AllClear Privacy Policy

Effective Date: April 2, 2020

AllClear App, Inc. (“Allclear,” “we,” “our,” or “us”) believes that transparency is vital to protecting people’s privacy, particularly in a global pandemic.

This privacy policy explains how we collect, use, and share your information, and some of the choices you may have.  This privacy policy applies to our collection of information, including personal information, through our website and mobile applications, including allclear.app and the Allclear iOS and Android applications (our “Sites”), and from your interactions with us (collectively with our Sites, the “Services”).

Please note that this privacy policy does not cover or apply to our processing of information about employees, contractors or through third party services integrated into our Services, including MIT’s Private Kit contact tracing services.  We may also provide additional privacy policies to you at the time we collect your information, which will govern how we process the information you provide at that time.

Moreover, due to the serious nature of this global pandemic, we may give public health authorities access to the large pool of self-reported data to aid in their research, analysis and resolution of this crisis.  We will endeavor to obtain assurances from these authorities that they will only use such data as necessary to respond to the pandemic, but we cannot guarantee this in every case.  As a result, this privacy policy does not apply to the processing of information by any third parties.

BY PROVIDING US WITH YOUR PERSONAL INFORMATION OR OTHERWISE USING OUR SERVICES, YOU AGREE TO THE TERMS OF THIS PRIVACY NOTICE AND OUR TERMS OF SERVICE.

Click on the links below to jump to each section:

  • Information We Collect and Use

  • How We Share and Disclose Personal Information

  • Online Privacy Choices

  • Children’s Privacy

  • Links to Other Websites and Services

  • How to Contact Us

  • Changes to Our Privacy Policy

1. INFORMATION WE COLLECT AND USE

When we use the term “personal information,” we mean any information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular individual person.

We collect your information from a variety of sources:

A. Information You Provide to Us.

We collect and use personal information you provide to use in the following ways:

  • Communications.   If you communicate with us through any paper or electronic form, we collect your contact information, such as your name, provided location, address, phone number, the content of the communication and the metadata associated with the communication.  We may use this information to investigate and respond to your inquiries and user support requests and to communicate with you, including through the Services or by email, mail, phone, text message, push notification, chat or any other paper or electronic form.

  • Alerts.   If you sign up to receive news or alerts from us, we may collect your contact information, provided location and communication preferences in order to send you regular updates about the Services and about testing in your area.  We may use this information to manage our communications with you and send you information about testing and other information related to the pandemic that you may need to know or that may be of interest to you.  If you wish to stop receiving push notifications or text messages from us, please see the “Online Privacy Choices” section below.

  • Registering.   If you register for an account through our Services, we may collect your contact information, including your name, provided location, phone number, one-time verification code, and information you provide about your background, COVID-19 exposure, symptoms and other health sensitivities, including pre-existing conditions and whether you are a health worker or first responder.  We use this information to create your profile, manage your preferences, communicate with you about available testing and changes in local rules and regulations, and for user support purposes.

  • Testing.   If you search for nearby testing centers, we will collect your provided location, and information in your profile in order to match you with centers where you may meet the criteria for testing.  Moreover, as part of the registration process and through your profile page, you have the option of providing us with the results of past tests you have taken, including by uploading a photo of the test results.  We will use this information to manage your profile, to provide you with a record of your past tests and in ways you otherwise direct.  We may derive aggregate statistics about test results or use de-identified test results to assist in public health efforts and research.

Invite Friends.   If you choose to invite your friends or other contacts to use the Services, you may share your device’s native contact list, or you may manually enter the name and phone number of your contact, which we will use to send the person a one-time text message inviting them to join the platform.  We will also use the information to manage and facilitate the contact list on your profile within the Services.  Please note that you may choose to share the results of your tests with your contacts.

B. Information from Third Party Sources.

We may receive personal information about you from our data partners and service providers and combine this information with other information we collect from or about you.  The third parties may include our academic or clinical partners, website operators, governmental agencies and analytics providers.  We may also receive your information from your friends or contacts who refer you to the Services.  The information may include contact information, demographic information, and information about your use of our Services.  We use this information to administer and facilitate our Services, communicate with you about our Services, and to obtain insights into and protect our Services.

C. Information we Collect Automatically.

We use various technologies to collect information about the device or browser you use to navigate our Sites, or from your use of our Services, including:

  • Web Logs and Usage Data.   As is true of many websites and email communications, we gather certain information automatically and store it in log files.  This information may include IP addresses, browser type, internet service provider, referring/exit pages, operating system, date/time stamp and/or clickstream data.  We use this data to analyze trends on our Sites, manage and administer the content, for security and availability of the Services, improve the performance of the Services, and for fraud protection and to protect our rights and the rights and safety of individuals.  Additionally, we may collect a record of your provided location and inquiries into testing centers, which we use for our own internal analytics and to recommend other information about testing that you may need to know or that may be of interest to you.

