1. Information We Collect
We may collect a variety of information from or about you or your devices from various sources, as described below.
A. Information You Provide to Us.
Registration Information. If you register to take the COVID-19 Home Test, we collect the information below listed in the “Public Health Authority Required Information.”
Communications. If you contact us directly, we may receive additional information about you. For example, when you contact our Customer Support Team, we may receive your name, email address, phone number, the contents of a message or attachments that you may send to us, and other information you choose to provide. If you choose to receive a result report via email, an email containing your name, date and time of test, result and information about your result will be emailed to you. If you subscribe to our newsletter or email marketing communications, then we will collect certain information from you, such as your email address. When we send you emails, we may track whether you open them to learn how to deliver a better customer experience and improve our Services.
Payment Information. If you make a payment through our Services, your payment-related information, such as credit card or other financial information, will be collected by our third-party payment processor on our behalf.
Public Health Authority Required Information. Due to the need to respond to the COVID-19 public health emergency, we are required to collect and share certain information about you with Public Health Authorities. We will collect and share the following information solely with public health authorities in compliance with applicable law:
- Test result
- Test result date
- Residential Zip Code
- State of Residence
- Date of birth
In addition to the data above, we may ask you to provide your:
- Full Name
- Phone Number
- Email Address
- This is you first test
- The date and type of the most recent test (if not your first
- You are employed in the health care field
- You are symptomatic
- You are a resident in a congregate care or living setting
- You are pregnant
This information is only used to meet our legal reporting requirements and is only shared with the applicable public health authority based on the residential address you provide to us and the Federal Department of Health and Human Services (HHS).
B. Information We Collect When You Use Our Services.
Location Information. When you use our Services on your mobile device, we may receive your precise location information. However, we do not use your precise location to perform the Services or for any other reason. We do not share your precise location information. We also infer your general location information.
Device Information. We receive information about the device and software you use to access our Services, operating system version, phone carrier and manufacturer, application version and diagnostic device identifiers.
Usage Information. To help us understand how you use our Services and to help us improve them, we automatically receive information about your interactions with our Services, like the pages or other content you view, the searches you conduct, and the dates and times of your visits.
2. How We Use the Information We Collect
If we are providing the Services on behalf of a third-party partner (such as your employer, health care provider or school) who has paid (in whole or in part) for you to use the Services, we will abide by the terms of our agreement with that third-party partner related to the use of the information we collect. Otherwise, we use the information we collect:
- To provide, maintain, improve, and enhance our Services;
- To share information you direct us to share with another User of the Services, such as an event organizer or venue;
- To personalize your experience on our Services;
- To understand and analyze how you use our Services and develop new products, services, features, and functionality;
- To communicate with you, provide you with updates and other information relating to our Services, provide information that you request, respond to comments and questions, and otherwise provide customer support;
- To facilitate the connection of third-party services or applications for authentication purposes;
- To generate anonymized, aggregate data containing only de-identified, non-personal information that we may use for internal research, development and product improvement;
- To find and prevent fraud, and respond to trust and safety issues that may arise;
- For other purposes for which we provide specific notice at the time the information is collected.
- For required public health data reporting responsibilities.
3. How We Share the Information We Collect
Vendors and Service Providers. We may share any information we receive with vendors and service providers retained in connection with the provision of our Services.
Customer Partners. If we are providing the Services on behalf of a third-party partner (such as your employer, health care provider or school) who has paid (in whole or in part) for you to use the Services, you acknowledge and agree that your information, including your Covid test result, may be shared with the third-party customer or its designee.
As Directed by You. At your direction, we will share your information, such as your name and evidence of your Covid test result, with another designated User of the Services, such as an event organizer or venue.
Marketing. We do not rent, sell, or share information about you with non-affiliated companies for their direct marketing purposes, unless we have your permission.
Analytics Partners. We use analytics services such as Google Analytics and Microsoft App Center Analytics to collect and process certain analytics data. You can learn more about Google’s practices by visiting https://www.google.com/policies/privacy/partners/ and Microsoft’s practices by visiting https://privacy.microsoft.com/en-ca/privacystatement. To help us understand how you use our Services and to help us improve them, we automatically receive information about your interactions with our Services, like the pages or other content you view, and the dates and times of your visits.
As Required By Law and Similar Disclosures. We disclose information about you as described in Section 1 in compliance with the Centers of Disease Control and Prevention requirements and state law public health requirements. We may access, preserve, and disclose your information if we believe doing so is required or appropriate to: (a) comply with law enforcement requests and legal process, such as a court order or subpoena; (b) respond to your requests; or (c) protect your, our, or others’ rights, property, or safety. For the avoidance of doubt, the disclosure of your information may occur if you post any objectionable content on or through the Services.
Consent. We may also disclose your information with your permission.
4. Your Choices
Location Information. There is currently no way to prevent certain devices from sharing precise location information. However, if your device shares precise location data, we will not store, share or otherwise use this precise location data.
Marketing Communications. If you subscribe to our promotional emails, you can unsubscribe via the link provided in the emails. Even if you opt-out of receiving promotional messages from us, you will continue to receive administrative messages from us.
Do Not Track. There is no accepted standard on how to respond to Do Not Track signals, and we do not respond to such signals.
5. Third Parties
We make reasonable efforts to protect your information by using physical and electronic safeguards designed to improve the security of the information we maintain. However, as no electronic transmission or storage of information can be entirely secure, we can make no guarantees as to the security or privacy of your information.
7. Children’s Privacy
8. International Visitors
Our Services are hosted in the United States and intended for Users located within the United States. If you choose to use Services from the European Union or other regions of the world with laws governing data collection and use that may differ from U.S. law, then please note that you are transferring your personal information outside of those regions to the United States for storage and processing. Also, we may transfer your data from the U.S. to other countries or regions in connection with storage and processing of data, fulfilling your requests, and operating the Services. By providing any information, including personal information, on or to the Services, you consent to such transfer, storage, and processing.
9. Update Your Information or Pose a Question
11. Contact Information
If you have any questions, comments, or concerns about our processing activities, please email us at firstname.lastname@example.org or write to us at:
24766 2nd St, Hayward, California, USA 94541
Last Updated: May 17, 2021