PRIVACY POLICY
Guardian Zone Services and Mobile Application Privacy Policy
Revised: June 18, 2020
Effective: June 18, 2020
Section I. General Provisions Regarding Privacy
Guardian Zone, LLC (“Guardian Zone,” “we,” “us”) has adopted the following policies regarding your privacy. We provide this Guardian Zone Services and Mobile Application Privacy Policy (or “Privacy Policy”) to inform you of our policies and procedures regarding the collection, use and disclosure of personal information we receive from users of our website at Guardian Zone.com (the “Site”) and the Guardian Zone Android and iOS mobile device applications (the “App”) or any other products provided by Guardian Zone, LLC. The Site, App, and all other Guardian Zone services are collectively referred to as the Guardian Zone Services (“Services.”) This Privacy Policy applies only to information that you provide to us through use of the Services or by direct contact with a representative of Guardian Zone. By using the Services, you are agreeing to be bound by these policies. Our privacy policy was updated effective June 18, 2020 and in the future will continue to be updated as necessary. We will notify you of any material changes and all updates to the privacy policy will be posted on the Site and within the mobile Application.
This this Guardian Zone Services and Mobile Application Privacy Policy includes four sections. The instant Section I states our General Provisions Regarding Privacy. Section II sets forth the Detailed Privacy Policy. Section III is the Guardian Zone Privacy Policy for Children Under Age 13. Section IV supplements Sections I – III, and is an additional Guardian Zone Privacy Notice for California Residents.
Key Terms
“Services.” The Guardian Zone Services (“Services”) include, collectively, the website at guardianzone.com (the “Site”) and the Guardian Zone Android and iOS mobile device applications (the “App”), and any services or products provided by Guardian Zone, LLC.
“User.” Any individual who is in contact with the Services, whether registered or not. All Users are bound by these Terms and Conditions whether registered or not.
“Registered User.” Any individual who has contacted the Services, provided the required information and completed the steps necessary to create an account.
“Venue.” Any Registered User who has created and manages a property listed in and contactable through the Services whether the owner, employee or authorized representative of the owner of that property. By creating and publishing a Property within the Services Venues indicate and attest they own or have obtained the right to operate on and transmit notifications related to the listed property.
“Property.” A property which has been input into the Services and is associated with a Venue.
“PII.” “Personally Identifiable Information”. Information about you that can be used to contact or identify you, and information on your use of, and activities through, our Services that may be connected with you
1. The PII We Collect. In the course of using the Services, you may provide us with PII. PII that we collect may include, but is not limited to, your first and last name, password, mobile number, email address, billing information, vehicle information, details regarding any transaction you make or action you take using the Services, location, and information voluntarily given to us by you. PII may also include information you supply to us concerning your location, preferences, and interests expressed in the course of use of the Services. It is not compulsory that you provide any of the above information; however, if you choose not to, you will not be able to register as a user of the Services and will not have access to certain information and features or capability to conduct any transactions with other Guardian Zone users.
1.1 Log Data. Our servers automatically record information about how Users (both account holders and non-account holders) use our Services. This information, referred to as “Log Data,” may include, but is not limited to, your computer’s Internet Protocol address, browser type, operating system, the web page you were visiting before you accessed our Services, the pages or features of our Services that you browsed and the time spent on those pages or features, search terms, the links on our Services that you clicked, and statistics related to your use of the Services. We use Log Data to administer the Services and to analyze (or have third parties analyze) the Log Data to improve, customize, and enhance our Services by expanding their features and functionality and tailoring them to our users’ needs and preferences.
1.2 Cookies. Like many websites, we also use automated data collection tools such as “cookies” and “web beacons” to collect certain information. “Cookies” are small text files that we transfer to your computer’s hard disk for record-keeping purposes. We use “persistent cookies” to save your registration ID and login password for future logins to the Site; and we use “session ID cookies” to enable certain features of the Site, to better understand how you interact with the Site and to monitor aggregate usage and web traffic routing on the Site. You can instruct your browser, by changing its options, to stop accepting cookies or to prompt you before accepting a cookie from the websites you visit. If you do not accept cookies, however, you may not be able to use all portions of the Site or all functionality of our Services. Note that this Privacy Policy covers only our use of cookies and does not include use of cookies by third parties.
1.3 Web Beacons. “Web Beacons” (also known as clear gifs) are tiny graphics with a unique identifier that may be included on our Services for several purposes, including to deliver or communicate with cookies, to track and measure the performance of our Services, to monitor how many visitors view our Services, and to monitor the effectiveness of our advertising. Unlike cookies, which are stored on the user’s hard drive, web beacons
are typically embedded invisibly on web pages (or in an e-mail).
