Privacy Policy

This privacy policy (“Privacy Policy”) describes the types of information we may collect from you or that you may provide  (“Personal Data”) when you visit the website, https://www.returnsafe.com, and its subdomains (“Website”), the ReturnSafe Portal, use our Bluetooth devices, our application, App Logbook, or our services (collectively with the Website, the “Services”)and how we collect, use, disclose, transfer, protect and store Personal Data. We value your privacy and observe due care in processing and protecting Personal Data. We recommend you read this notice carefully.

By voluntarily using the Services, and/or providing data or other information via the Services, you are indicating your consent to this Privacy Policy and agreement to be bound by its terms. If you do not agree with our policies and practices, your choice is not to use our Services. By accessing or using our Services, you agree to this Privacy Policy. This Privacy Policy may change from time to time (see Changes to our policy). Your continued use of our Services after we make changes is deemed to be acceptance of those changes, so please check this Privacy Policy periodically for updates.

Who we are

The Services are provided by ReturnSafe, an entity established under the laws of Delaware.   You may submit inquiries regarding personal data protection, privacy and security matters or contact us for other reason via support@returnsafe.com.

Scope

The scope of this Privacy Policy includes the collection of Personal Data through:

  • Our Services;
  • HTML-formatted email messages and polls that we send to you and that link to this Privacy Policy;
  • through telephone, email, video, text, and other electronic messages between you and our Services;

and applies to all visitors/users of the Services.

Data controller

ReturnSafe acts as a processor to your employer, university or college education facility, or to a facility in which you are a visitor or vendor (“Sponsor Facility” or “Sponsor Facilities”) who is the data controller of your Personal Data. At this time, ReturnSafe is not required to appoint a Data Protection Officer or a representative in the EU, and has elected not to do so. ReturnSafe, its Data Protection Officer, or its representative may be contacted in any manner set forth below (see Changes to our policy).

Children under the age of 18

Our Services are not intended for children under 18 years of age. No one under age 18 may provide any information to or through the Services. We do not knowingly collect Personal Data from children under 18. If you are under 18, do not use or provide any information to our Services or on or through any of their features, including your name, address, telephone number, email address, or any screen name or user name you may use. If we learn we have collected or received Personal Data from a child under 18 without verification of parental consent, we will delete that information. If you believe we might have any information from a child under 18, please contact us at support@returnsafe.com or call us at (512)-649-8568.

Personal data and how we collect it

You may visit the ReturnSafe Websites without registration. There are times, however, when we may need certain Personal Data from you.

  • We collect several types of Personal Data from and about users of our Services, specifically information:by which you may be personally identified, such as name, e-mail address, telephone number, your health status and health or medical information, and any other identifier by which you may be contacted online or offline; and
  • about the equipment you use to access our Services and usage details, such as traffic data, logs, referring/exit pages, date and time of your visit to our Services, error information, clickstream data, and other communication data and the resources that you access and use on or through the Services;

We collect this information: Directly from you when you provide it to us, automatically as you navigate through or use our Services, and from third parties, for example, our business partners, such as a Sponsor Facility that we provide Services to.

We may collect your Personal Data:

