Mobile App Privacy Policy

Every Two Minutes Inc. (collectively with its subsidiaries, “Every Two Minutes,” “the Company,” “we,” “us,” and “our,”) respects your privacy and is committed to protecting your privacy through our compliance with this mobile application privacy policy (the “Policy”).  This Policy should be read in conjunction with our Mobile Application Terms of Use, into which this Policy is incorporated by reference. 

Every Two Minutes understands and appreciates the importance privacy plays in offering its services and supporting its customers and users.  Your privacy is very important to us, so it is important that you understand how the App works and how you are empowered to protect your personal information.  

This Policy describes:

• The types of information we collect from you or that you may provide when you use the Every Two Minutes Mobile App, “MySideKick” (“the App”); and 
• Our practices for collecting, using, maintaining, protecting, and disclosing that information. 

Please read this Policy carefully to understand our practices regarding your information and how we will treat it.  If you do not agree with our policies and practices, then please do not use the App.  By using the App, you agree to the terms of this Policy.  This Policy may change from time to time (see below, “Changes to this Policy”). 

What We Collect and How We Collect It

To ensure that we provide you with the best possible experience, we will store, use, and share information about you in accordance with this Policy.  

Information You Provide to Us

You can have provided information to us in your capacity as a student or an employee of a school or Greek organization.  Personal Information is any information that can be used to individually identify you from a larger group, such as data including, but not limited to, your:

• first and last name
• mailing or campus address
• email address
• telephone number
• a photo of you (optional)
• date of birth
• your location
• comments, messages, or answers in any communications with us or other My SideKick users

You may also provide us the following information about you as part of your profile.

• school ID
• school major
• gender
• hair color
• eye color
• school affiliations
• sexual orientation
• location information

You may provide us Personal Information when you:  

• register to use the App
• create your profile
• upload pictures
• share My SideKick with others

The information that you provide in each case will vary. For example, we may ask you for your email in order to authenticate you to the App and create your account.  Or, the App may access your mobile device camera, if you opt to take a picture of yourself for your profile. 

Health Information.  The App will present helpful information related to health and medical conditions. You may also locate or contact medical professionals, and you may share such health information through the App.  However, it is important that you understand that such Personal Information is not considered “Protected Health Information” under the Health Insurance Portability and Accountability Act (“HIPAA”).  While such information is Personal Information and will be managed in accordance with the Policy, it is not protected under HIPAA.

Application Activity and Use.  For purposes of this App, any activity in the App attributable to you as an individual is also considered Personal Information and will only be used and disclosed by the Company in accordance with this Policy.  For example, if you make the choice to report an assault or other incident, we do not record that you, as an individual chose to report that assault.  

Automated Information Collection

In addition to the information that you provide to us, we may also collect information about you during your use of the App.  We collect this information using automated technology.  This technology may collect information about your behavior and your device, such as your internet address (IP Address), location, the screens you have viewed, and the actions you have taken while using the App. For example, before the App collects your location information, whether you are actively using the App or not, the App will request your permission to collect location information. This information is not personally identifiable or capable of being used to identify you in the scope of this Policy.  

What we DO NOT do with your Personal Information

• We will not disclose your Personal Information to law enforcement, unless required to do so under a subpoena or warrant, or you otherwise consent.  While the App does allow you to report information to law enforcement or campus police, the App does not disclose your Personal Information collected from the App unless you provide it.

• We will not disclose your Personal Information to your sponsoring school, your employer, your parents, or legal guardian without your consent.

• We will not disclose your Personal Information to any third party service provider, including crisis and advocacy organizations, except as described in this Policy or with your consent.  

Your Choices and Selecting Your Privacy Preferences

Through the App’s functionality, you will have the opportunity to indicate what Personal Information the App collects, processes, stores or shares with the Company or with other App Users.  For example, you will have the option to allow or not allow notifications to be sent to you in the form of alerts, sounds or badges.  Please review all options available to you prior to using the App. 

We always want to provide you with relevant information that you have requested and do so in a timely fashion. If we provide subscription-based services, such as email newsletters or in-App messaging, we will allow you to make choices about what information you provide at the point of information collection or at any time after you have received a communication from us while you are subscribed.  Any transactional or service-oriented messages are usually excluded from such preferences, as such messages are required to respond to your requests or to provide goods and services, and are not intended for the purposes of marketing.

We will not intentionally send you email newsletters and marketing emails unless you consent to receive such marketing information.  By registering with the App, you will automatically be subscribed to our email newsletters and marketing emails.  You may opt out of these emails at any time by selecting the “unsubscribe” link at the bottom of each email.  Please note that by opting out or unsubscribing you may affect other services you have requested we provide to you, in which email communication is a requirement of the service provided. 

Likewise, should you opt in to receiving text messages from Every Two Minutes or its affiliates, you can also opt out at any time by following the instructions or contacting us.  For more information on text messaging, please review the App’s Terms of Use.  

Any such communications you receive from us will be administered in accordance with your preferences and this Policy.  

