PREPARED Privacy Policy

Revised May 2024
THE BOTTOM LINE UP FRONT
At Prepared, privacy is more than just a priority – it is a core value that drives everything we do. Whether you are a Public Safety Answering Point, a public safety agency, or a member of the public calling 911, we are fiercely committed to protecting your privacy rights and the integrity of your data. We are fully compliant with the FBI’s Criminal Justice Information Services standards and maintain a 50-state data privacy compliance program. As a company founded and based in the United States, we keep all US data within the United States. We never sell or market data and use it only in service of 911 callers and our customers’ critical public safety mission.

PREPARED’S COMMITMENT TO PRIVACY

Invictus Apps, Inc. d/b/a PREPARED (“PREPARED,” sometimes referred to as “we”, “us” or “our”) respects the privacy of every visitor to our websites and every user of our mobile apps and desktop apps. Your privacy is a priority, and we go to great lengths to protect it. This Privacy Policy describes how we collect and use information about our online visitors. We know you care about your information and we want you to be fully informed about our practices.

This Privacy Policy (“Privacy Policy”) applies to our data collection practices, including when you use our Prepared Live Emergency Communications Service (“Prepared Live”), use and engage with our mobile apps and desktop apps, and when you visit our website (“Site”), inquire about our products or services, subscribe to our mailing lists, or when you engage with us via email or on social media.

This Privacy Policy may be changed or updated from time to time. By visiting PREPARED at one of our websites or using one of our apps or services, you accept the practices described in this Privacy Policy. California, Colorado, Connecticut and Virginia state laws confer certain rights relating to personal information to their residents. If you are a resident of these states, please also see the applicable privacy sections below:

California
Colorado
Connecticut
Virginia

Please review this Privacy Policy periodically. Whenever you submit personal information to us, you consent to the collection, use, disclosure, transfer, and storage of that information in accordance with this Privacy Policy.

All personal information may be used for the purposes stated in this Privacy Policy. We may make full use of all information that is de-identified, aggregated, or otherwise not in personally identifiable form. We may also make full use of all user-generated content you submit to us, in accordance with our Terms of Use.

THE DATA WE COLLECT

Our websites, mobile apps and desktop apps provide convenient ways for you to access our services and learn important information about PREPARED and our services. To a see a complete list of what we collect, and how we use this data, please see our Annex 1. We collect information about our online visitors both directly from our visitors and indirectly from other companies and/or government agencies that provide data to us. When you use our websites or apps to pay for a service, register asa user, configure your settings, monitor activity, send emergency alerts or communications, or do various other functions, we may ask you for your name, address, phone number(s), and other information relevant to the transaction or function. We also collect recordings of your voice as you speak to 911professionals and photo and video recordings if you use Prepared Live.

We may obtain information about our online visitors from other sources as well. For example, we may engage with third party sources, including our public agency partners that may provide contact information, location services, and other data. We use this data to help us improve our services and to engage with customers who may benefit from PREPARED’s activities or services. We also collect information about you through your browser, computer hardware and software. This information can include your IP address, device ID, browser type, domain names, access times and dates, number of clicks, pages viewed, one or more cookies (as described below) that may uniquely identify your browser, and referring website addresses. This information is used by PREPARED for the improvement of our Site.

We also collect non-personal information about our online visitors using “cookies,” pixels, web beacons, and other technologies that operate automatically when you visit our website. We use this information to give our website visitors a more relevant online experience and to help us make website improvements. The information helps us understand which parts of our websites are the most popular, where our online visitors are going, and how long they spend there. If you do not want us to collect information using cookies, you can disable this function in your browser. If you block cookies from us, however, you may not be able to see personalized content and our website may not function optimally.

We may combine data collected from third party sources, including our public agency partners.

HOW WE SECURE YOUR DATA
We use a variety of security measures designed to protect your data. We maintain physical, electronic and procedural safeguards to help prevent unauthorized access to and improper use of personal information, but we cannot guaranty the security of your information, as no website or electronic data can ever be completely secure.

