Smart Steps LLC Privacy Policy
1. OUR PRIVACY COMMITMENT
Smart Steps LLC (the “Company”, “we,” or “our”) is strongly dedicated to protecting the privacy of our customers’ personal information, which includes your personally-identifiable information (“PII”) and your Protected Health Information (“PHI”).
We are providing this privacy policy (“Privacy Policy”) in order to let you know how we collect, use, and disclose your personal information when you use our website, SmartSteps4me.com (the “Website”), when you use our mobile app, Smart Steps Mobile (the “MobileApp”), when you contact or interact with Contacts which you have elected to enter into your account (“Emergency Contact(s)”, “Contacts”) or when you interact with a Smart Steps representative for assistance with the Website or your account (“Services”).
For clarity, this Privacy Policy applies to your personal information:
(a) that we collect automatically from you when you use the Website or the MobileApp,
(b) that you provide or disclose to us when you, on the Website or the MobileApp, register, complete a survey, post information, participate in a conversation, or otherwise choose to provide or disclose information to us or to the public on the Website or the MobileApp,
(c) that you provide or disclose to your Contacts when you call or interact with your third party call center vendor(s) or Contact(s), or
(d) that you otherwise provide or disclose to us, a vendor(s), or with the public, either online or offline.
App User acknowledge that a third-party Company may, from time to time, monitor telephone communications for purposes of assuring quality and timeliness of responses.
The terms (“App User”, “you”, “your”, or “user”) as used herein refer to any individual or entity accessing or using the Services. Your use of any of the Services signifies your agreement with this Privacy Policy.
The term (“Group Account”) applies when two or more account holders (“Group Members”) are set up with a group account to share exclusive content within the group. The (“Group Admin”) manages the group membership and can create (“Group Tree(s)”) to share within the group. A Group Member CAN view Group Trees but CANNOT create or edit Group Trees. A Group Member or a Group Admin CAN create, edit and view personal trees (“My Trees”) in their own accounts.
2. INFORMATION WE COLLECT
When you use the Services, we may collect PII, and sometimes PHI, from you. When you use the Website or the MobileApp, we may also automatically collect non-personally identifiable information from you.
PII that could be collected includes your full name, your full address, your photograph, your e-mail address, your telephone number, and other specific information that you volunteered to us when you set up your account and/or when you create or edit content in the app. Much of this information is used to create your account and to display on your profile screen. It is not shared with others.
If you upgrade your account to a paid service, your financial information is provided to a third party service; Smart Steps does not store this information.
If you have location detection turned on (in your phone), we will record your location. This is used to display a usage report on your Dashboard.
When you click on a button in the app, it “pings” the database. This may be used for group data analysis purposes, for example, to analyze what content is most popular. If it is to be used in a study about your personal usage, you would give permission for that information to be analyzed.
PHI information that could be collected includes specific information that identifies you, plus information about your physical or mental health or the medical care that you have or may receive. We would only collect this information if you voluntarily posted or disclosed it on the Website or the MobileApp or if you voluntarily disclosed it to us in conversation. Typically, this information would be in the Notes box or in a custom Decision Tree in your account.
You have the option to post information about yourself in the Notes box, which shows up on your Profile screen. It is your responsibility to decide:
a) what to include in this box and
b) whether to share this information with someone by showing them the screen or in some other manner. It is important for you to consider what you want others to know about you.
You have the option to store personal information when creating or editing a decision tree. This is your choice. If Smart Steps or another party providing services to you is helping you create a decision tree, they may be exposed to information about you. It is your choice what to share with vendors, service providers, or third parties who are helping you with the software.
If you are a member of a Group, some additional information about data privacy applies. A Group has two types of members: a Group Admin and a Group Member. The Group Admin manages group membership, assigns roles and creates or edits Group Trees to share with Group Members. A Smart Steps representative can be one of the Group Admins to assist you with customization of the app. Group Members share responsibility for data privacy as follows:
a) A Group Admin can create content for Group Members to use. When creating content for a Group Tree, the Group Admin is responsible for ensuring data privacy in the content.
b) A Group Tree should not contain personal information about an individual Group Member unless the other Group Members also have permission to access the personal information. If other Group Members do not have permission to access personal information about a member, the Group Admin can use a private tree to store private information.
c) A Group Admin CANNOT access private trees of another Group Admin or Group Member.
Group Trees can assist a Group Member to copy and/or edit a custom private tree while the Group Member is logged into their own account.
You might indirectly disclose information with the Contacts that you choose to add to your account when you text or call them. You are responsible for the information that you disclose.
Non-personally identifiable information that could be automatically collected includes the IP address of your computer or mobile device, the make and model of your computer or mobile device, the type of web browser you are using, historical search data, information about your location (such as location information from your smart phone), and other electronic information. Such data is collected using cookies, web beacons, and other technologies.
3. HOW WE USE YOUR NON-MEDICAL INFORMATION
In general, we collect non-medical information from you so that we can more effectively serve you. Specifically, we may use the information to, among other things:
(a) personalize and improve your customer experience.
(b) better understand your needs and preferences.
(c) better understand how our customers use the Services.
(d) improve the performance of the Website and the MobileApp.
(e) provide better services through our technology or support vendor(s).
(f) resolve technical difficulties.
(g) contact and communicate with you via marketing emails.
(h) bill you for amounts owed.
(i) provide customer service via email, chat, phone calls, or video meetings.
