SOBER GRID PRIVACY POLICY

Last Updated:  May 25, 2018

 

This Privacy Policy is designed to help you understand how Sober Grid provides Services that collect, use and disclose information and what choices you have with respect to this information. There are a few terms that we will use frequently in this Privacy Policy that we want to define clearly for your understanding:

  • We use “Sober Grid” to refer to Sober Grid, Inc.

  • The “Sober Grid App” refers to any of Sober Grid’s mobile applications (e.g., Sober Grid iOS, Sober Grid iOS Pro, or Sober Grid Android).

  • We use “Sober Grid Site” to refer to the website http://www.sobergrid.com

  • We use “Sober Grid Services” to refer to the services provided in the Sober Grid App or any services at the Sober Grid Site.

  • We use “Visitor” to refer to anyone who visits the Sober Grid Site or a Sober Grid App store.

  • We use “User,” “Users,” “you” or “your” to refer to people who register to use Sober Grid Services

 

Sober Grid is a social network community and online platform focused on sobriety for Users of the Sober Grid Service. Our Privacy Policy applies to any User or Visitor to our Services. We have prepared this Privacy Policy to describe to you our practices regarding the Personal Data we collect from Users of the Sober Grid Service. Capitalized terms not defined in this Privacy Policy have the meanings given in our Terms of Service.  

 

Here are some links to help you navigate our Privacy Policy:

 

Accepting the Terms

 

Please read this Privacy Policy carefully because it discusses how we will collect, use, share and process your personal information, and by accessing Sober Grid Services you agree to this Privacy Policy and its terms and consent to having your data transferred to and processed in the United States. Your use of Sober Grid Services is also governed by our Terms of Use. Please read these terms carefully as well.

 

We welcome any questions or comments you may have about this Privacy Policy and our privacy practices. If you have any questions or comments, you may contact us as described in the Contact Information section at the end of this Privacy Policy.

 

Types Of Data We Collect

 

  • “Personal Data” means data that allows someone to identify or contact you, including, for example, your name, address, telephone number, email address, geolocation data, device identifier as well as any other non-public information about you that is associated with or linked to any of the foregoing data.

 

  • “Anonymous Data” means data that is not associated with or linked to your Personal Data; Anonymous Data does not, by itself, permit the identification of individual persons.

 

We collect Personal Data and Anonymous Data as described below.

 

Facilitating Your Use of Sober Grid

 

We use your email address to register your account. If you do not provide an email address, you may not be able to register as a User of Sober Grid Services.  We also ask you to voluntarily provide personal data such as age, gender, substance(s) of recovery, location and blocking preferences in order to provide certain functionality of Sober Grid, as described in greater detail in the following section. Using these features allows you to choose what information you want to share with other users with various profile information.

 

Data You Provide to Us

 

Account Information. We may require you to provide an email address and password to register as a User of the Sober Grid Service (“Account Information”).  You may change the email address and password associated with the account according to the methods provided by the Sober Grid Service. The security of your account relies on your protection of your mobile device and your password. You are responsible for maintaining the security of your password. You are solely responsible for any and all activities that occur under your account or on your mobile device. You may not share your password for the Sober Grid Service with anyone. We will never ask you to send your password or other sensitive information to us in an e-mail, though we may ask you to enter this type of information on the Sober Grid App interface. If you believe someone else has obtained access to your password, please change it immediately. If you believe that an unauthorized access has already occurred or may occur please report it immediately to contact@sobergrid.com. You must promptly notify us if you become aware that any information provided by or submitted to the Sober Grid App is lost, stolen or used without permission.

 

Profile. We may collect Personal Data from you, such as your photo, display name, status, relationship, looking for, ethnicity, age or date of birth, geo-location data, email address, password for the Sober Grid Service, height, weight, “Favorites”, “Blocks”, and any other information you voluntarily add to your profile on the Sober Grid App or that is generated by your use of the Sober Grid Service (“Profile Information”). You are not required to provide any personal data in order to be a Sober Grid User. Not providing information may limit the functionality of Sober Grid Services. We use the data that we have about you to provide, improve, and personalize Sober Grid, including with the help of automated technologies discussed in this policy and the inferences that we make from the information we collect.