HOW WE USE YOUR INFORMATION

If you consent to PREPARED’s Prepared Live Emergency Communications Services (“Prepared Live”), we will receive your personal information and location, text messages and images that you send to 911 professionals, and we will access your audio and camera feed for the limited purpose of helping public safety agencies aid you in an emergency. We may also use the sessions obtained during the Prepared Live feed for our business needs and purposes, including to make this service better; to identify other services we can provide to help before, during, and after emergencies; and to improve public safety.

If you provide PREPARED with personal information when you visit our Site, or use our mobile apps or desktop apps, we may use the information in our services and activities. We may enter your information into one of our databases so we can contact you to obtain your input, provide information about our services or products, or provide a more personalized online experience.

We may also use data or information provided to us to communicate with customers, emergency responders and law enforcement, and to support public safety agencies in preparing for, responding to, helping the public in recovering from, and mitigating against all emergency incidents.

HOW WE DISCLOSE YOUR PERSONAL INFORMATION
Except as described below, we do not share your information with third parties.

Service Providers. PREPARED may share your information with our vendors and other partners that help us with our activities and services, including developing analytical models to provide better support before, during, and after emergencies. For example, we disclose information with vendors that help us manage data and respond to emergencies. These vendors are bound by confidentiality rules and are permitted to use the information only to support PREPARED operations.

Third Party Partners. We may also share data and information from emergency situations with public safety agencies such as 911 centers, first responder agencies, and other public sector agencies, as they prepare for, respond to, help the public recover from, and mitigate against all emergency incidents. These third party partners are subject to confidentiality rules, and are required to maintain reasonable security measures to ensure that your information is protected.

Legal Obligations. We also may disclose information to outside parties (including, without limitation, governmental agencies) if required to do so by law, regulation or court order; to respond to governmental and/or law enforcement requests; to identify, contact or bring legal action against someone who may be causing injury to or interfering with our (or others’) rights or property; to support any actual or threatened claim, defense or declaration in a case or before any jurisdictional and/or administrative authority, arbitration or mediation panel; or in connection with disciplinary actions/investigations as required by law.

Sale or Corporate Restructuring. We may disclose personal information to third parties in connection with the sale, assignment or other transfer of the business of our website or the sale, assignment, merger, reorganization or other transfer of our brand or company.

HOW WE USE “COOKIES” AND OTHER TECHNOLOGY ON OUR SITE
As you enter the website, our server records and monitors your IP address and uses it to develop statistical analysis. These analyses assist us in refining and adapting the content and design of our site. The use of IP addresses also enables us to prevent malicious Internet users from masquerading as other users. Automated technology collects information from your computer or mobile device and includes cookies, web beacons, local shared objects, or other similar technology. A cookie is a small piece of information sent by a website that is saved on your hard drive by your computer’s browser. A “web beacon” is a small object or image that is embedded into a web page, application, or email and is used to track activity. They are also sometimes referred to as pixels and tags.

As you access or use our website, we and/or third parties may collect information using cookies, web beacons, pixels, and navigational and location data collection (clickstream, log files, server logs) for the purposes described in this Policy. Such automated technologies further help us to keep track of your interactions with our website and provide you with a more customized experience.

Google Analytics and Meta Pixel: We use Google Analytics, Meta Pixel, and LinkedIn Insight Tag to understand how our website, services, and products perform, how you use them, and to serve you with ads on third-party websites and social networking sites like Facebook. To learn more about how Google processes your data, please visit https://www.google.com/policies/privacy/. To opt out of Google Analytics please visit https://tools.google.com/dlpage/gaoptout. To learn more about how Meta uses your data, please visit https://www.facebook.com/policy.php. To learn more about how LinkedIn uses your data, please visit https://www.linkedin.com/legal/privacy-policy.

Advertising and Remarketing Services: We use remarketing services to inform, optimize, and serve ads on third-party websites such as Facebook to you based on your use of our Site and social media. To understand more about Facebook advertising and manage your preferences, please visit https://www.facebook.com/about/ads. For more information about targeted advertising and to opt out of collection of information and ad targeting from third-party websites, including Facebook and Google, please visit http://www.aboutads.info/choices. If you choose to opt out, you will continue to receive advertisements but they will not be tailored to your interests.

