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TITAN HEALTH & SECURITY TECHNOLOGIES, INC.

PRIVACY POLICY

Effective October 19, 2021

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
 
5.      Control Your Account
 
6.      California Privacy Rights
 
7.      EU Privacy Rights
 
8.      Disclaimer
 
9.      Changes to this Policy
 
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”). This is largely done through sending and receiving communications, pictures, video, or sound recordings about safety threats and emergencies (“Alerts”).

Titan also provides telemedicine communication solutions to various types of health care providers (“Providers”) who offer telehealth to their health care patients (“Patients”). Providers use Titan’s audio, video, and/or chat functions to communicate in real time with patients and deliver telemedicine services.  

This Privacy Policy explains how Titan collects, uses, or discloses Customers’, Providers’, End Users’, and Patients’ Personal Information when they use Titan’s websitemobile 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.

  1.    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.

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, Providers, and Patients.

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:

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:

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:

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.

Telemedicine

We collect Patient contact information from Providers when Providers engage Titan’s Services.  We then collect additional information from Patients who create accounts with us and participate in telemedicine encounters, such as:

Titan maintains audio, video, and chat logs created during telemedicine encounters. We encrypt all logs to protect you and your information. We retain telemedicine video logs and associated information as long as necessary to fulfill our contractual and regulatory obligations with your Provider. After the retention period, we promptly delete or anonymize this information unless we otherwise have a legal obligation to maintain it.

Titan provides the audio, video, and chat technology your Provider uses to connect with you for telemedicine services and may be considered a business associate to your health care provider, as that term is defined under the Health Insurance Portability and Accountability Act (“HIPAA”). However, Titan does not have access to your medical documentation, as we do not offer documentation services or otherwise connect to your electronic health record. Your provider is solely responsible for documenting your encounter in his or her electronic health record platform. If you have questions about your electronic health records or documentation, please contact your provider directly.

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: 

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: 

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:

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:

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.

  1.      When we Disclose your Personal Information

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.

  1.     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.

  1.     Control Your Account

End Users and Patients 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 Provider) to ensure that the Customer or Provider does not continue to use your information or unknowingly re-enroll you into Titan’s Services.

  1.     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 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:

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 not able 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.

Telemedicine Patients

To the extent you are a telemedicine patient and we received your information from your provider, you do not currently have rights under CCPA. Your provider may be required to provide you certain privacy rights under federal and state law. If you would like a copy of your privacy rights under federal and state law, please contact your provider directly. You may also contact us at support@titanhst.com with any questions. 

  1.     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:

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.

  1.     Disclaimer

Nothing in this Policy will restrict Titan’s ability to otherwise:

  1.     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.

  1.     Contact Us

If you have questions or concerns regarding this Policy or the handling of your Personal Information, please contact us at1-844-368-4826or email us at support@titanhst.com.