The Fine Print

This Privacy Notice describes the information collection, use, retention, and sharing practices of MyCareUpdate, LLC (“Carespondence”, “we”, “us”, “our”) when you interact with us through our website, www.carespondence.com (the “Website”), our application, Carespondence (the “App”), and when you interact with us offline, such as when you contact us via telephone or by other offline means (collectively, the “Services”).

As used in this Privacy Notice, “personal information” means information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular person.

PERSONAL INFORMATION WE COLLECT, WHY AND FOR HOW LONG

We collect personal information as you engage with our Services, including when you:

•  Contact us

When you contact us, we collect, from you,

your personal identifiers (name and email

address) and any additional information you

choose to include in your message. We use

this information to respond to your questions

or inquiries and to troubleshoot where

necessary.

•  Create a Caregiver account

When you create a caregiver account, we

collect, from you, your personal identifiers

(name, phone number, email address, and

address), visual information (your photo), and

selected password. If you are a professional

caregiver, we also collect your professional and

employment-related information (e.g.,

organization employed with name and any

certifications attained) and you can also log

your time spent caregiving. We use this

information to create and maintain your

account, communicate with you, and facilitate

your access to the Services. You can also

choose sign in with your Google or Apple

account. If you choose to sign in with your

Google or Apple account, we will receive data

about you from Google (your name, email

address, and profile picture) or Apple (name

and email address). Please see the following l

links for additional information on Sign in with

Google and Sign in with Apple.

•  Create a Care Recipient account

When a care recipient account is created, we

collect from the account creator, the care

recipient’s relationship to the care giver, the

care recipient’s personal identifiers (name,

phone number, and address), sensitive medical

information (e.g., known allergies and medical

conditions), and additional information you

choose to include in their profile. You can also

provide emergency contact information for the

care recipient that belongs to another

individual. Before providing the personal

information of any third parties, please ensure

you have their consent to provide their data. We

use this information to set up and populate the

care recipient’s profile, enable care providers to

understand a care recipient’s medical profile,

capture and display relevant medical

information for a care giver to provide the care

recipient with the necessary care, and provide

vital information in case of an emergency.

If a care recipient profile is created by an

individual other than the care recipient, we also

collect information from the caregiver

regarding the legal authority of the caregiver to

provide sensitive medical information about the

care recipient. This may include a request for

the care recipient to consent to the collection,

use, and disclosure of their personal and

medical information within the care recipient’s

profile or some other basis to act as the

caregiver’s legal representative to provide such

information. We use this information to ensure t

the caregiver has the lawful authority to provide

us with the care recipient’s information and to

ensure the care recipient’s privacy.

•  Enter data into the Care

Recipient’s profile

When entering information about the care

recipient, we collect sensitive medical

information (e.g., diagnosis, treatment, vitals,

toileting abilities, mobility capabilities, cognitive

status, bathing, eating habits, medications,

wound and skin care, or any other medical

information) about the care recipient provided

by the caregiver, audiovisual information about

the care recipient (photos and videos of the

care recipient uploaded by the caregiver), and

any other information input by the caregiver. We

use this information to maintain and update the

care recipient’s profile for the purpose of

providing the caregiver with the ability to track

and understand the care recipient’s wellbeing.

•  Submit payment

When you submit a payment for a subscription,

the payment processor collects your payment

card information (credit/debit card number,

expiration date, and CVV). The payment

processor then facilitates the payment to us. We

use this information to process your

subscription payment and to conduct financial

audits. Carespondence only has access to card

type and the last four digits of the card. For

transparency, the payment processor may share

information with third parties for fraud-related

purposes. The payment processor’s use and

retention of your personal information is subject

to their own privacy policies.

•  Opt in to receive SMS

communications

We collect mobile phone numbers to send

service-related SMS messages. By submitting

your mobile number specifically for SMS

messages, you agree to receive automated text

messages from Carespondence. Consent is not

a condition of purchase. You can opt out at any

time by replying STOP to any text message and

can reply HELP for help. Message and data

rates may apply. Message frequency varies. For

more information, please see our Terms and

Conditions. We do not share text messaging

originator opt-in data and consent information

with any third parties except service providers

that assist us in the delivery of text messages.