1.4 Location Information. When you use the Services, we may collect and store information about your location by converting your IP address into a geographic location, or by accessing your device’s GPS coordinates or course location if you enable location services on your device. We may use location information to improve and personalize our Services for you. You may opt to not allow us to use your device’s location, but doing so may prevent you from being able to use some or all of features provided by the Services.
1.5 Property Data. In order to become a Venue, you will be required to create a Property. In order to create and publish a Property you will be required input information specific to the Property including but not limited to address, property type, business name, business type, property features, and hours of operation.
1.6 User Ratings. The Services provides a means for other Registered Users to rate your performance and behavior as a Venue or User. We will aggregate and store this information.
1.7 How We Use PII. PII is used for the following purposes: (a) to provide and improve our Services, services, features, and content, (b) to administer your account and your use of our Services, (c) to enable Users to enjoy and easily navigate the Site and Mobile Application, (d) to better understand your needs and interests, (e) to fulfill requests you may make, (f) to personalize your experience, (g) to provide or offer software updates and product announcements, and (h) to provide you with further information and offers from us or our partners, and to market, advertise, and inform you about products and services that we may deem relevant to you. These may include products and services offered directly by us or any entity with which have formed a business relationship. This information and these communications may come to you in the form of email, mobile messaging, telephone contact, or direct mail depending upon the preferences which you indicate to us within your account.
If you decide at any time that you no longer wish to receive such communications, please follow the instructions provided in any of the communications or update your “user settings” information. (See “Changing or Deleting Information,” below.) We use information we obtain by technical means (such as the automatic recording performed by our servers or through the use of cookies) for the above purposes and in order to monitor and analyze use of the Services for behavioral information and for technical administration of the Services, to increase the functionality and user-friendliness of the Services, to better tailor the Services to your needs, to generate and derive useful data and information concerning the interests, characteristics, and website and Mobile App use behavior of our users, and to verify that visitors to the Services meet the criteria required to process their requests.
2. Information Sharing and Disclosure.
2.1 Information We Disclose with Your Consent or at Your Request. We will display portions of your PII in your profile page and elsewhere through the Services according to the preferences you set in your account. Any information you choose to provide should reflect how much you want all other Guardian Zone users to know about you. We may share your PII with third-party sites or platforms, such as social networking sites, if you have requested that we do so.
2.2 Information Shared with Services Providers and Analysts. We may engage third- party services providers to work with us to administer and provide the Services. These third- party services providers may have access to your PII only for the purpose of performing services on our behalf and are expressly obligated by agreement, statute and/or applicable regulations not to disclose or use your PII for any other purpose. We may share aggregated information and non-identifying information with third parties for purposes that include, but are not limited to, industry research and analysis, demographic profiling, and other similar purposes.
2.3 Information Disclosed in Connection with Business Transactions. Information that we collect from our Users, including PII, is considered to be a business asset. As a result, if we go out of business, enter bankruptcy, or are acquired as a result of a transaction such as a merger, acquisition, or asset sale, your PII may be disclosed or transferred to the third-party acquirer in connection with the transaction. In such an event we will take the steps we deem appropriate to ensure that your privacy rights remain protected.
2.4 Information Disclosed to Protect Us and Others. We cooperate with government and law enforcement officials or private parties to enforce and comply with the law. We may disclose any information about you to government or law enforcement officials, or private parties as we, in our sole discretion, believe necessary or appropriate to: (a) respond to claims, or legal process (including subpoenas); (b) protect our property, rights, safety, and the property, rights, and safety of a third party or the public in general; and (c) stop any activity that we consider illegal, unethical, or legally actionable.
3. Changing or Deleting Your Information. All Registered Users may review, update, correct, or delete the PII provided in their registration or account profile by contacting us at [email protected] or by changing their user profile information. If you completely delete all such information, then your account may become deactivated.
4. Security. We take reasonable administrative, physical, and electronic measures designed to protect the information that we collect from or about you (including your PII) from unauthorized access, use, or disclosure. Please be aware, however, that no method of transmitting information over the Internet or storing information is completely secure. Accordingly, we cannot guarantee the absolute security of any information. By agreeing to our terms of services, you agree to indemnify and hold Guardian Zone and any affiliated entities harmless, in the event that your PII is accessed by an unauthorized party as a result of using the Services.
