SafeKeeping, Inc. ("SafeKeeping", “we”, “us” and “our”) respects your privacy and is committed to protecting your privacy through our compliance with this Privacy Policy. 

This Privacy Policy should be read in conjunction with our Terms of Use, into which this Privacy Policy is incorporated by reference.

SafeKeeping operates the https://www.howsmom.net/ website, SafeKeeping web portal https://signature.howsmom.info/ websites, My Signature Portal application for use by Covered Entities (defined below) and other Authorized Users, and the SafeKeeping mobile application (collectively, the "Services"). This Privacy Policy informs you of our policies regarding the collection, use and disclosure of personal information when you use our Service and the choices you have associated with that information. 

By using the Services, you agree to the collection and use of information in accordance with this Privacy Policy. This Privacy Policy may change from time to time (see below, “Changes to this Privacy Policy”). Unless otherwise defined in this Privacy Policy, the terms used in this Privacy Policy have the same meanings as in our Terms of Use. If you do not agree with our policies and practices, then please do not use our Services.

HIPAA; Relationship with Covered Entities; and PHI Important Information Relating to Health Information. SafeKeeping is not a Covered Entity as defined by the Health Insurance Portability and Accountability Act (“HIPAA”). SafeKeeping may be a Business Associate under HIPAA of certain Covered Entities, as that term is defined under HIPAA. Covered Entities can include senior care, nursing homes, and other healthcare facilities that enlist the services of SafeKeeping. Under the terms of any Business Associate Agreement ("Agreement" or “Business Associate Agreement”) by and between SafeKeeping and a Covered Entity, SafeKeeping provides services to Covered Entity that may involve individually identifiable health information constituting Protected Health Information (“PHI”). Additionally, the Services are provided to you, as an Authorized User (defined below), in order to access certain information regarding an individual under the care of a Covered Entity (a “Patient”). 

SafeKeeping's uses and disclosures of PHI and other actions under each Agreement are and shall be consistent with the Covered Entity's privacy policies, as stated in Covered Entity's notice, and which may be modified or altered by the Covered Entity from time to time.

Authorized Users. The Services may be accessed by third parties, however, PHI may only be accessed by third parties authorized by the Covered Entity ("Authorized Users"). 

Authorized Users may include, but is not necessarily limited to, Covered Entity employees, family members of a Patient, and a Patient’s power of attorney. Authorized Users have been, directly or indirectly, authorized by the Patient to receive information from the Covered Entity.

Not For Medical Advice. SafeKeeping does not provide medical advice, diagnosis, or treatment. You acknowledge and agree that the Covered Entities are solely responsible for and have complete authority, responsibility, supervision, and control over the provision of medical services, advice, instructions, treatment decisions, and other professional health care services performed for any Patient whose information you are authorized to access under this Agreement, and that all diagnoses, treatments, procedures, and other professional health care services are provided and performed exclusively by or under the supervision of Covered Entities as they, in their sole discretion, deem appropriate. You further acknowledge and agree that SafeKeeping does not provide or endorse any medical advice or treatment on or through the Services and no information obtained through the Services can be so construed or used.

Terms of Use; Covered Entity Employees and Agreements

This Privacy Policy should be read in conjunction with any applicable Terms of Use, into which this Policy is incorporated by reference. This Privacy Policy also applies to your use of the Services, including as an employee of a Covered Entity. Your use of the Services and our processing of your information may be subject to a Business Associate Agreement, written contract with your employer, or other agreement with a Covered Entity specific to the nature of any transaction in which you are participating, in which such agreement may supersede this Privacy Policy.

Information SafeKeeping Collects

Information given by Covered Entity, Authorized Users, or third-party users. Services provided may require you to sign up for a SafeKeeping or My Signature Portal account(s) ("SafeKeeping Account"). When you do, certain information about you, the related facilities, staff, and residents may be collected. This information will only be used to authorize your access and provide such information to you through the Services.

