Seniors in Transition::privacy-policy

Privacy Policy

In order to effectively use Seniors in Transition (S.I.T.), S.I.T. must collect some of your personal data. We understand that your data is private and that you are trusting us to use it in a safe and ethical manner. We are committed to that and want you to be aware of our privacy policy.

This policy describes the personal data we collect, how we use it, how it’s stored and your options regarding your personal data.

Last modified: February 19, 2020

Effective data: March 1, 2020

Overview
Scope

This policy applies to users of S.I.T.’s services anywhere in the United States, including users of S.I.T.’s app, features, or other services. This policy sets forth how S.I.T. and its affiliates collect and use your personal data and applies to all our apps, features, or other services. This policy specifically applies to:

Seniors/Riders: individuals who the services are for and whom transportation services have been received or requested by themselves or another individual
Family members: individuals who use the app and its features to secure transportation for their senior family member and/or use any of the other features
Drivers: individuals who provide transportation through partner transportation companies
Caregivers/Service Providers/Facilities: individuals or business that provide services to Senior and interact with Seniors and their family through the app
Delivery partners: individuals who provide delivery or other services

This policy also governs S.I.T.’s other collections of personal data in connection with S.I.T.’s services. For example, we may collect other personal data in connection with our mapping technology and features.

All those subject to this policy are referred to as “users” in this policy.

In addition, please not the following:

For riders without an Uber account: The personal data of riders who take trips arranged by the owners of an Uber account, such as when a rider takes a ride arranged by the owner of an Uber Health account (such as a hospital or healthcare provider), is processed in accordance with our contract with the owner of that account, and not as otherwise described in this notice. Such processing may include sharing of rider location data with the owner of that account. Please contact the owner of such account for more information.

Our data practices are subject to applicable laws in the places in which we operate. This means we engage in the practices described in this notice in a particular country or region only if permitted under the laws of those places.

Data controller and transfer

Seniors In Transition (S.I.T.) is the data controller for the personal data collected in connection with use of S.I.T.’s services. We process personal data inside and outside the United States. S.I.T. LLC is the data controller for the personal data collected in connection with use of S.I.T.’s services anywhere else. The personal data of users outside the United States is transferred on the basis of mechanism approved under applicable laws, such as the Standard Contractual Clauses. Questions, comments, and complaints about S.I.T.’s data practices can be submitted to this email address: seniorstransitioning@gmail.com.

Data collections and uses
The data we collect

S.I.T. collects:

Data provided by users to S.I.T., such as during account creation (e.g. name, telephone number, etc.)
Data created during use of our services, such as location, app usage, and device data
Data from other sources, such as S.I.T.’s partners and third-party APIs

The following data is collected by or on behalf of S.I.T.:

Data provided by users. This includes:

User profile: S.I.T. collects data when users create or update their accounts. This may include their name, email, phone number, address, payment or banking information (including related payment verification information), government identification documents, birthdate, etc.
Demographic data: We may collect demographic data about users, including through user surveys. We may even receive demographic data about users from third parties.
User content: We collect the information users submit when they contact S.I.T. customer support or otherwise contact S.I.T.

Data created during use of our services. This includes:

Location data: We collect precise or approximate location data from a user’s mobile device if enabled by the user to do so. S.I.T. collects this data when the S.I.T. app is running in the foreground. S.I.T. may also collect this data when the S.I.T. app is running in the background of the user’s mobile device. Users may use the app without enabling S.I.T. to collect location data from their mobile devices. However, this may affect some functionality available in the S.I.T. app. For example, a user who has not enabled location data collection will have to manually enter their addresses.
Transaction information: We collect transaction information related to the use of our services, including the type of services requested or provided, data and time the service was provided and payment method.
Usage data: S.I.T. collects data about how users interact with our services. This includes data such as access dates and times, app features or pages viewed, app crashes and other system activity and third-party sites or services used before interacting with our services.
Device data: We may collect data about the devices used to access our services, including the hardware models, device IP address, operating systems and versions, software, preferred languages, unique device identifiers, serial numbers, device motion data and mobile network data.
Communications data: We enable users to communicate with each other and S.I.T. through S.I.T.’s mobile app. We allow users to text or send files to service providers, family members, etc. To provide this service, S.I.T. receives some data regarding the texts, or other communications, including the date and time of the communications and the content of the communications. S.I.T. may also use this data for customer support services (including to resolve disputes between users), for safety and security purposes, to improve our services and for analytics.

Data from other sources. This includes:

User feedback, such as feedback or complaints.
S.I.T. account owners who request services for or on behalf of other users, or who enable such users to request or receive services through their accounts.
Users or others providing information in connection with claims or disputes.
Data and information from third-party service providers.
Partner transportation companies.
Marketing service providers.

S.I.T. may combine the data collected from these sources with other data in its possession.

How we use personal data

S.I.T. collects and uses data to enable reliable and convenient transportation, healthcare services, and other services. We also use the data we collect:

To enhance the safety and security of our users and services
For customer support
For research and development
To enable communications between users
To send marketing and non-marketing communications to users
In connection with legal proceedings

S.I.T. does not sell or share user personal data with third parties for their direct marketing, except with users’ consent.