5. Our General Policy Regarding Children. Section III of this Guardian Zone Services and Mobile Application Privacy Policy sets forth our specific policy to safeguard the privacy of children in relation to providing the Services. The Services are not directed to children under the age of 18. We do not knowingly collect personally identifiable information from children under the age of 16. Where a child under the age of 13 is identified in the course of attempting to create a Registered User account, or as having access to a Registered User account without express parental authorization, as necessary for any user to be granted authorization to make ordinary use of the Guardian Zone Services including personally identifiable information such as geo-location information for tracking a Registered User’s wireless device in providing the Guardian Zone Services, the attempted registration will not be completed to establish the Registered User account enabling such ordinary use of the Guardian Zone Services in the absence of express parental authorization, such authorization is conditioned upon, and requires, both confirmation of the identity of the parent and actual delivery of express authorization by the identified parent to Guardian Zone LLC, in compliance with applicable law including the Children’s Online Privacy Protections Act (“COPPA”), and where any instance of a child under age 13 accessing the Services without express parental authorization is identified, such Registered User account will be blocked until an identified parent is notified and express parental authorization of the identified parent is received, and any PII will be deleted from our files. If a parent or guardian becomes aware that his or her child has provided us with PII without their consent, he or she should contact us at [email protected]. If we become aware that a child under 16 has provided us with PII, we will delete such information from our files.
6. Contacting Us. If you have any questions about this Privacy Policy, please contact us at [email protected].
Section II. Detailed Privacy Policy
Introduction
Guardian Zone LLC (“Company” or “We”) respects your privacy and is committed to protecting it through our compliance with this Guardian Zone Services and Mobile Application Privacy Policy (“policy”). The Detailed Privacy Policy set forth in this Section II prescribes:
• The types of information Guardian Zone LLC may collect or that you may provide when you purchase, download, install, register with, access, or use the Guardian Zone Application (the “App”), the Guardian Zone website (www.guardianzone.com) in relation to the App, and any other URLs operated by Guardian Zone LLC (if any) to provide services for users in relation to the App (collectively, “Guardian Zone Services”).
• Our practices for collecting, using, maintaining, protecting, and disclosing that information.
This policy applies only to information we collect in this App and in related Guardian Zone Services, which are provided in relation to usage of the App, and in email, text, and other electronic communications sent through or in connection with this App and Guardian Zone Services including www.guardianzone.com.
This policy DOES NOT apply to information that:
• We collect offline.
• Any third-party websites you may access through this App.
• You provide to or is collected by any third party.
Other third parties may have their own privacy policies, which we encourage you to read before providing information on or through them.
Please read this policy carefully to understand our policies and practices regarding your information and how we will treat it. If you do not agree with our policies and practices, do not download, register with, or use this App or any of the related Guardian Zone Services. By downloading, registering with, or using this App and related Guardian Zone Services, you agree to this privacy policy. This policy may change from time to time (see subsection “Changes to Our Privacy Policy”). Your continued use of this App and related Guardian Zone Services after we revise this policy means you accept those changes, so please check the policy periodically for updates.
Children Under the Age of 13
Section III of this policy, titled “Guardian Zone Privacy Policy for Children Under Age 13” governs our interactions with children under age 13. The App and Guardian Zone Services are not intended for children under 13 years of age, and we do not knowingly collect personal information from children under 13. If we learn we have collected or received personal information from a child under 13 without verification of parental consent, we will delete that information. If you believe we might have any information from or about a child under 13, please contact us at [email protected].
California residents under 16 years of age may have additional rights regarding the collection and sale of their personal information. Please see Section IV of this policy, titled “Guardian Zone California Privacy Rights Notice” for more information.
Information We Collect and How We Collect It
We collect information from and about users of our App:
• Directly from you when you provide it to us.
• Automatically when you use the App.
Information You Provide to Us
When you download, register with, or use this App, we may ask you provide information:
• By which you may be personally identified, such as name, age, postal address, email address, telephone number, wireless device identifiers, your wireless service provider, your wireless device location and tracked locations, answers to questions the App may present to you, interactions with other users, interactions with security personnel of Venues and events, interactions with public safety personnel, your panic button interactions, communications to us by you, any other identifier by which you may be contacted online or offline (“personal information”).
• That is about you but individually does not identify you, such as your brand or model of wireless device.
This information includes:
• Information that you provide by filling in forms in the App. This includes information provided at the time of registering to use the App, subscribing to our Services, posting material, and requesting further services. We may also ask you for information when you enter a contest or promotion sponsored by us, and when you report a problem with the App.
• Records and copies of your correspondence (including email addresses and phone numbers), if you contact us.
• Your responses to surveys that we might ask you to complete for research purposes.
• Details of transactions you carry out through the App and of the fulfillment of your orders. You may be required to provide financial information before placing an order through the App.
• Your search queries on the App.
• Your communications with Venue and event security personnel and public safety personnel.
• Your panic button communications.
• Your device location information.
You may also provide information for publication or display (“Posted”) on public areas of the app or www.guardianzone.com (collectively, “User Contributions”). Your User Contributions are Posted and transmitted to others at your own risk. Although you may set certain privacy settings for such information by logging into your account profile and adjusting your privacy settings, please be aware that no security measures are perfect or impenetrable. Additionally, we cannot control the actions of third parties with whom you may choose to share your User Contributions. Therefore, we cannot and do not guarantee that your User Contributions will not be viewed by unauthorized persons.
