Rave - Privacy

Date of Last Revision: May 5, 2023

Introduction

This Privacy Policy applies to data collection practices by Rave Wireless, Inc. (“Rave Mobile Safety,” “we” or “us”) via Rave Mobile Safety products including Rave Alert (getrave.com), Rave Panic Button, the Rave Guardian mobile app, and the Rave Smart911 service, (each, a “Site” and collectively the “Sites”) and shall apply to your use of the Sites and their capabilities and services (“Services”). This Privacy Policy governs the manner in which Rave Mobile Safety collects and uses information from you (“you”) on the Sites.

We are committed to protecting your privacy in compliance with all pertinent laws and regulations. Our Privacy Policy explains: (1) what information we collect and why we collect it; (2) how we use and share that information; (3) the choices we offer you, including how to access and update information, including the following topics:

When this Privacy Policy Applies
Terms of Use
Information We Collect
How We Use Information We Collect
Our Legal Basis for Collecting Personal Data
Information We Share
Consequences of Your Failure to Provide Personal Data
Our Retention of Your Personal Data
Your Choices regarding Accessing, Updating or Deleting Your Personal Data
European Users’ Rights with Respect to Personal Data
Our Opt-in/Out-out Policy
Third Party Links
International Transfer
How We Protect Personal Data
Children
Direct Marketing and “Do Not Track” Signals
Rights of California Residents
Smart911 Additional Terms
Changes to this Privacy Policy
How to Contact Us

Please familiarize yourself with our privacy practices that are described here and let us know if you have any questions. By using the Sites and the mobile apps, you confirm your acceptance of this Privacy Policy. If you do not agree to this Privacy Policy, please do not use the Sites or mobile apps.

Irrespective of the country you live in, you authorize us to transfer, store, and use your information in the United States and Canada in the manner described in this Privacy Policy, unless otherwise agreed upon between Rave Mobile Safety and our customer (which typically would be your school or employer). The privacy and data protection laws and rules regarding when government authorities may access data may vary from those in the country where you live. Learn more about our data transfer operations in the “International Transfer” section below. If you do not agree to the transfer, storage and use of your information in the United States and Canada, you must not use the Sites.

If you have any questions or comments about this Privacy Policy, please submit a request to privacy@ravemobilesafety.com.

When this Privacy Policy Applies

Our Privacy Policy applies to the Services offered by Rave Mobile Safety in the Introduction section above and excludes services that have separate privacy policies that do not incorporate this Privacy Policy.

Our Privacy Policy does not apply to services offered by other companies or individuals, including products or sites that may be displayed to you by Rave Mobile Safety, or other sites linked from our Services or Sites. Our Privacy Policy does not cover the information practices of other companies and organizations who advertise our Services, and who may use cookies, pixel tags and other technologies to serve and offer relevant ads.

Terms of Use

By accessing or using the Sites or Services in any manner, you also agree to be bound by Rave Mobile Safety's Terms of Use for the service or application you are using (the “Agreement”). Please read the Agreement carefully. If you do not accept all of the terms and conditions contained in or incorporated by reference into the Agreement, please do not use the Sites or Services.

Information We Collect

We collect information, including Personal Data, to provide better Services to all our users. We use the term “Personal Data” to refer to any information that identifies or can be used to identify an individual. Common examples of Personal Data include: first and last name, address, email address, business email address, organization name, phone number, digital identity such as a login name or handle, information about your device, and certain metadata.

“Sensitive Personal Data” refers to a smaller subset of Personal Data which is considered more sensitive to the individual, such as race and ethnic origin, political opinions, religious or philosophical beliefs, trade-union membership, genetic or biometric information, physical or mental health information, medical insurance data, or sexual orientation. Rave Mobile Safety does not collect or use Sensitive Personal Data through our Sites and Products and asks that you do not provide Sensitive Personal Data to us.

We collect Personal Data in the following ways:

1. Information You Give to Us

When registering for our Services or creating a subscriber account, you may choose to provide us with Personal Data such as your name, phone number, email address, physical address, geolocation, and medical or household information.

When using our Services, you may provide us with information sent between you and individuals authorized to administer our Services. You may elect to share information with the Services that includes location data, address data, and phone contact data. You may also provide us with Personal Data about yourself when you report a problem or have a question about our Sites or Services. Please note that if you do not provide us with Personal Data, your ability to use certain aspects of our Sites and Services may be limited.

