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LEEPS PRIVACY POLICY

Effective Date: April 2019

Welcome! Thank you for visiting a LEEPS PRO, Inc. (“LEEPS,” “we,” “our,” or “us”) offering. To help inform you, we provide this notice explaining our online information practices and the choices you can make about the collection and use of information you submit or we collect through our LEEPS mobile application and services (collectively, the “Services.”).

1. Scope and Consent

When you use the Services, you are contracting with LEEPS PRO, Inc., which is located at 2005 De La Cruz Boulevard, Suite 275, Santa Clara, California, 95050. By using the Services, you expressly consent to our collection, use, disclosure, and retention of your personal information as described in this Privacy Policy.

2. Information We Collect

(a) Registration and Account Information: When you register for an account on the LEEPS system, you must provide personal information, including name, email address, phone number, mobile telephone number, other contact information about yourself and a password. You may also upload photographs for your account. Personal information is only associated with your account when you sign in as a registered user.

(b) Health and Medical Information You Provide: You may also choose to provide health and medical information about yourself on your account profile, such as health conditions, medicines you take, or medical devices you use.

(c) Health Information and Other Data From Other Sources: You may also choose to allow the LEEPS system to read and collect health and other information provided from any wearable medical monitoring equipment or your mobile phone. To allow this, you must give permission directly in the mobile application to allow LEEPS to read and collect said information. The health information that the LEEPS system could collect about you includes your heart rate, blood pressure, and other vitals in order to determine if you are in distress. The LEEPS mobile application may also access your mobile phone’s audio system in order to determine if you are in any danger as well as motion sensors in order to determine your activity level, such as if you are running or if you are motionless. This information is only collected with your specific permission given within the application settings of the LEEPS mobile application.

(d) Mobile Information: We may collect additional information from your mobile device if allowed in the LEEPS mobile application (e.g. your unique device identifier, device’s operating system, mobile carrier, location or GPS/geo-location).

(e) Geolocation Information: When you use the LEEPS mobile application, your geo-location information may be collected in order to provide your whereabouts should it be determined you are in distress.

(f) Technical Usage Information: When you use our Services, we collect usage information sent to us by your computer, mobile device, or other access device that tells us how you are using the Services (“usage information”). We use tracking technologies (including cookies stored in HTML-5), web beacons/GIFs, embedded scripts, e-tags/cache browsers) to collect usage information.

Our goal is to collect and use only that information that we think is required in order to provide the Services to you and for our legitimate business interests, in order to better understand your interests and improve your experience of using the Services.

3. Uses and Retention

(a) Operate Our Services: We use the information collected to operate our Services, such that the information collected is available on the dispatch portal and viewable by anyone on your account who is given dispatch privileges so that help can be sent to you by your dispatch team if you are in medical or other distress.

(b) Analyze and Aggregate Non-Personal Information: We use aggregate information about our users and non-personal information to analyze our Services and user behavior and prepare aggregated reports.

(c) Prevent Fraud: We use information from the Services to prevent, detect, and investigate fraud, security breaches, potentially prohibited or illegal activities, and enforce our terms of service.

(d) Communicate With You: We use your information to contact you to maintain the Services, your account, to comply with your stated communication preferences, to provide other services requested by you, as described at the time when we collect the information from you, to send you marketing communications, or contact you for other purposes authorized by law.

(e) Mobile Data: When you access the Service on a mobile device, we may use the information collected for any purpose set forth in this Privacy Policy. For example, we may use this information to provide you with location-based services.

We retain information as long as it is necessary and relevant for our operations. You consent to our retention of your video viewing tracking data for as long as permissible under applicable law – up to one year after you close your account or otherwise withdraw consent for video tracking.

