ATTENTION: PLEASE READ THIS RAYVN U.S. INC. PRIVACY POLICY (“PRIVACY POLICY”) CAREFULLY. THIS PRIVACY POLICY PERTAINS TO ACCESSING, DOWNLOADING, OR USING RAYVN’S WEB-BASED SUBSCRIPTON SITE (“SUBSCRIPTION SITE”), AND THE RAYVN MOBILE APPLICATION (“APP”), AND ACCESSING ANY ASSOCIATED CONTENT, SUCH AS EMAIL FEEDS OR OTHER RELATED SERVICES PROVIDED BY RAYVN (TOGETHER, THE “SUBSCRIPTION SERVICE”), INCLUDING ALL CONTENT AVAILABLE THROUGH THE SUBSCRIPTION SERVICE.

The Subscription Service is operated by Rayvn U.S. Inc., P.O. Box 6699, Bozeman, MT 59771 (“We” or “Rayvn”). This Privacy Policy describes the information collected through the use by our Customers (“Customers”) and the use by their Users (“User”) of the Subscription Service, how We use such information, how We share it, how We protect it, and the choices Customers and Users can make about their information. This Privacy Policy is not a contract and does not create any legal rights or obligations.

Customers and Users who do not agree with our policies and practices must not access or use the Subscription Service.

To provide the Subscription Site and the App, We and our Customers share personal information We collect from Users.

Unless explicitly stated otherwise, any new features that augment or enhance the current Subscription Service shall be subject to this Privacy Policy.

I.              Information We Collect

We collect information from Customers and Users when they use the Subscription Service, contact or interact with us, and voluntarily provide us with their comments and other content in connection with using the Subscription Service, including through use of their cameras, locations, and photos. Such information may include, but is not limited to, username, password, exact geolocation, first name, last name, telephone number, email address, profile picture, message contents, incident information, information related to assignment to teams and participation in incidents and incident management, and information sufficient to operate the Next of Kin Center, whereby relatives of a Customer or User may contact the Center for information germane to a Customer or User involved in an incident.

Customers and Users may use some portions of the Subscription Service without providing any personal information, though We automatically collect certain information regarding each user of the Subscription Service, including:

• Contact information, which may include, without limitation, name, email address, phone number, country of residence, current employer or company affiliation, and additional information that Customers or Users provide when they interact with us or the Subscription Service.
• Data that may be derived from interactions with us or the Subscription Service (including, without limitation, support tickets, questions, phone conversations, feedback, submitted emails, submitted forms, signed agreements, and any other content related to our services or operations that you provide to us).
• Technical Data, which may include without limitation information about the software (operating system, browser), the settings (display resolution, time zone, language preferences), the internet connection (IP address, bandwidth, latency, location) and the device (device type) used while accessing our services or website.

Interactivity Data, which may include, without limitation, information about the actions performed while interacting with our services or website (logins and logouts, form submissions, API calls, etc.), site navigation (menu choices, URLs visited), and usage patterns (timing, mouse activity).

Additional information collected is described in the Analytics and Cookies sections below.

We may collect information about Customers and Users from third-party sources.

• Google Maps. We may receive personal information from Google in connection with use of some Subscription Services that use Google Maps. Such information may include search terms, IP address, and latitude/longitude coordinates. See https://policies.google.com/privacy?hl=en&gl=us for Google’s privacy policy.
• Rayvn Customers. We receive information from Rayvn Customers. Customers are responsible for managing and operating the Platform Website and the App on behalf of their organization, and We may receive User personal information in connection with Users’ use of the Subscription Site and the App.
• Twilio is a communications company that Rayvn uses to facilitate text messaging and other communication services between Customers and their recipients for alert purposes. Further information related to the Twilio platform, including how messages are sent, is available through Twilio’s website. In using the Subscription Service, Twilio may collect information about Customer and User communications. For more information on how Twilio collects data, please visit the following:
• https://www.twilio.com/legal/privacy,
• https://www.twilio.com/legal/privacy/developer, and
• https://www.twilio.com/legal/tos#our_use.

