Digital contact tracing wearables
Digital contact tracing wearables

Privacy Policy

VOS Systems LLC / AlertTrace™ PRIVACY POLICY

VOS Systems LLC, a US Delaware limited liability company (“VOS”) respects the privacy of all who utilize the AlertTrace system (“AlertTrace” or “System”) and are committed to protecting that privacy through our compliance with this Privacy Policy (“Policy”).

This Policy describes the types of information we may collect from users and our practices for collecting, using, protecting and disclosing that information.

This Policy applies to information we collect:

  • When you visit our website alertrace.com (“Website”).
  • Via the wearables devices that are part of our AlertTrace system (“AT Devices”).
  • Through our data gateways/hubs (“AT Hubs”) which collect data from our Devices and transmit the data to cloud-based servers.
  • Through any servers we utilize that store AlertTrace-related data and which are controlled by VOS (“AT Servers”).
  • Through our mobile and desktop applications (“AT Apps”), which provide dedicated non-browser-based interaction between users and the AlertTrace-related data stored on our AT Servers or on private servers provided by the VOS customer companies or organizations who are users of the System.
  • When VOS customer companies or organizations register the AT Devices via our AT Apps.
  • When users interact with our advertising on third-party websites and services, if those applications or advertising include links to this Policy.
  • In e-mail, text and other electronic messages between users and our Websites or AT Apps.
  • Through our VOS/AlertTrace dealers or distributors.
  • When anyone interacts with us in another way – for example, contacting us with an inquiry.

This Policy outlines our policies and practices regarding personal information (information relating to individuals who can be identified) and how we will treat it. This Policy may change from time to time (see Changes to our Privacy Policy section below), so please check the Policy periodically for updates. If any questions arise about the meaning or interpretation of this Policy, the English-language version of this Policy is the official text.

Information We Collect and How We Collect It

AlertTrace is designed to protect the personal information of individuals who are wearing an AT Device or using our System:

  • No personal identifying information (“Personal Information”) is stored on the Devices and no Personal Information is transmitted by or stored in the System other than Personal Information which a company or organization which is utilizing the System chooses to include in either the AT server or a server under direct control of that organization.
  • Specifically, the Devices do not store or transmit Personal Information that can identify age, gender, movement, location, language preference, expertise, date of birth; and/or information about internet connections or social media contacts or details.

Information Users Provide to Us

We collect information provided to us by those who choose to interact with us via our Websites or when dealing with VOS (“User-Provided Information”), including:

  • Information that you provide by making an inquiry.
  • In the event that you contact us, we maintain records and copies of your correspondence (including e-mail and other electronic messages).
  • Responses to surveys that we might request for research purposes.
  • Search queries on our Websites.

Usage Details, IP Addresses, Cookies and Other Technologies

As you navigate through and interact with our Websites, we may automatically collect certain information about your equipment, browsing actions and patterns, including:

  • Details of your visits to our Websites, including traffic data, location data, logs and other communication data and the resources that you access and use on our Websites.
  • Information about your computer and internet connection, including your IP address, operating system and browser type.

The information we collect in this way is anonymous. It is aggregated into statistical data to help us improve our Websites and to deliver a better and more personalized service by enabling us to:

  • Estimate our audience size, browser statistics, popularity of content and usage patterns.
  • Speed up your searches.
  • Recognize you when you return to our Websites.

The technologies we use for this automatic data collection may include:

  • Cookies (or browser cookies).A cookie is a small file placed on the hard drive of your computer. In some jurisdictions, we are not permitted to send cookies to the browser of a user without the prior consent of the affected user. In this case, we will seek such consent. The remainder of this section assumes that either the use of cookies is not restricted by applicable law, or if it is restricted that the individual has explicitly consented to the use of the cookies.  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 certain parts of our Websites. 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 Websites.

We do not collect User-Provided Information automatically, but we may tie this information to User-Provided Information about you that we collect from other sources or you provide to us, in which case we will process such User-Provided Information in accordance with the remainder of this Policy.