S.I.T. uses the data it collects for purposes including:

Providing services and features. S.I.T. sues the data collected to provide, maintain, improve and personalize our services.

This includes using the data to:

Create and update users’ accounts.
Verify users, third-party service providers.
Enable transportation and other services.
Offer, process, or facilitate payments for our services.
Track and share the progress of rides and services.
Enable features that allow users to share information with other people such as when submitting a complaint about a driver or service provider, when users provide feedback, or share ETA and location with their contacts.
Enable features to personalize users’ SIT accounts, such as enabling quick access to previous destinations.
Enable Accessibility features that make it easier for users with disabilities to use our services, such as those that enable deaf or hard-of-hearing users to alert their service providers/transportation of their disabilities.
Perform internal operations necessary to provide our services, including to troubleshoot software bugs and operational problems; to conduct data analysis, testing, and research; and to monitor and analyze usage and activity trends.

Safety and security. We use personal data to help maintain the safety, security and integrity of our services and users. This includes:

Using device, location, profile, usage, and other data to prevent, detect, and combat fraud or unsafe activities.
Screening third-party service providers.

Customer support. S.I.T. uses the information we collect to provide customer support, including to:

Direct questions to the appropriate customer support person
Investigate and address user concerns
Monitor and improve our customer support responses and processes

Research and development. We may use the data we collect for testing, research, analysis, product development, and machine learning to improve the user experience. This helps S.I.T. to improve and enhance the safety and security of our services, improve our ability to prevent the use of our services for illegal or improper purposes and develop new features and products.

Enabling communications between users. A user may message or call a family member or service provider to confirm a pickup location, a service being provided or any other pertinent information.

Marketing. S.I.T. may use the data we collect to market our services to our users. This includes sending users communications about S.I.T. services, features and updates. We may also send communications to our users about products and services offered by S.I.T. partners. But we do not sell users’ personal data to, or share it with, such partners or others for purposes of their own direct marketing or advertising, except with users’ consent. We may also use the data we collect to personalize the marketing communications (including advertisements) that we send, including based on user location, past use of S.I.T.’s services, and user preferences and settings.

Non-marketing communications. S.I.T. may use the data we collect to generate and provide users with receipts, inform them of changes to our terms, services or policies; or send other communications that aren’t for the purpose of marketing the services or products of S.I.T. or its partners.

Legal proceedings and requirements. We may use the personal data we collect to investigate or address claims or disputes relating to use of S.I.T.’s services, or as otherwise allowed by applicable law, or as requested by regulators, government entities, and official inquiries.

Cookies and third-party technologies

S.I.T. and its partners use cookies and other identification technologies on our apps for the purposes described in this policy.

Cookies are small text files that are stored on browsers or devices by websites, apps, online media, and advertisements. S.I.T. uses cookies and similar technologies for purposes such as:

Authenticating users
Remembering user preferences and settings
Analyzing site traffic and trends, and generally understanding the online behaviors and interests of people who interact with our services

Dating sharing and disclosure

Some of S.I.T.’s products, service and features require that we share data with other users or at a user’s request. We may also share data with our affiliates, subsidiaries, and partners, for legal reasons or in connection with claims or disputes.

S.I.T. may share the data we collect:

With other users

This includes sharing:

User’s first name and pickup and/or drop-off locations with drivers and other service providers.
We may share driver’s information such as vehicle make, model, color, license plate and location.

At the user’s request

This includes sharing data with:

Other people at the user’s request. We share a user’s ETA and location with family members or service providers when requested by that user.

With SIT account owner

If a user requests transportation or a service using an account owned by another party, we may share their order or trip information, including real-time location data, with the owner of that account. This occurs, for example, when:

A rider/Senior takes a trip arranged by a friend or under a Family profile

With S.I.T. service providers

S.I.T. provides data to vendors, consultants, marketing partners, research firms, and other service providers. These include:

Transportation providers
Health services providers
Payment processors and facilitators
Cloud storage providers
Marketing partners and marketing platform providers
Data analytics providers
Research partners
Vendors that assist S.I.T. to enhance the safety and security of its apps
Consultants, lawyers, accountants, and other professional service providers

For legal reasons or in the event of a dispute

S.I.T. may share users’ personal data if we believe it’s required by applicable law, regulation, legal process or government request or where the disclosure is otherwise appropriate due to safety or similar concerns. This includes sharing personal data with law enforcement officials, public health officials, other government authorities or other third parties as necessary to enforce our Terms of Service or other policies; to protect S.I.T.’s rights or property or the rights, safety, or property of others; or in the event of a claim or dispute relating to the use of our services.

With consent

S.I.T. may share a user’s personal data other than as described in this policy if we notify the user and they consent to the sharing. S.I.T. retains user profile, transaction and other information for as long as a user maintains their account. Users may request deletion of their account at any time through the Settings > Privacy menus on the S.I.T. “Contact Us” page. Following the request, SIT deletes the data that it is not required to retain for purposes of regulatory, tax, insurance, litigation or other legal requirements. S.I.T. retains location, device and usage data for these purposes for a minimum of 7 years; while it retains such data, it may also use it for purposes of safety, security, fraud prevention and detection, and research and development. S.I.T. may also retain certain information if necessary for purposes of safety, security and fraud prevention.