Instant Messages. When you send an instant message (which may include photos, location, audio or video) to other Users of the Sober Grid Service, we may retain the messages (“Instant Messages”).

 

Feedback/Support. If you provide us feedback or contact us via e-mail (e.g., for support) or via the “Contact Us” page on the Sober Grid Site, we will collect your name and email address, as well as any other content included in the e-mail or web form submission, in order to send you a reply. If you contact us for support, we may also collect and retain certain technical diagnostic data, e.g., your phone model.

 

Mailing List. When you register to use the Sober Grid Service, we ask you to provide us your email address for inclusion in our mailing lists. We may email you Sober Grid news, Sober Grid Service updates, the latest information on products and services, and third party offers that apply to you. You may opt out of such third party emails at the time of registration, or you will have the opportunity to “opt-out” by following the unsubscribe instructions provided in the email you receive. You may not opt out of emails related to the operation of the Sober Grid Service (such as password recovery) as this may be necessary for the normal operation of the Sober Grid Service.

 

Provider Groups. On the Sober Grid Site, providers may sign up to start a private group in the Sober Grid App by filling out the web form on our “For Providers” page.  We ask that an authorized representative of the provider submit her or his name, business email address and phone number, as well as the name and location of the facility. Subject to our review, the provider will be given access to a private administrator dashboard where the provider can organize and maintain a private group in the Sober Grid Service environment.

 

Partner Promotion. We may collect information you voluntarily provide when you participate in a Partner Promotion.

 

Other. We may also collect Personal Data at other points within the Sober Grid Service that state that Personal Data is being collected.  Sober Grid will retain Profile Information and Instant Messages in the Sober Grid App or on the servers for the Sober Grid Service, for as long as needed to provide the Sober Grid Service and to comply with our legal obligations, resolve disputes and enforce our agreements.  Sober Grid may also use Anonymous Data that has been fully de-identified and that is derived from your Profile Information and Instant Messages created in the Sober Grid App or on the servers for the Sober Grid Service for health outcome research purposes. All de-identified data used for health outcomes research purposes will comply with applicable law, including, if applicable, The Health Information Portability and Accountability Act of 1996, as amended, and its implementing regulations (collectively “HIPAA”).

 

Data Collected via Technology.

 

Device Information. We will collect an ID that is unique to the mobile device on which you install the Sober Grid App (“Device ID” and “Device”, respectively). We use your Device ID to provide improved security when authenticating your use of the Sober Grid Service. If a different mobile device uses your account, we will send you an email notification alerting you to this use.  In order to protect your privacy we may create an encrypted version of your Device ID and use your encrypted Device ID to log you into the Sober Grid Service. We may store your Device ID and/or your encrypted Device ID with the other information we collect about you, including your Profile Information and your instant message information. We will collect certain software and hardware information about your Device in order to improve our services and provide a more personal experience.

 

Location and Distance Information. When you use the Sober Grid App, we will collect your location to determine your distance from other Users (“Location and Distance Information”) through the GPS, Wi-Fi, and/or cellular technology in your Device (e.g., iPhone, iPad, iPod Touch or Android device). Your location is stored on our servers for the purpose of  identifying other Users of Sober Grid Services and calculating the distance between you and other Users, and calculating your distance (“Distance Information”) to Users nearby. Where permitted by law, your Location and Distance Information may also be used in a de-identified manner for health outcomes research.

 

Log Files. To make the Sober Grid Service more useful to you, our servers (which may be hosted by a third party service provider) or Analytic Partners may collect information from you, including your browser type, operating system type, Internet Protocol (IP) address (a number that is automatically assigned to your computer when you use the Internet, which may vary from session to session), domain name, and/or a date/time stamp for your visit. We also use cookies and URL information to gather information regarding the date and time of your visit and the information for which you searched and which you viewed.  Please refer to the explanation of our Analytics Partners in the “Disclosure of your Personal Data” section for more information about our use of cookies and other tracking technologies.