4. Disclosure

Information collected on the Site may be shared with:

(a) The LEEPS Corporate Family: We may share the information we collect about you with the LEEPS corporate family, including LEEPS PRO, Inc. and our affiliates and subsidiaries, as well as with third-party suppliers. The information may be disclosed to: (i) provide joint content and our services (e.g., registration, transactions, analytics and customer support); (ii) help detect and prevent potentially illegal acts, violations of our policies, fraud and/or data security breaches; and (iii) guide decisions about our, LEEPS or a third-party’s products, sites, applications, services, tools and communications. Members of our corporate family will use this information to send you marketing communications and you will have the opportunity to opt-out in email communications.

(b) Service Providers and Other Third-Parties: We may disclose your information to service providers under contract who help with our business operations (such as, but not limited to, fraud investigations, advertising, ad operations).

(c) Other Entities with Your Consent: Other third-parties to whom you explicitly ask us to send your information (or about whom you are otherwise explicitly notified and consent to when using a specific service).

(d) Legal and Law Enforcement: Law enforcement, governmental agencies, or authorized third-parties, in response to a verified request relating to a criminal investigation or alleged illegal activity or any other activity that may expose us, you, or any other LEEPS user to legal liability. In this regard, we may share your information with third parties in response to a subpoena, other legal process and/or as permitted by law. In such events, we will only disclose information relevant and necessary to the investigation or inquiry, such as name, city, state, zip code, telephone number, email address, user ID history, IP address, fraud complaints and anything else we may deem relevant to the investigation.

(e) Change of Control – New Owners: We may share your information with other business entities, should we plan to merge with or be acquired by that business entity. Should such a combination occur, we will make reasonable efforts to request that the new combined entity follow this Privacy Policy with respect to your personal information. If your personal information would be used contrary to this policy, we will request that the new owner provide you with prior notice.

(f) Companies in The Mobile App Industry: If you access the Services through a mobile device, we may also share your information with carriers, operating systems and platforms.

(g) Information You Share

If you add information to your account regarding your medical information, or if you allow the LEEPS mobile application to access heath data from your medical wearable devices, the information will be available for viewing on the dispatch portal. This will not be made available to the public but anyone within your account that has dispatch privileges will be able to view your medical information. This allows the Service to operate so that you can be reached or found if you are in medical distress. If you do not want this information to be disclosed to anyone, do not use the Service.

5. Your Choices

You can control how and when you want to receive notifications from LEEPS by following instructions within the notices. You may not opt-out of administrative emails (for example, emails about your transactions or policy changes) for your registered account.

6. Cookies and Tracking Technologies

When you use the Services, we and our business partners may use cookies and other tracking technologies for a variety of purposes and to enhance your experience, for example, by remembering your log-in status and viewing preferences.

A few additional important things you should know about our use of tracking technologies (e.g., cookies, HTML-5 stored technologies):

· We offer certain features that are available only through the use of tracking technologies.

· We use both session and persistent tracking technologies. Tracking technologies (e.g., cookies) can either be persistent (i.e., they remain on your computer until you delete them) or temporary (i.e., they last only until you close your browser). You are always free to decline tracking technologies if your browser permits, although doing so may interfere with your use of the Site. Refer to the help section of your browser, browser extensions, or installed applications for instructions on blocking, deleting, or disabling tracking technologies such as cookies.

· With your prior consent as obtained through your use of this Site.

· We encode and protect the tracking technologies that LEEPS sets, so that only we can interpret the information stored in them.

· You may encounter tracking technologies/cookies from our third-party service providers that we have allowed on our Services that assist us with various aspects of our operations, such as Google Analytics.

7. Accessing, Reviewing, and Changing Your Personal Information

Registered members can review and change personal information at any time by accessing their accounts on the Services. You should promptly update your personal information if it changes or becomes inaccurate. We may retain some information from closed accounts so that we can comply with law, prevent fraud, assist with investigations, resolve disputes, analyze, or troubleshoot programs, enforce our terms of service, or take other actions permitted by law. Likewise, if your account or membership is terminated or suspended, we may maintain some information to prevent re-registration.