Automatic Information Collection and Tracking
When you download, access, and use the App, it may use technology to automatically collect:
• Usage Details. When you access and use the App, we may automatically collect certain details of your access to and use of the App, including traffic data, location data, logs, and other communication data and the resources that you access and use on or through the App.
• Device Information. We may collect information about your mobile device and internet connection, including the device’s unique device identifier, IP address, operating system, browser type, mobile network information, and the device’s telephone number.
• Stored Information and Files. The App also may access metadata and other information associated with other files stored on your device. This may include, for example, photographs, audio and video clips, personal contacts, and address book information.
• Location Information. This App collects real-time information about the location of your device. This includes real-time information about the interactions of your wireless device with geofences and communications network resources, and other wireless devices of users.
If you do not want us to collect this information do not download the App or delete it from your device. For more information, see the section titled “How We Use and Store Your Information.” Note, however, that opting out of the App’s collection of location information will disable its location-based features.
Information Collection and Tracking Technologies
The technologies we use for automatic information collection may include:
• Cookies (or mobile cookies). A cookie is a small file placed on your smartphone. It may be possible to refuse to accept mobile cookies by activating the appropriate setting on your smartphone. However, if you select this setting you may be unable to access certain parts of our App.
• Web Beacons. Pages of the App and our emails] may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit the Company, for example, to count users who have visited those pages [or opened an email and for other related app statistics (for example, recording the popularity of certain app content and verifying system and server integrity).
• Geofences. The App may interact with information about geofences, and may cause your device to provide information about interactions with geofences.
Third-Party Information Collection
When you use the App or its content, certain third parties may use automatic information collection technologies to collect information about you or your device. These third parties may include:
• Advertisers, ad networks, and ad servers.
• Analytics companies.
• Your mobile device manufacturer.
• Your mobile service provider.
• Venues and event operators.
These third parties may use tracking technologies to collect information about you when you use this app. The information they collect may be associated with your personal information or they may collect information, including personal information, about your online activities over time and across different websites, apps, and other online services websites. They may use this information to provide you with interest-based (behavioral) advertising or other targeted content.
We do not control these third parties’ tracking technologies or how they may be used. If you have any questions about an advertisement or other targeted content, you should contact the responsible provider directly. For information about how you can opt out of receiving targeted advertising from many providers, see the subsection of this policy titled “Your Choices About Our Collection, Use and Disclosure of Your Information.”
How We Use Your Information
We use information that we collect about you or that you provide to us, including any personal information, to:
• Provide you with the App and its contents, and any other information, products or services that you request from us.
• Fulfill any other purpose for which you provide it.
• Give you notices about your account, including expiration and renewal notices.
• Carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collection.
• Notify you when App updates are available, and of changes to any products or services we offer or provide though it.
The usage information we collect helps us to improve our App and to deliver a better and more personalized experience by enabling us to:
• Estimate our audience size and usage patterns.
• Store information about your preferences, allowing us to customize our App according to your individual interests.
• Speed up your searches.
• Recognize you when you use the App.
We use location information we collect to track the location and movement of your device, and for communications with you, your designated contacts, Venue and event security personnel, and public safety personnel.
We may also use your information to contact you about our own and third parties goods and services that may be of interest to you. If you do not want us to use your information in this way, please adjust your user preferences in your account profile. For more information, see the subsection of this policy titled “Your Choices About Our Collection, Use and Disclosure of Your Information.”
We may use the information we collect to display advertisements to our advertisers’ target audiences. Even though we do not disclose your personal information for these purposes without your consent, if you click on or otherwise interact with an advertisement, the advertiser may assume that you meet its target criteria.
Disclosure of Your Information
We may disclose aggregated information about our users, and information that does not identify any individual, without restriction.
In addition, we may disclose personal information that we collect or you provide:
• To our subsidiaries and affiliates.
• To contractors, service providers, and other third parties we use to support our business and who are bound by contractual obligations to keep personal information confidential and use it only for the purposes for which we disclose it to them.
• To a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of Guardian Zone LLC’s assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by Guardian Zone LLC about our App users is among the assets transferred.
• To third parties to market their products or services to you if you have not opted out of these disclosures. We contractually require these third parties to keep personal information confidential and use it only for the purposes for which we disclose it to them. For more information, see the subsection of this policy titled “Your Choices About Our Collection, Use and Disclosure of Your Information.”
• To fulfill the purpose for which you provide it. For example, if you give us an email address to use the “email a friend” feature of our Website or App, we will transmit the contents of that email and your email address to the recipients.
• For any other purpose disclosed by us when you provide the information.