  • When you sign up to use the ReturnSafe Services: When you participate in the ReturnSafe Services, we will collect Service usage statistics and analytics that consist of Personal Data (such as your name, company, platform activities).
  • From other sources: we may receive Personal Data from other sources, marketing partners, as well as from other third parties.
  • When you contact us with your questions, comments, ideas, complaints, or communicate with ReturnSafe (including when applying for employment with ReturnSafe): we may collect various information, depending on the manner in which you contact us (e.g. if you send us an email, we will collect your email address; if you solicit for a job, we will collect your details as provided in your application) and the reason for contacting us. In any case, we will collect your contact details to be able to respond and further communicate with you.
  • When you subscribe to our newsletters and updates mailing list: we will collect your first and last names and your email address if you wish to subscribe to our newsletters and updates.
  • When you submit a support ticket with ReturnSafe: we will collect your first and last names and your contact details so we can respond to your report. You will also need to describe the problem that you have experienced with our services so we can take care of it. We strongly recommend you not to send us screenshots and/or attachments that contain production data of the applications, or any confidential or personal data, when you submit a support ticket with us.
  • Automatically: When you visit and interact with the Services, ReturnSafe may use automatic data collection technologies to collect certain data about your equipment, location, browsing actions, patterns and internet connection, including traffic data, location, logs, referring/exit pages, the IP address of your computer, the date and time you accessed our web sites, the internet address of web sites from which you link to the Website, error information, clickstream data, and other communication data and the resources that you access and use on the Website or in the application, information about the device you are using (such as laptop, mobile device or tablet), specifically your IP address, operating system, browser type, and application version information, and your movements and preferences on the Website or application, and information collected through cookies.
    • Location Data. Our Services, at the option of the Sponsor Facility, uses real-time information about your location through your mobile device or Bluetooth enabled tracking hardware, such as a lanyard, tag or wristband. If you do not want us to collect this information, please request your Sponsor Facility to opt out of the Services.
    • Cookies are small snippets of text saved on your computer or mobile device that distinguish you from other users. Like most websites, we and our service providers may use cookies, and other technologies to receive and store certain types of information whenever you interact with our Website and application through your computer or mobile device. On your computer, you may refuse to accept browser cookies by activating the appropriate setting on your browser, and you may have similar capabilities on your mobile device in the preferences for your operating system or browser. However, if you select this setting you may be unable to access certain parts of our Website or use certain parts of our application. Unless you have adjusted your browser or operating system setting so that it will refuse cookies, our system will issue cookies when you direct your browser to our Website or use our application.
    • Google Analytics. We use Google Analytics, a web analytics service provided by Google, Inc. (“Google”) to collect certain information relating to your use of the Website. Google Analytics uses cookies to help the Website analyze how users use the site. You can find out more about how Google uses data when you visit our Website by visiting “How Google uses data when you use our partners’ sites or apps”, (located at google.com/policies/privacy/partners/). We may also use Google Analytics Advertising Features or other advertising networks to provide you with interest-based advertising based on your online activity. For more information regarding Google Analytics please visit Google’s website and pages that describe Google Analytics, such as www.google.com/analytics/learn/privacy.html.
  • Offline: We may collect Personal Data about you offline, such as when you attend one of our events or visit our exhibition booth or call our customer service representatives.

The Personal Data we collect from you is required to enter into a contract with ReturnSafe, for ReturnSafe to perform under the contract with your Sponsor Facility, and to provide you or your Sponsor Facility with our Services. If you refuse to provide such Personal Data or withdraw your consent to our processing of Personal Data, then in some cases we may not be able to enter into the contract or fulfill our obligations to you under it.

If you submit any Personal Data relating to other people to us in connection with our services or talent acquisition, you represent you have the authority to do so and permit us to use the information in accordance with this Privacy Policy.

Newsletters & Updates

If you subscribe to our newsletter and/or updates, we will use your name and email address to send the newsletter and/or updates to you. At any time you may unsubscribe by using the link in each newsletter or to unsubscribe or update communication, or visit our Website unsubscribe page.

Statistical Information

We collect information from visits to the Websites to help us provide a better experience, service and to make the Websites as user friendly and purposeful as possible. For example, we keep track of the domains from which people visit and we also measure visitor activity on the Websites. ReturnSafe may use this data to analyze trends and statistics and to help us provide better user experience and service.

Links to Other Web Sites

The ReturnSafe Website may contain links to other websites. ReturnSafe is not responsible for the privacy practices or the content of such websites. The links from the ReturnSafe Website to other websites do not imply that ReturnSafe endorses or has reviewed the third party websites. We suggest contacting the operators of those websites directly for information on their privacy policies.

Platform Usage Analytics

We collect information from the Services to help us provide a better experience. This analysis, statistics and other data generated by your use of the Services may be disclosed with your team members, campus or other Sponsor Facility community.

Use of personal data

We use Personal Data only when we’re allowed to by law and only for the reasons we collected it. Most commonly, the reasons are the performing of a contract with you or your employer, the consent you gave to us, when it is necessary for our legitimate interests (and your interests and rights don’t override ours), and when we need to comply with legal or regulatory obligations.

