Presage Technologies, Inc.

PRIVACY POLICY

We respect your privacy.

This privacy policy (this "Privacy Policy") explains what information Presage ("the Company" "we" or "us") collects from you when you use our software development kit (SDK) (the "SDK") or interact with our third-party partners ("Partners"), as applicable. By using our SDK, you agree to all the terms and conditions stated in this Privacy Policy. You are responsible for ensuring this privacy policy is available within your application that utilizes our SDK and that you obtain appropriate consent from your users. You assert that you are of legal age to accept the terms and conditions of this agreement. You may not utilize this SDK if you are under the age of 18 years or older. 

Please take a moment to review this information. 

  1. HOW WE PROTECT YOUR INFORMATION

We take reasonable measures to protect your personally identifiable information ("Personal Information") to prevent against unauthorized use, access, disclosure, and destruction. Your name and email address, along with other information that can be used to identify you, constitute your Personal Information. Please be aware that, despite our best efforts, security measures are not impenetrable, and we can't guarantee against misuse. 

  1. WHAT INFORMATION WE COLLECT

Contact Information

If you choose to contact us via email at support@presagetech.com or physical mail 13755 Sunrise Valley Dr, STE 450, Herndon, VA 20171, we'll collect the contact information you provide, such as your name and email address, postal address, or phone number so we can communicate with you. If you write a message, we will store the message so we can reference it to tailor our responses to you. 

Account, Health, Biometric and Geolocation Information

We collect additional Personal Information that you voluntarily submit to us through the SDK for other purposes, including information needed to open an account if you choose to do so. This information may include username and password as well as name, email address, date of birth, telephone number, and home address. 

When you open an account and use our SDK, we also collect or monitor information you submit to us or allow us to collect or monitor through video or other electronic means. This information includes authorization forms you sign; answers to health screening questions; your vital signs; health symptoms you may be experiencing; and biometric information.  We may also access or collect information on your personal device maintained or collected by you from other sources, such as a photograph of you that we might access, with your permission. We also collect or use background health information and demographics data. We do not collect Geolocational data at this time but may add collection in the future. Should we decide to do so, you will be prompted to agree to share location access with our SDK. By doing so you agree we have the right to use and share your location information in accordance with the rest of this Privacy Policy and our Terms of Service.

SDK User Data

Directly or through the use of third-party data analytics services (including Google Analytics), we collect visitor information, including your IP address and server log data (the address of the web page you visited before using the SDK, your browser type and settings, the date and time of your use of the SDK, language preferences). We may gather your information about the device you are using to access our SDK, including what type of device it is, what operating system you are using, device settings, application IDs, location, unique device identifiers, and crash data. Other data is collected, including data generated by your use of the SDK and links you interact with. Further information on how Google uses data collected by Google Analytics can be found at https://support.google.com/analytics/answer/6004245?hl=en . Information about how to opt out of Google Analytics can be found at https://tools.google.com/dlpage/gaoptout/

  1. HOW WE USE YOUR INFORMATION 
  1. HOW WE SHARE YOUR INFORMATION 

We do not knowingly sell, trade or otherwise share your Personal Information with any third parties without your consent except as disclosed in this Privacy Policy, as required by law, and when we reasonably believe it is necessary to prevent or take action regarding illegal activities, suspected fraud, or to protect the safety of any person.

We may share Personal Information in collaboration with our Partners, including companies that assist with business analytics, data processing, customer and user management, and other services. We instruct these parties to use your Personal Information only to the extent necessary to provide the services we have requested. Although we take reasonable steps to ensure that Partners receiving your information are bound by privacy restrictions as restrictive as those set forth in this Privacy Policy, we are not responsible for any issues that may arise regarding the privacy policies or practices of any of Partners. By using the SDK, you agree that we are not responsible or liable for any claims and/or damages that may arise from the actions of any of our Partners. 

With your permission, we share your Personal Information with the Apps that integrate our SDK, which you have downloaded and you agree to be enrolled in. We do not direct or control how those organizations use or disclose the Personal Information they receive from us, and we are not responsible in any way for their privacy and security practices.

