TITAN HEALTH & SECURITY TECHNOLOGIES, INC.
PRIVACY POLICY
EFFECTIVE DATE: March 2020
LAST REVIEW: June 2024
NEXT REVIEW: January 2025
APPROVED BY: Legal
At Titan Health & Security Technologies, Inc. (“Titan”) we respect and value your privacy. The purpose of this Privacy Policy is to provide you with information about how we may collect, use, or disclose your Personal Information. It also contains important information about your rights over your Personal Information.
Quick Reference Guide
1. Who This Privacy Policy Applies To
2. What Information Titan Collects and How it is Used
3. When We Disclose Your Personal Information
4. When We Collect Information On Minors
8. Disclaimer
10. Contact Us
1. Who This Privacy Policy Applies To
Titan provides emergency communication solutions to its customers, including public authorities, schools, and private companies (“Customers”). Our Customers leverage Titan’s Services to support their onsite security, emergency management, and disaster planning by enrolling their staff, students, personnel, and others in Titan’s Services (“End Users” or “you”). This is largely done through sending and receiving communications, pictures, video, or sound recordings about safety threats and emergencies (“Alerts”).
This Privacy Policy explains how Titan collects, uses, or discloses Customers’ and End Users’ Personal Information when they use Titan’s website, mobile app, beacon, SoS Button, Gateway or any of our services (our “Services”).
If you have questions or concerns regarding this Privacy Policy, please e- mail support@titanhst.com.
2. What Information Titan Collects and How it is Used
We collect information that identifies, describes, or is reasonably capable of being associated with you (“Personal Information”). Personal Information does not include publicly available information in government records or any data that has been deidentified, aggregated, or otherwise anonymized.
We have signed an agreement with each Customer (the “Customer Agreement”) that may define how this information may be used and we only will use information according to the terms set forth in the Customer Agreement. End Users should contact the Customer who manages their account for more information about the specific content and other information collected from them and how it may be used by us.
Listed below are details about how we treat the Personal Information we maintain based on the different ways we may interact with Customers, End Users (including Covered Entities and Individuals as defined by HIPAA).
Engaging Titan’s Services
We collect Personal Information about End Users from our Customers when Customers engage Titan’s Services. Customers must have first obtained End Users’ consent or have some other legal basis to provide us with End Users’ Personal Information. The information we collect about End Users from Customers includes:
· Basic personal identifiers, including first and last name, phone number, email address, and emergency contact information; or
· Professional, employment, or educational information, such as which Customer site the End User works at or the school they go to.
We use this information to provide our Services and ensure the right people receive the right Alerts by associating End Users with the Customers they work for or where they go to school.
We retain this information as long as the Customer’s or End User’s account is active. Once your account is closed, we promptly delete or anonymize this information unless we have a legal obligation to maintain it.
Registering an Account or Downloading the App
We may also collect Personal Information from End Users with their consent when they set up an account or download Titan’s app. If so, we may collect the following Personal Information:
· Username and password;
· Basic personal identifiers, including first and last name, phone number, email address, and emergency contact information;
· Professional, employment, or educational information, such as which Customer site the End User works at or the school they go to;
· Geolocation data, through Titan’s Beacons or SoS Buttons, if deployed, and through End Users’ devices if the End User shares their location or enables location settings on their phone.
We use this information to further customize our Services and ensure the right people receive the right Alerts.
We retain this information as long as the Customer’s or End User’s account is active. Once your account is closed, we promptly delete or anonymize this information unless we have a legal obligation to maintain it.
Sending and Receiving Emergency Alerts
We may collect Personal Information from Customers and End Users who choose to send or respond to Alerts, such as:
· Alert type;
· Audio, electronic, or visual information, such as the content of any sound recording, photograph, video, chat, or text communicating the details about the emergency;
· Basic personal identifiers, including first and last name, phone number, email address, emergency contact information, or address of the Customer or End User who sent the Alert;
· Geolocation data, through Titan’s Beacons or SoS Buttons, if deployed, and through Customers’ or End Users’ devices if they enable location settings are set on their phone.
We use this information to make our emergency communications platform effective by collecting important details about safety threats or other issues through Alerts. This is necessary to provide the Services that Customers and End Users have engaged Titan to perform. It may also be necessary to protect individuals’ vital interests in light of an emergency.
As a default, our Services are set to retain Alert data for 90 days after an Alert is generated. However, Customers may choose to reset this default setting and retain Alert data for a longer period. End Users should ask the Customer who manages their account for more information about how long their Alert data may be retained.
Contact Tracing
If Customers and End Users choose to use our contact-tracing features, we may collect the following Personal Information on behalf of our Customers:
· Username and password.
