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Effective Date: August 25, 2021
Last Updated: August 25, 2021

Introduction

Vacmobile Corp. (collectively referred to herein as “Vacmobile”, “we”, “our” or “us”), recognizes the importance of protecting personal data we may collect from visitors and any other individual or entity (“Users”, “you”, or “your”) who visit our web sites and who use our application. This Privacy Policy applies to data collection by Vacmobile and shall apply to your use of the website, www.vacmobile.app and other Vacmobile-related sites, application (“App”), software, communications, capabilities and services (“Services”) accessible on or by any top-level Vacmobile domain owned by us (each, a “Site” and collectively the “Sites”), but excluding services that state that they are offered under a different privacy policy.

Vacmobile allows you to create a digital credential that contains information about your COVID-19 vaccination or negative test result status.

Our Privacy Policy explains: (1) what information we collect; (2) why we collect it; (3) how we use that information; (4) how we may share it; (5) the choices we offer, including how to access and update information; (6) and the measures we take to keep your information safe. Specifically, our Privacy Policy covers the following topics:

  • When This Privacy Policy Applies
  • Terms and Conditions
  • Information We Collect
  • How We Use Information We Collect
  • Information We Share
  • Our Legal Basis for Collecting Personal Data
  • Your Failure to Provide Personal Data
  • Our Retention of Your Personal Data
  • Your Privacy Rights and Choices
  • Privacy Rights Specific to EU Residents
  • Third Party Links
  • International Transfer
  • How We Protect Personal Data
  • Children
  • Direct Marketing and “Do Not Track” Signals
  • Changes to this Privacy Policy
  • How to Contact Us

 

Please familiarize yourself with our privacy practices and let us know if you have any questions. By using the Sites, you signify your acceptance of this Privacy Policy. If you do not agree to this Privacy Policy, please do not use the Sites.Irrespective of which country you live in, you authorize us to transfer, store, and use your information in the United States, and any other country where we operate. In some of these countries, the privacy and data protection laws and rules regarding when government authorities may access data may vary from those in the country where you live. Learn more about our data transfer operations in the “International Transfer” section below. If you do not agree to the transfer, storage and use of your information in the United States, and any other country where we operate, please do not use the Sites or Services.

If you have any questions or comments about this Privacy Policy, please submit a request to privacy@vacmobile.app.

 

When this Privacy Policy Applies

Our Privacy Policy applies to all of the Services offered by Vacmobile and its affiliates, and Services offered on other sites, but excludes services that have separate privacy policies that do not incorporate this Privacy Policy.

Our Privacy Policy does not apply to services offered by other companies or individuals, including products or sites that may be displayed to you, or other sites linked from our Services. Our Privacy Policy does not cover the information practices of other companies and organizations who advertise our Services, and who may use cookies, pixel tags and other technologies to serve and offer relevant ads.

 

Terms and Conditions

By accessing or using the Sites in any manner, you also agree to be bound by Vacmobile’s Terms and Conditions (the “Agreement”). Please read the Agreement carefully. If you do not accept all of the terms and conditions contained in or incorporated by reference into the Agreement, please do not use the Sites.

 

Information We Collect

We collect information, including personal data, to provide better services to all our Users. We use the term “Personal Data” to refer to any information that identifies or can be used to identify you. Common examples of Personal Data include: full name, email address, digital identity, such as a login name or handle, information about your device, and certain metadata.

“Sensitive Personal Data” refers to a smaller subset of Personal Data which is considered more sensitive to the individual, such as race and ethnic origin, political opinions, religious or philosophical beliefs, trade-union membership, genetic or biometric information, physical or mental health information, medical insurance data, or sexual orientation.

When you use our Services, we collect Personal Data and Sensitive Personal Data in the following ways:

  1. Information You Give to Us
  • Individual Users
    • Online Platform

 

We may collect information you provide us if you access, voluntary enter information into, or sign up for or request certain services from us on our Website. For example, if you are interested in learning more about Vacmobile and the services and products we offer, we may ask for information such as your name, alias, title, physical address, email address, telephone number, type of user (individual end user, or employer), and city/state. If you have an account with us, we may also collect your username or other login information you use to log into or access your account.

  • Mobile Application

 

Certain information is required when creating an account to use our Services on the mobile application, such as your name, email address, user name and password.

In addition, we will ask that you upload a photo of your vaccination card. We may collect the following:

  • Name
  • Date of birth
  • COVID-19 Vaccination type (e.g., Pfizer, Moderna, Johnson and Johnson)
  • Date when Covid-19 vaccination administered
  • Healthcare professional or clinic site

 

You can choose not to provide certain information, but then you may not be able to register for the Vacmobile Services or take advantage of some features of the Services.