  1. SOCIAL MEDIA

If you click on our social media links (such as Twitter, YouTube, and LinkedIn), you will be directed to a third-party platform, and any information you share on those SDKs will be covered by their privacy policies, not this Privacy Policy.   

  1. COOKIES AND OTHER TECHNOLOGIES

What are cookies?

A cookie is a small file that can be placed on your computer's hard disk or on an App server. Cookies do not retrieve information stored on your hard drive and do not corrupt or damage your computer or computer files. For those using our SDK, we may link cookie information to your email address to maintain and recall your preferences within the SDK.   

Why we use cookies

We may use cookies and similar tracking technologies to improve or administer the SDK, analyze trends, track users' movements around the SDK, support security features on the SDK, and to gather demographic information about our user base. 

How to manage cookie preferences

Depending on their purpose, some cookies will only operate for the length of a single browsing session, while others have a longer life span to ensure that they fulfill their longer-term purposes. Your web browser can be set to allow you to control whether you will accept cookies or reject cookies, to notify you each time a cookie is sent to your browser, or to delete cookies that have already been set. If your browser is set to reject cookies, certain aspects of the SDK that are cookie-enabled will not recognize you when you return to the SDK, and some SDK functionality may be lost. The "Help" section of your browser may tell you how to prevent your browser from accepting cookies. To find out more about cookies you may visit http://www.aboutcookies.org

  1. OPT-IN /OPT-OUT OF COMMUNICATIONS

By using our SDK, you expressly allow us to contact you and use your information as set forth in this Privacy Policy. You may opt-out of receiving marketing emails anytime by clicking the "unsubscribe" button in the email that contains the marketing communication.  

  1. LINKS

This App may contain links to other third-party apps. Please be aware that we are not responsible for the privacy practices of third parties and their other apps. This Privacy Policy applies only to the information we collect on this App. We encourage you to read the privacy policies of other apps you link to from our App or otherwise visit.

  1. YOUR CHOICE TO ACCESS, EDIT, OR DELETE INFORMATION

We strive to provide you with choices regarding your Personal Information. You have the right to access and change your Personal Information. Please contact us as noted at the bottom of this Privacy Policy to find out how. We will, upon receiving your request, make reasonable efforts to correct, delete, and/or block your Personal Information from further use to the extent it remains in our possession, except to the extent not permitted by law.

  1. MINORS

Our App is not directed at nor intended for use by individuals under 13 unless a parent or guardian has consented on behalf of the minor. If you learn that a child under 13 has provided us with Personal Information without parental or guardian consent, please contact us at support@presagetech.com. If we become aware that a child under 13 has provided us with his or her Personal Information without proper consent, we will promptly delete such data.

  1. BUSINESS TRANSITIONS 

In the event we go through a business transition, including without limitation any merger, acquisition, partnership, business reorganization, debt finance, or sale of association assets, or in the event of an insolvency, bankruptcy, or receivership (together a "Business Transition"), we may use information collected in accordance with this Privacy Policy and subject to its restrictions, as part of any such Business Transition. In such instances, your information can be part of the assets transferred. 

  1. DO-NOT-TRACK

You may have implemented a "do-not-track" signal through your browser. As there currently is no fixed standard for do-not-track signals, we currently do not respond to do-not-track signals from your web browser.

  1. DATA RETENTION AND DESTRUCTION 

We will retain Personal Information for as long as necessary to accomplish our purposes for such data as set forth in this Privacy Policy. Biometric information, vital signs,  and health symptoms you may be experiencing data is used for ongoing research to improve the SDK. Geolocation tracking data will be deleted on a rolling, 30-day basis. You can request that your information be deleted by emailing us at  support@presagetech.com. If you do not have your own API key, you must submit your request via the App that is utilizing our SDK, as we will need information from that organization to locate your data for deletion. At the time your information is deleted, we will destroy your Personal Information using reasonable data destruction practices. We may, however, retain certain information to comply with legal or contract obligations or to facilitate law enforcement requests.    