Digital Advertising Alliance: You can also opt out from companies like Google, Instagram, Pinterest, Meta and other participating companies through the Digital Advertising Alliance in the USA: http://www.aboutads.info/choices/. You can also opt out of participating companies from the Digital Advertising Alliance of Canada in Canada: http://youradchoices.ca/ or the European Interactive Digital Advertising Alliance in Europe: http://www.youronlinechoices.eu/, or opt out using your mobile device settings.

To find more information about cookies please visit www.allaboutcookies.org. Most browsers are initially set to allow cookies, but also offer the option to restrict cookies or warn you of their use. By disabling cookies, you won’t be able to enjoy the convenience provided by our customization.

RETENTION OF PERSONAL INFORMATION
We will retain your Personal Information as long as it is necessary to fulfill the purposes outlined in this Privacy Policy and to the extent necessary to comply with our legal obligations, resolve disputes, and enforce our legal agreements and policies, whichever is shorter. For more information regarding retention of personal information see Annex 1.

CONTACT PREFERENCES; OPT-IN AND OPT-OUT
We would like to keep in touch with you in ways that you find to be beneficial. If you don’t want us to use your contact information to communicate with you for promotional purposes, please tell us that when you provide your contact information. If at any time you would like to unsubscribe from receiving future emails, you can click the unsubscribe link at the bottom of any email. You may also contact us at contact@preparedapp.com. Keep in mind that these preferences regarding promotional contacts do not mean that we might not contact you for other reasons, such as those related to an inquiry you made, a legally required notice and so on.

External Links
We may make available third party applications through our Site and social media applications for your use. Links to such applications, any other websites included in this Site or links on our social media accounts operate with privacy policies beyond our control. Unless otherwise indicated, once you have left our Site or our social media account, all use of information you provide is governed by the privacy policy of the other website’s or social media account operators. We are not responsible for any transactions that occur between you and a third-party website or social media account.

MISCELLANEOUS
PREPARED is committed to accuracy and precision in processing your information. We have procedures to check for errors, and our systems are periodically audited to make sure we process your information securely and accurately.

Contact Us
If you have any questions or concerns about this Privacy Policy, please contact us at contact@preparedapp.com.

CALIFORNIA CONSUMERS ONLY: Your California Privacy Rights

This Privacy Rights Act Notice (“Notice”) provides additional information to California residents whose Personal Information is collected by us pursuant to California law, including the California Consumer Privacy Act (“CCPA”), as amended by the California Privacy Rights Act (“CPRA”). If you are not a California resident, this Notice does not apply to you. Please visit our Privacy Policy Privacy Policy (“Policy”) for more information. Any capitalized terms undefined in this Notice have the same definition as the Policy.

RIGHT TO KNOW ABOUT PERSONAL INFORMATION COLLECTED OR DISCLOSED

Requests to Know

You have the right to request that we disclose personal information we collect about you. To make a request for any of the information set forth above (a “Request to Know”), please submit a verifiable consumer request pursuant to the instructions below. You may make a Request to Know twice within a 12-month period. We will acknowledge your Request to Know within 10 days and will attempt to respond substantively within 45-90 days.

The Request to Know must provide sufficient information to allow us to verify that you are the person about whom the personal information was collected, sold or disclosed and must contain sufficient detail to allow us to properly understand, evaluate and respond to your request. If we cannot verify your identity, we will not be able to respond to your request.

You can make a Request to Know the personal information we have about you in the following ways:

— You make may a request here: contact@preparedapp.com
— You may also make a request by phone by contacting us at +1 (201) 608-3829.

Once we receive your Request to Know, we will begin the process to verify that you are the person that is the subject of the request (the “Verification Process”). The Verification Process consists of matching identifying information provided by you with the information we have about you in our records. You will be asked to provide us with two or three pieces of information that will help us to verify your identity.