 

Third Parties. Our advertisers and partners may also use their own cookies or other tracking technology that may collect information about you within the Sober Grid Service. This Privacy Policy does not apply to information collected by third parties—for example, if you click on an in-app advertisement or visit a third-party website—unless and until we receive your information from those parties. Further, some third parties may place additional restrictions on our use of your personal data, in which case, portions of this Policy may not apply to you. Please review any third-parties’ privacy policies before disclosing information to them. We do not control the use of these tracking technologies used by advertisers and partners and expressly disclaim responsibility for information collected through them. When you use or connect to a Sober Grid Site or download the Sober Grid App by or through a website owned and/or operated by a third party (including Facebook) (a “Third Party Platform”), you  consent to providing us access to collect certain information from your Third Party Platform profile/account. By doing so, you may also allow us to access information contained in cookies placed on your device by the Third Party Platform as permitted by the terms of your agreement and privacy settings with the Third Party Platform. We may share this information with the Third Party Platform for their use as permitted by the terms of your agreement and privacy settings with the Third Party Platform.  We may share some of the information we collect from you with vendors and other service providers who work with us to support the internal operations of the Sober Grid Site and the Sober Grid App.

 

Important Notes about Profile Information, Distance Information and Information Used for Research.

 

IMPORTANT NOTE ABOUT PROFILE INFORMATION.

 

When you use the Sober Grid app, as a default, your profile information is public and other Users of the Sober Grid app can see your profile information. Do not include information in your profile that you want to keep private. Users of the Sober Grid App can use the search feature in the Sober Grid App to search for other Users by different profile criteria, like age. Your Profile Information will be used for these searches. The Sober Grid App user interface includes other related features; for example, to make certain items of Profile Information non-public or to designate certain Users as “Favorites” or “Blocked”.  Your continued use of any of our Sober Grid Services indicates your acknowledgment of the practices described in this Policy.

 

IMPORTANT NOTE ABOUT DISTANCE INFORMATION.

 

When you use the Sober Grid app, as a default, your Distance Information is public and other users of the Sober Grid app can see your Distance Information within your profile. Users of the Sober Grid App can use the search feature in the Sober Grid App to search for other Users by distance. Your Distance Information will be used for these searches. Your Distance Information is public, but the Sober Grid App includes a feature to hide or change the accuracy of your Distance Information. Your continued use of any of our Sober Grid Services indicates your acknowledgment of the practices described in this Policy.

 

IMPORTANT NOTE ABOUT INFORMATION USED FOR RESEARCH.

 

As described herein, in some instances and consistent with federal and state law, Sober Grid may use information about you that has been fully de-identified for health outcomes research.   By your use of Sober Grid, you are permitting the use and disclosure of de-identified information for these research purposes. Additionally, from time to time, Sober Grid may engage in research, either alone or with outside research partners that will use identifiable information about you.  Prior to engaging in any such research using your information, Sober Grid will contact you about receiving your consent to participate in such research and obtain your authorization to use your identifiable information. Such research will be conducted in accordance with applicable law, including HIPAA, if applicable.    

 

General Use of Your Personal Data.

 

We use your Personal Data in the following ways and as described elsewhere in this Privacy Policy: (i) to identify you as a User on the Sober Grid Service; (ii) to operate the Sober Grid Site and Sober Grid App, and to improve the Sober Grid Service; (iii) to provide the services you request, including the Sober Grid Service; (iv) to respond to your requests and inquiries related to support, employment opportunities or other requests; (v) to send you Promotional Emails; (vi) to fulfill a product or service purchase; (vii) to conduct a Partner Promotion; (viii) to notify you about important changes to the Sober Grid Service or our company; (ix) to review usage and operations of the Sober Grid Site and Sober Grid App and to improve the content and functionality of the Sober Grid Site and Sober Grid App; (x) to protect the security or integrity of the Sober Grid Site, Sober Grid App, or our business generally; (xi) to enforce our Terms of Use; (xii) to tailor the Sober Grid Service to your needs and the needs of other Users; and (xiii) to conduct de-identified health outcomes research.

 

Disclosure of Your Personal Data.