The Services can be used by Sponsor Facilities for employee, student, vendor and visitor health monitoring and COVID-19 screening. To reduce the risk of spreading the COVID-19 virus in and through the workplace or community and protect our employees, students and visitors, employers and Sponsor Facilities can implement procedures for screening employees, students, visitors, and other vendors coming into a Sponsor Facility in an effort to identify individuals who have or may have symptoms of, or have recently been exposed to, COVID-19 or related illness. As part of the screening, through the Services you may be asked certain questions for the purposes stated above in connection with your access to a Sponsor Facility.

In this regard, we will collect from you Personal Data about your health and potential symptoms and/or exposure to COVID-19, such as whether you have recently experienced a fever, cough, shortness of breath or other symptoms related to COVID-19, and whether you have or may have been in close contact with individuals who have been diagnosed with COVID-19 or experiencing symptoms of the virus.

We may use Personal Data:

  • For the employee and community health monitoring and COVID-19 screening described above;
  • To login you to the Services;
  • To manage our relationship with you, such as your registration to our events or as a customer;
  • Providing you with the information and Services you have requested;
  • To respond to your inquiries and fulfill your requests;
  • To send administrative information to you, such as the services and changes to our terms, conditions and policies;
  • To send marketing communications that may be relevant to you;
  • To carry out our obligations and enforce our rights arising from any contracts entered into between you and us or your Sponsor Facility and us, including for billing and collection;
  • For our business purposes, such as data analysis, audits, fraud monitoring and prevention, developing new products, enhancing, improving and modifying our services, identifying usage trends, determining the effectiveness of our promotional campaigns and operating and expanding our business activities;
  • As we believe to be necessary or appropriate: (a) under applicable law, including laws outside your country of residence; (b) to comply with legal processes; (c) to respond to requests from public and government authorities including public and government authorities outside your country of residence; (d) to enforce our terms and conditions; (e) to protect our operations and those of any of our affiliates; (f) to protect our rights, privacy, safety and property, and that of our affiliates, you and others; and (g) to allow us to pursue available remedies and limit the damages that we may sustain.

Lawful basis for processing your Personal Data

If you are in the EU, the processing of your Personal Data is lawful only if it is permitted under the applicable data protection laws. We have a lawful basis for each of our processing activities (except when an exception applies as described below):

  • Consent. By using our Services, you consent to our collection, use, and sharing of your Personal Data as described in this Privacy Policy. If you do not consent to this Privacy Policy, please do not use the Services;
  • Legitimate Interests. We will process your Personal Data as necessary for our legitimate interests. Our legitimate interests are balanced against your rights and freedoms and we do not process your Personal Data if your rights and freedoms outweigh our legitimate interests. Our legitimate interests are to: facilitate communication between ReturnSafe and you; detect and correct bugs and to improve our Services; safeguard our IT infrastructure and intellectual property; detect and prevent fraud and other crime; promote and market our business; perform and provide health monitoring to Sponsor Facilities;
  • To Fulfill Our Obligations to You under our Contract. We process your Personal Data in order to fulfill our obligations to you or your Sponsor Facility pursuant to our contract with you or your Sponsor Facility to deliver our Services.
  • As Required by Law. We may also process your Personal Data when we are required or permitted to by law; to comply with government inspections, audits, and other valid requests from government or other public authorities; to respond to legal process such as subpoenas; or as necessary for us to protect our interests or otherwise pursue our legal rights and remedies (for instance, when necessary to prevent or detect fraud, attacks against our network, or other criminal and tortious activities), defend litigation, and manage complaints or claims.

For any uses on the basis of legitimate interest, we have conducted a legitimate interest assessment to ensure that such processing isn’t overridden by your rights or interests.

Developing the Services: We use aggregated Personal Data about your use of the Services to develop the platform. These activities are necessary to fulfill our interest in creating a better platform and helping us create better technology and better communications.

Sending Direct Marketing Communications: We use your data to send marketing communications about our products and Services and offerings from our affiliates. We may send these communications via email, post or call. If you wish to opt-out of receiving such communications, you may do so at any time by clicking unsubscribe at the bottom of these communications or by visiting the User Profile page.

