A. About Tego
We provide organizations, our clients, and their users with the App, an online communications platform to help manage safety-related information and incidents. Except as otherwise described below, we act as a service provider to our clients and we collect and process data received from you through the App on behalf of our clients. The data we receive through the App from you will be available to organizations you affiliate with through the App. Therefore, our use and disclosure of Personal Information is limited by our agreements with them.
B. Information We Collect and Use
Profile Information You Provide
We collect the Personal Information that you submit when you create or update your App profile. The profile Personal Information includes your name, e-mail address, mobile phone number, and other registration information. We use the Personal Information in your profile to provide the App services, including to display on the App and personalize messages, provide the information to your chosen protectors, organizations, emergency safety services, and to respond to any requests and questions. We use the contact information to facilitate sending you electronic messages and safety and service-related notifications from your organization by email, SMS text message, push notifications, secure live chat, and other methods. By submitting your email address and mobile phone number, you consent to receiving communications from them for the purpose of the App. We use your email address or mobile phone number as a username to allow you to log-in on multiple devices. The processing of your Personal Information for these purposes is to meet our contractual obligations with our clients.
Information You Submit When Using the App
We collect the information you submit when using the App, such as to report a tip and to submit text, pictures, videos, audio files, or other content to your affiliated organization. You may receive the information submitted through the App. Some of the information you provide may constitute special categories of data or sensitive Personal Information about you or another person, such as information related to current health status, potential criminal activity, and racial or ethnic origin. This information is used for safety and security purposes, such as to send your organization and emergency personnel the information so they can help you and others. They also support your use of certain App features such as communicating with friends, family, your organization, and others that you choose.
You may be able to submit certain information, such as tips, anonymously. Unless Tego receives a warrant for anonymous tips, we will only disclose identifying or location information about an anonymous tipster to your organization or emergency personnel in “exigent circumstances.” We define an “exigent circumstance” as a situation in which there is imminent risk of serious bodily injury or death. Tego has the sole authority to decide whether something meets the requirement of being an exigent circumstance. The processing of your Personal Information for these purposes is to meet our contractual obligations with our clients.
Many of our App’s safety and security-related services rely on users’ precise location information. This information helps provide actionable safety and security intelligence to you, your organization, emergency personnel, and other users. For example, your organization may send safety and security messages to any and all App users in a certain geographic area and your last-used location information may be used to target such messages. Your precise location information will not be provided to your organization when targeting these messages. However, your location information may be provided to your organization when you interact with your organization to submit a tip or check-in or on confirmation that you received a broadcast message to users in a certain geographic area. To support these services, the App may use your IP address, GPS, Bluetooth, WiFi hotspot, and cell tower location information, and other technologies to determine the most accurate location information possible. You may adjust your location settings on your mobile device at any time to disable location services by managing your location services preferences or, if available, through the App’s permission settings. If you disable location services on your device or for the App, your use of the App will be significantly impaired. The processing of your Personal Information for these purposes is based on your consent.
Address Book Contacts
Certain App functions permit you to communicate through the platform with individuals in your mobile device’s address book. To connect you with an individual contact in your address book, the App may access your device’s address book with your permission and receive the name and contact information of only those individuals that you submit. By submitting contact information of another person to the App, you represent that all such contacts have consented to receive SMS texts from you through the App. The processing of this Personal Information for these purposes is with your consent and your organization will not have access to your address book information or the name or contact information of users with whom you have participated on a Tego trip.
We may request the username you use with your organization so that the App can connect with your organization’s user authentication service and permit you to gain access to your organization’s communities using your organization’s single sign-on capabilities. The processing of your Personal Information for these purposes is to meet our contractual obligations with our clients.
Information Obtained From Other Sources
We may receive information about you from your organization if it provides you with access to the App, and we combine that information with the information we collect from and about you through the App. The processing of your Personal Information for these purposes is to meet our contractual obligations with our clients. You may also choose to log into your Tego account using social media or other third-party log-in features, such as those provided by Facebook. We receive Personal Information about you from the social media or the third-party service provider, including your name and email address. We use this information for the purposes of creating your profile and connecting you to your organization in the App. The processing of your Personal Information for these purposes is with your consent.