We may combine all of the information We collect from or about Customers, Users, and their recipients and use it in the manner described in this Privacy Policy.

II.            How We Use Information

We use the information that We collect for several purposes, including:

• The purposes for which it was provided;
• To provide information and services, including event and incident response team notifications and messaging, operations dashboard, and next-of-kin communication;
• To contact Customers, Users, and their recipients for the purposes of managing a critical event and incident, assigning tasks, and monitoring responses;
• To locate Users when a situation occurs and share relevant information;
• To process and respond to inquiries and comments;
• To display relevant advertising;
• To administer, operate, and improve the Subscription Service;
• To personalize and enhance Customer and User experience using the Subscription Service;
• To send periodic emails. If email recipients choose, the email address they provide may be used to send them occasional news, updates, related product or service information, etc. Note: If at any time email recipients would like to unsubscribe from receiving future commercial emails, We include detailed unsubscribe instructions at the bottom of each email;
• To generate and review reports and data about our user base and Subscription Service usage patterns;
• To analyze the accuracy, effectiveness, usability, or popularity of the Subscription Service;
• To compile aggregate data for internal and external business purposes;
• To prevent fraud and abuse of the Subscription Service and to otherwise protect Customers, Users, and our business;
• To assist law enforcement and respond to subpoenas; and
• To perform other business activities as needed, or as described elsewhere in this Privacy Policy.
• As explained elsewhere in this Privacy Policy, personal information We collect may be processed by our partners in providing services related to the Subscription Service (such as administration services, technical services relating to the maintenance, servicing, and upgrading of software, hosting services, customer service, data migration services, and analytical services, among others).

III.          How Information is Disclosed

Information may be disclosed to third parties in accordance with our Privacy Policy. Please note that a Customer or User may choose not to share certain information as described in the Analytics section below.

A.            Third Party Service Providers and Business Partners. We may use third-party service providers and business partners to perform functions in connection with the Subscription Service, such as social sharing, marketing, site analytics, relationship management, functions related to analyzing and improving the Subscription Service usefulness, reliability, user experience, and operation, storing data, and as otherwise described in this Privacy Policy. We also may share personal information with these providers and partners for their direct marketing and promotional purposes and so they can provide services to Customers and Users. Additionally, We may share information with Apple, Android mobile device manufacturers and providers, Twilio, and Google in their capacities as mobile application platforms, to be used in accordance with their respective privacy policies.

• Google Maps. We may receive personal information from Google in connection with use of some Subscription Services that use Google Maps. Such information may include search terms, IP address, and latitude/longitude coordinates. See https://policies.google.com/privacy?hl=en&gl=us for Google’s privacy policy.
• Rayvn Customers. We share information with our Customers. Customers are responsible for managing and operating the Subscription Site and the App on behalf of their organization, and We may disclose User personal information in connection with their use of the Subscription Site and the App.
• Twilio is a communications company that Rayvn uses to facilitate text messaging and other communication services between Customers, Users, and their recipients for alert purposes. These relate to messages providing notifications of incidents. Further information related to the Twilio platform, including how messages are sent, is available through Twilio’s website. In using the Subscription Service, Twilio may collect telephone numbers, IP addresses, device tokens, device location, and information related to communications (including content, date, time, duration, and type of communication). For more information on how Twilio collects data, please visit https://www.twilio.com/legal/privacy,https://www.twilio.com/legal/privacy/developer, and https://www.twilio.com/legal/tos#our_use.

B.             Advertisers. We may share information with advertisers for use in their advertising and marketing.

C.            Customer Administrators. Customer Administrators have access to all User information entered through the Subscription Site and the App. Group administrators and log managers may also have access to certain logs, users, teams, groups, and sites.

D.            Other Users. The primary purpose of Rayvn is to facilitate team-based event management and incident response. We may share information related to or posted by Users pursuant to their engagement with an active log feed with other Users or Customers of the Subscription Site and the App.