 

Sharing of your Personal Data. Sober Grid does not sell, lease or rent the Personal Data you share with us on or through the Sober Grid Service with third parties.  Sober Grid may disclose your Personal Data to third parties only (i) as required by law or regulation or as we believe in good faith that disclosure of such Personal Data is reasonably necessary to: (1) satisfy any applicable law or regulation, (2) to respond to claims and/or to comply with a judicial proceeding, court order or legal process served on us, (3) to protect and defend our rights or property and/or the rights or property of third parties, as permitted by law, (4) to detect, prevent or otherwise address fraud, security or technical issues, or (5) to enforce our Terms of Service; and/or (ii) with our third party service providers as set forth below.

 

Analytics Partners.

 

Sober Grid has engaged certain analytics partners (“Analytics Partners”) to collect Anonymous Data about how the Sober Grid Site and Sober Grid App are used.  Our Analytics Partners may use cookies, web beacons, or other automated technologies to collect information about how many times you visit the Sober Grid Site and/or Sober Grid App, what parts of the Sober Grid Site and/or Sober Grid App you access, and the functionality you are using.  To help you understand these technologies better:

  • “Cookies” are electronic files many websites place on a visitor’s computer to store information that makes each visit to a respective website more efficient.  We may use both session cookies (which expire once you close your web browser) and persistent cookies (which stay on your computer until you delete them) to provide you with a more personal and interactive experience on the Sober Grid Service. Persistent cookies we place may be removed by following instructions provided by your operating platform.  If you choose to disable cookies, some areas or features of the Sober Grid Service may not work properly. To remove cookies, you may configure your browser to clear all cookies or configure it to reject cookies whenever you visit a new website. Please consult your browser’s user guide for specific instructions on removing cookies.

  • “Beacons” are small graphic files with a unique identifier that are used to track a web or mobile site user’s online movements.  Unlike cookies, beacons are embedded on websites, not downloaded on your computer or device.

 

Our Analytics Partners may use these or other techniques to collect Anonymous Data about the Sober Grid Site and/or Sober Grid App.  In order to make sure you understand how our Analytics Partners handle your information and how they interact with the Sober Grid Site and Sober Grid App, we have shared hyperlinks below to their policies.   We encourage you to review these terms as Sober Grid has no ability to control or monitor our Analytics Partners’ data collection or data use practices.

 

Third Party Service Providers. We may share your Personal Data with third party service providers to: (i) maintain and operate the Sober Grid Service or to help us deliver services to you; (ii) prepare communications for distributions; (iii) host our website platform; (iv) conduct quality assurance testing; (v) provide technical support; and/or (vi) enable their provision of other services to Sober Grid.  Your Personal Data may be processed by these third party service providers for the purposes described in this section and so that we can utilize tools provided by the third party service providers. Except as otherwise stated in this Privacy Policy, these third party service providers are required by contract not to use your Personal Data other than to provide the services requested by Sober Grid.

 

Other Disclosures. Sober Grid in its sole discretion may disclose Personal Data in response to subpoenas, warrants, or court orders, or in connection with any legal process, or to comply with relevant laws; to establish or exercise our rights to defend against legal claims; if we believe it is necessary to investigate, prevent, or take action regarding illegal activities, suspected fraud, safety of person or property, violation of our policies, or as otherwise required by law.

 

Third Party Payment Processor.

 

We use a third-party payment card processor (“Payment Processor”) to process payment card transactions for purchases made through the Sober Grid Site. To make this possible, your name, payment card information, billing information, address, telephone number, email address and amount of your purchase are transmitted via secure (encrypted) gateway with the Payment Processor for the sole purpose of completing any transactions you initiate through the Sober Grid Site. Please note that your payment card information (number, expiration date, security code) is provided directly to the Payment Processor and is stored by the Payment Processor and not by us, and as such, it is important to review the Payment Processor’s privacy policy and terms of service to understand their information security practices. The Payment Processor’s privacy policy will apply to the information you provide to the Payment Processor. Sober Grid is not affiliated in any way with the Payment Processor and we have no responsibility or liability for the services provided by the Payment Processor or for the Payment Processor’s acts or omissions. By purchasing products and services through the Store on our Sober Grid Site, you agree to pay us, through the Payment Processor, all charges at the prices then in effect for the purchased products and services in accordance with the applicable payment terms and you authorize us, through the Payment Processor, to charge your chosen payment provider.