When your device syncs with Vacmobile’s application, certain data recorded on your device is transferred from your device to our servers.

 

  1. Information We Obtain from Your Use of Our Services

We also collect information about your interaction with the Services, such as creating or logging into your account, or opening or interacting with the Services on Your mobile device. When you use our Site, we automatically collect and store this information in service logs. This includes: details of how you used our Site; Internet protocol address; cookies that uniquely identify your browser, the referring web page and pages visited.  We may also collect and process information about your actual location. The information we collect automatically is statistical data and may or may not include Personal Data, but we may maintain it or associate it with Personal Data we collect in other ways or receive from third parties.

 

  1. Identity Verification

During the sign-up process, we will verify your identity. We engage Jumio, a third party vendor that provides identity verification services. The verification process may require that you provide a copy of one of the following documents to Jumio. This includes:

  • Driver’s License,
  • Non-Driver’s License ID Card,
  • Passport,
  • Military ID.

 

How We Use Information We Collect

We use your Personal Data in ways that are compatible with the purposes for which it was collected or authorized by you, including for the following purposes:

  1. To present, operate or improve the Site and Services, including analysis of Site activity;
  2. To authorize access to our Sites and Services;
  3. To provide, maintain, administer or expand the Services, performing business analyses, or for other internal purposes to support, improve or enhance our business, the Services, and other products and services we offer;
  4. To secure our Services, including to authenticate Users;
  5. To comply with all applicable legal requirements;
  6. To verify and audit feature accuracy and success;
  7. To investigate possible fraud or other violations of our Terms and Conditions or this Privacy Policy and/or attempts to harm our Users;
  8. To resolve disputes;
  9. To otherwise fulfill the purpose for which the information was provided.

 

We use the information we collect from our Sites to provide, maintain, and improve them, to develop new services, and to protect our company and our Users.

We will ask for your consent before using information for a purpose other than those set out in this Privacy Policy.

 

Information We Share

We do not share Personal Data with companies, organizations and individuals outside of Vacmobile unless one of the following circumstances applies:

  • With your consent. We will share Personal Data with organizations or individuals outside of Vacmobile when we have your consent to do so.
  • For external processing. We provide Personal Data to our affiliates or other trusted businesses or partners to process it for us, based on our instructions and in compliance with our Privacy Policy and any other appropriate confidentiality and security measures. These third parties include their vendors and contractors that provide ID authentication and verification, process transactions, marketing partners, cloud service providers and similar partners. It is our policy to only share Personal Data with contractors, service providers, technology partners, and other third parties who are bound by contractual obligations to keep Personal Data confidential and use it only for the purposes for which we disclose it to them. Under certain circumstances, you may avoid having us share your information with our business partners and vendors by not granting us permission to share your information.  Not granting us permission to share your information with our business partners or vendors may limit your access to their services through the Sites.
  • For Legal Reasons. We will share Personal Data with companies, organizations or individuals outside of Vacmobile if we have a good-faith belief that access, use, preservation or disclosure of the information is reasonably necessary to:
    • meet any applicable law, regulation, legal process or enforceable governmental request.
    • enforce applicable Terms and Conditions, including investigation of potential violations.
    • detect, prevent, or otherwise address fraud, security or technical issues.
    • protect against harm to the rights, property or safety of Vacmobile, our Users or the public as required or permitted by law.

 

We attempt to notify Users about legal demands for their Personal Data when appropriate in our judgment, unless prohibited by law or court order or when the request is an emergency. We may dispute such demands when we believe, in our discretion, that the requests are overbroad, vague or lack proper authority, but we do not promise to challenge every demand.

  • Business Transfers. If we establish a new related entity, are acquired by or merged with another organization, or if substantially all of our assets are transferred to another organization, Personal Data about our Users is often a transferred business asset. In the event that Vacmobile itself or substantially all of our assets are acquired, Personal Data about our Users may be one of the transferred assets.

 

Our Legal Basis for Collecting Personal Information

Whenever we collect Personal Information from you, we may do so on the following legal bases:

  1. Your consent to such collection and use;
  2. Out of necessity for the performance of an agreement between us and you, such as your agreement to use our Services or your request for Services;
  3. Our legitimate business interest, including but not limited to the following circumstances where collecting or using Personal Information is necessary for:
    • Intra-organization transfers for administrative purposes;
    • Product development and enhancement, where the processing enables Vacmobile to enhance, modify, personalize, or otherwise improve our services and communications for the benefit of our Users, and to better understand how people interact with our Sites;
    • Fraud detection and prevention;
    • Enhancement of our cybersecurity, including improving the security of our network and information systems; and
    • General business operations and diligence;

 

Provided that, in each circumstance, we will weigh the necessity of our processing for the purpose against your privacy and confidentiality interests, including taking into account your reasonable expectations, the impact of processing, and any safeguards which are or could be put in place. In all circumstances, we will limit such processing for our legitimate business interest to what is necessary for its purposes.