E.             Emergency Responders. When a Customer creates an emergency responder outside of the Customer’s organization as a User, such emergency responder may view information posted by Customers and Users.

F.             Business Changes. If We become involved in a merger, acquisition, sale of assets, joint venture, securities offering, bankruptcy, reorganization, liquidation, dissolution, or other transaction, or if the ownership of all or substantially all of our business otherwise changes, We may transfer information related to Customers and Users to a third party or parties in connection therewith.

G.            Affiliates. We may also share information with our affiliates for purposes consistent with this Privacy Policy. Our affiliates will be required to maintain that information in accordance with this Privacy Policy.

H.            Investigations and Law. We may disclose information to third parties if We believe that such disclosure is necessary to:

• Comply with the law or guidance and cooperate with government or law enforcement officials or private parties;
• Investigate, prevent, or take action regarding suspected illegal activities, suspected fraud, our rights, reputation, safety, and property or that of others, or violations of our policies or other agreements with us;
• Respond to claims and legal process (for example, subpoenas); and/or
• Protect against legal liability.

I.              Aggregated Information. We may share aggregated information relating to Customers and Users with affiliated or unaffiliated third parties. This aggregated information does not contain personal information about any Customer or User.

J.              Analytics. We use third-party analytics tools to better understand who is using the Subscription Service and how people are using it. These tools may use cookies and other technologies to collect information about Customers’ and Users’ use of the Subscription Service and their preferences and activities. These tools collect information sent by their device and other information that assists us in improving the Subscription Service. This information may be used to analyze and track data, determine the popularity of certain content, and better understand Customers’ and Users’ activity, among other things.

K.            Cookies and Other Tracking Technologies

We, along with third parties, use cookies, local storage objects, Web beacons, and other technologies. These technologies are used for tracking, analytics, and personalization and optimization of the Subscription Service.

Cookies, understood within this Privacy Policy to mean both traditional cookies and other types of tracking technologies that provide “cookie-equivalent functionality,” such as software development kits, device identifiers, and statistical IDs, are small text files or pieces of code that enable the Subscription Site and the App to capture and remember certain information.

Customers and Users can instruct their devices to stop accepting cookies. But, if they do not accept cookies, they may not be able to use all portions of all functionality of the Subscription Service.

• Persistent cookies remain on the Customer’s or User’s device until they have either been deleted or expire.
• Session cookies disappear from the Customer’s or User’s device when they close the App.

Flash cookies (also known as local shared objects) are data files that can be created on a Customer’s or User’s device by the websites or apps they visit, and are a way for websites or apps to store information for later use. Flash cookies are stored in different parts of a Customer’s or User’s device from ordinary browser cookies. Customers and Users can disable the storage of flash cookies. For additional information about managing and disabling flash cookies, please visit: http://helpx.adobe.com/flash-player/kb/disable-local-shared-objects-flash.html.

Web beacons are small strings of code that provide a method for delivering a graphic image on a web page or in an email message for the purpose of transferring data. Customers and Users can disable the ability of web beacons to capture information by blocking cookies.

We may deliver advertisements to Customers and Users. We may work with third-party advertising companies that help deliver these advertisements. To learn more about third-party online advertising and to opt out of certain types of advertising, please see http://optout.networkadvertising.org/?c=1#!%2F. Note that clearing cookies from a device will remove the above opt-outs because they are stored in cookies.

We use cookies and other tracking technologies on the Subscription Service to help us understand and save Customers’ and Users’ preferences and interests, so We can personalize their future visits and compile aggregate data about Subscription Service traffic and Subscription Service interaction to offer better Subscription Service experiences and tools in the future.

Some of our business partners, such as our analytics providers and advertising networks, also use cookies and other tracking technologies on the Subscription Service, some of which may track Customers and Users across online services and over time.

IV.          Security

We implement a variety of security measures to protect the safety of Customers’ and Users’ personal information when they enter, submit, or access their personal information.