RIGHT TO KNOW AND LIMIT SENSITIVE PERSONAL INFORMATION COLLECTED

We collect and use your Sensitive Personal Information as described in Annex 1. Under the CCPA, you have the right to limit the use of your Sensitive Personal Information to the purposes specified in the CCPA. However, we already limit our use of your Sensitive Personal Information to such specified purposes.request to limit the use of your Sensitive Personal Information in certain circumstances by sending a request here: contact@preparedapp.com

RIGHT TO REQUEST DELETION OF PERSONAL INFORMATION

You have the right to request the deletion of your personal information collected or maintained by us (“Request to Delete”), subject to certain exceptions permitted by law.

To make a Request to Delete, please submit a verifiable consumer request pursuant to the instructions below. You may make a verifiable consumer Request to Delete twice within a 12-month period. We will acknowledge your Request to Delete within 10 days and will attempt to respond substantively within 45-90 days.

The Request to Delete must provide sufficient information to allow us to verify that you are the person about whom the personal information was collected, sold or disclosed and must contain sufficient detail to allow us to properly understand, evaluate and respond to your request. If we cannot verify your identity, we will not be able to respond to your request. Additionally, as permitted by law, if the information requested to be deleted is necessary for us to maintain, we will
not be able to comply with your request. We will notify you if this is the case.

You can make a Request to Delete in the following ways:
— You may make a request here: contact@preparedapp.com
— You may also make a request by phone by contacting us at +1 (201) 608-3829.
Once we receive your initial request to delete and your separate confirmation to delete, we will need to verify that you are the person that is the subject of the request (the “Verification Process”). The Verification Process consists of matching identifying information provided by you with the information we have about you in our records. You will be asked to provide us with two or three pieces of information that will help us to verify your identity.

We will retain correspondence, documents and information related to any Request to Know, Request to Delete, or Request to Opt-Out for 24 months as required by law.

RIGHT TO CORRECT

You have the right to request that we rectify inaccurate information about you.

To make a Request to Correct, please submit a verifiable consumer request pursuant to the instructions below. We will acknowledge your Request to Correct within 10 business days and we will attempt to respond substantively within 45-90 days.

You can make a Request to Correct in the following ways:
— You can make a request here: contact@preparedapp.com
— You may also make a request by phone by contacting us at +1 (201) 608-3829.

Once we receive your request to correct, we will need to verify that you are the person that is the subject of the request through the Verification Process.

We will review all information provided by you to us, to determine whether the information is inaccurate. We reserve the right to delete the information instead of correcting if such deletion does not impact you or you consent to the deletion.

We will inform you of our decision to deny or grant your request.

We will retain correspondence, documents and information related to any Request to Correct for 24 months as required by law.

RIGHT TO ACCESS INFORMATION ABOUT AUTOMATED DECISION MAKING AND THE RIGHT TO OPT-OUT OF AUTOMATED DECISION MAKING

We do not engage in automated decision-making with respect to your personal information.

RIGHT TO NON-DISCRIMINATION FOR EXERCISING CONSUMER PRIVACY RIGHTS

You have the right not to receive discriminatory treatment for exercising your privacy rights conferred by the California Consumer Privacy Act, including by exercising the rights specified herein.

RETENTION OF PERSONAL INFORMATION

We will retain your Personal Information as long as it is necessary and to the extent necessary to comply with our legal obligations, resolve disputes, and enforce our legal agreements and policies, whichever is shorter. For more information regarding retention of personal information Annex 1.

AUTHORIZED AGENT INFORMATION

You may designate an authorized agent to make a request on your behalf under the California Consumer Privacy Act.

In order to allow an authorized agent to make a request on your behalf, please email us at contact@PreparedApp.com to provide your written request and consent to an authorized agent. When your authorized agent makes a request related to your personal information, we will require the agent to provide the above written permission. We may also require that you verify your own identity directly with us at the time such a request is made.