• With your consent.
• For locating your device and you, when you are co-located with your device.
• To comply with any public safety investigation, court order, law, or legal process, including to respond to any government or regulatory request.
• To enforce our rights arising from any contracts entered into between you and us, including the Guardian Zone Terms and Conditions. If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of Guardian Zone LLC, our customers or others. This includes exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction.
Your Choices About Our Collection, Use, and Disclosure of Your Information
We strive to provide you with choices regarding the personal information you provide to us. This section describes mechanisms we provide for you to control certain uses and disclosures of over your information.
• Tracking Technologies. You can set your browser to refuse all or some browser cookies, or to alert you when cookies are being sent. You can choose whether or not to allow the App to collect information through other tracking technologies by adjusting your personal user settings at www.guardianzone.com to select “opt-out.” If you disable or refuse cookies or block the use of other tracking technologies, some parts of the App may then be inaccessible or not function properly.
• Location Information. You can choose whether or not to allow the App to collect and use real-time information about your device’s location through the device’s privacy settings. If you block the use of location information, the App may become inaccessible or not function properly.
• Promotion by the Company. If you do not want us to use your email address/device phone number/contact information to promote our own or third parties’ products or services, you can opt-out by selecting “opt-out” in your user settings. You can also always opt-out by logging into the App and adjusting your user preferences in your account profile by checking or unchecking the relevant boxes or by sending us an email stating your request to [email protected].
• Targeted Advertising by the Company. If you do not want us to use information that we collect or that you provide to us to deliver advertisements according to our advertisers’ target-audience preferences, you can opt-out by selecting “opt-out” in your user settings. You can also always adjust your user advertising preferences in your account profile by checking or unchecking the relevant boxes or by sending us an email stating your request to [email protected].
• Disclosure of Your Information for Third-Party Advertising and Marketing. If you do not want us to share your personal information with unaffiliated or non-agent third parties for advertising and marketing purposes, you can opt-out by selecting “opt-out” in your user settings. You can also always opt-out by logging into the App and adjusting your user preferences in your account profile by checking or unchecking the relevant boxes or by sending us an email stating your request to [email protected].
We do not control third parties’ collection or use of your information to serve interest-based advertising. However these third parties may provide you with ways to choose not to have your information collected or used in this way. You can opt out of receiving targeted ads from members of the Network Advertising Initiative (“NAI”) on the NAI’s website.
California residents may have additional personal information rights and choices. Please see the section titled “Guardian Zone California Privacy Rights Notice” for more information.]
Data Security
We have implemented measures designed to secure your personal information from accidental loss and from unauthorized access, use, alteration, and disclosure. All information you provide to us is stored on our secure servers behind firewalls.
The safety and security of your information also depends on you. Where we have given you (or where you have chosen) a password for access to certain parts of our App, you are responsible for keeping this password confidential. We ask you not to share your password with anyone. We urge you to be careful about giving out information in public areas of the App like message boards. The information you share in public areas may be viewed by any user of the App.
Unfortunately, the transmission of information via the internet and mobile platforms is not completely secure. Although we do our best to protect your personal information, we cannot guarantee the security of your personal information transmitted through our App. Any transmission of personal information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures we provide.
Changes to Our Privacy Policy
We may update our privacy policy from time to time. If we make material changes to how we treat our users’ personal information, we will post the new privacy policy on this page with a notice that the privacy policy has been updated and notify you by email and/or text message to the primary email address and/or phone number specified in your account and/or via an in-App alert the first time you use the App after we make the change.
The date the privacy policy was last revised is identified at the top of the page. You are responsible for ensuring we have an up-to-date active and deliverable email address and/or phone number for you and for periodically visiting this privacy policy to check for any changes.
Contact Information
To ask questions or comment about this privacy policy and our privacy practices, contact us at: Guardian Zone LLC
via email: [email protected]
or via our toll-free number: 1-866-866-8731
To register a complaint or concern, please notify us in writing that you have a complaint or concern.
Section III. Guardian Zone Privacy Policy for Children Under Age 13
Guardian Zone Privacy Policy for Children Under Age 13
Last modified: June 18, 2020
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 the Guardian Zone Services. The “Services” are defined in the definitions of the Guardian Zone Terms & Conditions.
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. Terms that are defined in the general privacy policy have the same meanings as used in this Privacy Policy for Children Under the Age of 13.
Information We Collect from Children
Children can access many parts of the Guardian Zone Services and its content and use many of its features without providing us with personal information. However, some content and features are available only to registered users and certain information, including personal information, is collected from them. In addition, we use certain technologies, such as cookies, to automatically collect information from our users (including children) when they visit or use the Guardian Zone Services.
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.