  1. CALIFORNIA PRIVACY RIGHTS

We do not share information for marketing purposes and therefore do not process requests under the California Privacy Rights Notice. Please contact support@presagetech.com with any specific inquiries.

  1.  HIPAA

The Health Insurance and Portability Act of 1998 (HIPAA)  and its associated regulations may apply if we collect, use or disclose your health information through the SDK, or access your health information through the SDK, in our capacity as a HIPAA business associate of a HIPAA covered entity. If HIPAA applies to us, we will comply with our HIPAA business associate obligations when using and disclosing your health information. 

  1. CHANGES

We may revise this Privacy Policy from time to time. If we decide to change our Privacy Policy, we will post the revised policy here. If changes are significant and materially affect your rights under this Privacy Policy, we may provide a more prominent notice on the SDK. In certain cases, we may also provide email notification of the revised Privacy Policy and either seek your consent or give you the right to opt out from our use of your Personal Information in accordance with the revised Privacy Policy. However, because we may make changes without directly notifying you, we suggest that you periodically consult this Privacy Policy. Please note that our rights to use any information collected will be based on the privacy policy in effect at the time the information is used.

  1. CONTACT US

If you have any questions about the Privacy Policy, please contact us at support@presagetech.com or at the mailing address below:

Presage Security

13755 Sunrise Valley Dr

Suite 450

Herndon, VA 20171

This Privacy Policy was last updated: February 2, 2024.

SUPPLEMENT TO PRIVACY POLICY: RIGHTS OF CALIFORNIA RESIDENTS

This Supplement to our Privacy Policy (the "Supplement") is part of our Privacy Policy and is directed to you if you are a California resident and therefore have certain rights under the California Consumer Protection Act of 2018 ("CCPA").  The Supplement applies to personal information we collect when we operate as a "business" as defined under the CCPA.   This Supplement describes what those rights are and how you may exercise them when we act as a business.  If there is any term in this Supplement that conflicts with a term in our Privacy Policy, the term in this Supplement shall control. 

When we operate as a "service provider" (as defined under the CCPA) for our customers and they provide us with your personal information for business purposes under a service contract, the CCPA applies primarily to those customers, not to us.  In such cases, we will direct any requests you send us to exercise your rights under the CCPA to the applicable customer.  

  1. INFORMATION WE COLLECT AS A BUSINESS 

We collect the following categories of personal information as defined under the CCPA:

Type of information Examples Collected by Us
Identifiers Name, postal address, e-mail address, IP address, phone number and similar identifiers.  See Section 2 of the Privacy Policy for details. Yes; API Sign-up only
Information specified in California Consumer Records statute Name, signature, postal address, telephone number, employment.  See Sections Section 2 of the Privacy Policy for details. Yes
Protected classifications under California or federal law Age, race, national origin, citizenship, religion or creed, marital status, gender, sexual orientation, health status Yes
Commercial information Records of personal property, products, services purchased or purchasing histories No
Biometric information Genetic, physical, behavioral or biological characteristics, such as fingerprints, iris scans, voiceprints, health/exercise or sleep data Yes
Internet and similar network activity Browsing history, App analytics, app interactions.  See Sections 2 and 6 of this Policy for details. Yes
Geolocation data Physical locations and/or movements No
Sensory data Audio, visual, or similar data related to physical characteristics Yes
Professional or employment-related information Current employment or job history No
Non-public educational information Educational records under federal law No
Inferences drawn from other personal information Profiling of preferences, personal characteristics, behavior, attitudes or aptitudes No

Personal information does not include: (i) information publicly available from government records, (ii) de-identified or aggregated information, or (iii) information addressed by certain state and federal data privacy laws (e.g., personal health information subject to federal health privacy law).

  1. CATEGORIES OF SOURCES OF INFORMATION WE COLLECT

We obtain the categories of information described in this Supplement from the same categories of sources as described in Section 2 of our Privacy Policy. 

  1. PURPOSE OF OUR USE OF PERSONAL INFORMATION

We use the personal information we collect, as described in this Supplement, for the same purposes identified in Sections 2, 3, 6 and 11 of our Privacy Policy.