•  Sign up to receive a newsletter

When you sign up to receive a newsletter, we

collect, from you, your personal identifiers

(name and email address) and if you are a

caregiver, family member, care recipient, or

another role with interest in Carespondence. We

use this data to send you information about the

Carespondence app and its features. You may

revoke your consent to us sending you emails at

any time with effect moving forward by clicking

the “unsubscribe” link included within each

email we send to you. However, we will continue

to send you important service-related

messages. We, through our service provider,

use tracking pixels and web beacons to

determine whether you open emails, the time of

opening, information about the device you use

(including IP address), whether you interacted

with the email, the topic of the email, whether it

was delivered, sender and recipient addresses.

We use this information to:

(1)  measure the effectiveness of our

communications and make them more

attractive, particularly by improving email

subject lines;

(2)  limit the frequency of sending or stop it,

ensuring emails continue to reach their

recipients;

(3)  detect and analyze suspected fraud;

(4)  personalize communications based on

your interest in received emails and

interaction with them. This personalization

includes: adapting message content /

adjusting sending frequency or

communication channel / optimizing

campaigns based on reactions (e.g.,

adjusting email subject lines); and

(5)  offer tailored content or advertisements

on other websites, applications, or

communication channels.

You can avoid downloading the pixel by

rejecting the download of images in the

email.

•  Interact with us on social media

When you interact with our social media pages

on social networking websites, such as

Facebook, LinkedIn, Instagram, Reddit, and

YouTube (each a “Social Media Page” and

collectively, “Social Media Pages”), we collect

basic engagement metrics and use it to tailor

content and marketing and use it to improve

user experience as set forth in this section.

Please note that we do not control the use or

storage of the information that you have posted

to any social networking websites. This

information is collected and processed by the

social networking websites for their own

purposes, including marketing. For more

information on how Facebook, LinkedIn,

Instagram, Reddit, and YouTube use your

personal information, please see Facebook’s

Privacy Policy, LinkedIn’s Privacy Policy,

Instagram’s Privacy Policy, Reddit’s Privacy

Policy, and YouTube’s Privacy Policy.

•  Social Media Pages

When interacting with our Social

Media Pages, we collect, from you,

your personal identifiers (first and

last name) and visual information

(photograph, i.e., profile picture), as

well as any information that you

provide when interacting with our

Social Media Pages (e.g.,

commenting, sharing, and rating).

We use this information to advertise

our products, for events and

invitations, and to communicate with

users via the contribution and

comment function. Because our

Social Media Pages are publicly

accessible, when you use them to

interact with other users, for

example by posting, leaving

comments or liking or sharing posts,

any personal information that you

post in them or provide when

registering can be viewed by others

or used by them as they see fit. The

content posted on our Social Media

Pages or other public areas of social

networking websites can be deleted

in the same way as other content

that you have created. If at any time

you want content posted to be

deleted, please email your request

to us at hello@carespondence.com.

•  Community Management

We collect, from you, your contact,

including “likes”, shares, messages and

other interactions with the content, in order

to analyze and evaluate how our content is

perceived, to learn from it, and to improve

our public relations efforts.

•  Page Insights

When you visit our Social Media

Page, the applicable Social Network

records your IP address and other

information about your usage

behavior on our Social Media Page.

The Social Network collects this

information through trackers in the

browser of your device or via the

advertising ID (IDFA from Apple or

GAID from Google), when you open

the Social Network app through

your mobile device (e.g.,

smartphone or tablet). The Social

Network uses this information to

provide us with statistical

evaluations of the use of our Social

Media Page. We receive this

information directly from Social

Network, in the form of aggregated

data and anonymous statistics

regarding certain data points, such

as: age; gender; city/country;

device; inquiries from fans about

other Social Media Pages; region

and language settings of the users;

proportion of men and women; the

number of people reached; clicks on

posts, “likes” and reactions;

comments and shared content; and

total video views. We use this

information to analyze and improve

the advertising campaigns we

conduct through our Social Media

Pages. We do not collect or process

any other personal information in

connection with Social Network

“Page Insights” function.

We do not retain this information

independently. For information on

data protection and the storage

period on the Social Network in

relation to its Insights function, see

the Social Network privacy policy

linked above. It has been

contractually agreed with the Social

Network that the Social Network is

responsible for providing you with

information about the processing for

Page Insights.