8. Notice to California Residents

(a) Residents of the State of California may request a list of all third-parties to which our Site has disclosed certain personal information (as defined by California law) during the preceding year for those third-parties’ direct marketing purposes. If you are a California resident and want such a list, please contact us at support@leepsinc.com. For all requests, you must put the statement “Your California Privacy Rights” in the body of your request, as well as your name, street address, city, state, and zip code. In the body of your request, please provide enough information for us to determine if this applies to you. You need to attest to the fact that you are a California resident and provide a current California address for our response. Please note that we will not accept requests via the telephone, mail, or by facsimile, and we are not responsible for notices that are not labeled or sent properly, or that do not have complete information.

(b) How We Respond to Do Not Track Signals for California Residents: California Business & Professions Code Section 22575(b) (as amended effective January 1, 2014) provides that California residents are entitled to know how LEEPS responds to “Do Not Track” browser settings. LEEPS does not currently take actions to respond to Do Not Track signals because a uniform technological standard has not yet been developed. We continue to review new technologies and may adopt a standard once one is created.

9. Third-Parties

Our Services may contain links to other third-party websites. We are not responsible for the privacy practices or the content of these third-party sites.

10. Security

We store and process your information on our servers located in the United States. We maintain technical, physical, and administrative security measures to protect the security of your personal information against loss, misuse, unauthorized access, disclosure, or alteration. Some of the safeguards we use are firewalls, data encryption, physical access controls to our data centers and information access authorization controls. It is your responsibility to make sure that your personal information is accurate and that your password(s) and account registration information are secure and not shared with third-parties.

11. Children Under the Age of 13

The Children’s Online Privacy Protection Act of 1998 and its rules (collectively, “COPPA”) require us to inform parents and legal guardians (as used in this section, “parents”) about our practices for collecting, using, and disclosing personal information from children under the age of 13 (“children”). It also requires us to obtain verifiable consent from a child’s parent for certain collection, use, and disclosure of the child’s personal information.

This section notifies parents of:

· The types of information we may collect from children.

· How we use the information we collect.

· Our practices for disclosing that information.

· Our practices for notifying and obtaining parents’ consent when we collect personal information from children, including how a parent may revoke consent.

· All operators that collect or maintain information from children through this Service.

This section only applies to children under the age of 13 and supplements the other provisions of this privacy policy. Only the other provisions of this privacy policy apply to teens and adults.

Information We Collect from Children

The Services are available only to registered users and require us to collect certain information, including personal information, from children. In addition, we use certain technologies, such as cookies, to automatically collect information from our users (including children) when they use the Service.

We only collect as much information about a child as is reasonably necessary for the child to participate in an activity, and we do not condition his or her participation on the disclosure of more personal information than is reasonably necessary.

You must directly and explicitly consent to allow us to collect any information from your child. In order to consent, you must confirm via email that you allow your child’s personal information to be collected.

Information We Collect Directly.

(a) Registration and Account Information: When you register for an account for your child on the LEEPS system, you must provide your child’s personal information, including name, email address, phone number, mobile telephone number, other contact information as well as a password. You may also upload photographs of your child to the account. Personal information is only associated with the account when the child is signed in as a registered user.

(b) Health and Medical Information You Provide: You may also choose to provide health and medical information about your child on your child’s account profile, such as health conditions, medicines, or medical devices used.

(c) Health Information and Other Data From Other Sources: You may also choose to allow the LEEPS system to read and collect health and other information about your child provided from any wearable medical monitoring equipment or your child’s mobile phone. To allow this, you must give permission directly in the mobile

application to allow LEEPS to read and collect said information. The health information that the LEEPS system could collect about your child includes heart rate, blood pressure, and other vitals in order to determine if your child is in distress. The LEEPS mobile application may also access your child’s mobile phone’s audio system in order to determine if your child is in any danger or suffering from a medical problem as well as motion sensors in order to determine your child’s activity level. This information is only collected with your specific permission given within the application settings of the LEEPS mobile application.

