SAFER COMMUNITY PRIVACY POLICY

INTRODUCTION: BY INSTALLING, USING, OR OTHERWISE ACCESSING THE SAFER COMMUNITY APPLICATION FROM ANY DEVICE, MOBILE OR OTHERWISE, YOU AGREE TO ABIDE BY THE TERMS OF SERVICE AND CONDITIONS OF THIS PRIVACY NOTICE. IF YOU DO NOT AGREE TO THESE TERMS AND CONDITIONS, DO NOT DOWNLOAD AND/OR ACCESS OUR APPLICATION. BY USING THIS APPLICATION, AND SUBJECT TO YOUR EXPLICIT OPT-IN CONSENT TO YOUR HEALTHCARE PROVIDER PROVIDING YOUR TEST RESULTS, AND TO CONNECTING TEST RESULTS FROM YOUR HEALTHCARE PROVIDER WITH THE SAFER COMMUNITY APPLICATION, YOU ARE CONSENTING TO THE COLLECTION, USE, AND DISCLOSURE OF INFORMATION IN ACCORDANCE WITH THIS PRIVACY NOTICE.

This Privacy Notice sets forth how your information is collected, used, transferred, and stored through the mobile application titled “Safer Community” (“Application”) and the terms and conditions governing your use of the Application. The Application was created by and is owned by ROKMETRO, Inc. (“ROKMETRO”, “we”, “our”, “us”) and is intended for use only by persons physically present in the United States. The purpose of this Application is to:

a) Provide you with the ability to track your COVID-19 testing history and display your color-coded status on the Application home screen. The status is set as yellow, orange, or red based on your test results, and will be used to help determine if you are permitted to access University facilities.

b) Provide you with recommendations and next steps based on your status and the latest guidelines from the local county health department.

c) Provide you with the ability to privately track any COVID-19 symptoms you are experiencing.

1. WHAT INFORMATION MAY THE APPLICATION COLLECT FROM YOU?

You are not required to provide the personal information requested by the Application; however, you may not be able to use some of the features offered by the Application if you choose not to provide your personal information. By providing us with your personal information, you are consenting to our use of it in accordance with this Privacy Notice.

a. The Safer Community app uses GPS to provide the user with interactive maps to find test locations.

c. The Safer Community app uses Cameras to allow users to import their personal encryption key (QR code) into the app and to allow reporting a test result from a non-University testing center.

d. The Safer Community app uses Photos and Videos to allow a user to import their personal encryption key (QR code) into the app and enable reporting a test result from a non-University testing center.

e. The Safer Community app uses Files to allow users to import their personal encryption key (QR code) into the app and allow reporting a test result from a non-University testing center.

f. Personally Identifiable Information (“PII”). “Personally Identifiable Information” for purposes of this Privacy Notice means information that can be used to identify, contact, or locate an individual, as well as test results and reported symptoms. The Application collects the following PII from you, from University information systems, and from your healthcare provider: your name, your email address, your phone number, your local physical address, your NetID, student registration information, your test results, information required by the local Department of Public Health, any voluntarily reported symptoms, and your building access status.

g. Automatic Collection of Non-Personal Information (“non-PII”). The Application may collect certain non-personal information automatically that may not, on its own, permit direct association with any specific individual. The following are some examples of non-personal information that may be collected: usage, including frequency of access, duration, and time of access. By using the Application, you are consenting to the collection, use, and disclosure, of non-personal information by the Application.

h. Location. Location services on your device must be turned on to provide navigation to COVID-19 test sites. However, the Application does not access, collect, or store any location data, including GPS data. If location services on your device are turned off, the Application will perform the limited functions of storing and providing information about COVID-19 test results, any voluntarily reported symptoms, and building access status.

i. Your Data. All PII and non-PII data will be stored on Amazon Web Services (“Servers”). Your PII and non-PII will also be stored in the Application. In particular:

i. Your test results and reported symptoms are stored encrypted on Servers and are decrypted only on your device by this Application when you want to view the history.

iii. We follow generally accepted industry standards to protect the PII submitted to the Application. No method of transmission, or method of electronic storage, is 100% secure. Therefore, we cannot guarantee its absolute security.

iv. How are Your Test Results Submitted to the Application? Sponsored test results are sent automatically to the Application. Additionally the Application supports a manual upload of positive test results (typically from off-campus test locations) to be reviewed and/or acted upon by a University Health Services medical professional.

2. HOW IS YOUR INFORMATION USED?

Your PII is used to establish and display your building access status and determine your compliance with the required testing frequency. Your building access status is established based on your compliance with your assigned testing frequency, test results, and self-reported symptoms. Non-PII may be used for statistical analysis related to the use of the Application and for research related to the COVID-19 pandemic subject to applicable law and University policy.

3. IS YOUR PERSONALLY IDENTIFIABLE INFORMATION SHARED?

Your ID, name, building access status, and compliance with testing frequency, are shared with the University’s alternative building access web application and other university systems needed to track compliance. This information is stored on Servers to support consistent and efficient building access and compliance tracking. Your personal information requested in the app is shared with your test results to public health authorities and the University. The remainder of your PII is not shared and is stored on Servers in an encrypted format and can only be decrypted on your mobile device.

4. OPT-OUT INFORMATION

You may opt out of information collection from within the Application. In Application Settings, you can request your PII data be deleted from Servers. Your PII and non-PII may be retained on Servers until you request its deletion.

5. CHANGES TO THIS PRIVACY NOTICE

We may amend this Privacy Notice from time to time. If we change this Privacy Notice, we will post the changes here. Your continued use of the Application after any such changes will constitute your acceptance of the updated Privacy Notice. If you do not wish to accept the revised Privacy Notice, you must not use or access (or continue to use or access) our Application. Please regularly check our Application or website to determine if the Privacy Notice has been updated and to review those changes before deciding whether or not to access (or continue to access) the Application.