· Basic personal identifiers, including first and last name, phone number, email address, and emergency contact information.
· Professional, employment, or educational information, such as which Customer site the End User works at or the school they go to.
· On-premise geolocation data, while on our Customers’ property, End Users’ location may be tracked through Titan’s Beacons, if deployed, and through End Users’ mobile devices, if the End User shares their location or enables location settings on their phone.
· Medical information, including whether an End User has tested positive or has COVID-related symptoms.
· Inferences drawn from this data, including other individuals that End Users may have come into contact with and analytical data about on-premise hot spots.
We use this information to log when and where End Users may have come into contact with each other. If an End User reports he or she tested positive for COVID-19, Customers may analyze the information collected to determine whether any other End Users may have come into contact with that End User. Customer may then choose to provide exposure notifications.
We retain this information only for as long as necessary to provide contact tracing and exposure notifications, then we promptly delete or anonymize this information unless we have a legal obligation to maintain it.
COVID-19 Screening
We offer COVID-19 screening services that enable End Users to upload and share Personal Information with Customers, so that they can make determinations about access to facilities, areas, or venues. We collect the following Personal Information directly from you on behalf of our Customers, if you use our COVID-19-Related Services:
· Basic personal identifiers, including your first and last name, phone number, and email address.
· Medical information, such as your response to COVID-19 screening questions, results from a COVID-19 test, and information about your COVID-19 vaccine, if you upload a copy of your vaccine card.
We use this information to allow our Customers to screen their facilities, areas, or venues for COVID-19. We use the Personal Information provided to notify Customers about whether screening questionnaires are completed and if End Users have uploaded the requested materials. This is necessary to provide the Services that Customers and End Users have engaged Titan to perform.
We retain this information only for as long as necessary to facilitate COVID-19 screenings for the facility, area, or event. We will promptly delete or anonymize this information unless we have a legal obligation to maintain it.
Providing Technical Support
We provide support whenever Customers or End Users need help using our Services. When Customers or End Users reach out to us for support we collect:
· Basic personal identifiers, including first and last name, phone number, or email address;
· Professional, employment, or educational information, such as which Customer site the End User works at or the school they go to; and,
· Audio or electronic information such as a recording of the call or text or SMS messages.
We use this information to support and assist the Customer or End User.
We retain this information until the request for support has been resolved, then we promptly delete or anonymize this information unless we have a legal obligation to maintain it.
Improving User Experience
We collect information about how Customers and End Users interact with our Services including:
· Internet or network activity, such as cookie data, device identifiers, and IP address; and,
· User preferences, trends, and other inferences drawn from personal information.
We combine this information with anonymized and aggregate data to improve our Services and ensure they are reliable and effective.
We retain this information only for as long as necessary to observe a given feature or quality of our Services, then we promptly delete or anonymize this information unless we have a legal obligation to maintain it.
For more information about how we use cookies, please see our Cookie Policy.
3. When We Disclose Your Personal Information
We disclose your Personal Information only as permitted and in accordance with the terms of the Customer Agreement between us and the Customer who manages your account.
We use service providers so that our Services function properly. Service providers may maintain or have access to Customers’, End Users’, Providers’, and Patients’ Personal Information.
We may also need to share Personal Information with emergency response personnel or public authorities, such as medics or law enforcement, so that they may resolve an emergency Alert or other crisis.
Sometimes, it may also be necessary to disclose Personal Information to public authorities, courts, or litigants to comply with the law.
Additionally, Titan HST offers its Customers mobile alerts regarding emergency-related notifications to End Users who sign up through or become enrolled in Titan HST by SMS message. Any data obtained through text messaging will not be shared with any third parties, other than those necessary to perform the Services. For more information, please see Titan HST SMS Terms of Use.
4. When We Collect Information On Minors
In limited circumstances, Titan collects Personal Information from Customers about End Users who are ages 13-18. Under those circumstances, Customers are responsible for obtaining verified parental consent prior to disclosing such information to Titan. If we learn that a Customer has not obtained parental consent or parental consent is revoked, we will close the End User’s account and delete their information from our records.
Apart from this, our Services are intended for users who are 13 years or older and we do not otherwise knowingly collect Personal Information from minors who are under 13 years old. Users are required to acknowledge their age when creating an account on our Services. If we learn that we have collected the information of a child under 13, we will close the End User’s account and delete their information from our records.
If you are a parent or legal guardian and think your child has given us information and you did not provide consent, please call us at 1-844-368-4826 or email us at support@titanhst.com.
5. Control Your Account
End Users and Individuals can review, correct, update, remove, or change their Personal Information at any time by logging into their account and doing so. However, you cannot opt-out of providing certain Personal Information as our Services will not function properly without that data.