•  Information Processed Solely

by Social Networks

We do not know how the Social Networks

use personal information for their own

purposes, how long the personal

information is stored on the Social

Networks or whether the Social Networks’

data is passed on to third parties. If you are

currently logged in to a Social Network as

a user, the Social Network automatically

collects, through trackers on your device,

your Social Network ID or a link between

the Social Network ID and the advertising

ID (IDFA from Apple or GAID from Google)

when you open the Social Network app

through your mobile device (e.g.,

smartphone or tablet). This enables the

Social Network to understand that you

have visited our Social Media Page along

with other social media pages that you

have clicked on, whether you clicked on

Social Network buttons integrated into

websites that partner with the Social

Network, and other online interactions that

report user data to the Social Network.

Based on this data, content or advertising

tailored to you can be offered. You can find

more information about the personal

information collected by Social Networks,

how it is used and how long it is stored by

visiting the Social Network’s privacy

policies, linked above.

•  Interact with the App and Website

In addition to the personal information you

provide directly to us, we also collect

information from you automatically as you use

our App and Website via marketing and

analytics technologies.

We use essential, functional, marketing, and

analytics technologies, including software

development kits (SDK) in our App and cookies

on our Website, to automatically collect certain

internet and other electronic network activity

information when you interact with the App and

Website. This includes things like Internet

Protocol address (e.g. IP address), location,

device type, browser type, browser version, the

App or Website pages and features that you

visit, the time and date of your visit, the time

spent on those pages, unique device identifiers,

and other diagnostic data. We use this

information to: (i) track you within the App and

Website to understand how you use them; (ii)

enhance the App and Website user experience

to improve their design; (iii) conduct analytics to

improve App and Website features; (iv) prevent

fraudulent use of the App and Website; (v)

diagnose and repair App errors, and, in cases of

abuse, track and mitigate the abuse; and (vi)

provide interest-based advertising to Website

users (i.e., targeted advertising).

Third party marketing and analytics within the

App and Website may be considered sharing

personal information. In your web browser, you

can generally disable website cookies by

setting your browser to refuse cookies or

indicate when a cookie is being sent. Please

note, if you opt out of these targeted advertising

cookies, your opt-out will be specific to the web

browser, app, or device from which you

accessed the opt-out and you would need to

opt out separately on other devices and

browsers.

Third Party analytics in our App include:

•  Firebase Crashlytics

We use the Firebase Crashlytics, a

software development kit that uses

technology to track user activity and

collect information from your device. The

Firebase Crashlytics SDK collects crash

report information, including log data, user

interactions occurring immediately before

a crash occurs, crash counts, and user IDs.

This information is disclosed to and

processed by Google, a third-party

provider, to enable crash reporting and

crash management services, as well as to

assist our developers in analyzing and

preventing subsequent crashes from

occurring in the future. Please review

Firebase’s Privacy and Security Terms for

additional information on how Firebase

uses the information collected.

Third Party analytics on our Website include:

•  Google Analytics

We use Google Analytics to collect

information on your use of the Website for

its improvement. To collect this

information, Google Analytics installs

cookies on your browser or reads cookies

that are already there. Google Analytics

also receives information about you from

applications you have downloaded or

services that you use that partner with

Google. Google’s ability to use and share

information collected by Google Analytics

about your visits to our Website or to

another application which partners with

Google is restricted by the Google

Analytics Terms of Use and Privacy Policy.

To prevent your data from being used by

Google Analytics, you can download the

Google Analytics opt-out browser add-on.

You can also adjust your Ad Settings or

change settings in your Google My Activity

if you are signed into your Google Account.

•  Aggregate and anonymize data

We may deidentify and/or aggregate the data

we collect and use and share it, in deidentified

and/or aggregated form, for benchmarking

purposes, advertising, and internal analytics. We

maintain and use this data in deidentified form.

We will not attempt to reidentify the data unless

it is necessary to determine whether our

deidentification processes satisfy applicable

data protection laws.

Carespondence will also use the personal information we collect as described in this section to comply with the law, to efficiently maintain our business, and for other limited circumstances as described in HOW WE SHARE YOUR PERSONAL INFORMATION.