Grounds for processing

We only collect and use personal data where we have lawful grounds to do so. These include processing user personal data to provide requested services and features, for purposes of S.I.T.’s legitimate interests or those of other parties, to fulfill our legal obligations, or based on consent.

S.I.T. collects and uses personal data only where we have one or more lawful grounds for doing so. Such grounds may vary depending on where our users are located, but generally include processing personal data:

To provide requested services and features

In order to provide our services, we must collect and use certain personal data. This includes:

User profile data, which we use to establish and maintain user accounts; verify user identity; communicate with users about their trips, services and accounts
Location data, which we use to track trips
Usage data, which is necessary to maintain, optimize and enhance S.I.T.’s services
Transaction information
Information relating to customer support

For purposes of the legitimate interests of S.I.T. or other parties

This includes using personal data to enhance and maintain our users’ safety and security. This also includes purposes such as combating fraud; improving our services, direct marketing, research and development and enforcing S.I.T.’s Terms of Service.

To fulfill S.I.T.’s legal obligations

With consent

S.I.T. may collect and use personal data based on the user’s consent, through things such as voluntary surveys. A user who has provided consent to a collection or use of their personal data can revoke it at any time. However, the user will not be able to use any service or feature that requires collection or use of that personal data.

Choice and transparency

S.I.T. enables users to access and control the data that S.I.T. collects, including through:

In-app settings
Device permissions
Marketing opt-outs

S.I.T. also enables users to request access to or copies of their data, changes or updates to their accounts, deletion of their account or that S.I.T. restricts its processing of user’s personal data.

Privacy settings

Settings menus in the S.I.T. app for riders give them the ability to set or update their location-sharing preferences and their preferences for receiving mobile notifications from S.I.T. Information about these settings, how to set or change these settings, and the effect of turning off these settings is described below.

Location data

S.I.T. uses user’s device location services to make it easier to get a ride or services whenever they need them. Location data helps improve our services, including pickups, service options and customer support. Users may enable or disallow S.I.T. to collect location data from their mobile devices through the Settings > Privacy menus in the S.I.T. app.

Emergency Data Sharing

Users who have enabled S.I.T. to collect location data from their mobile device may also enable the Emergency Data Sharing feature that shares data with emergency police, fire, and ambulance services. Such data includes approximate location at the time the emergency call was placed; the user’s name and phone number and pickup and drop-off locations. Users may enable or disable this feature through the Settings > Privacy menus or the Safety Center in the app.

Share Live Location

Users who have enabled S.I.T. to collect location data from their mobile device may also enable S.I.T. to share their location with their family and driver from the time the ride is requested to the start of the trip. Users may enable or disable this feature through the Settings > Privacy menus in the app.

Notifications: account and trip updates

S.I.T. provides users with trip and health services notifications and updates related to activity on their account. These notifications are a necessary part of using the app and cannot be disabled. However, users may choose the method by which they receive these notifications through the Settings > Privacy menus in the S.I.T. app.

Device permissions

Most mobile device platforms (iOS, Android, etc.) have defined certain types of device data that apps cannot access without the device owner’s permission, and these platforms have different methods for how the permission can be obtained. iOS devices notify users the first time the S.I.T. app requests permission to access certain types of data and gives users the option to grant or refuse permission. Android devices notify users of the permissions that the S.I.T. app seeks before their first use of the app, and use of the app constitutes a grant of such permission.

Marketing opt-outs

Users may opt out of receiving promotional messages from S.I.T. here. Users may also opt out of receiving emails and other messages from S.I.T. by following the unsubscribe instructions in those messages. We may still send users who have opted out non-promotional communications.

User data requests

S.I.T. provides users with a variety of ways to learn about, control, and submit questions and comments about S.I.T.’s handling of their data. To make a request, please go here.

Accessing data: Users can ask for an explanation of the data we collect from them and how we use it.
Receiving data: Users can ask for a copy of data that S.I.T. collects from them with their consent or as necessary to provide our services.
Changing or updating data: Users can edit the name, number, email address and payment method associated with their account through the Settings menu in S.I.T.’s app. They may also ask that S.I.T. change or update their data, including if they believe such data is inaccurate or incomplete.
Deleting data: Users may request deletion of their account at any time through the Settings > Privacy menus in the S.I.T. app.
Objections, restrictions and complaints: Users may request that we stop using all or some of their personal data, or that we limit our use of their data. S.I.T. may continue to process data after such objection or request to the extent required or permitted by law.

Updates to this policy

We may occasionally update this policy. Use of our services after an update constitutes consent to the updated notice to the extent permitted by law. If we make significant changes, we will notify users in advance of the changes through the S.I.T. apps or through other means, such as email. We encourage users to periodically review this notice for the latest information on our privacy practices.