Accuracy and Access to Your Personal Information

We strive to maintain and process your information accurately.  We have processes in place to maintain all of our information in accordance with relevant data governance frameworks and legal requirements.  We employ technologies designed to help us maintain information accuracy on input and processing. 

Where we can provide you access to your Personal Information in our possession, the App will always ask you for a username and password to help protect your privacy and security.  We recommend that you keep your password safe, that you change it periodically, and that you do not disclose it to any other person or allow any other person to use it.  

To view and change the Personal Information that you have provided to us, you can log in to your account and follow the instructions in the App, or contact us directly for assistance.

Information of Minors

Unless otherwise authorized by contract, we do not intentionally gather information from individuals under the age of thirteen.  We do not target the App to individuals under the age of thirteen, and would not expect them to be engaging with the App or services.  

How We Use Your Information

The information we gather and that you provide is collected to provide you with the information and services you request, in addition to various other purposes, including, but not limited to: 

• Sharing and processing information to process your requests of the App or the Company.
• Assisting you with items such as personalized experiences, facilitation of product usage, and enforcement of Terms of Use.   
• Preventing malicious activity and providing you with a secure experience.  
• Providing service and support for services you request.
• Providing marketing communications that are effective and optimized for you. 
• Keeping you up-to-date with the latest benefits available from us.
• Preventing unwanted messages or content.
• Measuring the performance of our marketing programs. 
• Contacting you about services and offers that are relevant to you.

How We Share Your Information

We may disclose your Personal Information to our trusted third-party business partners in accordance with this Policy, but only for the purposes of providing the services of the App to you. We work with a number of partners that help us process your requests, deliver customer service and support, send email marketing communications, and provide experiences that you have come to expect from us.  We will share your personal information with these third parties in order to fulfill the service that they provide to us. These third-party partners are under contract to keep your Personal Information secure and not to use it for any reason other than to fulfill the service we have requested from them. 

We never collect or share with any third-party partner the information a user provides when that user reports, seeks help with, or discloses his or her experience of sexual violence.  We provide the access to advocacy, reporting, medical and mental health providers and services, but we do not record or collect any of the information you provide them, nor do we disclose or identify you personally when you select those links in the App.

We do not sell or lease your Personal Information to any third party.  We will not disclose or share your Personal Information with third parties for the purposes of third-party marketing to you without your prior consent.

We may aggregate or otherwise anonymize the data we collect for purposes of analytics, research, marketing and other interests of Every Two Minutes business interests.  Such use shall not include Personal Information or information that can identify you as an individual or reasonably be used to identify you.

Except as described in this Policy, we will not share your information with third parties without your notice and consent, unless it is under one of the following circumstances:  

• Responding to duly authorized information requests from law enforcement or other governmental authorities.
• Complying with any law, regulations, subpoena, or court order.
• Investigating and helping prevent security threats, fraud, or other malicious activity.
• Enforcing or protecting the rights and properties of Every Two Minutes or its subsidiaries. 
• Protecting the rights or personal safety of Every Two Minutes’ employees or other users of the My SideKick App. 

There are circumstances where Every Two Minutes may decide to buy, sell, or reorganize its business in selected countries.  Under these circumstances, it may be necessary to share or receive Personal Information with prospective or actual partners or affiliates. In such circumstances, the Company will ensure your information is used in accordance with this Policy. 

United States Only

This App is designed for use by individuals in the United States only.  We do not warrant or represent this Policy or the App’s use of your Personal Information complies with the laws of any other jurisdiction.  Furthermore, to provide you with our services, we may store, process, and transmit information in the United States and other locations around the world, including countries that may not have the same privacy and security laws as yours.  Regardless of the country in which such information is stored, we will process your Personal Information in accordance with this Policy.  

Third-party Websites and Applications

This Policy does not apply to websites, applications, or other domains that are maintained or operated by third parties or our affiliates.  The App may link to third-party websites and services, but these links are not endorsements of these sites, and this Policy does not extend to them.  Because this Policy is not enforced on these third-party websites or applications, we encourage you to read any posted privacy policy of the third-party website before using the service or site and providing any information  

Safeguarding the Information We Collect

We take reasonable technical, administrative, and physical safeguards in order to protect your Personal Information against accidental loss and from unauthorized access, use, alteration, and disclosure.  For example, employees and contractors of Every Two Minutes only have access to the information they require to complete their assigned job duties. 

However, we can never promise 100% security.  You have a responsibility, as well, to safeguard your information through the proper use and security of any online credentials used to access your Personal Information, such as a username and password.  If you believe your credentials have been compromised, please change your password. Please also notify us of any unauthorized use of your Personal Information or your credentials.      

Changes to this Policy

If we make any changes to this Policy, a revised Policy will be posted on this screen and the date of the change will be reported in the “Last Revised” block above. 

How to Contact Us

We value your opinions, questions and welcome your feedback.  To contact us about this Policy or your Personal Information, please contact us at privacy@mysidekickapp.io.