California Do Not Track Notice: Because there are not yet common, industry accepted “do not track” standards and systems, our website does not respond to Do Not Track signals.

California Shine The Light Disclosure Information

Although we do not disclose to any third-parties for their marketing purposes any personal information, California residents are entitled to receive the following disclosure information under California law:

Under California Law, California residents have the right to request in writing from businesses with which they have an established business relationship, (1) a list of the categories of personal information, such as name, address, email address, and the type of services provided to the customer, that a business has disclosed to third-parties (including affiliates that are separate legal entities) during the immediately preceding calendar year for the third-parties' direct marketing purposes, and (2) the names and addresses of all such third parties. We will respond to such written requests within 30 days following receipt at the email or mailing address specified below under “Contact Us”. If we receive your request at a different email or mailing address, we will respond within a reasonable period of time, but not to exceed 150 days from the date received.

Please note that we are required to respond to each customer only once per calendar year.

Changes to This Privacy Policy

This Privacy Policy may be revised from time to time for any reason. If this Privacy Policy changes, the revised policy will include a new effective date, and we will notify you of such changes by posting the revised policy on this page. Be sure to check the Privacy Policy whenever you submit personal information to us.

CONTACT FOR MORE INFORMATION

For information and questions about the use of your personal information or this California Consumer Privacy Section or your rights under California law, you may contact us at contact@preparedapp.com.

COLORADO, CONNECTICUT AND VIRGINIA CONSUMERS ONLY:

COLORADO, CONNECTICUT AND VIRGINIA PRIVACY ACT NOTICES

This Notice provides additional information to Colorado, Connecticut, and Virginia residents whose Personal Information is collected pursuant to the Colorado Privacy Act (“CPA”), Connecticut Data Privacy Act (“CTDPA”), and Virginia Consumer Data Protection Act (“VCDPA”).

The Notice below applies only to Connecticut, Colorado, and Virginia residents. Please visit our Privacy Policy (“Privacy Policy”) for more information. Any capitalized terms undefined in this Notice have the same definition as the Privacy Policy.

RIGHT TO CONFIRM, ACCESS AND DATA PORTABILITY
You have the right to confirm whether or not we are processing your personal data and to access such personal data in a portable and, to the extent technically feasible, readily usable format that allows you to transmit the data to another controller without hindrance, where the processing is carried out by automated means. We will respond to your request within 45 days of receipt, unless we request an extension for an additional 45 days to respond.

You can exercise this right in the following ways:

— You may make a request here: contact@preparedapp.com
— You may also make a request by phone by contacting us at +1 (201) 608-3829

Once we receive your request, we will begin the process to verify your identity to confirm that you are the person that is the subject of the request (the “Verification Process”). The Verification Process consists of matching identifying information provided by you with the information we have about you in our records. Upon making a request, you should be prepared to provide us with information that will help us to verify your identification. If we cannot verify your identity, we will not be able to respond to your request.

RIGHT TO REQUEST DELETION OF PERSONAL DATA

You have the right to request the deletion of your personal data provided by or obtained about you (“Request to Delete”), subject to certain exceptions permitted by law.

To make a Request to Delete, please submit a verifiable consumer request pursuant to the instructions below. We will respond to your request within 45 days of receipt, unless we request an extension for an additional 45 days to respond.

Requests to Delete
You can make a Request to Delete in the following ways:

— You may make a request here: contact@preparedapp.com
— You may also make a request by phone by contacting us at +1 (201) 608-3829

Once we receive your request, we will begin the process to verify your identity to confirm that you are the person that is the subject of the request (the “Verification Process”). The Verification Process consists of matching identifying information provided by you with the information we have about you in our records. Upon making a request, you should be prepared to provide us with information that will help us to verify your identification. If we cannot verify your identity, we will not be able to respond to your request.

RIGHT TO CORRECT
You have the right to request that we rectify inaccurate information about you. To make a Request to Correct, please submit a verifiable consumer request pursuant to the instructions below. We will attempt to respond substantively within 45-90 days.

