Effective date: June 16, 2020

1. Introduction

Red e App, Inc. (“Red e App” or “We“) respects your privacy and is committed to protecting it through our compliance with this policy. This policy describes:

  • The types of information we may collect or that you may provide when you use our Passport service offering (the “Passport Service Offering”) that is part of the workflow, communication, and data management services provided by Red e App through our proprietary platform (the “Red e App Services”).
  • Our practices for collecting, using, maintaining, protecting, and disclosing that information.

This policy applies to information we collect in connection with our Passport Service Offering and in email, text, and other electronic communications sent through or in connection with Passport Service Offering.

This policy applies to information we collect in connection with our Passport Service Offering and in email, text, and other electronic communications sent through or in connection with Passport Service Offering.

This policy supplements our Red e App privacy policy (available here) (the “Red e App Privacy Policy”), which applies to information collected in connection with our Passport Service Offering as well as more broadly to other types of information as described in the Red e App Privacy Policy itself.  To the extent there is a conflict between the terms in this privacy policy and the Red e App Privacy Policy, the terms in this policy will control with respect to the Passport Service Offering.

2. What Information we collect

In connection with our Passport Service Offering, we collect the following information in addition to the information we already collect about you through your use of the Red e App Services:

  • Location and Proximity Information. With your consent, we may automatically collect your location information. This information may include your device’s latitude, longitude, elevation, time of data collection, as well as an indicator of the quality of the location data collected. We may use this information to determine your proximity to other users (proximity information).
  • Health Information. We collect health information through your direct interactions with our Passport Service Offering. For example, you may be asked to provide us information by filling in forms relating to your health status and whether you have any symptoms believed to be associated with COVID-19. In addition, you may have the opportunity to upload tests results relating to whether or not you have been diagnosed with COVID-19. Whether you provide such information or results is voluntary.

Some of the information we collect about you may be personal information, or personal data, that can be used to identify you including, for example, your name, email address, mailing address or delivery address. In some jurisdictions, certain unique identifiers like IP addresses and other usage or technical information may be considered personal information. It does not include data where your identity has been removed so that we can no longer identify you (anonymous data), which we may use for any purpose. 

3. How we use your personal information

We use information that we collect about you or that you provide to us, including any personal information, in connection with our Passport Service Offering as follows:  

  • If you have consented to our collection of health information, then we may use this information along with your identity information
    • to help prevent further COVID-19 infections.
    • to identify you as having symptoms consistent with COVID-19 or a positive COVID-19 diagnosis.
    • to identify other users of our Passport Service Offering who may have been near you based upon your GPS location who may be at risk of a COVID-19 infection.
    • to communicate this information along with your identity to your employer or other third-party who has hired us to perform contact tracing services. Your employer, in turn, may use this information to warn you or other users that you may be at risk for or may have been exposed to a COVID-19 infection, share this information as required by applicable law, or in accordance with its own privacy policies.
  • If you have consented to our collection of location information, we use the location information we collect about you along with your identity information:
    • to help prevent further COVID-19 infections.
    • to perform contact tracing services for your employer or other third-party who hired us. To do this we will retain location data so that we can determine users of our app who may have been exposed to infection by COVID-19.  
    • specifically, we use your GPS location information to warn your employer (or other third party) if you have been in close proximity to another person who has either had a positive COVID-19 diagnosis or have been in close proximity to a person who has had symptoms consistent with COVID-19.
    • conversely, if you have consented to the collection of health information and report a positive COVID-19 diagnosis or self-report symptoms that are consistent with a COVID-19 diagnosis, we will use your location information to identify persons who, based upon your GPS location, may have been at risk of exposure to COVID-19 and warn your employer (or other third party) of persons who may have had exposure to COVID-19.
    • We never share location information with your employer.
  • In any other way we may describe when you provide the information.
  • For any other purpose with your consent.

We may use information that is not personal information for any purpose. For example, we may aggregate usage data to report trends relating to COVID-19. 

4. Disclosure of Your Information

We may share your personal information with:

  • your employer (or other third party who hired us to perform contact tracing services) as described above.
  • To contractors, service providers, and other third parties we use to provide services to us. For example, we use ELTORO.COM LLC to perform location matching to identify potential COVID-19 exposures. We contractually require such third parties to keep information confidential and use it only for the purposes for which we disclose it to them.
  • To an actual buyer or other successor in the event of merger, divestiture, restructuring, reorganization, dissolution or other sale or transfer of some or all of our assets, where one of the transferred assets is the personal information we hold.
  • To fulfill the purpose for which you provide it.
  • For any other purposes that we disclose when you provide the information.
  • With your consent.

We may also disclose your personal information:

  • To comply with any court order, law, or legal process, including responding to any government or regulatory request.
  • To protect the rights, property, health, or safety of our business, our employees, our customers, or others.
  • To investigate suspected violations of any law, rule or regulation, or the terms or policies for our website.

We may share non-personal information without restriction.

5. Your Rights and Choices

a.  Choices for Users.

  • Revoke Consent. You may choose whether or not to allow the Red e App Services to collect and use real-time information about your device’s location and/or health information by providing affirmative consent when we prompt you. If you consent to provide such information, you can always revoke your consent to our collection of your location by disabling location services in your mobile device settings. To revoke consent with regard to previously collected personal information, contact your employer’s or organization’s system administrator. If you revoke consent or block use of your real-time location information, some parts of the Passport Service Offering may become inaccessible or not function properly.
  • Access, Delete, and Modify Your Information. You may delete information that is stored on your device. We act as a service provider to your employer or other third-party. You should contact your employer (or other third-party) for information about how to access, delete, or modify information that you are unable to access, delete, or modify through your ordinary use of the Passport Service Offering.

b.  Choices for Organizations & Administrators. If you act as a network administrator on behalf of an organization, you may: access, delete, and modify information that is stored in the Passport Service Offering. In some cases, you may have a legal obligation to fulfill such requests from your users.

6. Data Security

We follow generally accepted security standards to protect information that is submitted to us, both during transmission and once we receive it, which includes encrypted storage practices, firewalls and user password protection. The security of user information extends to internal reviews of our information collection, processing, and storage processes. Each of our employees are aware of our security policies, and your information is only available to those employees who need it to perform their jobs.

To learn more about our security practices and policies, please see our Security Policy.

7. Data Retention

We will only retain your personal information for as long as reasonably necessary to fulfill the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting, or reporting requirements. We may retain your personal information for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.

8. Contact Us

If you have questions regarding our Passport Privacy Policy, please contact us at privacy@redeapp.com  or send your comments by mail to:

Red e App, Inc
900 E Main Street Suite 207
Louisville, KY 40206