Special categories of information

Some Personal Data processed by ReturnSafe may be considered sensitive, including personal data concerning your health. ReturnSafe processes this information only to the extent necessary to carry out its obligations under the law or to the extent necessary to protect ReturnSafe’s legitimate interests.

Disclosure of personal data

ReturnSafe is not in the business of selling Personal Data. We consider this information to be a vital part of our relationship with you. There are, however, certain circumstances in which we may share Personal Data with certain third parties without further notice to you, as set forth below:

  • ReturnSafe may disclose your Personal Data to your Sponsor Facility in connection with the Sponsor Facility’s community health monitoring and COVID-19 screening;
  • When someone tests positive for COVID-19, ReturnSafe may provide an alert to individuals in the community you have come into contact with that they have been exposed to COVID-19. This alert will not include any personally identifying information.
  • ReturnSafe, like many businesses, sometimes hires other companies to perform certain business-related functions, such as website hosting, data analysis, information technology and related infrastructure provision, customer service, email delivery, auditing, processing payments, and other similar services. When we employ another company to perform a function of this nature, we only provide them with the information that they need to perform their specific function.
  • In the event of any reorganization, merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of our business, assets or stock (including in connection with any bankruptcy or similar proceedings) we may disclose Personal Data to a third party.

As we believe to be necessary or appropriate we may also disclose Personal Data to a third party: (a) under applicable law, including laws outside your country of residence; (b) to comply with any court order, law, or legal processes, including to respond to any government or regulatory request; (c) to respond to requests from public and government authorities including public and government authorities outside your country of residence; (d) to enforce our terms and conditions; (e) to protect our operations and those of any of our service providers and business partners; (f) to protect our rights, privacy, safety and property, and that of our affiliates, you and others; and (g) to allow us to pursue available remedies and limit the damages that we may sustain.

Additionally, we may disclose anonymized information about our users, and information that does not identify any individual, without restriction.

Security

We have taken appropriate technical and organizational security measures to secure your Personal Data against accidental loss and unlawful processing of such information. Unfortunately, no data transmission or storage system can be guaranteed to be 100% secure. If you have reason to believe that your interaction with us is no longer secure (for example, if you feel that the security of any account you might have with us has been compromised), please notify us immediately about the problem by contacting us. The safety and security of your information also depends on you. Where you have chosen a password for the use of our Services, you are responsible for keeping this password confidential. We ask you not to share your password with anyone.

Automated decision making

ReturnSafe does not use your Personal Data with any automated decision making process, including profiling, which may produce a legal effect concerning you or similarly significantly affect you.

Your rights

If you tell us that you do not want us to use Personal Data as a basis for further contact, we will respect your wishes. Regarding our processing of the Personal Data about you, you can exercise a variety of the rights, such as:

  • Access and Update. You can review and change your Personal Data by logging into the Services and visiting your “Account” page. You may also notify us through the Contact Information below of any changes or errors in any Personal Data we have about you to ensure that it is complete, accurate, and as current as possible. We may also not be able to accommodate your request if we believe it would violate any law or legal requirement or cause the information to be incorrect.
  • You have the right to restrict our processing of your Personal Data under certain circumstances. In particular, you can request we restrict our use of it if you contest its accuracy, if the processing of your Personal Data is determined to be unlawful, or if we no longer need your Personal Data for processing but we have retained it as permitted by law.
  • To the extent the Personal Data you provide ReturnSafe is processed based on your consent or that we process it through automated means, you have the right to request that we provide you a copy of, or access to, all or part of such Personal Data in structured, commonly used and machine-readable format. You also have the right to request that we transmit this Personal Data to a data controller, when technically feasible.
  • Withdrawal of Consent. To the extent that our processing of your Personal Data is based on your consent, you may withdraw your consent at any time by closing your account. Withdrawing your consent will not, however, affect the lawfulness of the processing based on your consent before its withdrawal, and will not affect the lawfulness of our continued processing that is based on any other lawful basis for processing your Personal Data.
  • Right to be Forgotten. You have the right to request that we delete all of your Personal Data. We cannot delete your Personal Data except by also deleting your user account, and we will only delete your account when we no longer have a lawful basis for processing your Personal Data or after a final determination that your Personal Data was unlawfully processed. We may not accommodate a request to erase information if we believe the deletion would violate any law or legal requirement or cause the information to be incorrect. In all other cases, we will retain your Personal Data as set forth in this policy. In addition, we cannot completely delete your Personal Data as some data may rest in previous backups. These will be retained for the periods set forth in our disaster recovery policies.
  • You have the right to lodge a complaint with the applicable supervisory authority in the country you live in, the country you work in, or the country where you believe your rights under applicable data protection laws have been violated. However, before doing so, we request that you contact us directly in order to give us an opportunity to work directly with you to resolve any concerns about your privacy.
  • How You May Exercise Your Rights. If you want to exercise any of the foregoing rights or have any other question regarding the Personal Data related to you, please contact us at: support@returnsafe.com. In your request, please let us know what limitations you would like to put on our use of Personal Data related to you. For your protection, we may only implement requests with respect to the Personal Data associated with the particular email address that you use to send us your request, and we may need to verify your identity before implementing your request. We will try to comply with your request as soon as reasonably practicable. Please note that if you make unfounded, repetitive, or excessive requests (as determined in our reasonable discretion) to access your Personal Data, you may be charged a fee subject to a maximum set by applicable law.

