Privacy Policy

Effective Date of this Privacy Notice: April 20, 2021

This privacy policy is for users of the Care360 and Care685 platforms and related web and mobile applications (referred to herein as “Platform”) only. If you are an enrolled CareValidate Inc user for another product or service, you can review our related privacy policy with the materials you received during the enrollment process.

Your privacy is important to us. CareValidate Inc Corporation (referred to herein as “CareValidate”, “we”, “us”, “our”) appreciates your interest in our Platform. Our Platform is designed to provide mobile and web access to information and services related to our Back-To-Work program for employees. In connection with providing this access and service, there are times when we may ask for or collect information from you in the form of personal data. As part of our commitment to honoring your privacy, this Privacy Policy explains the approach we take in protecting and using the information that we gather from you on the Platform. By using our Platform, you consent to this Privacy Notice.

If you choose to use our Platform, your visit and any disputes over privacy are subject to this Privacy Policy. We reserve the right to change this Privacy Policy at any time without notice except as otherwise provided here. Please check back periodically to see if our Privacy Policy has been updated. If we make material changes to this Privacy Policy, we will notify you by updating this Privacy Policy, posting notice of the change on our home page and/or sending you email notification. Your continued use of our App(s) constitutes your agreement to the terms of this Privacy Policy and any future versions of this Privacy Policy.

Owner and Data Controller
CareValidate, Inc.
4575 Webb Bridge Road
Alpharetta, GA 30005
Owner contact email:

Types of Data collected
Among the types of data that this Application collects, by itself or through third parties, there are:
1. Cookies
2. Usage Data
3. Proximity Tracking Data through Bluetooth Badges
4. Device Logs
5. Data communicated while using the service

Complete details on each type of Data collected are provided in the dedicated sections of this privacy policy or by specific explanation texts displayed prior to the Data collection. Unless specified otherwise, all Data requested by this Platform is mandatory and failure to provide this Data may make it impossible for this Platform to provide its services. In cases where this Platform specifically states that some Data is not mandatory, Users are free not to communicate this Data without consequences to the availability or the functioning of the Service. Users who are uncertain about which Data is mandatory are welcome to contact the Owner.

Any use of Cookies – or of other tracking tools – by this Application or by the owners of third-party services used by this Application serves the purpose of providing the Service required by the User, in addition to any other purposes described in the present document and in the Cookie Policy, if available. Users are responsible for any third-party Data obtained, published or shared through this Application and confirm that they have the third party's consent to provide the Data to the Owner.

Mode and place of processing the Data

Methods of processing
The Owner takes appropriate security measures to prevent unauthorized access, disclosure, modification, or unauthorized destruction of the Data. The Data processing is carried out using computers and/or IT enabled tools, following organizational procedures and modes strictly related to the purposes indicated. In addition to the Owner, in some cases, the Data may be accessible to certain types of persons in charge, involved with the operation of this Application (administration, sales, marketing, legal, system administration) or external parties (such as third-party technical service providers, mail carriers, hosting providers, IT companies, communications agencies) appointed, if necessary, as Data Processors by the Owner. The updated list of these parties may be requested from the Owner at any time.

Legal basis of processing
The Owner may process Data relating to Users if one of the following applies:
Users have given their consent for one or more specific purposes. Note: Under some legislations the Owner may be allowed to process Data until the User objects to such processing (“opt-out”), without having to rely on consent or any other of the following legal bases. This, however, does not apply, whenever the processing of Data is subject to European data protection law; provision of Data is necessary for the performance of an agreement with the User and/or for any pre-contractual obligations thereof;
processing is necessary for compliance with a legal obligation to which the Owner is subject; processing is related to a task that is carried out in the public interest or in the exercise of official authority vested in the Owner; processing is necessary for the purposes of the legitimate interests pursued by the Owner or by a third party. In any case, the Owner will gladly help to clarify the specific legal basis that applies to the processing, and in particular whether the provision of Data is a statutory or contractual requirement, or a requirement necessary to enter into a contract.

The Data is processed at the Owner's operating offices and in any other places where the parties involved in the processing are located. Depending on the User's location, data transfers may involve transferring the User's Data to a country other than their own. To find out more about the place of processing of such transferred Data, Users can check the section containing details about the processing of Data. Users are also entitled to learn about the legal basis of Data transfers to a country outside the European Union or to any international organization governed by public international law or set up by two or more countries, such as the UN, and about the security measures taken by the Owner to safeguard their Data. If any such transfer takes place, Users can find out more by checking the relevant sections of this document or inquire with the Owner using the information provided in the contact section.

Retention time
Data shall be processed and stored for as long as required by the purpose they have been collected for. Therefore:
Data collected for purposes related to the performance of a contract between the Owner and the User shall be retained until such contract has been fully performed.