Information We Collect Directly. A child must provide us with the following information to register with the Guardian Zone Services: the child’s first name, birth date, email address, text message account such as mobile phone number, parent’s names, and at least one parent’s email address and/or parent’s mobile phone number. We also require the child to create a member name and password. We may request additional information from your child, but this information is optional. We specify whether information is required or optional when we request it.
Your Express Parental Consent is Required for Activating Registration and Authorizing Guardian Zone Services to Track the Device Location(s) and Use Location Tracking Information for Wireless Devices of Children Under Age 13. When a child under age 13 is identified as a prospective user of the Guardian Zone Services when attempting to register for a Guardian Zone User Account, your child must provide your email address and/or mobile phone number before his or her registration will be completed to authorize your child to make use of the Guardian Zone App. If you do not wish to authorize your child to make use of the App, then it is within your sole discretion to decline to provide your authorization. Declining to provide your express authorization, following a series of automated attempts by Guardian Zone LLC to contact you via email or text messaging and requesting your express authorization, will cause the location tracking feature of the Guardian Zone App to remain disabled.
We enable registered users to communicate with others on or through the Guardian Zone Services through chat, email, text messaging, and posting to public areas of the Guardian Zone Services (“Social Features”). The nature of these features allows children to disclose personal information about themselves. We do not monitor or review this content before it is posted, and we do not control the actions of third parties with whom your child shares his or her information. We encourage parents to educate their children about safe use of mobile applications and the internet, and to monitor their children’s use of social features.
Automatic Information Collection and Tracking. We use technology to automatically collect information from our users, including children, when they access and navigate through the Guardian Zone Services and use certain of its features. The information we collect through these technologies may include:
• One or more persistent identifiers that can be used to recognize a user over time and across different websites and online services[SPECIFIC IDENTIFIER].]
• Information that identifies a device’s location (geolocation information).
We also may combine non-personal information we collect through these technologies with personal information about you or your child that we collect online.
For information about our automatic information collection practices, including how you can opt out of certain information collection, see the subsections “Automatic Information Collection and Tracking” and “Choices About How We Use and Disclose Your Information” of our Detailed Privacy Policy (Section II., above).
How We Use Your Child’s Information
We use the personal information we collect from your child to:
• register him or her with the Guardian Zone Services;
• communicate with him or her about activities or features of the Guardian Zone Services that may be of interest;
• track his or her performance in activities;
• track his or her device’s location;
• track his or her device’s communications to us, you or Venues.
We use the information we collect automatically through technology (see Automatic Information Collection and Tracking) and other non-personal information we collect to improve our Guardian Zone Services and to deliver a better and more personalized experience by enabling us to:
• Estimate our audience size and usage patterns.
• Store information about the child’s preferences, allowing us to customize the content according to individual interests.
• Speed up your searches.
We use geolocation information we collect to enable important location specific features of the Guardian Zone Services, such as locating his or her device, determining interactions with geofences, interacting and communicating with Venues or events, communications to his or her device, communications with public safety, event and Venue security personnel, and communications to you.
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 Guardian Zone Services 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 Guardian Zone LLC, our customers or others, including to:
• protect the safety of a child;
• protect the safety and security of the Guardian Zone Services; or
• enable us to take precautions against liability.
• To law enforcement agencies or for an investigation related to public safety.
In addition, if Guardian Zone, LLC is involved in a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of Guardian Zone LLC’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.
Social Features. The Guardian Zone Services offers social features, including: instant messaging, chat, email, posting on message boards, communications with public safety, Venue and event security personnel, and location information, that enable children to communicate with others on our through the Guardian Zone Services. We do not control the types of information your child can send or post through them. We encourage parents to educate their children about safety online and to carefully monitor their children’s use of social features to ensure they do not disclose their personal information through them.
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 [email protected]. 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
A list of all operators that may collect or maintain personal information from children through the Guardian Zone Services is available upon request from [email protected].
Please direct your inquiries about any operator’s privacy practices and use of children’s information to the operator at its contact information provided in the list of all operators available upon request from [email protected].
Section IV. Guardian Zone Privacy Notice for California Residents
Guardian Zone LLC Privacy Notice for California Residents
Effective Date: June 18, 2020
Last Reviewed on: June 18, 2020
This Privacy Notice for California Residents supplements the information contained in Sections I, II and III. Guardian Zone LLC’s and applies solely to all visitors, users, and others who reside in the State of California (“consumers” or “you”). We adopt this notice to comply with the California Consumer Privacy Act of 2018 (CCPA) and any terms defined in the CCPA have the same meaning when used in this Notice.
Information We Collect
Our Guardian Zone Services collect information that identifies, relates to, describes, references, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer, household, or device (“personal information”). Personal information does not include:
• Publicly available information from government records.
• Deidentified or aggregated consumer information.