 

Sober Grid does not collect payment card information directly and kindly asks you not to share this information with us when submitting requests for additional information.

 

Partner Promotions.

 

We may offer contests, sweepstakes, or other promotions with our third party partners from time to time (“Partner Promotion”). If additional or different privacy practices govern a Partner Promotion, then we will present you the additional or different terms prior to your entering the Partner Promotion, and such terms will apply to how we collect, use and disclose the information you provide through the Partner Promotion.   Otherwise we may disclose information you voluntarily provide when you participate in a Partner Promotion.

 

Third Party Websites.

 

The Sober Grid Service may contain links to third-party websites.  The fact that Sober Grid has provided a link to a website is not an endorsement, authorization, sponsorship or acknowledgment of affiliation with respect to such website, or with respect to any products, services, information or content on such website.  When you click on a link to any other website or location, you will leave the Sober Grid Site or Sober Grid App and go to another website and another entity may collect Personal Data or Anonymous Data from you. We have no control over, do not review, and cannot be responsible for, these third party websites or their content. Please be aware that the terms of this Privacy Policy do not apply to these third party websites or content, or to any collection of data after you click on links to such third party websites. Not all third party websites allow you to opt out of their tracking and analytics.

 

Research Institutions.

 

Sober Grid may provide your de-identified Personal Data or Anonymous Data to third parties we are working with on research related to health outcomes.  We also may publish or otherwise disseminate the results of such research performed on de-identified data. Those publications will never identify you individually as a subject to the research.  If, in the future, Sober Grid wishes to partner with third parties to perform research on identifiable data involving you, you will be contacted about participating in such research in accordance with applicable law and your prior consent to participate will be obtained.

 

Your Choices Regarding Your Personal Data; Changing Your Personal Data.

 

You have choices regarding the information we collect and how it's used. These are described below.

Our Promotional Emails. We may periodically send you free newsletters, surveys, offers, and other promotional materials related to Sober Grid and/or the Sober Grid Service (“Promotional Emails”). Additionally, we may send you targeted offers from third parties (“Third Party Emails”), or deliver authorized Third Party Emails on behalf of certain third parties.  When you receive Promotional Emails from us, you may indicate a preference to stop receiving further Promotional Emails from us and you will have the opportunity to “opt-out” by following the unsubscribe instructions provided in the email you receive. If you have opted out of Promotional Emails, we may still contact you in connection with your relationship, activities, transactions and/or communications with us, including notices of any updates to our Terms of Service or Privacy Policy.

 

• Geolocation and Push Notifications. You may at any time opt out from further allowing Sober Grid to access location data or send you push notifications by adjusting your permissions or disabling these functions on your Device.

• Uninstall the Sober Grid App. You can stop all collection of information by the Sober Grid App by uninstalling the Sober Grid App. You may use the standard uninstall processes as may be available as part of your Device or via the mobile application marketplace or network.

 

Changes to Your Personal Data. You may change certain fields of your Profile Information by editing your profile in the Sober Grid App. You may request deletion of your Personal Data by us, but please note that we may be legally required to keep certain information and not delete it (or to keep this information for a certain time, in which case we will comply with your deletion request only after we have fulfilled such requirements). Additionally, we may store your Personal Data, Distance Information, Device ID, hashed Device ID, and your usage history (including a history of text or photos that were censored, any suspensions or bans imposed on you, and a history of your profile photos) for administrative or record retention purposes, to enforce and defend our legal rights and remedies, or to comply with applicable laws.  We may also keep your de-identified Personal Data, Distance Information, as described above for de-identified research purposes.

 

Security Of Your Personal Data.

 

Sober Grid is committed to protecting the security of your Personal Data from unauthorized access, use, or disclosure. We use a variety of industry-standard security technologies and procedures designed to help protect your Personal Data from unauthorized access, use, or disclosure. However, no method of transmission over the Internet, or method of electronic storage is fully secure. Therefore, while Sober Grid uses reasonable efforts to protect your Personal Data from unauthorized access, use, or disclosure.  Please know that Sober Grid cannot guarantee its absolute security.