Data collected for the purposes of the Owner’s legitimate interests shall be retained as long as needed to fulfill such purposes. Users may find specific information regarding the legitimate interests pursued by the Owner within the relevant sections of this document or by contacting the Owner.

The Owner may be allowed to retain Data for a longer period whenever the User has given consent to such processing, as long as such consent is not withdrawn. Furthermore, the Owner may be obliged to retain Data for a longer period whenever required to do so for the performance of a legal obligation or upon order of an authority.

Once the retention period expires, Data shall be deleted. Therefore, the right to access, the right to erasure, the right to rectification and the right to data portability cannot be enforced after expiration of the retention period.

The purposes of processing
The Data concerning the User is collected to allow the Owner to provide its Services. The Services can be used by employers and / or event organizers for employee, student, vendor and visitor health monitoring and COVID-19 screening and tracing.  As part of the screening, through the Services you may be asked certain questions for the purposes stated above in connection with your access to a worksite or event venue.

In this regard, we will collect from you Personal Data about your health and potential symptoms and/or exposure to COVID-19, such as whether you have recently experienced a fever, cough, shortness of breath or other symptoms related to COVID-19, and whether you have or may have been in close contact with individuals who have been diagnosed with COVID-19 or experiencing symptoms of the virus. If and when collected, this data will only be used to support COVID-19 related efforts or for epidemiological research in direct support of the public health emergency.  Non-personal data will be used for the following purposes:

1. Analytics,
2. Hosting and backend infrastructure,
3. Handling activity data,
4. Contacting the User,
5. Interaction with external social networks and platforms,
6. Infrastructure monitoring,
7. Registration and authentication,
8. Device permissions for Data access,
9. Remarketing and behavioral targeting,
10. Managing contacts and sending messages,
11. Social features,
12. Location-based interactions,
13. Displaying content from external platforms,
14. Platform services and hosting and Beta Testing.

Device permissions for Data access
Depending on the User's specific device, this Application may request certain permissions that allow it to access the User's device Data as described below. By default, these permissions must be granted by the User before the respective information can be accessed. Once the permission has been given, it can be revoked by the User at any time. In order to revoke these permissions, Users may refer to the device settings or contact the Owner for support at the contact details provided in the present document. The exact procedure for controlling app(s) permissions may be dependent on the User's device and software. Please note that the revoking of such permissions might impact the proper functioning of this Application. If User grants any of the permissions listed below, the respective Data may be processed (i.e accessed to, modified or removed) by this Application.

Bluetooth connection and location sharing permission
Our Apps may request always on, background access to Bluetooth radio in order to connect to nearby badges to detect proximity. We do not collect any location information as part of our proximity tracking feature. Although some devices and platforms may require the user to also grant access to location data, in order to use the Bluetooth radio.

Camera and Local Storage Permission
Our Apps may request access to the camera and to the device’s local storage in order to allow the user to upload proof of immunization and reports.

The rights of Users
Users may exercise certain rights regarding their Data processed by the Owner.
In particular, Users have the right to do the following:

Details about the right to object to processing
Where Data is processed for a public interest, in the exercise of an official authority vested in the Owner or for the purposes of the legitimate interests pursued by the Owner, Users may object to such processing by providing a ground related to their particular situation to justify the objection.

Users must know that, however, should their Data be processed for direct marketing purposes, they can object to that processing at any time without providing any justification. To learn whether the Owner is processing Data for direct marketing purposes, Users may refer to the relevant sections of this document.

How to exercise these rights
Any requests to exercise User rights can be directed to the Owner through the contact details provided in this document. These requests can be exercised free of charge and will be addressed by the Owner as early as possible and always within one month.

Additional information about Data collection and processing

Legal action
The User's Data may be used for legal purposes by the Owner in Court or in the stages leading to possible legal action arising from improper use of this Application or the related Services.
The User declares to be aware that the Owner may be required to reveal data upon request of public authorities.

Additional information about User's Data
In addition to the information contained in this privacy policy, this Application may provide the User with additional and contextual information concerning particular Services or the collection and processing of Data upon request.

System logs and maintenance
For operation and maintenance purposes, this Application and any third-party services may collect files that record interaction with this Application (System logs) use other Data (such as the IP Address) for this purpose.

Information not contained in this policy
More details concerning the collection or processing of Data may be requested from the Owner at any time. Please see the contact information at the beginning of this document.

How “Do Not Track” requests are handled
This Application does not support “Do Not Track” requests.
To determine whether any of the third-party services it uses honor the “Do Not Track” requests, please read their privacy policies.

Changes to this privacy policy
The Owner reserves the right to make changes to this privacy policy at any time by giving notice to its Users on this page and possibly within this Application and/or - as far as technically and legally feasible - sending a notice to Users via any contact information available to the Owner. It is strongly recommended to check this page often, referring to the date of the last modification listed at the bottom.

Should the changes affect processing activities performed on the basis of the User’s consent, the Owner shall collect new consent from the User, where required.

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