  1. OUR DISCLOSURE OF PERSONAL INFORMATION

We may disclose the personal information we collect, as described in this Supplement, for any of the same purposes and to the same categories of persons and entities as identified in Sections 2, 4, 6 and 11 of our Privacy Policy.

  1. YOUR RIGHTS REGARDING YOUR PERSONAL INFORMATION

The CCPA gives certain rights to California residents regarding their personal information.  We summarize below what those rights are and how you may exercise them.  You do not need to have an account with us to exercise these rights.

The CCPA also gives California residents the right to opt out of (or for minors under 16, the ability to opt in to) sales of their personal information.  However, we do not and will not sell your personal information.  If, in the future, we decide to sell personal information, we will provide you with notice and the right to opt-out of (or for minors, opt-in to) such sales.

Please note that we may deny your deletion request if your personal information based on certain provisions of the CCPA, including where it is necessary for us or our service providers to carry out certain business functions, comply with laws or to engage in other internal and lawful uses of the information within the context in which you provided it to us.

Please also note if you do not have your own API and are utilizing the SDK via another App, you will need to request your data be deleted via the App you are using that is hosting the SDK because we will need to collaborate with the App to locate and delete your data.

  1. MAKING A VERIFIED CONSUMER REQUEST TO US

To make a request to exercise your rights under CCPA described above, please submit a verifiable request to us by either:

A verifiable consumer request must be made by you or a person registered with the California Secretary of State whom you have authorized to make the request on your behalf.  (A representative must be authorized by you in writing or have a valid power of attorney under California probate law.)  You may also make a verifiable request to us on behalf of your minor child.  

To be considered a proper verified request, your request must: 

(1) provide us with sufficient information allowing us to reasonably verify that you are the same person about whom we collected the personal information or the authorized representative, and 

(2) describe your request in reasonable detail so we can correctly understand, evaluate and respond to the request.  

We may ask you for additional information if needed in order to verify your request, but if we do, we will use such additional information only to verify your identity (or the authority of the representative) and for security and fraud-prevention purposes.

We will also ask you to separately confirm, by e-mail or 1-800-829-4493, any request to delete personal information.

  1. RESPONDING TO YOUR VERIFIABLE CONSUMER REQUEST

We will use reasonable efforts to respond to your verifiable consumer request within 45 days of receiving it. In some cases, we may require more time (up to 90 days). If that is the case, we will communicate to you in writing (by postal mail or electronically, at your option) the reason and the length of anticipated delay.  We will not be able to fulfill your request if we cannot verify your identity (or the authority of your representative) and confirm that the personal information subject to the request relates to you.  

Disclosures we provide in response to a verified consumer request will cover only the 12-month period before we received the request.    If we deny part or all of a verified consumer request, we will provide a reasonable explanation for the denial.

We do not charge fees for responding to verifiable consumer requests unless they are excessive, repetitive or manifestly unfounded.  If we determine that a fee is appropriate, we will provide you with an explanation and a cost estimate before we complete your request.

We will keep records of consumer requests and our responses as required under the CCPA.

  1. NON-DISCRIMINATION

We will not discriminate against you for exercising any of your rights under the CCPA.  This means that, except where permitted under the CCPA, if you make a request for disclosure or to delete your personal information, we will not (i) deny you goods or services, (ii) charge you different prices for goods or services (e.g., through penalties or withholding of otherwise available discounts), (iii) giving you a different level of goods or services,  or (iv) suggesting to you that we will take any of the actions in (i) through (iii).

  1.  HIPAA

This Supplement does not apply to your health information if it is collected, used or disclosed in our capacity as a business associate under the Health Insurance and Portability Act of 1998 (HIPAA) and its associated regulations. 

  1. HOW TO CONTACT US TO EXERCISE YOUR CALIFORNIA RIGHTS 

If you have questions about our Privacy Policy or this Supplement, please feel free to contact us by either:

This Supplement was last updated on February 2, 2024.