Authorized User’s may provide personal information while using the Services, including, but not limited to, the following:

• First and last name;
• Email address;
• Telephone number;
• Date of birth;
• Mailing address;
• Geolocation data; and
• Comments or messages provided in free text boxes.

Covered Entity employees may provide personal information while using the Services, including, but not limited to, the following:

• First and last name;
• Covered Entity information (i.e. mailing address and company name);
• Geolocation data; and
• Comments or messages provided in free text boxes.

The information that you provide in each case will vary. In some cases, you may be able to provide personal information via email or free text boxes or uploading documents to the Services, such as contacting SafeKeeping to request further information. When providing your personal information in these situations, please provide only relevant information and do not provide unnecessary sensitive information, such as Social Security numbers, credit card information or other sensitive personal data, unless required by the Services. Additionally, we may ask you to create a username and password that should only be known to you. 

Information of Other Individuals. As a user of the Services, you (as an employee of a Covered Entity or an Authorized User) may have the opportunity to provide information of other individuals, such as providing Patient or Authorized User personal information.

When providing such information, you are solely responsible for obtaining the necessary consents and authorizations from any individuals in accordance with applicable data security laws and regulations, and SafeKeeping shall not be responsible or held liable for your failure to obtain the necessary consents.

Information we get from your use of our services. We may collect information about the services that you use and how you use them, like when you visit our website or access our Services. This information includes:

• Device Information. We may collect device-specific information (such as your
  hardware model, operating system, and mobile network information).
• Log information. When you use the Services or view content provided by
  SafeKeeping, we may automatically collect and store certain information in our
  server logs. This may include: 
  • details of how you used the Services.
  • Internet protocol addresses
  • device event information such as crashes, system activity, hardware settings, browser type, browser language, the date and time of your request and referral URL.
  • cookies that may uniquely identify your browser or your Authorized User account.
• Location information. When you use a location-enabled SafeKeeping Services, we may collect and process information about your actual location, like GPS signals sent by a mobile device. We may also use various technologies to determine location, such as sensor data from your device that may, for example, provide information on nearby Wi-Fi access points and cell towers.

• Cookies and anonymous identifiers. We use various technologies to collect and store information when you visit SafeKeeping Services, and this may include sending one or more cookies or anonymous identifiers to your device. Cookies are sent to your browser from a website and stored on your device. Other tracking technologies are also used such as beacons, tags and scripts to collect and track information and to improve and analyze our Services. You can instruct your browser to refuse all cookies or to indicate when a cookie is being sent. However, if you do not accept cookies, you may not be able to use some portions of our Service.

How SafeKeeping uses collected information

SafeKeeping uses the information collected from the Services to provide, maintain, protect and improve them, to develop new ones, and to protect SafeKeeping and the users of the Services. SafeKeeping may also use your information to provide service and support communications, marketing communications that are effective and optimized for you, and to prevent malicious activity and provide you with a secure experience. Information collected from cookies and other technologies may be used to improve the user experience and overall quality of the Services.

How We May Share Your Information

We do not sell or lease your personal information to any third party. We may disclose your personal information to our trusted third-party business partners in accordance with this Privacy Policy. We work with a number of partners that help us process your requests, deliver customer service and support, send email marketing communications, and provide experiences that you have come to expect from us. We will share your personal information with these third parties in order to fulfill the service that they provide to us. These third-party partners are under contract to keep your personal information secure and not to use it for any reason other than to fulfill the service we have requested from them. Additionally, we may share your personal information for the following reasons:

• Covered Entities. The Services and SafeKeeping may share, provide or otherwise disclose your personal information to Covered Entities in accordance with this Privacy Policy. Additionally, the Services and SafeKeeping may receive from such Covered Entities certain personal information, including PHI. The sharing of your information by these third-parties will be subject to an authorization and release form executed between you and the applicable Covered Entity. Personal information shared by these Covered Entities will be governed by that Covered Entity’s privacy policy and not necessarily the terms of this Privacy Policy once shared. In the event that personal information contains PHI, such PHI will be stored, processed, and transmitted in accordance with any applicable Business Associate Agreement.

