encourage you to periodically review this page for the latest information on our privacy practices.

Contacting Us

If you have any questions about this privacy notice, please contact us at the following address:

Conect Inc., Inc.

Email: [email protected]

The data controller of your personal information is Conect Inc.

Effective Date

This privacy notice is effective as of November 8, 2018.