 

Your Failure to Provide Personal Data

Your provision of Personal Data is required in order to use certain parts of our services and our programs.  If you fail to provide such Personal Data, you may not be able to access and use our Services and/or our programs, or parts of our Services and/or our programs.

 

Our Retention of Your Personal Data

We may retain your Personal Data for a period of time consistent with the original purpose for collection.  For example, we keep your Personal Data for no longer than reasonably necessary for your use of our programs and Services and for a reasonable period of time afterward. We also may retain your Personal Data during the period of time needed for us to pursue our legitimate business interests, conduct audits, comply with our legal obligations, resolve disputes and enforce our agreements.

We retain your Personal Data even after your business relationship with us ends if reasonably necessary to comply with our legal obligations (including law enforcement requests), meet regulatory requirements, resolve disputes, maintain security, prevent fraud and abuse, enforce our Terms of Use, or fulfill your request to “unsubscribe” from further messages from us. We will retain de-personalized information after your account has been closed.

 

Your Privacy Rights and Choices

Whenever you use our Services, we aim to provide you with choices about how we use your Personal Data. We also aim to provide you with access to your Personal Data. If that information is wrong, we strive to give you ways to update it quickly or to delete it – unless we have to keep that information for legitimate business or legal purposes. Subject to applicable law, you may obtain a copy of personal information we maintain about you or you may update or correct inaccuracies in that information by contacting us. To help protect your privacy and maintain security, we will take steps to verify your identity before granting you access to the information. In addition, if you believe that personal information we maintain about you is inaccurate, subject to applicable law, you may have the right to request that we correct or amend the information by contacting us as indicated in the How to Contact Us section below.

 

  • Privacy Rights Specific to EU Residents

The European Union’s General Data Protection Regulation (“GDPR”), and corresponding legislation in the United Kingdom and Switzerland, provide European, Switzerland and United Kingdom residents with certain rights in connection with Personal Information you have shared with us. If you are resident in the European Economic Area, you may have the following rights:

  1. The right to be informed. You are entitled to be informed of the use of your Personal Information. This Privacy Policy provides such information to you.
  2. The right of access. You have the right to request a copy of your Personal Information which we hold about you.
  3. The right of correction: You have the right to request correction or changes of your Personal Information if it is found to be inaccurate or out of date.
  4. The right to be forgotten: You have the right to request us, at any time, to delete your Personal Information from our servers and to erase your Personal Information when it is no longer necessary for us to retain such data. Note, however, that deletion of your Personal Information will likely impact your ability to use our services.
  5. The right to object (opt-out): You have the right to opt-out of certain uses of your Personal Information, such as direct marketing, at any time.
  6. The right to data portability: You have the right to a “portable” copy of your Personal Information that you have submitted to us. Generally, this means your right to request that we move, copy or transmit your Personal Information stored on our servers / IT environment to another service provider’s servers / IT environment.
  7. The right to refuse to be subjected to automated decision making, including profiling: You have the right not to be subject to a decision and insist on human intervention if the decision is based on automated processing and produces a legal effect or a similarly significant effect on you.
  8. The right to lodge a complaint with a supervisory authority. You have the right to lodge complaints about our data processing activities by filing a complaint with us or with the relevant Supervisory Authority. A list of Supervisory Authorities is available here:  http://ec.europa.eu/justice/data-protection/bodies/authorities/index_en.htm.

 

To exercise these rights, please submit a request by emailing privacy@vacmobile.app. Please be as specific as possible in relation to the personal information you wish to access. Please note that we may ask you to verify your identity and request before taking further action on your request. Once we receive your request, we will review it, determine whether we can verify your identity, and process the request accordingly. If we need additional information to verify your identity, we will let you know. We may respond to your request by letter, email, telephone or any other suitable method. If you completely delete all such information, then your account may become deactivated. We may retain an archived copy of your records as required by law, to comply with our legal obligations, to resolve disputes, to enforce our agreements or for other legitimate business purposes. We will respond to your request within 30 days of receipt, or notify you if we require additional time.

 

Our Opt-in/Opt-out Policy

By providing an email address on the Vacmobile Sites or Services, you agree that we may contact you in the event of a change in this Privacy Policy, to provide you with any Service related notices, or to provide you with information about our events, invitations, or related educational information.

For purposes of this Privacy Policy, “opt-in” is generally defined as any affirmative action by a User to submit or receive information, as the case may be.