• Information excluded from the CCPA’s scope, like:
• health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and the California Confidentiality of Medical Information Act (CMIA) or clinical trial data;
• personal information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FCRA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver’s Privacy Protection Act of 1994.
In particular, the Guardian Zone Services have collected the following categories of personal information from its consumers within the last twelve (12) months:
Category
Examples
Collected
A. Identifiers.
A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, Social Security number, driver’s license number, passport number, or other
similar identifiers.
YES
B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code
§ 1798.80(e)).
A name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver’s license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information.
Some personal information included in this category may overlap with other categories.
YES
C. Protected classification characteristics under California or federal law.
Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information).
NO
D. Commercial information.
Records of personal property, products or services purchased, obtained, or considered, or other
purchasing or consuming histories or tendencies.
NO
E. Biometric information.
Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as, fingerprints, faceprints, and voiceprints, iris or
retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data.
NO
F. Internet or other similar
network activity.
Browsing history, search history, information on a consumer’s interaction with a website, application, or
advertisement.
NO
G. Geolocation data.
Physical location or movements.
YES
H. Sensory data.
Audio, electronic, visual, thermal, olfactory, or similar information.
YES
I. Professional or employment-
related information.
Current or past job history or performance evaluations.
NO
J. Non-public education
Education records directly related to a student maintained by an educational institution or party acting
NO
information (per the Family Educational Rights and Privacy Act (20
U.S.C. Section 1232g, 34
C.F.R. Part 99)).
on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records.
K. Inferences
Profile reflecting a person’s preferences,
NO
drawn from
characteristics, psychological trends, predispositions,
other personal
behavior, attitudes, intelligence, abilities, and aptitudes.
information.
We obtain the categories of personal information listed above from the following categories of sources:
• Directly from you. For example, from forms you complete or products and services you purchase.
• Indirectly from you. For example, from observing your actions on our Guardian Zone Services.
• Indirectly from you. For example, from observing the location of your mobile device.
• Indirectly from you. For example, from observing your communications using your wireless mobile device.
Use of Personal Information
We may use or disclose the personal information we collect for one or more of the following purposes:
• To fulfill or meet the reason you provided the information. For example, if you share your name and contact information to request a price quote or ask a question about our products or services, we will use that personal information to respond to your inquiry. If you provide your personal information to purchase a product or service, we will use that information to process your payment and facilitate delivery. We may also save your information to facilitate new product orders or process returns.
• To provide, support, personalize, and develop our Guardian Zone Services.
• To create, maintain, customize, and secure your account with us.
• To process your requests, purchases, transactions, and payments and prevent transactional fraud.
• To provide you with support and to respond to your inquiries, including to investigate and address your concerns and monitor and improve our responses.
• To personalize your experience using the Guardian Zone Services and to deliver content and product and service offerings relevant to your interests, including targeted offers and ads through our Guardian Zone Services, third-party websites, third-party applications, Venues, events, and via email or text message (with your consent, where required by law).
• To help maintain the safety, security, and integrity of our Guardian Zone Services databases and other technology assets, and business.
• For testing, research, analysis, and product development, including to develop and improve our Guardian Zone Services.
• To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.
• As described to you when collecting your personal information or as otherwise set forth in the CCPA.
• To communicate with, and provide information to, security personnel of Venues and events, and public safety personnel.
• To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by us about users of our Guardian Zone Services is among the assets transferred.
We will not collect additional categories of personal information or use the personal information we collected for materially different, unrelated, or incompatible purposes without providing you notice.
Sharing Personal Information
We may disclose your personal information to a third party for a business purpose. When we disclose personal information for a business purpose, we enter a contract that describes the purpose and requires the recipient to both keep that personal information confidential and not use it for any purpose except performing the contract.
We share your personal information with the following categories of third parties:
• Service providers.
• Security personnel of public agencies such as police and paramedics.
• Security personnel of Venues and events.
Disclosures of Personal Information for a Business Purpose
In the preceding twelve (12) months, Company has disclosed the following categories of personal information for a business purpose:
Category A: Identifiers.
Category D: Commercial information. Category G: Geolocation data.
Category H: Sensory data.
We disclose your personal information for a business purpose to the following categories of third parties:
• Service providers.
• Security personnel of Venues and events.
• Public safety personnel.
Sales of Personal Information
In the preceding twelve (12) months, Company has not sold personal information.
Your Rights and Choices
The CCPA provides consumers (California residents) with specific rights regarding their personal information. This section describes your CCPA rights and explains how to exercise those rights.
Access to Specific Information and Data Portability Rights
You have the right to request that we disclose certain information to you about our collection and use of your personal information over the past 12 months. Once we receive and confirm your verifiable consumer request, we will disclose to you:
• The categories of personal information we collected about you.