Third-party Advertiser Use of Cookies and Other Tracking Technologies

Some advertisements on our Websites and the advertisements and offers on our Websites are served by third-party advertisers, ad networks, and ad servers. Additionally, some of the applications accessible from, or on, our Websites may be owned by third parties. These third parties may use cookies alone or in conjunction with other tracking technologies to collect information about our users. We do not control these third parties’ tracking technologies or how they may be used. If you have any questions about an advertisement on VOS.com or AlertTrace.com or an advertisement or offer on our Websites or at our dealers or distributors, you should contact the responsible advertiser directly. For information about how you can opt out of receiving targeted advertising from these providers, see Choices About How We Use and Disclose Your Information section below.

How We Use Your Information

We use information that we collect about you or that you provide to us, including any User-Provided Information for the following legitimate business purposes:

  • To present our Websites and its contents to you.
  • To provide you with information, products or services that you request from us.
  • To offer and fulfill our core business purposes which include:
    • Fulfilling VOS/AlertTrace’s obligation to AlertTrace owners
    • Financial processing
    • Communicating key organizational messages
    • Supporting programs and organizations using VOS/AlertTrace
    • Complying with any legal obligations
  • To fulfill any other purpose for which you provide it.
  • To carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collection.
  • To notify you about changes to our Websites or any products or services we offer or provide though it.
  • To allow you to participate in interactive features on our Websites.
  • To store information about your preferences, allowing us to customize our Websites according to your individual interests.
  • In any other way we may describe when you provide the information.
  • For any other purpose where we have your consent.

We may also use your information to contact you about our own and third-parties’ goods and services that may be of interest to you. VOS/AlertTrace will not sell or trade any data collected on or by the System.

Disclosure of Your Information

Please note that we may still use any aggregated and de-identified information that does not identify any individual and may also retain and use your information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements. We may disclose User-Provided Information that you provide as described in this Policy:

  • To contractors, service providers and other third parties we use to support our business and who are bound by contractual obligations to keep User-Provided Information confidential and use it only for the purposes for which we disclose it to them.
  • To third parties to market their products or services to you if you have consented to these disclosures. We contractually require these third parties to keep User-Provided Information confidential and use it only for the purposes for which we disclose it to them. For more information, see Choices About How We Use and Disclose Your Information section below.
  • To fulfill the purpose for which you provide it.
  • For any other purpose disclosed by us when you provide the information.
  • With your consent.

We may also disclose your User-Provided Information:

  • To comply with any court order, law or legal process, including to respond to any government or regulatory request.
  • If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of VOS/AlertTrace, dealers or distributors. This includes exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction.

Choices About How We Use and Disclose Your Information

We strive to provide you with choices regarding the User-Provided Information you provide to us. We have created mechanisms to provide you with the following control over your information:

  • Tracking Technologies and Advertising.You can set your browser to refuse all or some browser cookies, or to alert you when cookies are being sent. If you disable or refuse cookies, please note that some parts of this site may then be inaccessible or not function properly.
  • Disclosure of Your Information for Third-Party Advertising.We do not share your User-Provided Information with unaffiliated or non-agent third parties for promotional purposes without your consent, but if you have previously consented and want us to no longer share your User-Provided Information with unaffiliated or non-agent third parties for promotional purposes, you can send us an e-mail stating your request to Support@AlertTrace.com.
  • Promotional Offers.If you do not wish to have your contact information used by VOS/AlertTrace to promote our own or third parties’ products or services, for some third parties’ products or services you can opt-out by sending us an e-mail stating your request to Support@AlertTrace.com. If we have sent you a promotional e-mail, you may send us a return e-mail asking to be omitted from future e-mail distributions.

Do Not Sell

VOS/AlertTrace will not sell, trade or share   User-Provided Information, including their name, phone number, email, or physical address with non-VOS/AlertTrace third parties nor will it send mailings on behalf of other unrelated organizations. This policy applies to all information received by VOS/AlertTrace, both online and offline, as well as any electronic, written or oral communication. VOS/AlertTrace occasionally uses third-party vendors to manage and process your information. These vendors are bound by strict confidentiality agreements.

Accessing and Correcting Your Information

You may also send us an e-mail at Support@AlertTrace.com to request access to, correct or delete any User-Provided Information that you have provided to us. We cannot delete your User-Provided Information except by also deleting your user account. We may not accommodate a request to change information if we believe the change would violate any law or legal requirement or cause the information to be incorrect.