DATA RETENTION

Unless otherwise stated in this Privacy Notice, we retain your personal information (i) for as long as you maintain an account with us, (ii) until we receive a valid request to delete the information, in which case we will delete or anonymize the information, (iii) until we no longer need the information to fulfill the purposes for which we collected it, or (iv) until the information is no longer needed for a service provider or contractor’s operational purpose(s).

We use the following criteria to determine whether it remains reasonably necessary to retain your personal information for such purposes or a service provider or contractor’s operational purpose(s): (i) whether there is a retention period required by statute or regulations; (ii) the existence of actual or threatened litigation for which we are required to preserve the information; (iii) the statutes of limitations for potential legal claims; and (iv) generally accepted best practices in our industry, including in relation to the safety and security of our properties and assets. When we determine that it is no longer reasonably necessary to retain your personal information for one or more disclosed operational purposes based on the above criteria, we will delete or anonymize your personal information.

HOW WE SHARE YOUR PERSONAL INFORMATION

Carespondence shares personal information as described in the PERSONAL INFORMATION WE COLLECT, WHY AND FOR HOW LONG section, and generally in the following instances:

•  Within Carespondence

We share your personal information within

Carespondence for the legitimate business

purposes of efficiently and effectively providing

the Services, such as accounting and customer

service support. Access to your personal

information is limited to those on a need-to-

know basis.

•  In the event of a corporate

reorganization

In the event that we enter into, or intend to enter

into, a transaction that alters the structure of our

business, such as a reorganization, merger,

acquisition, sale, joint venture, assignment,

consolidation, transfer, change of control, or

other disposition of all or any portion of our

business, assets or stock, including without

limitation bankruptcy or liquidation, we would

share personal information with third parties,

including the buyer or target (and their agents

and advisors) for the purpose of facilitating and

completing the transaction.

•  For legal purposes

We share personal information where we are

legally required to do so, such as in response to

court orders, subpoenas,

governmental/regulatory bodies, law

enforcement or legal process, including for

national security purposes. We may share your

information with our legal advisors or auditors to

establish, protect, or exercise our legal rights or

as required to enforce our terms of service or

other contracts or to defend against legal

claims or demands. We also share this

information with third parties as necessary to:

detect, investigate, prevent, or take action

against illegal activities, fraud, or situations

involving potential threats to the rights, property,

or personal safety of any person; to comply with

the requirements of any applicable law; or to

comply with our legal obligations.

•  With your consent

Apart from the reasons identified above, we may

request your permission to share your personal

information for a specific purpose. We will notify

you and request consent/authorization before

you provide the personal information or before

the personal information you have already

provided is shared for such purpose. You may

revoke your consent/authorization at any time

with effect moving forward and may do so by

contacting us via email at

hello@carespondence.com.

•  With additional caregivers

Within the App, a care recipient’s profile can be

shared with additional caregivers. Caregivers

must be registered with the App to see a care

recipient’s information. Care recipients, or their

legal representative, must authorize the

disclosure to share the care recipient’s

information with additional individuals. Sharing

with additional caregivers beyond the primary

caregiver is limited to one year from the date of

the authorized disclosure. The care recipient, or

their legal representative, may re-authorize

sharing with non-primary caregivers after one

year.

•  For a business purpose

We have disclosed your personal information to

service providers that assist us in providing the

Services, including our App. These service

providers assist us with the following:

information technology (“IT”) support; website

hosting; application development; cloud

storage; data analysis; customer service; email

delivery; push notifications; marketing; external

auditors; payment processing; distribution; and

similar services. We have disclosed your internet

or other electronic network activity information

collected by analytics in the App or Website

cookies to our IT support to detect security

incidents, protect against malicious, deceptive,

fraudulent, or illegal activity, and to identify and

repair the Services and platform errors. We have

disclosed your internet or other electronic

network activity information collected by

cookies to our IT support to update, improve,

and maintain the Website.

All of the above categories exclude text messaging originator opt-in data and consent. We will not share this information with any third parties except for service providers that assist us in the delivery of text messages.

YOUR INFORMATION CHOICES

You have the following choices with respect to your personal information:

•  Correct or View Your Information

You may access your account to correct or view

certain personal information you have provided

to us, and which is associated with your account.

•  Opt Out of Google Analytics

To prevent your personal information from being

used by Google Analytics, you can download

the Google Analytics opt-out browser, which

can be accessed here.