We currently provide the following opt-out opportunities:

  1. At any time, you can follow a link provided in offers, newsletters or other email messages (except for e-commerce confirmation or service notice emails) received from us or a Vacmobile Partner to unsubscribe from the service.
  2. At any time, you can contact us through privacy@vacmobile.app or the address or telephone number provided below to unsubscribe from the service and opt-out of our right per your consent under the terms of this Privacy Policy to share your Personal Data.

 

Notwithstanding anything else in this Privacy Policy, please note that we always reserve the right to contact you in the event of a change in this Privacy Policy, or to provide you with any service related notices.

 

Third Party Links

The Sites may contain links to webpages operated by parties other than Vacmobile. We do not control such websites and are not responsible for their contents or the privacy policies or other practices of such websites. Our inclusion of links to such websites does not imply any endorsement of the material on such websites or any association with their operators. Further, it is up to the User to take precautions to ensure that whatever links the User selects or software the User downloads (whether from this Site or other websites) is free of such items as viruses, worms, trojan horses, defects and other items of a destructive nature. These websites and services may have their own privacy policies, which the User will be subject to upon linking to the third party’s website. Vacmobile strongly recommends that each User review the third party’s terms and policies.

 

International Transfer

We may, directly or indirectly through third-party entities around the world, process, store, and transfer the information you provide, including your Personal Information, as described in this Privacy Policy. Specifically, the information and Personal Information that we collect may be transferred to, and stored at, a location outside of your jurisdiction. It may also be processed by staff operating outside of your jurisdiction who work for us or for one of the organizations outlined in this Privacy Policy in connection with the activities outlined in this Privacy Policy. By submitting your information and Personal Information using the Sites, you agree to this transfer, storing or processing. We will take all steps necessary to ensure that your Personal Information is treated securely and in accordance with this Privacy Policy. We have put in place commercially reasonable technical and organizational procedures to safeguard the information and Personal Information we collect on the Sites.

 

How We Protect Personal Data

Vacmobile maintains administrative, technical and physical safeguards designed to protect the User’s Personal Data and information against accidental, unlawful or unauthorized destruction, loss, alteration, access, disclosure or use. We implement appropriate technical and organizational measures to ensure a level of security appropriate to the risk, taking into account technological reality, cost, the scope, context and purposes of processing weighted against the severity and likelihood that the processing could threaten individual rights and freedoms. For example, we restrict access to personal information to Vacmobile employees, contractors, business partners and agents who need to know that information in order to operate, develop or improve our services. These individuals are bound by confidentiality obligations and may be subject to discipline, including termination and criminal prosecution, if they fail to meet these obligations. We use commercially reasonable security measures such as encryption, firewalls, and Secure Socket Layer software (SSL) or hypertext transfer protocol secure (HTTPS) to protect Personal Data.

If Vacmobile collects account information for payment or credit, Vacmobile will use the information only to complete the task for which the account information was offered.

 

Children

The Site is not intended for use by children.  We do not intentionally gather Personal Data persons who are under the age of 13.  If a child has provided us with Personal Data, a parent or guardian of that child may contact us to have the information deleted from our records. If you believe that we might have any information from a child under the age of 13 in the applicable jurisdictions, please contact us at privacy@vacmobile.app.  If we learn that we have inadvertently collected the personal information of a child under the minimum age depending on jurisdiction, we will take steps to delete the information as soon as possible.

 

Direct Marketing and “Do Not Track” Signals

Vacmobile does not respond to Do Not Track (DNT) signals. However, some third party sites do keep track of your browsing activities when they serve you content, which enables them to tailor what they present to you. If you are visiting such sites, your browser may include controls to block and delete cookies, web beacons and similar technologies, to allow you to opt out of data collection through those technologies.

California residents are entitled to contact us to request information about whether we have disclosed personal information to third parties for the third parties’ direct marketing purposes.  Vacmobile does not disclose personal information to third parties for their direct marketing purposes. California users may request further information about our compliance with this law by e-mailing us at the address listed in the “How to Contact Us” section.

 

Changes to this Privacy Policy

Our Privacy Policy may change from time to time. We will not reduce your rights under this Privacy Policy without your explicit consent. We will post any privacy policy changes on this page and, if the changes are significant, we will provide a more prominent notice (including, for certain services or programs, email notification or privacy policy changes). We will also keep prior versions of this Privacy Policy in an archive for your review.

 

How to Contact Us

If you have any specific questions about this Privacy Policy, you can contact us via email or phone or by writing to us at the address below:

Send e-mail to: privacy@vacmobile.app

Send mail to our address:

Vacmobile Corp.
Attn: Privacy Policy Inquiry
2972 Webb Bridge Road
Alpharetta, GA 30009