If you delete your User Content from the Websites, copies of your User Content may remain viewable in cached and archived pages, or might have been copied or stored by other Websites users. Proper access and use of information provided on our Websites, including User Content, is governed by our Terms of Use, although for EU/EEA based individuals this does not prejudice your mandatory rights under EU Protection Law (see EU Privacy Notice below).

Children Under the Age of 16

Our Websites is not intended for children under 16 years of age. No one under age 16 may provide any User-Provided Information to or on our Websites. We do not knowingly collect User-Provided Information from children under 16. If you are under 16, do not use or provide any information on our Websites or on or through any of its features/register on our Websites, make any purchases through our Websites, use any of the interactive or public comment features of our Websites or provide any information about yourself to us, including your name, address, telephone number, e-mail address or any screen name or user name you may use. If we learn we have collected or received User-Provided Information from a child under 16 without verification of parental consent, we will delete that information. If you believe we might have any information from or about a child under 16, please contact us at Support@AlertTrace.com.

California Privacy Rights

The California Consumer Privacy Act (CCPA) provides California consumers with the right to request access to their personal data, additional details about our information practices and deletion of their personal data (subject to certain exceptions).  California consumers also have the right to opt out of sales of personal data, if applicable.   We describe how California consumers can exercise their rights under the CCPA below.  Please note that you may designate an authorized agent to exercise these rights on your behalf by providing written materials demonstrating that you have granted the authorized agent power of attorney.  Please note that if an authorized agent submits a request on your behalf, we may need to contact you to verify your identity and protect the security of your personal data.  We will not fulfill your CCPA request unless you have provided sufficient information for us to reasonably verify you are the consumer about whom we collected personal data.  We will not discriminate against you if you choose to exercise your rights under the CCPA. 

You may request, no more than twice in a 12-month period, access to the specific pieces of personal data we have collected about you in the last 12 months.  You may also request additional details about our information practices, including the categories of personal data we have collected about you, the sources of such collection, the categories of personal data we share for a legitimate business or commercial purposes, and the categories of third parties with whom we share your personal data. You may make these requests by contacting using the contact information provided below in the “Contact Information” Section.   After submitting your request, please monitor your email for a verification email.  We are required by law to verify your identity prior to granting access to your data in order to protect your privacy and security.

You may request, no more than twice in a 12-month period, transportable copies of your personal data that we have collected about you in the last 12 months.  You may make these requests by contacting using the contact information provided below in the “Contact Information” Section.   After submitting your request, please monitor your email for a verification email.  We are required by law to verify your identity prior to granting access to your data in order to protect your privacy and security.

You may request that we delete the personal data we have collected about you.  Please note that we may retain certain information as required or permitted by applicable law.  You may make these requests by contacting us using the contact information provided below in the “Contact Information” Section below.  After submitting your request, please monitor your email for a verification email.  We are required by law to verify your identity prior to granting access to your data in order to protect your privacy and security.

Data Security

We will only retain User-Provided information

We have implemented reasonable administrative, physical, and electronic measures designed to secure your User-Provided Information from accidental loss and from unauthorized access, use, alteration and disclosure. All User-Provided Information you provide to us is stored on password-protected databases on our secure servers behind firewalls and we use Secure Sockets Layer (SSL) to ensure that the transmission of sensitive data for payments and contributions is encrypted and appropriately safeguarded. We train our employees on the importance of information security and focus specifically on practices for protecting against unauthorized disclosure of personal data. We have a documented incident response plan for acting upon events that violate VOS/AlertTrace’s security or privacy policies, should they occur, and this plan is reviewed and updated on an ongoing basis.

The safety and security of your information also depends on you. Where we have given you (or where you have chosen) a password for access to certain parts of our Websites, you are responsible for keeping this password confidential. Passwords registered with our Websites are encrypted to ensure protection against unauthorized access to your User-Provided Information. We ask you not to share your password with anyone. We urge you to be careful about giving out information in public areas of our Websites. The information you share in public areas may be viewed by any user of our Websites. Should you think your account or password has been compromised, please notify us immediately.

Unfortunately, the transmission of information via the internet is not completely secure. Although we do our best to protect your User-Provided Information, we cannot guarantee the security of your User-Provided Information transmitted to our Websites or over any public network. Any transmission of User-Provided Information is at your own risk. Without prejudice to any mandatory legal obligations to which we may be subject, we are not responsible for circumvention of any privacy settings or security measures contained on our Websites.