2. Information We Obtain from Your Use of Our Sites

We collect certain information automatically, such as your operating system version, browser type, and internet service provider. When you use our Sites or Services, we automatically collect and store this information in service logs. This includes: details of how you used our Sites and Services; Internet protocol address; and cookies that uniquely identify your browser. We may also collect and process information about your actual location. The information we collect automatically is statistical data and may or may not include Personal Data, but we may maintain it or associate it with Personal Data we collect in other ways or receive from third parties.

3. Information our Customers May Give Us About You

Others who may have contracted for our Services for your use, such as your employer or your school, have the option to provide us with Personal Data and your eligibility to use the Services they purchased. The information provided by your employer or school may include your name, phone number, email address, street address, geolocation (if you opt-in for the Services, and such other data as you may request or it determines is appropriate.

4. Cookies

We and our partners use cookies and web log files to collect and store information when you visit or use one of our Services, and this may include using cookies or similar technologies to identify your browser or device. With both cookies and log files, the information that we collect, and share is anonymous and not personally identifiable. It does not contain your name, address, telephone number, or email address. A cookie is a small file placed on the hard drive of your computer. You may refuse to accept browser cookies by activating the appropriate setting on your browser. However, if you select this setting, you may be unable to access or have the benefit of certain parts of our Services. Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies when you direct your browser to our Services. For more information about our use of cookies, including details on how to opt-out of certain cookies, please see our Cookie Policy.

How We Use Information We Collect

We use your Personal Data in ways that are compatible with the purposes for which it was collected or authorized by you, including:

To inform you about Services available from Rave Mobile Safety;
To authorize access to our Sites and Services;
To provide you with Services;
To improve our customer service;
To respond to and support your school or employer regarding its use of the Sites and Services;
To comply with all applicable legal requirements. and
To investigate possible fraud or other violations of our Terms of Use or this Privacy Policy and/or attempts to harm our users.

We use the information we collect from our Sites to provide, maintain, and improve them, to develop new Services, and to protect our company and our customers.

We may use information collected from cookies and other technologies to improve your user experience and the overall quality of our Services. For example, by saving your language preferences, we’ll be able to have our Services appear in the language you prefer. We may use your personal information to see which web pages you visit at our Sites, and we may then develop statistics that help us understand how our visitors use our Sites and how to improve them. We may also use the information we obtain about you in other ways for which we provide specific notice at the time of collection.

We will ask for your consent before using information for a purpose other than those set out in this Privacy Policy.

Our Legal Basis for Collecting Personal Data

Whenever we collect Personal Data from you, we may do so on the following legal bases:

Your consent to such collection and use;
Out of necessity for the performance of an agreement between us and you, such as your agreement to use our Services and products;
Our legitimate business interest, including but not limited to the following circumstances were collecting or using Personal Data is necessary:
- Intra-company transfers of customer data for administrative purposes;
- Product development and enhancement, where the processing enables us to enhance, modify, personalize, or otherwise improve our Services and communications for the benefit of our customers, and to better understand how people interact with our Sites and Services;
- Fraud detection and prevention;
- Enhancement of our cybersecurity, including improving the security of our network and information systems; and
- General business operations and diligence;

provided that, in each circumstance, we will weigh the necessity of our processing for the purpose against your privacy and confidentiality interests, including taking into account your reasonable expectations, the impact of processing, and any safeguards which are or could be put in place to protect your privacy. In all circumstances, we will limit such processing for our legitimate business interest to what is necessary for its purposes.

Information We Share

We do not share Personal Data collected through the Sites or Services with companies, organizations and individuals outside of Rave Mobile Safety unless one of the following circumstances applies:

With your consent. We may share Personal Data with companies, organizations, or individuals outside of Rave Mobile Safety when we have your consent to do so.
Enterprise accounts. Your employer or school may have offered you access to our Services. In such a circumstance, we may share Personal Data you provide with your employer or school so that it can review and manage your use of such enterprise Services.
For external processing. We may provide Personal Data to our affiliates or other trusted businesses or partners to process it for us, based on our instructions and in compliance with this Privacy Policy and any other appropriate confidentiality and security measures. These third parties include communication service providers, emergency service providers and public safety agencies. Examples of permitted disclosure of Personal Data include:

Your wireless phone number may be submitted to participating safety and emergency response service providers, including without limitation, 9-1-1 or equivalent services, fire, police, emergency medical, emergency management, campus safety officials and public health services in order to locate the device during an emergency or transmit messages that you send or receive. We may store or archive snapshots of then-current Subscriber information as it’s made available to emergency service providers, for the period of time dictated by their record keeping policies. Such third parties may use such information to send emergency and general interest notifications to you via various communication methods (e.g. voice calls, text messaging, email, etc.).
In the event an emergency call or other direct communication is placed from your phone or device, and provided that the agency receiving the call uses our Services, your information may be displayed on the answering operator's workstation screen or made available to emergency responders. 3. In the event a non-9-1-1 call is made to a public safety agency from your phone and is then routed into a 9-1-1 system, if the receiving 9-1-1 agency uses our Services your information may be displayed on the 9-1-1 operator's workstation screen. In these situations, once information is passed to the local 9-1-1 authorities, we no longer have control over the transmission of the information. It may be conveyed verbally over an unsecured radio or transmitted in some other way to the responding emergency response team or others.