• Vendors, Subcontractors and other Third-Party Service Providers. When necessary, SafeKeeping discloses to its subcontractors, agents or other third parties, and requests from the Covered Entity, only the minimum PHI necessary to performing or fulfilling a specific required or permitted function. SafeKeeping establishes and maintains all appropriate safeguards to prevent any use or disclosure of PHI other than pursuant to the terms and conditions of any applicable Business Associate Agreement.

• Domain/IT administration. If you create a SafeKeeping Account and it is managed by an IT administrator then your IT administrator may have access to your SafeKeeping Account information (including your data, email, and personal information). Your IT administrator may be able to:
  • view statistics of the account;
  • change the account password;
  • suspend/terminate account access;
  • access information retained on the account;
  • access or receive other information or data of your account or adjust settings within your account; and 
  • refer to the IT/Domain administrator's own privacy policy.

• Legal Concerns. Personal information may be shared with companies, organizations, or individuals outside of SafeKeeping if there is a good-faith belief that access, use, preservation or disclosure of the information is reasonably necessary to: 
  • enforce applicable Terms of Use;
  • meet applicable laws, regulations, legal processes or enforceable
    governmental requests;
  • detect, prevent, or otherwise address fraud, security or technical issues and defend rights or property of SafeKeeping;
  • investigate wrongdoing in connection with the Services; and
  • protect personal safety of users of the Services or the public.

• Merger or Acquisition. There are circumstances where SafeKeeping may decide to buy, sell, or reorganize its business in selected countries. Under these circumstances, it may be necessary to share or receive personal information with prospective or actual partners or affiliates. In such circumstances, SafeKeeping will ensure your information is used in accordance with this Privacy Policy.

We may aggregate or otherwise anonymize the data we collect for purposes of analytics, research, marketing and other business interests of SafeKeeping. Such use shall not include Personal Information or information that can identify you as an individual or reasonably be used to identify you.

Your Choices and Selecting Your Privacy Preferences

We want to provide you with relevant information that you have requested. If we provide subscription-based services, such as email newsletters, we will allow you to make choices about what information you provide at the point of information collection or at any time after you have received a communication from us while you are subscribed. Transactional or service-oriented messages are usually excluded from such preferences, as such messages are required to respond to your requests or to provide goods and services, and are not intended for the purposes of marketing.

We will not intentionally send you email newsletters and marketing emails unless you consent to receive such marketing information. After you request to receive these emails, you may opt out of them at any time by selecting the “unsubscribe” link at the bottom of each email. Please note that by opting out or unsubscribing you may affect other services you have requested we provide to you, in which email communication is a requirement of the service provided.

Push Notifications. You may receive push notifications in accordance with the features and policies of the application. You can control these tools on your mobile devices; for 72139614v1example, you can turn off the GPS locator or push notifications on your phone. To modify the push notifications you get from our app, you can alter your preferences in your profile. You may not be able to use our application to its full extent by disabling certain features and tools.

Text Messaging. You may have the opportunity to receive SMS or "text" messages, pre- recorded voice messages or auto-dialed phone calls from SafeKeeping, its affiliates and related entities as well as third parties. Such messaging may be used to authenticate your identity or mobile device, as well as provide you informational updates about services you may have requested. In providing your mobile device number or cell phone number to SafeKeeping, you knowingly consent to such communications from SafeKeeping or for SafeKeeping to use your cell phone number or mobile device number in accordance with the Privacy Policy. In providing your number and accepting this Privacy Policy, you represent that you have the authority to agree to receive text messages at the telephone number that you provide to SafeKeeping, or from which you sent the text message request to us. You further acknowledge that no purchase is required to opt into this service, and you may opt out at any time by following instructions below.