Payment

We use outside service providers to facilitate payments on the Websites and to perform functions on our behalf associated with all processing of payments. Such third party providers may include but are not limited to Stripe.  These third parties may have access to your information as needed to perform their functions, but they may not use it for any other purpose. 

Changes to Our Privacy Policy

VOS/AlertTrace may change, add, modify or remove portions of this Policy at any time, which shall become effective immediately upon posting on this page. The date the Policy was last revised is identified at the bottom of the page. It is your responsibility to review this Policy for any changes. By continuing to use our Websites, you agree to any changes in the Policy.

EU Privacy Notice

If you are a resident of the European Union (EU) or European Economic Area (EEA) whose Personal Information and User-Provided Information we collect, the following additional information applies to you.

1 Introduction

1.1 – Where you are an EU or EEA resident and VOS knowingly collects your Personal Information or User-Provided Information (also called ‘personal data’), we will do so in accordance with applicable laws that regulate data protection and privacy. This includes, without limitation, the EU General Data Protection Regulation (2016/679) (‘GDPR’) and EU member state national laws that implement or regulate the collection, processing and privacy of your personal data (together, ‘EU Data Protection Law’).

1.2 – This EU privacy notice (‘EU Privacy Notice’) which should be read in conjunction VOS’s Privacy Policy provides further information as required under EU Data Protection Law on how we handle or process the personal data we collect and who we may share it with.

1.3 – This Privacy Notice also provides information on your legal rights under EU Data Protection Law and how you can exercise them.

2 How personal data is collected

2.1 – Because of the global nature of our organization, VOS/AlertTrace may hold and process personal data that is collected from companies and organizations around the world, including within the EU/EEA.

2.2 – This also means that if you are a member or individual contact of a VOS customer company or organization in the EU/EEA, your personal data may be transferred from the EU/EEA to VOS servers in the United States or to VOS customer company or organization servers in the United States.

2.3 – US data privacy laws are currently not considered to meet the same legal standards of protection for personal data as set out under EU Data Protection Law. However, in order to safeguard personal data received from the EU/EEA, we only allow such a transfer of personal data to the US or other third countries under an approved contract or another appropriate mechanism which is legally authorized under EU Data Protection Law.

2.4 – This is to make sure that the personal data that VOS/AlertTrace receives and processes (so far as it relates to residents of the EU/EEA) is properly safeguarded in accordance with similar legal standards of privacy you would enjoy under EU Data Protection Law.

3 Direct Marketing

3.1 – If VOS/AlertTrace provides direct marketing communications to individuals in the EU/EEA regarding services and/or events which may be of interest, this will be done in accordance with EU Data Protection Law, and in particular where we contact individuals for direct marketing purposes by SMS, email, fax, social media and/or any other electronic communication channels, this will only be with the individual’s consent or in relation to similar services to services that the individual has purchased (or made direct enquiries about purchasing) from VOS/AlertTrace before.

3.2 – Individuals are also free to object or withdraw consent to receive direct marketing from us at any time, by contacting us using the email address below.

4 The lawful grounds on which we collect and process personal data

4.1 – We process your personal data for the above purposes, relying on one or more of the following lawful grounds under EU Data Protection Law:

(a) where you have freely provided your specific, informed and unambiguous consent for VOS/AlertTrace to process your personal data for particular purposes:

(b) where we agree to provide services to you, in order to set up and perform our contractual obligations to you and/or enforce our rights:

(c) where VOS customer companies or organizations need to process and use your personal data in connection with their legitimate interests as a company or organization. We will always seek to pursue these legitimate interests in a way that does not unduly infringe on your legal rights and freedoms and, in particular, your right to privacy: and/or

(d) where we need to comply with a legal obligation or for the purpose of us being able to establish, exercise or defend legal claims.

4.2 – Please also note that we do not collect, transmit or process any personal data that would include what is known as ‘sensitive’ or ‘special category’ personal data about you, for example, information regarding your ethnic origin or political, philosophical and religious beliefs. This is not the type of data that VOS/AlertTrace or its VOS customer companies or organizations would routinely collect. However, in the event that such sensitive or special category data were to be collected, it would only be in some specific situations where:

(a) you have provided this with your explicit consent for us to use it: or,

(b) there is a legal obligation on us to process such data in accordance with EU Data Protection Law

(c) it is needed to protect your vital interests (or those of someone else) such as in a medical emergency: or,

(d) where you have clearly chosen to publicize such information: or,

(e) where needed in connection with a legal claim that we have or may be subject to.