4. In the event an emergency service provider uses the Services’ database query tools, and your information includes an address within the querying provider's jurisdiction, and a portion of your information matches the provider's query criteria, and if you have elected to participate in this portion of our Services, your information will be displayed in the search results presented to that provider.

It is our policy to only share Personal Data with contractors, service providers and other third parties who are bound by obligations to keep Personal Data confidential and use it only for the purposes for which we disclose it to them. Under certain circumstances, you may avoid having us share your information with our business partners and vendors by not granting us permission to share it. Not granting us permission to share your information with our business partners or vendors may limit your access to their services through the Sites. We do not share Personal Data with third parties for their own marketing purposes.

4. For Legal Reasons. We may share Personal Data with companies, organizations or individuals outside of Rave Mobile Safety if we have a good-faith belief that access, use, preservation or disclosure of the information is reasonably necessary to:

Comply with an applicable law, regulation, legal process or enforceable governmental request.
Enforce applicable terms of use, including investigation of potential violations.
Detect, prevent, or otherwise address fraud, security, or technical issues.
Protect against harm to the rights, property or safety of Rave Mobile Safety, our users or the public, as required or permitted by law.

We attempt to notify users about legal demands for their Personal Data when appropriate in our judgment, unless prohibited by law or court order or when the request is an emergency. We may dispute such demands when we believe, in our discretion, that the requests are overbroad, vague or lack proper authority, but we do not promise to challenge every demand.

The specific circumstances under which we may share your Personal Data will vary based on the information you provide, the Services you elect to participate in, and how you use the Services.

Business Transfers. As we continue to develop our business, we may buy, sell, or share assets in connection with, for example, a merger, acquisition, reorganization, sale of assets, or bankruptcy. In such transactions, Personal Data about our users is often a transferred business asset. In the event that Rave Mobile Safety itself or substantially all of our assets are acquired, Personal Data about our users may be one of the transferred assets to enable the new owner to provide the Services to you in compliance with our agreements, this Privacy Policy and applicable law. Subsequent to the change of ownership, the new owner will be solely responsible for compliance with this Privacy Policy (or a replacement to which you agree) and the law.
Aggregate Site Use Information. Our Services may automatically collect usage information, such as the numbers and frequency of visitors to our Sites and users who use our Services. We use this information in aggregate form and not in a manner that would identify you personally. We may share aggregate and anonymized/ pseudonymized Personal Data to advertisers and other third parties in order to promote or describe use of the Sites and Services.
3rd Party Product Training Tools. If you choose to interact with the in-product training and walkthrough tools, we do collect individual user information in accordance with our "Information We collect" section above.

Rave Mobile Safety is not responsible for the actions or inactions of any third party receiving your Personal Data as permitted herein. These third parties may have their own respective privacy policies governing their use, protection, and disclosure of your Personal Data.

Consequences of Your Failure to Provide Personal Data

Your provision of Personal Data is required in order to use certain parts of our Sites and Services. If you fail to provide such Personal Data, you may not be able to access and use our Services on our Sites or parts of our Services available via the Sites.

Our Retention of Your Personal Data

We may retain your Personal Data for a period of time consistent with the original purpose for collection. We keep your Personal Data for no longer than reasonably necessary for your use of our products and Services and for a reasonable period of time afterward to conform to legal and business requirements.

If your account is removed from our Sites and Services, we generally delete account information within thirty (30) days of account removal, except that we retain your Personal Data even after you have closed your account if reasonably necessary to address our legitimate business interests, including to comply with our legal obligations (including law enforcement requests), meet regulatory requirements, conduct audits, comply with our legal obligations, resolve disputes, maintain security, prevent fraud and abuse, enforce our Terms of Service, or fulfill your request to “unsubscribe” from further messages from us.