We will not rent or sell your information to third parties for marketing purposes. However, we may disclose:
(a) aggregated (information that cannot be traced back to you) PII data to specific third party contractors and vendors that provide web analytics or other related services to us.
(b) non-aggregated PII data to courts or law enforcement agencies as required by law or legal process, or to protect the safety of any person.
(c) aggregated and non-aggregated PII, plus PHI, to another company (and related parties and vendors) if we are acquired or merged with the company (whose use of the information will be subject to this Privacy Policy).
4. HOW WE HANDLE PERSONAL HEALTH INFORMATION
Smart Steps does not intentionally or routinely collect Personal Health Information (PHI). Smart Steps does not routinely share PHI with any entity. SMART STEPS IS NOT A HEALTH CARE PROVIDER.
When completing the User Profile or creating content in a decision tree in a personal or group account, you may choose to enter PHI or you may share PHI when communicating with Smart Steps or a vendor/Contact by email or phone. Certain PHI about you is protected under the Health Insurance Portability and Accountability Act of 1996 (“HIPAA”) and applicable state law.
We may disclose PHI that you have disclosed verbally or in writing to courts or law enforcement agencies as required by law or legal process, and we may disclose PHI in life threatening situations or to protect the safety of any person.
5. HOW WE USE COOKIES AND WEB BEACONS
We use “cookies” to collect information. Cookies are data files that are stored on your hard drive and that are used, generally, to improve your online experience. For example, cookies can be used save your user credentials for future logins, to enable certain features of the Website and the MobileApp, and to track your usage of the Website and the MobileApp. We also may work with third party contractors and vendors who will place or read cookies on your hard drive. You can set your web browser to stop accepting cookies or to warn you before it accepts cookies. However, if you do not accept cookies certain functionality of the Website and the MobileApp will not work.
We also may use web beacons to collect information. Web beacons are transparent graphic images placed on the Website or the MobileApp or in an email that tell us about your interactions with us. For example, a web beacon may tell us if you have opened an e-mail from us.
6. SECURITY MATTERS
We have put in place industry-standard technology and administrative processes and privacy and security measures designed to safeguard and protect information under our control from unauthorized access, disclosure, or use. However, we cannot guarantee or warrant that such unauthorized access, disclosure, or use will never occur. You acknowledge and agree, therefore, that any information or communication that you send or transmit to us, or that is stored by us, is communicated, transmitted, and/or stored at your own risk.
We will make all legally required disclosures regarding any breach of security or confidentiality regarding your PII. Any such required disclosures will be made by e-mail or by posting to the Website or the MobileApp, without unreasonable delay.
7. LINKS TO THIRD PARTY WEBSITES
The Website and the MobileApp may contain hypertext links to third party websites. The opportunity to click on these links does not constitute an endorsement or representation regarding the content, security, privacy policies, or terms of use of these third party websites, nor is it a representation that we have any affiliation with these third party websites, and we disclaim any and all responsibility for such content, security, privacy policies, or terms of use. You should check the privacy policies of these other websites before you provide any personal information to them. You acknowledge and agree, therefore, that your use of any third party websites linked by hypertext to the Website or the MobileApp is at your own risk.
8. CHANGING YOUR PERSONAL INFORMATION
You may update, change, or delete information you have previously provided to us. You may update your information through the Website. You may delete your account in the MobileApp.
The Website and the MobileApp may make available functionality that allows you to communicate online and to post or upload personal information, including PII and PHI. THE COMPANY IS NOT RESPONSIBLE FOR THE USE OF ANY PERSONAL INFORMATION, INCLUDING PII AND PHI, THAT YOU VOLUNTARILY SUBMIT THROUGH THE WEBSITE, THE MOBILEAPP, OR BY ANY OTHER USE OF THE SERVICES.
You understand and agree that all of the personal content, communications, and disclosures that you post or upload to the Website or the MobileApp, and that are visible to other users of the Website or the MobileApp becomes public information. In addition, you agree that by making such personal content, communications, and disclosures you grant to the Company a perpetual, irrevocable, worldwide, license to publish, display, copy, transmit, distribute, and otherwise use such personal content, communications, and disclosures in any media or medium and in any format now known or hereafter developed.
You agree that you will not use the Website or the MobileApp to post or upload any personal content, communications, or disclosures that violate or infringe upon any rights of any party, including, but not limited to, any person’s copyright, trademark, or other intellectual property rights. This includes, but is not limited to, content and images used in creating or editing decision trees.
In addition, you agree that you will not use the Website or the MobileApp to post or upload any personal content, communications, or disclosures that are abusive, offensive, hateful, obscene, pornographic, or sexually explicit.
10. HOW TO OPT OUT OF COMMUNICATIONS FROM US
You may opt-out of receiving most communications from us by clicking unsubscribe in the footer of emails. However, as long as your account is open, you will be unable to opt-out of certain minimal communications from us, including policy updates and certain account and billing matters.
11. CHANGES TO THIS PRIVACY POLICY
The Company may amend, modify, change, or remove this Privacy Policy, in whole or in part, at any time. All updated notices will be immediately posted to the web site and will be effective when posted. We will indicate the date of the most recent update. Your continued use of the Services following any amendment, modification, change, or removal shall constitute your acceptance thereof.
12. HOW TO CONTACT US
If you have any questions about this Privacy Policy, the Terms of Use, or any other practices or policies of the Company, you may contact us at connect@smartsteps4me.com. Please note that given the nature of e-mail technology, your e-mail communications may not be secure, so you should not include any PHI, credit card, or other confidential information in your e-mails to us.