While We take reasonable measures to protect the information Customers and Users submit via the Subscription Service against loss, theft, and unauthorized use, disclosure, or modification, We cannot guarantee its absolute security. No Internet, email, or mobile application transmission is ever fully secure or error free. Email or other messages sent through the Subscription Service may not be secure. Customers and Users should use caution whenever submitting information through the Subscription Service and take special care in deciding with which information they provide us.

We cannot guarantee that transmissions of Customer or User personal information will be fully secure and that third parties will never be able to defeat our security measures or the security measures of our partners. WE ASSUME NO LIABILITY FOR DISCLOSURE OF CUSTOMER OR USER INFORMATION DUE TO TRANSMISSION ERRORS, THIRD-PARTY ACCESS, OR CAUSES BEYOND OUR CONTROL.

Any information collected through the Subscription Service is stored and processed in the United States.

V.            Data Retention Policy, Managing Your Information

We will retain Customer or User information for as long as they use the Subscription Service and for a reasonable time thereafter. We may maintain anonymized or aggregated data, including usage data, for analytics purposes. We may retain and use Customer or User information as necessary to comply with our legal obligations, resolve disputes, and/or for the period required by laws in applicable jurisdictions. Please note that some or all of the information We have collected may be required for the Subscription Service to function properly.

VI.          Links to Other Websites or Applications

This Privacy Policy applies only to the Subscription Service. The Subscription Service may contain links to other websites or apps or may forward Customers or Users to other websites or apps that We may not own or operate and to which this Privacy Policy does not apply. The links from the Subscription Service do not imply that We endorse or have reviewed these websites or apps. The policies and procedures We describe here do not apply to these websites or apps. We neither can control nor are responsible for the privacy practices or content of these websites or apps. We suggest contacting these websites or app providers directly for information on their privacy policies. Nonetheless, We seek to protect the integrity of our Subscription Service, and welcome any feedback about these linked websites and mobile applications.

VII.        Your Choices Regarding Your Information

Customers and Users have choices regarding the use of information by the Subscription Service.

• Changing Information – For Customers or Users who wish to change their information, please contact us at jarl.ulvin@rayvn.global, or as provided in their applicable Agreement with us.
• Closing An Account – Subject to any applicable Agreement with us, Customers and Users may close their account by contacting us at jarl.ulvin@rayvn.global, or as provided in their applicable Agreement with us. If the email account associated with an individual Customer’s or User’s email address is not active, We may close the account without notice.

VIII.     Information Collected from Other Websites
and Mobile Applications and Do Not Track Policy

A Customer’s or User’s browser or device may offer a “Do Not Track” option, which allows Customers or Users to signal to operators of websites, web applications, mobile applications, and services (including behavioral advertising services) that they do not wish such operators to track certain of their online activities over time and/or across different websites or applications. Our Subscription Service does not support Do Not Track requests at this time, which means that We or our analytics providers or other third parties with which We are working may collect information about Customers’ or Users’ online activity both during and after their use of the Subscription Service.

IX.          Children

Our Subscription Service is not intended for children under 13 years of age. We do not knowingly collect personal information from an individual under age 13. An individual under the age of 13 must not submit any personal information through the Subscription Service. If a Customer or User has reason to believe that We may have accidentally received personal information from an individual under age 13, please contact us immediately at jarl.ulvin@rayvn.global.

X.             Changes to Privacy Policy

We reserve the right to update or modify this Privacy Policy at any time and from time to time without prior notice. Please review this Privacy Policy periodically, and especially before providing any information. This Privacy Policy was made effective on the date indicated above. If We materially change this Privacy Policy, We will let Customers and Users know by sending an email notifying them of the changes to the email address We have on file for them.

XI.          How to Contact Us

Please feel free to contact us by email at jarl.ulvin@rayvn.global, or by writing us at Rayvn U.S. Inc., P.O. Box 6699, Bozeman, MT 59771 with any questions about this Privacy Policy.