  • Cookies and Other Data Collection Technologies.   We and our service providers use cookies, scripts and similar technologies to manage the Sites and to collect information about you and your use of our Sites.  These technologies help us to recognize you, customize or personalize your experience, and analyze the use of our Sites to make them more useful to you.  These technologies may also allow us to aggregate demographic and statistical data and provide this information to our service providers to facilitate their provision of services.  Most Internet browsers allow you to remove or manage cookie functions and adjust your privacy and security preferences.  For information on how to do this, access the “help” menu on your Internet browser, or access http://www.aboutcookies.org/how-to-control-cookies. Please note, however, that disabling our cookies may result in your inability to take full advantage of all of the features of our Services.

Google Analytics.   We use “Google Analytics” to collect information about your use of the Services.  Google Analytics collects information such as how often users access the Services, what pages they access when they do so and what other sites they used prior to using the Services.  We use the information we get from Google Analytics only to improve the Services.  To learn more about the use of data collection technologies by Google for analytics and to exercise choice regarding those technologies, please visit the Google Analytics Opt-Out browser add-on page.

D. Other Uses of Personal Information.

In addition to the uses described above, we may collect and use personal information for the following purposes:

  • To develop, maintain, improve and operate the Services.

  • To personalize your user experience.

  • To communicate with you to provide technical or administrative support.

  • To operate, manage and grow our organization.

  • To prevent, investigate and provide notice of fraud, unlawful or criminal activity, unauthorized access to or use of personal information, the Services or our data systems, and to meet legal, regulatory, judicial and institutional policy obligations.

  • To investigate and resolve disputes and security issues and to enforce our Terms of Service.

For any other lawful, legitimate business purpose.

2. HOW WE SHARE AND DISCLOSE PERSONAL INFORMATION

We may share your personal information in the following ways:

  • Service Providers.   We share personal information with third party service providers who perform services on our behalf, such as technology providers, including technology support providers, text message and push notification communications providers, analytics providers, data storage providers and web hosting providers and developers.

  • Business Partners.   At your request or for purposes consistent with this privacy policy, we may disclose personal information to our third-party partners to enable their functionality.  In some cases, you may ask us to share your information with academic institution (e.g., MIT) for its own contact tracing functionality or for regulatory reporting purposes.

  • Regulatory or Legal Requirements, Safety and Terms Enforcement.   We may disclose personal information to governmental regulatory authorities as required by law or for public health reasons in response to their requests for such information or to assist in investigations.  We may also disclose personal information to third parties in connection with claims, disputes or litigation, when otherwise required by law, or if we determine its disclosure is necessary to protect the health and safety of you or any other person, to protect against fraud, or to enforce our legal rights or contractual commitments that you have made.

  • Business Transfers.   We may disclose personal information as part of an organizational business transaction, such as a merger, acquisition, joint venture, financing, or sale of organizational assets and may transfer personal information to a third party as one of the business assets in such a transaction.  We may also disclose personal information in the event of insolvency, bankruptcy, or receivership.

  • At Your Request.   We may disclose your information publicly or with another third party with your prior authorization.

3. ONLINE PRIVACY CHOICES

You have some choices regarding how we use your personal information, including the following:

  • Access to Your Device Information. You may control the Service’s access to your device information through your “Settings” app on your device.  For instance, you can withdraw permission for the Sites to access your contacts, provided location, and camera or its integration with other permitted applications.

  • How to Control Your Communications Preferences. You can stop receiving promotional text message alerts from us by following the “unsubscribe” instructions provided in such communications or by changing your preferences within the settings menu of the Sites.  You may not opt-out of Service-related communications (e.g., account verification, transactional communications, changes/updates to features of the Service, technical and security notices).

  • How to Control Push Notifications. You can stop receiving push notifications from us by changing your preferences in the iOS or Android notifications settings menu.

    Modifying or Deleting Your Information. If you have any questions about reviewing, modifying, or deleting your information, you can contact us directly at privacy@allclear.app.  You may also request deletion of your profile from within the settings menu of the Sites.  We may not be able to modify or delete your information in all circumstances.

4. CHILDREN’S PRIVACY

We do not knowingly collect or solicit any information from anyone under the age of 13 on the Services and the Services are not targeted towards anyone under the age of 13.  In the event that we learn that we have inadvertently collected personal information from someone under age 13, we will delete that information as quickly as possible.  If you believe that we might have received information from a child under 13, please contact us at privacy@allclear.app.

5. LINKS TO OTHER WEBSITES AND SERVICES

The Services may contain links to third party websites or services, including those of our partners, like MIT.  You may also be able to interact with us or our Services through third parties, such as social media sites.

This privacy policy does not apply to the practices of these or any other third parties.  Allclear is not responsible for the privacy practices of any entity that it does not own or control.  We encourage you to review the privacy policies and terms of those third parties to learn more about their privacy practices.

6. HOW TO CONTACT US

If you have any questions about this privacy policy or the Services, please contact us by email at privacy@allclear.app.

7. CHANGES TO OUR PRIVACY POLICY

This privacy policy is subject to occasional revisions.  We will notify you of the changes by posting the new privacy policy on the Sites and updating the effective date.  We encourage you to check this page periodically to stay informed about how we are processing personal information.