You can delete your entire account by logging out of the app and sending an account deletion request to privacy@titanhst.com. You should also contact the Customer responsible for your account (e.g. your school, your employer, the business where you used Titan, your Covered Entity) to ensure that the Customer or Covered Entity does not continue to use your information or unknowingly re-enroll you into Titan’s Services.
6. California Privacy Rights
California residents may have additional rights over their Personal Information.
The Right to Request More Information
You may have the right to request more information about how we treated your Personal Information in the past 12 months, including:
· The categories of Personal Information we collected about you;
· The categories of sources from which we collected that Personal Information;
· Our business or commercial purpose for collecting that Personal Information;
· The categories of third parties with whom we shared that Personal Information; and
· The specific pieces of Personal Information we collected about you.
The Right to Request Access
You also may have the right to request access to your Personal Information.
The Right to Request Deletion
Under certain conditions, you may have the right to request that we delete your Personal Information. However, we may decline to process this request if we believe we have an applicable exception under the law. Please note that simply logging out or uninstalling an app does not delete your account or the Personal Information we may have collected.
How to Exercise these Rights
To submit a request to exercise these rights you may contact us at:
· 1-844-368-4826
For all requests, please clearly state that the request is related to “Your California Privacy Rights” and provide your name, state, zip code and an e-mail address or phone number where you may be contacted.
If you make a request, we will acknowledge we have received it within ten days and we have forty-five days to respond to you.
Verification
Before we can respond to your request, we must verify your identity using Personal Information. If we are unable to verify your request we will contact you for more information. If we are unable to verify your identify after a good faith attempt, we may deny the request and, if so, will explain the basis for the denial.
Designating an Authorized Agent
You may designate someone to submit requests and act on your behalf (an “Authorized Agent”). To do so, you must provide us with written permission to allow your Authorized Agent to act on your behalf. If necessary, we may also require you to verify your identity before we disclose Personal Information to your Authorized Agent.
Do Not Track Requests
Some web browsers or smartphones have the ability to set “Do Not Track” requests to block user activity from being tracked across web pages or devices. Our website and app do not recognize “Do Not Track” signals.
Third-Party Marketing and Selling
We do not provide your information to third parties for their direct marketing purposes. We do not sell or intend to sell your Personal Information to third parties without providing you notice and an opportunity to opt out.
No Discrimination
We will not unlawfully discriminate against you for exercising any of these rights.
7. EU Privacy Rights
If you are located in the EU, you also have specific rights over your Personal Information.
The Right to Access
You have the right to request copies of your personal data. We may charge you a small fee for this service.
The Right to Rectification
You have the right to request that we correct any information you believe is inaccurate. You also have the right to request we complete information you believe is incomplete.
The Right to Erasure
Under certain conditions, you have the right to request that your personal data be erased.
The Right to Restrict Processing
Under certain conditions, you have the right to restrict the processing of your personal data.
The Right to Object to Processing
Under certain conditions, you have the right to object to the processing of your personal data.
The Right to Data Portability
Under certain conditions, you have the right to request we transfer the Personal Information that we have collected to another organization, or directly to you.
How to Exercise these Rights
To make a request to exercise any of these rights, please contact us at:
· 1-844-368-4826
· Titan HST, 500 Newport Center Dr. #950, Newport Beach, CA, 92660, USA
If you make a request, we have one month to respond to you. We may require you to verify your identity before we may respond to you.
Although we urge you to contact us to find a solution for every concern you may have, you always have the right to lodge a complaint with your competent data protection authority.
Transfers to Countries Outside the EU
Titan is based in California. This means that EU Customers must transfer End Users’ Personal Information to the United States for processing. The Commission has not determined the laws of the United States provide an adequate level of protection over personal data. However, we are committed by contract and in principle to upholding data privacy.
8. Disclaimer
Nothing in this Policy will restrict Titan’s ability to otherwise:
· Comply with the law;
· Comply with a civil, criminal, or regulatory inquiry, investigation, subpoena, or lawful court order;
· Cooperate with law enforcement agencies concerning conduct we reasonably and in good faith believe may violate the law; or
· Otherwise exercise or defend legal claims.
9. Changes To This Policy
This Privacy Policy is reviewed and updated annually to ensure it accurately captures our practices and procedures. The effective date of each version is identified above. If we make material changes to this Privacy Policy, we will use reasonable means to inform you and, where necessary, obtain your consent.
10. Contact Us
If you have questions or concerns regarding this Policy or the handling of your Personal Information, please contact us at 1-844-368-4826 or email us at support@titanhst.com.