5 Disclosing your personal data to third parties

5.1 – Although we do not collect personal data, the VOS customer companies and organizations who utilize the AlertTrace system do collect and process such data as part of their company or organization mission to protect the safety of staff, employees, contactors or volunteers. VOS and its VOS customer companies and organizations will use that data solely in accordance with policies which protect the privacy of users, including any third-party companies and/or organizations that support their business and operations (for example providers of web or database hosting, IT support, payment providers, event organizers, agencies used to conduct fraud checks or mail management service providers) as well as professionals they use such as lawyers, insurers, auditors or accountants. Only such data processors will be used who can guarantee that adequate safeguards are put in place by them to protect the personal data they process on our and our VOS customer companies’ or organizations’ behalf.

5.2 – Other than as described above, we will treat your personal data as private and will not routinely disclose it to third parties without you knowing about it. The exceptions are in relation to legal proceedings or where we are legally required to do so and cannot tell you (such as a criminal investigation). We always aim to ensure that your personal data is only used by third parties we deal with for lawful purposes and who observe the principles of EU Data Protection Law.

6 How long we retain your personal data for

6.1 – VOS customer companies and organizations will retain personal data identifying you for as long as necessary in the circumstances – for instance, as long you are an employee, contractor, staff member or volunteer with the VOS customer company or organization – or for a reasonable period as may be needed to enforce or defend contract claims or as is required by applicable law.

6.2 – VOS has adopted a data retention policy for EU residents (which we may make available on request) that sets out the different periods we may retain personal data – in the event VOS does in the future retain any personal information – in respect of relevant purposes in accordance with our duties under EU Data Protection Law. The criteria we use for determining the relevant retention and disposal periods we adopt are based on the purpose for which we hold data and the reasonable expectations of those whose personal data we collect in these circumstances, taking into account various legislative requirements and guidance issued by relevant EU regulatory authorities.

6.3 – In accordance with the above retention policy, any personal data that we no longer need will be disposed of and/or anonymized so you can no longer be identified from it.

7 Your personal data rights

7.1 – In accordance with your legal rights under EU Data Protection Law, you have a ‘subject access request’ right under which can request information about the personal data that we hold about you, what we use that personal data for and who it may be disclosed to as well as certain other information.

7.2 – Usually we will have one month to respond to a subject access request. However, we reserve the right to verify your identity and we may, in case of complex requests, require a further two months to respond. We may also charge for administrative time in dealing with any manifestly unreasonable or excessive requests. We may also require further information to locate the specific information you seek and certain legal exemptions under EU Data Protection Law may apply when responding to your subject access request.

7.3 – Under EU Data Protection Law. EU/EEA residents also have the following rights. which are exercisable by making a request to us in writing:

(a) that we correct personal data that we hold about you which is inaccurate or incomplete:

(b) that we erase your personal data without undue delay if we no longer need to hold or process it:

(c) to object to any automated processing (if applicable) that we carry out in relation to your personal data. for example if we conduct any automated credit scoring:

(d) to object to our use of your personal data for direct marketing:

(e) to object and/or to restrict the use of your personal data for purpose other than those set out above unless we have a compelling legitimate reason: or

(f) that we transfer personal data to another party where the personal data has been collected with your consent or is being used to perform contract with you and is being processed by automated means.

7.4 – So we can fully comply, please note that these requests may also be forwarded on to third party data processors who are involved in the processing of your personal data on our behalf.

7.5 – If you would like to exercise any of the rights set out above, please contact us at the address below.

7.6 – If you make a request and are not satisfied with our response, or believe that we are illegally processing your personal data, you have the right to complain to the Office of the Information Commissioner in the United Kingdom.

Contact Information

If you have any questions about VOS/AlertTrace’s privacy protection practices or believe we have not adhered to this Policy, please contact us at Support@AlertTrace.com or call us at (855) 631-6541.

– Last modified: 11 January 2020 –