Please note also that we may need to retain certain information for record keeping purposes. There may also be residual information that will remain within our databases and other records, which will not be removed.

Do not track signals

We also may use automated data collection technologies to collect information about your online activities over time and across third-party websites or other online services (behavioral tracking). Some web browsers permit you to broadcast a signal to websites and online services indicating a preference that they “do not track” your online activities. At this time, we do not honor such signals and we do not modify what information we collect or how we use that information based upon whether such a signal is broadcast or received by us.

State specific privacy rights

The law in some states may provide you with additional rights regarding our use of Personal Data. To learn more about any additional rights that may be applicable to you as a resident of one of these states, please see the privacy addendum for your state that is attached to this Privacy Policy.

Retention

We will retain Personal Data for the period necessary to fulfill the purposes outlined in this Privacy Policy, unless a longer retention period is required or permitted by law. We will retain data that has been rendered anonymous in such a manner that you are no longer identifiable indefinitely.

Consent to the processing of personal data in the United States

Personal Data may be stored on servers located within the European Union but may also be processed in any country where we have facilities or in which we engage service providers. Your Personal Data is transferred by ReturnSafe to another country only if it is required or permitted under applicable data protection law and provided that there are appropriate safeguards in place to protect your Personal Data. By using our Services, you represent that you have read and understood the above and hereby consent to the storage and processing of Personal Data that you provide directly to us on our through our Services. To ensure your Personal Data is treated in accordance with this Privacy Policy, ReturnSafe uses Data Protection Agreements between ReturnSafe and all other recipients of your data that include, where applicable, the Standard Contractual Clauses adopted by the European Commission (the “Standard Contractual Clauses”). The European Commission has determined that the transfer of Personal Data pursuant to the Standard Contractual Clauses provides for an adequate level of protection of your Personal Data. Under these Standard Contractual Clauses, you have the same rights as if your data was not transferred to such third party. You may request a copy of the Data Protection Agreement by contacting us through the Contact Information methods listed below.

Changes to our policy

We may change our business and the Services from time to time. As a result, at times it may be necessary for us to make changes to this Privacy Policy. We reserve the right to update or modify this Privacy Policy at any time without prior notice. If we make material changes to how we treat our users’ Personal Data, we will notify you or the Sponsor Facility by email to the email address specified in your account and/or through a notice on the Websites’ home page. We recommend that you review this Privacy Policy regularly so that you remain informed of any changes. Your continued use of the Services after any changes or revisions to this Privacy Policy shall indicate your agreement with the terms of such revised policy. The date this Privacy Policy was last revised is identified at the bottom of this page.

Contact Information

If you have any questions, concerns, complaints or suggestions regarding our Privacy Policy, have any requests related to your Personal Data pursuant to applicable laws, or otherwise need to contact us, you must contact us at the contact information below or through the “Contact Us” page on our Website.

To Contact ReturnSafe

ReturnSafe

6602 Ladera Norte

Austin, TX 78731

United States of America

(512)-649-8568

support@returnsafe.com

 

This Privacy Policy was last updated on March 17th, 2021.