Requests to Correct
You can make a Request to Correct in the following ways:

— You may make a request here: contact@preparedapp.com
— You may also make a request by phone by contacting us at +1 (201) 608-3829

Once we receive your request, we will begin the process to verify your identity to confirm that you are the person that is the subject of the request (the “Verification Process”). The Verification Process consists of matching identifying information provided by you with the information we have about you in our records. Upon making a request, you should be prepared to provide us with information that will help us to verify your identification. If we cannot verify your identity, we will not be able to respond to your request.

We will retain correspondence, documents and information related to any Request to Correct for 24 months as required by law.

RIGHT TO NON-DISCRIMINATION FOR EXERCISING CONSUMER PRIVACY RIGHTS

You have the right not to receive discriminatory treatment for exercising your privacy rights, including by exercising the rights specified herein. As the Right to Non-Discrimination is effective across the board, there is no specific “request” that you need to make in order to exercise this right.

RIGHT TO OPT OUT OF PROFILING
You have the right to opt out of the processing of your personal data for purposes of profiling in furtherance of decisions that produce legal or similarly significant effects (“Request to Opt Out of Profiling”).

Requests to Opt Out of Profiling
You can make a Request to Opt Out of Profiling in the following ways:

— You may make a request here: contact@preparedapp.com
— You may also make a request by phone by contacting us at +1 (201) 608-3829

Once we receive your request, we will begin the process to verify your identity to confirm that you are the person that is the subject of the request (the “Verification Process”). The Verification Process consists of matching identifying information provided by you with the information we have about you in our records. Upon making a request, you should be prepared to provide us with information that will help us to verify your identification. If we cannot verify your identity, we will not be able to respond to your request.

Authorized Agent
You may designate an authorized agent to make a request on your behalf to opt out of the sale of personal information.

Authorized agents may make requests under the CTDPA, CPA, and VCDPA on behalf of consumers by emailing contact@preparedapp.com. We will require authorized agents to provide proof of the consumer’s consent to and designation of the authorized agent for purpose of making the request, and will require authorized agents to provide information necessary to verify the identity of the consumer who is the subject of the request.  We may also require that a consumer verify his or her own identity directly with us before we respond to an authorized agent’s request.

RIGHT TO APPEAL
You have the right to appeal our decision to deny any of your privacy rights requests above. Within 60 days of receipt of your appeal (45 days for Colorado residents), we will inform you in writing of any action taken or not taken in response to the appeal, including a written explanation of the reasons for the decisions.

Colorado residents, if your appeal is denied, you may submit a complaint to the Colorado Attorney General at https://coag.gov/office-sections/consumer-protection.

Connecticut residents, if your appeal is denied, you may submit a complaint to the Connecticut Attorney General at https://portal.ct.gov/AG/Common/Complaint-Form-Landing-page

Virginia residents, if your appeal is denied, you may submit a complaint to the Virginia Attorney General at https://www.oag.state.va.us/consumer-protection/index.php/file-a-complaint.

Making an Appeal

You can make an appeal in the following ways:
— You may make an appeal here: contact@preparedapp.com
— You may also make an appeal by phone by contacting us at +1 (201) 608-3829.

We reserve the right to deny appeals in certain circumstances, such as where we have a reasonable belief that the request is fraudulent.

RETENTION OF PERSONAL INFORMATION
We will retain your Personal Information for 10 years as required by the Health Insurance Portability and Accountability Act of 1996 (“HIPAA”) or as long as it is necessary and to the extent necessary to comply with our legal obligations, resolve disputes, and enforce our legal agreements and policies, whichever is shorter. For more information regarding retention of personal information see Annex 1.

Do Not Track Notice

Because there are not yet common, industry-accepted “do not track” standards and systems, the Site does not currently respond to Do Not Track signals. Further information is available in the “Information Collection and Use” section above and described in in Annex 1 below.

Notice of Collection, Use, and Disclosure
See our full Privacy Policy here
See California Privacy Rights here
See Colorado, Connecticut and Virginia Privacy Rights here

ANNEX 1

See our full Data Privacy Table here

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