• You can cancel the SMS service at any time. Just text "STOP" to the short code. After you send the SMS message "STOP" to us, we will send you an SMS message to confirm that you have been unsubscribed. After this, you will no longer receive SMS messages from us. If you want to join again, contact your loved one's facility to sign up as you did the first time and we will start sending SMS messages to you again.

• If you are experiencing issues with the messaging program you can reply with the keyword HELP for more assistance, or you can get help directly at Support+Signature@Howsmom.Info.

• Carriers are not liable for delayed or undelivered messages.

• As always, message and data rates may apply for any messages sent to you from us and to us from you. You will receive occasional messages for COVID-19 updates and other facility notifications. If you have any questions about your text plan or data plan, it is best to contact your wireless provider.

Accuracy and Access to Your Personal Information.

We strive to maintain and process your information accurately. We have processes in place to maintain all of our information in accordance with relevant data governance frameworks and legal requirements. We employ technologies designed to help us maintain information accuracy on input and processing. 

Where we can provide you access to your personal information in our possession, we will always ask you for a username and password to help protect your privacy and security. We recommend that you keep your password safe, that you change it periodically, and that you do not disclose it to any other person or allow any other person to use it.

To view and change the personal information that you have provided to us, you can log in to your account and follow the instructions on that webpage, or contact us directly for assistance.

Third-Party Websites

This Privacy Policy does not apply to websites or other domains that are maintained or operated by third parties or our affiliates. Our Services may link to third-party websites and services, but these links are not endorsements of these sites, and this Privacy Policy does not extend to them. Because this Privacy Policy is not enforced on these third-party websites, we encourage you to read any posted privacy policy of the third-party website before using the service or site and providing any information.

Your California Rights.

Pursuant to California Civil Code Section 1798.83, we will not disclose or share your personal information with third parties for the purposes of third-party marketing to you without your prior consent.

“Do Not Track” Signals. We do not support Do Not Track (“DNT”). Do Not Track is a preference you can set in your web browser to inform websites that you do not want to be tracked. You can enable or disable Do Not Track by visiting the Preferences or Settings page of your web browser. 

If you are a California consumer, as defined by the California Consumer Privacy Act of 2018 (“Act”), please be advised that SafeKeeping does not currently meet the regulatory thresholds of a “business” as that term is defined under the Act and therefore is not required to comply with the Act. Regardless, all Personal Information will be processed in accordance with this Privacy Policy.

Children

SafeKeeping does not knowingly collect personal information from children under the age of 13, and our Service is not directed at users under the age of 13. If we find that personal information has inadvertently been collected for an individual under the age of 13, we will immediately delete it. You hereby acknowledge and agree that children under the age of 13 are prohibited from using our Services. A parent, guardian, or personal representative may use the Software on behalf of a child under the age of 13. 

Furthermore, you acknowledge and agree that minors between the ages of 13 and 17 may use our Software, but that a parent, guardian or personal representative must consent to this Agreement and our Privacy Policy on their behalf.

Safeguarding the Information We Collect

We use reasonable technical, administrative, and physical safeguards in order to protect your personal information against accidental loss and from unauthorized access, use, alteration, and disclosure. In addition, for any PHI provided to the Service or SafeKeeping, we utilize all appropriate safeguards as agreed to in any applicable Business Associate Agreement executed with the applicable Covered Entity. However, we can never promise 100% security. You have a responsibility, as well, to safeguard your information through the proper use and security of any online credentials used to access your personal information, such as a username and password. You are solely responsible for any use of your account under your assigned credentials, including if you share those credentials with an advocate, surrogate or other party to act on your behalf. If you believe your credentials have been compromised, please change your password. Please also notify us of any unauthorized use.

Changes to This Privacy Policy

The SafeKeeping 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, and email notification of privacy policy changes).

Contact Us

If you have any questions about this Privacy Policy, please contact us at: inquiries@safekeepingapp.com or 318 Main Street, Evansville, In 47708