Your Choices regarding Accessing, Updating or Deleting Your Personal Data

Whenever you use our Services, we aim to provide you with choices about how we use your Personal Data. We also will provide you with access to your Personal Data. If that information is wrong, we will give you ways to update it quickly or to delete it – unless we have to keep that information for legitimate business or legal purposes. Subject to applicable law, you may obtain a copy of personal information we maintain about you or you may update or correct inaccuracies in that information through your Profile or Account, or by contacting us

at privacy@ravemobilesafety.com. To help protect your privacy and maintain security, we will take steps to verify your identity before granting you access to the information. In addition, if you believe that personal information, we maintain about you is inaccurate, subject to applicable law you may have the right to request that we correct or amend the information by contacting us as indicated in the How to Contact Us section below.

You may update your information stored on the Sites at any time, as applicable to your Sites and Services:

Where you have been given access to the Sites and Services, you may update your information in the "My Profile" and/or "My Account" areas.
Where your organization provides your information on your behalf, you must contact the organization to access this information or request changes to it.

You may also update or correct information about yourself by emailing us at privacy@ravemobilesafety.com.

We may contact you to request that you update your Personal Data on a regular basis to ensure its integrity for the purposes of ongoing data management.

European Users’ Rights with Respect to Personal Data

Some data protection laws, including the European Union’s General Data Protection Regulation (“GDPR”), provide you with certain rights in connection with Personal Data you have shared with us. If you are resident in the European Economic Area, you have the following rights, all of which we provide you, as described in this Privacy Policy:

The right to be informed: You are entitled to be informed of the use of your Personal Data.
The right of access: You have the right to request a copy of your Personal Data which we hold about you.
The right of correction: You have the right to request correction or changes of your Personal Data if it is found to be inaccurate or out of date.
The right to be forgotten: You have the right to request us, at any time, to delete your Personal Data from our servers and to erase your Personal Data when it is no longer necessary for us to retain such data. Note, however, that deletion of your Personal Data will likely impact your ability to use our Services.
The right to object (opt-out): You have the right to opt-out of certain uses of your Personal Data, such as direct marketing, at any time.
The right to data portability: You have the right to a “portable” copy of your Personal Data that you have submitted to us. Generally, this means your right to request that we move, copy or transmit your Personal Data stored on our servers / IT environment to another service provider’s servers / IT environment.
The right to refuse to be subjected to automated decision making, including profiling: You have the right not to be subject to a decision and insist on human intervention if the decision is based on automated processing and produces a legal effect or a similarly significant effect on you.
The right to lodge a complaint with a supervisory authority: Should you do that, we encourage you also to contact us using the contact information below, and we will consider your request in accordance with applicable laws.

Our Opt-in/Opt-out Policy

By providing an email address or other contact information on the Rave Mobile Safety Sites or it is provided with your consent by your school or employer, you agree that we may contact you in the event of a change in this Privacy Policy, to provide you with any Services-related notices, or to provide you with information about our events, invitations, or related educational information.

We currently provide the following opt-out opportunities:

At any time, you can follow a link provided in offers, newsletters or other messages (except for Service notice emails) received from us to unsubscribe from the Services.
At any time, you can contact us through privacy@ravemobilesafety.com or the address provided below to unsubscribe from the Services and opt-out of our right per your consent under the terms of this Privacy Policy to share your Personal Data.
Where you have been given access to the Sites and Services, you may update your subscription settings in your account.
Where your organization provides your information on your behalf, you must contact the organization to access this information or request changes to your information.

Third Party Links

The Sites may contain links to webpages operated by parties other than Rave Mobile Safety. We do not control such websites and are not responsible for their contents or the privacy policies or other practices of such websites. Our inclusion of links to such websites does not imply any endorsement of the material on such websites or any association with their operators. Further, it is up to the user to take precautions to ensure that whatever links the user selects or software the user downloads from such websites is free of such items as viruses, worms, trojan horses, defects and other items of a destructive nature. These websites and services may have their own privacy policies, which the user will be subject to upon linking to the third party's website. Rave Mobile Safety strongly recommends that each user review the third party's terms and policies.

International Transfer

We are committed to complying with applicable laws, regulations and mandatory government standards regarding the protection of Personal Data.

Since we are a global organization, Personal Data and any additional information submitted may be used globally in connection with employment, business processes within Rave Mobile Safety, or communicating with our clients. Therefore, Personal Data may be transferred to other Rave Mobile Safety entities worldwide, where it will be processed in accordance with this Privacy Policy and laws that are applicable in each country. Countries where we process data may have laws which are different, and potentially not as protective, as the laws of your own country.

If we transfer your Personal Data out of your jurisdiction, we will implement suitable safeguards and rely on legally provided mechanisms to lawfully transfer data across borders to ensure that your Personal Data is protected.