Information We Automatically Collect
Psuedonymization and Anonymization
We may psuedonymize and/or anonymize the information collected through the App and use and disclose it for business purposes, including for improving our products and services, in which case we may use such information without further notice to you. The processing of your Personal Information for this purpose is based on our legitimate interests.
Legal and Other Similar Uses
C. Information Sharing
When you connect your profile to an organization, we treat the Personal Information received through your use of the App in connection with an organization as that organization’s information. In other words, we process the information to provide the App services to the organization in compliance with our agreement with it, including by providing access to all Personal Information of the user connected to the organization. Please see above for more information about anonymous tips. The organization accesses, uses, and discloses this information for its business purposes. You may contact your organization to learn about how it uses this information.
We will disclose the Personal Information we collect from and about you through the App with other users (including your family and friends) when requested by you.
Your organization may disclose the Personal Information collected from and about you through the App with public safety officials and other government entities on an emergency basis or when requested by you.
Third Party Service Providers and Vendors
We share the Personal Information we collect with our service providers and vendors so they can provide their services to us. For example, we partner with certain service providers to collect diagnostic and usage information as described above and to engage in analysis, auditing, research, and reporting on our behalf. We also work with service providers and vendors to provide the App’s technical infrastructure and send communications, such as email and text messages.
Merger, Sale, or Other Asset Transfers
To the extent permitted by applicable law, if we are involved in a merger, acquisition, financing due diligence, reorganization, bankruptcy, receivership, sale of company assets, or transition of service to another provider, your information may be disclosed in connection with the negotiation of such transaction, and/or sold or transferred as part of such a transaction as permitted by law and/or contract.
D. Third-Party Links and Features
The App also may contain third-party links or features. We are not responsible for the collection and use of your Personal Information by such third parties that are not under our control. We encourage you to review the privacy policies applicable to third-party websites or features. For example, we provide you with the ability to log into your account using social media or other third-party login features, such as those provided by Facebook. We do not control these third-party services, your profiles on social media services, or determine how your Personal Information will be used by these third-party services. We are not responsible for any acts or omissions by any social media service or other third-party service that you choose to use.
Where Information is Processed
We operate the services in the United States. Therefore, if you provide us with Personal Information during your use of the Services, we collect, process, and store that information in the United States. We may also transfer that information to our affiliates and subsidiaries or to other third parties, across borders to other countries or jurisdictions around the world. If you are visiting from the European Economic Area or other regions with laws governing data collection and use that may differ from U.S. law, please note that you may be transferring your Personal Information to the United States, which does not have the same data protection laws as the EU or other countries. We maintain appropriate safeguards to properly protect Personal Information concerning you when it is transferred to the United States, such as agreeing with our clients to comply with the EU Standard Contractual Clauses. For more information about our data transfer safeguards, please send a request to email@example.com.
How Information is Stored and Secured
We maintain appropriate organizational and technical measures for the protection of the security, the confidentiality, and integrity of Personal Information from unauthorized or unlawful access, accidental loss, destruction, damage, misuse, disclosure and alteration. However, no information system can be 100% secure, so we cannot guarantee the absolute security of your Personal Information. Moreover, we are not responsible for the security of Personal Information that you transmit to the App over networks that we do not control, including the Internet and wireless networks. You do so at your own risk. If Tego learns of a security system’s breach, we will comply with all applicable law to notify you about the breach so that you can take protective steps.
How Long We Keep Information
We consider several factors to determine how long we keep Personal Information. We consider the amount, nature, and sensitivity of the Personal Information, the potential risk of harm from unauthorized use or disclosure of your Personal Information, the purposes for which we process your Personal Information and whether we can achieve those purposes through other means, the contractual requirements with our client organizations, and the applicable legal requirements. Once we no longer have a need for your Personal Information, we will securely destroy it in accordance with our standards and applicable laws and regulations.
Your Choices and Rights
You choose whether to report tips, use emergency features, communicate with your chosen organization, friends, family and others, or invite a third party to participate in a Tego trip or share in other App features. In connection with some features, you may be able to submit certain information anonymously. Within the App, you can access your profile to update your name and contact information, manage the organizations with which you are connected, and view your App activity. If you cannot find the information you are looking for or make the changes you want to make in the App, please contact your organization. If you believe your information has been submitted to the App and you are not associated with an organization using the App, please contact us at firstname.lastname@example.org.