•  Opt Out of Advertising Cookies

All session cookies are temporary and expire

after you close your web browser. Persistent

cookies can be removed by following your web

browser’s directions. To find out how to see what

cookies have been set on your computer or

device, and how to reject and delete the

cookies, please visit:

https://www.aboutcookies.org/. Please note

that each web browser is different. To find

information relating to your browser, visit the

browser developer’s website and mobile

application. If you reset your web browser to

refuse all cookies or to indicate when a cookie is

being sent, some features of our website may

not function properly. If you choose to opt out,

we will place an “opt-out cookie” on your device.

The “opt-out cookie” is browser specific and

device specific and only lasts until cookies are

cleared from your browser or device. The opt-

out cookie will not work for essential cookies. If

the cookie is removed or deleted, if you

upgrade your browser or if you visit us from a

different computer, you will need to return and

update your preferences. By clicking on the

“Opt-Out” links below, you will be directed to the

respective third-party website where your

computer will be scanned to determine who

maintains cookies on you. At that time, you can

either choose to opt out of all targeted

advertising or you can choose to opt out of

targeted advertising by selecting individual

companies who maintain a cookie on your

machine. Our use of third-party marketing and

analytics cookies is considered a sale/sharing

under certain state privacy laws and is also

considered to be what is known as interest-

based advertising (IBA). To opt out of the

sale/sharing through cookies and IBA across

various platforms, please visit the Digital

Advertising Alliance’s YourAdChoices program

tools (Your Ad Choices) or visit one of the links

below.

•  Network Advertising Initiative (NAI) Opt-Out: https://www.networkadvertising.org/managing/opt_out.asp

•  Digital Advertising Alliance (DAA) Opt-Out:

https://optout.aboutads.info

•  European Union (EU) / European Economic

Area (EEA) Opt-Out:

http://www.youronlinechoices.eu

•  In general, you can also disable cookies by

setting your browser to refuse cookies or

indicate when a cookie is being sent.

•  Opt Out of Email Tracking

You can disable this tracking by blocking

automatic loading of images in your email.

•  Opt Out of Marketing

Communications

You may opt out of receiving marketing emails

from us by clicking the “unsubscribe” link

provided at the bottom of each email we send.

Please note that we will continue to send you

notifications necessary to the services.

NEVADA RESIDENTS

If you are a consumer in the State of Nevada, you may request to opt-out of the current or future sale of your personal information. We do not currently sell any of your personal information under Nevada law, nor do we plan to do so in the future. However, you can submit a request to opt-out of future sales by contacting us at hello@carespondence.com regarding the sale of such information. Please include “Opt-Out Request Under Nevada Law” in the subject line of your message.

DO NOT TRACK

We do not respond to Do Not Track requests. Do Not Track is a preference you can set in your web browser to inform websites and mobile applications that you do not want to be tracked. You can enable or disable Do Not Track by visiting the Preferences or Settings page of your web browser.

INFORMATION SECURITY

We implement appropriate technical and organizational security measures, such as access controls and encryption, to protect the personal information that we collect and maintain from unauthorized access, destruction, use, modification, or disclosure. However, no security measure or modality of data transmission is 100% secure, and we are unable to guarantee the absolute security of the personal information we have collected from you.

CHILDREN’S PRIVACY

The Services are not intended for anyone under the age of eighteen (18). We do not knowingly collect the personal information of anyone under the age of eighteen (18). If we learn that we have collected or received personal information from individuals under the age of eighteen (18), we will delete the personal information. If you believe we have personal information on individuals under the age of eighteen (18), please contact us at the contact information provided below.

CHANGES TO THIS PRIVACY NOTICE

We may amend this Privacy Notice in our sole discretion at any time. If we do, we will post the changes to this page and will indicate the date the changes go into effect. We encourage you to review our Privacy Notice to stay informed. If we make changes that materially affect your privacy rights, we will notify you by prominent posting on the Website and/or via email, and obtain your consent, if required.

CONTACT US

If you have any questions about this Privacy Notice or need to access this Privacy Notice in an alternative format due to having a disability, please contact us by email at hello@carespondence.com (and use “Privacy Inquiry” in the subject line) or calling or texting us toll-free at 1-844-253-3722.