How We Protect Personal Data

Rave Mobile Safety maintains administrative, technical and physical safeguards designed to protect the user's Personal Data and information against accidental, unlawful or unauthorized destruction, loss, alteration, access, disclosure or use. We implement appropriate technical and organizational measures to ensure a level of security appropriate to the risk, taking into account technological reality, cost, the scope, context and purposes of processing weighted against the severity and likelihood that the processing could threaten individual rights and freedoms. For example, we use commercially reasonable security measures such as encryption, firewalls, and transport layer security (TLS) or hypertext transfer protocol secure (HTTPS) to protect Personal Data. However, Rave Mobile Safety cannot guarantee the security of user account or other personal information. Unauthorized entry or use, hardware or software failure, and other factors, could compromise the security of user information at any time.

Children

In accordance with the Children’s Online Privacy Protection Act (“COPPA”), we do not market to or knowingly collect any information about children under the age of 13 unless and until a relevant institution has provided consent and authorization for a child under the age of 13 to use the Sites or Services and for us to collect information from such child. If you are a minor less than 13 years old, please do not register for Services or provide any personal information about you to us. If you are less than 16 years old, do not provide any personal health information about yourself to us. If you believe that we might have inadvertently collected personal information from a child under age 13 or personal health information from a child under age 16 without proper consent, please contact us at privacy@ravemobilesafety.com. If we learn that we have inadvertently collected the personal information of a child under 13, or equivalent minimum age depending on jurisdiction, without proper consent, we will take steps to delete the information as soon as possible.

Direct Marketing and “Do Not Track” Signals

Rave Mobile Safety does not track its customers over time or across third party websites to provide targeted advertising and therefore does not respond to Do Not Track (DNT) signals. However, some third-party sites do keep track of your browsing activities when they serve you content, which enables them to tailor what they present to you. If you are visiting such sites, your browser may include controls to block and delete cookies, web beacons and similar technologies, to allow you to opt out of data collection through those technologies.

Rights of California Residents

California residents are entitled under the California Consumer Privacy Act to contact us for various purposes, including to request information about whether we have disclosed personal information to third parties for their direct marketing purposes. We do not disclose personal information to third parties for their direct marketing purposes. California residents have the right to be informed as to what personal information about them we may have, how we collected and may use that information and how to have it corrected or deleted and may request further information about our compliance with this law by contacting us by one of the means listed in the “How to Contact Us” section below.

Smart911 Additional Terms

If you are a Smart911 subscriber, the following additional terms apply:

You may choose to provide additional personal information in your subscriber account. The types of additional personal information collected may include driver’s license number, license plate number, photos, and date of birth. You may also include personal health information such as medical and health conditions, medical devices and medications. This additional information is optional and is provided at your sole discretion. It is your responsibility to determine how much or how little information you wish to make available.
If you are a legal guardian or parent of a minor, you may provide the service with personal information including personal health information about the minor and we will treat it under this Privacy Policy.
You can change your subscriber account at any time, whether it is the information supplied at registration, as part of maintaining your subscriber account, or anything else. You may add, modify, or remove information on your subscriber account by logging into www.smart911.com and accessing your profile. You understand that we use your personal information to provide you with the Services. If you refuse to provide us with the personal information we require or later withdraw your consent to use and disclose this information, we may no longer be able to provide you with these Services.
You may add or remove which Services you choose to participate in at any time, by logging into www.smart911.com and modifying your preferences.
You may cancel any or all of the Services at any time by logging into www.smart911.com and accessing account settings.
In addition to the possible uses of your Personal Data referenced elsewhere in this Privacy Policy, (a) your location and subscriber information may be shared with other individuals that you have designated as guardians; (b) in the event you send a “Tip”, your subscriber information may be viewed by an emergency service provider, unless the emergency service provider receiving your Tip has configured the service to be anonymous; and (c) when you invite a guardian, we may send such person a message on your behalf using your name and contact details. We may also send reminders to them in your name.

Changes to this Privacy Policy

Our Privacy Policy may change from time to time. The latest version will always be available here and the most recent revision date will be indicated at the top of this page. We will not reduce your rights under this Privacy Policy without notice. We will post any privacy policy changes on this page and, if the changes are significant, we will provide a more prominent notice (including, for certain Services or products, email notification of privacy policy changes). Please check this page occasionally to make sure you are aware of any updates.

How to Contact Us

If you have any questions about this Privacy Policy, you can contact us via email or phone, or by writing to us as follows:

Rave Mobile Safety

Attn: Privacy Policy Inquiry

492 Old Connecticut Path

2nd Floor

Framingham, MA 01701

Toll-free: 888-605-7164

privacy@ravemobilesafety.com