(d) Mobile Information: We may collect additional information from your child’s mobile device if allowed in the LEEPS mobile application (e.g. the unique device identifier, device’s operating system, mobile carrier, location or GPS/geo-location).

(e) Geolocation Information: When your child uses the LEEPS mobile application, your child’s geo-location information may be collected in order to provide your child’s whereabouts should it be determined your child is in distress.

(f) Technical Usage Information: When your child uses our Services, we collect usage information sent to us by your child’s computer, mobile device, or other access device that tells us how you or your child are using the Services (“usage information”). We use tracking technologies (including cookies stored in HTML-5), web beacons/GIFs, embedded scripts, e-tags/cache browsers) to collect usage information.

Our goal is to collect and use only that information that we think is required in order to provide the Services to you and your child and for our legitimate business interests, in order to better understand your interests and improve your experience of using the Services.

How We Use Your Child’s Information

(a) Operate Our Services: We use the information collected to operate our Services, such that the information collected is available on the dispatch portal and viewable by you or anyone else you give dispatch privileges to so that help can be sent to your child by your dispatch team if your child is in medical or other distress.

(b) Analyze and Aggregate Non-Personal Information: We use aggregate information about our users and non-personal information to analyze our Services and user behavior and prepare aggregated reports.

(c) Prevent Fraud: We use information from the Services to prevent, detect, and investigate fraud, security breaches, potentially prohibited or illegal activities, and enforce our terms of service.

(d) Communicate With You: We use your child’s information to contact you to maintain the Services, your child’s account, to comply with your stated communication preferences, to provide other services requested by you, as described at the time when we collect the information from you, to send you marketing communications, or contact you for other purposes authorized by law.

(e) Mobile Data: When you access the Service on a mobile device, we may use the information collected for any purpose set forth in this Privacy Policy. For example, we may use this information to provide you and your child with location-based services.

We retain information as long as it is necessary and relevant for our operations. You consent to our retention of your video viewing tracking data for as long as permissible under applicable law – up to one year after you close your account or otherwise withdraw consent for video tracking.

Our Practices for Disclosing Children’s Information

We do not share, sell, rent, or transfer children’s personal information other than as described in this section.

We may disclose aggregated information about many of our users, and information that does not identify any individual. In addition, we may disclose children’s personal information:

· To third parties we use to support the internal operations of our Service and who are bound by contractual or other obligations to use the information only for such purpose and to keep the information confidential.

· If we are required to do so by law or legal process, such as to comply with any court order or subpoena or to respond to any government or regulatory request.

· If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of LEEPS PRO, Inc., our customers or others, including to:

· protect the safety of a child;

· protect the safety and security of the [Website/App/Service]; or

· enable us to take precautions against liability.

· To law enforcement agencies or for an investigation related to public safety.

In addition, if LEEPS PRO, Inc. is involved in a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of LEEPS PRO, Inc.’s assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding or event, we may transfer the personal information we have collected or maintain to the buyer or other successor.

Accessing and Correcting Your Child’s Personal Information

At any time, you may review the child’s personal information maintained by us, require us to correct or delete the personal information, and/or refuse to permit us from further collecting or using the child’s information.

You can review, change, or delete your child’s personal information by:

· Logging into your child’s account and visiting his or her account profile page.

· Sending us an email at support@leepsinc.com. To protect your privacy and security, we may require you to take certain steps or provide additional information to verify your identity before we provide any information or make corrections.

Operators That Collect or Maintain Information from Children

We do not allow any third-party operators to collect or maintain any personal information from a child.

12. Notification Regarding Updates

From time to time, we may update this Privacy Policy. You agree that we may notify you about material changes in the way we treat personal information by placing a notice on the Site. You should check the Site frequently for updates.

13. Contact Us

If your questions are not answered online, you may email us at support@leepsinc.com.