 

Choice of Law and Forum.

 

This Privacy Policy and all matters relating to your access to, and use of, the Sober Grid Service, including all of your interactions with the Sober Grid Site and Sober Grid App, shall be governed by the laws of the Commonwealth of Massachusetts without regard to its conflict of laws. Any dispute arising out of or relating to this Privacy Policy or your access or use of the Sober Grid Service, including all of your interactions with the Sober Grid Site and Sober Grid App, shall be subject to the exclusive jurisdiction of the federal or state courts located in Suffolk County in the Commonwealth of Massachusetts, and you hereby submit to the personal jurisdiction of such courts. If any provision in this Privacy Policy is held invalid or unenforceable, that provision shall be construed in a manner consistent with the applicable law to reflect the original intent of the provision, and the remaining provisions of this Privacy Policy shall continue in full force and effect.

 

Children.

 

The Sober Grid Service, including the Sober Grid Site and Sober Grid App, is encouraged for Users 18 years of age and older only.  We do not intentionally gather information from individuals who are under the age of 13 years old and, upon notification that a child under 13 years old has provided us with Personal Data and/or other personal information of any kind, we will promptly delete such information from our records in compliance with applicable law.  

 

Users from California.

 

California Civil Code Section 1798.83 permits visitors to the Sober Grid Site who are California residents and who have provided us with "personal information" (as that term is defined in Section 1798.83) to request certain information about the disclosure of that information to third parties for their direct marketing purposes.  If you are a California resident, you may contact us by writing to the mailing address provided in the “Contact Information” section at the end of this Privacy Policy.

 

Users from the European Union, Switzerland, and the European Economic Area.

 

If you are a data subject in the European Economic Area (“EEA”), you have the right to access, rectify, or erase any personal data we have collected about you through any Sober Grid Services.  You also have the right to data portability and the right to restrict or object to our processing of personal data we have collected about you through the use of Sober Grid Services. You may withdraw your consent at any time for any data processing we do based on consent you have provided to us.

 

To exercise any of these rights, please contact us as described in the “Contact Information” section below and specify which right you intend to exercise.  We will respond to your request within 30 days. We may require additional information from you to allow us to confirm your identity. If you have any issues with our compliance, you have the right to lodge a complaint with an EEA supervisory authority.


 

Users Outside Of The United States and the EEA.

 

You should be aware that the United States and other countries have not harmonized their privacy regulations.  Because Sober Grid and its servers are located in the United States and the Sober Grid Service is directed toward the United States market, our Privacy Policy has been prepared to comply with applicable United States laws and regulations.  By accessing and/or using the Sober Grid Service and providing Personal Data to us through the Sober Grid Site and/or Sober Grid App, you agree to the level of privacy protection set out in this Privacy Policy.

 

Users from Canada.

 

Canadian citizens, except under circumstances defined by law, are entitled to access their own Personal Data collected by Sober Grid by writing to the mailing address provided in the “Contact Information” section at the end of this Privacy Policy.  If you believe that the personal information about you that we have collected is incomplete or inaccurate, please contact us and we will correct the information upon verification of the omission or error and of the identity of the person requesting the change.

 

Changes To This Privacy Policy.

 

We may change, modify, add or remove portions of this Privacy Policy (each, an “Update”) from time to time. If we make any material Updates to this Privacy Policy, we will change the "Last Updated" date above, post the changes in a prominent portion of the Privacy Policy on our website, or notify you directly.. Your continued use of the Sober Grid Service will confirm your acceptance of the updated Privacy Policy. In any case, we encourage you to frequently review the Privacy Policy to ensure you understand the latest terms and conditions associated with use of the Sober Grid Service.  If you do not agree to the updated Privacy Policy, you must discontinue using the Sober Grid Service and uninstall the Sober Grid App immediately.

 

Contact Information.

 

Sober Grid welcomes your comments or questions regarding this Privacy Policy. Please contact us by using the following information:

  • Mailing Address: Sober Grid, Inc., ℅ Athenahealth, MDP Co-working, 311 Arsenal Street, 02472

  • Email: contact@sobergrid.com

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
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