• The categories of sources for the personal information we collected about you.
• Our business or commercial purpose for collecting or selling that personal information.
• The categories of third parties with whom we share that personal information.
• The specific pieces of personal information we collected about you (also called a data portability request).
• If we sold or disclosed your personal information for a business purpose, two separate lists disclosing:
• sales, identifying the personal information categories that each category of recipient purchased; and
• disclosures for a business purpose, identifying the personal information categories that each category of recipient obtained.
Deletion Request Rights
You have the right to request that we delete any of your personal information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request, we will delete (and direct our service providers to delete) your personal information from our records, unless an exception applies.
We may deny your deletion request if retaining the information is necessary for us or our service provider(s) to:
1. Complete the transaction for which we collected the personal information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, fulfill the terms of a written warranty or product recall conducted in accordance with federal law, or otherwise perform our contract with you.
2. Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
3. Debug products to identify and repair errors that impair existing intended functionality.
4. Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
5. Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et. seq.).
6. Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information’s deletion may likely render impossible or seriously impair the research’s achievement, if you previously provided informed consent.
7. Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
8. Comply with a legal obligation.
9. Make other internal and lawful uses of that information that are compatible with the context in which you provided it.
Exercising Access, Data Portability, and Deletion Rights
To exercise the access, data portability, and deletion rights described above, please submit a verifiable consumer request to us by either:
• Emailing us at [email protected], or
• Visiting www.guardianzone.com.
Only you, or someone legally authorized to act on your behalf, may make a verifiable consumer request related to your personal information. You may also make a verifiable consumer request on behalf of your minor child. To designate an authorized agent, visit www.guardianzone.com.
You may only make a verifiable consumer request for access or data portability twice within a 12-month period. The verifiable consumer request must:
• Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative, which may include:
• Identity verification information provided by you when registering to use the Guardian Zone Services;
• Your name and the location of your wireless device at the day and time you knowingly interacted or intended to interact with the Guardian Zone Services, the name of your major wireless service provider, the model of your wireless device, and either or both of: an identifier assigned by the manufacturer of your device or identifier assigned for your wireless device by your wireless service provider.
• Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.
We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you.
Making a verifiable consumer request does not require you to create an account with us. However, we do consider requests made through your password protected account sufficiently verified when the request relates to personal information associated with that specific account.
We will only use personal information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.
We do not sell your personal information.
Response Timing and Format
We endeavor to respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time (up to 90 days), we will inform you of the reason and extension period in writing.
If you have an account with us, we will deliver our written response to that account. If you do not have an account with us, we will deliver our written response by mail or electronically, at your option.
Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request’s receipt. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your personal information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance.
We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.
Personal Information Sales Opt-Out and Opt-In Rights
If you are 16 years of age or older, you have the right to direct us to not sell your personal information at any time (the “right to opt-out”). We do not sell the personal information of consumers we actually know are less than 16 years of age, unless we receive affirmative authorization (the “right to opt-in”) from either the consumer who is at least 13 but not yet 16 years of age, or the parent or guardian of a consumer less than 13 years of age. Consumers who opt-in to personal information sales may opt-out of future sales at any time.
To exercise the right to opt-out, you (or your authorized representative) may submit a request to [email protected]
Once you make an opt-out request, we will wait at least twelve (12) months before asking you to reauthorize personal information sales. However, you may change your mind and opt back in to personal information sales at any time by submit a request to [email protected].
You do not need to create an account with us to exercise your opt-out rights. We will only use personal information provided in an opt-out request to review and comply with the request.
Non-Discrimination
We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not:
• Deny you goods or services.
• Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.
• Provide you a different level or quality of goods or services.
• Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.
However, we may offer you certain financial incentives permitted by the CCPA that can result in different prices, rates, or quality levels. Any CCPA-permitted financial incentive we offer will reasonably relate to your personal information’s value and contain written terms that describe the program’s material aspects. Participation in a financial incentive program requires your prior opt in consent, which you may revoke at any time. We currently do not provide financial incentives for your opt-in consent.
Changes to Our Privacy Notice
We reserve the right to amend this privacy notice at our discretion and at any time. When we make changes to this privacy notice, we will post the updated notice on the Website and update the notice’s effective date. Your continued use of our Guardian Zone Services following the posting of changes constitutes your acceptance of such changes.
Contact Information
If you have any questions or comments about this notice, the ways in which Guardian Zone LLC collects and uses your information described here [and in the Privacy Policy], your choices and rights regarding such use, or wish to exercise your rights under California law, please do not hesitate to contact us at:
Phone: 1-866-866-8731
Website: www.guardianzone.com
Email: [email protected]
Postal Address:
Guardian Zone LLC Attn: Privacy Support
4843 Colleyville Blvd #251-155
Colleyville, TX 76034
