Privacy Policy
Effective Date: June 1, 2024. This Privacy Policy will be effective as of June 1, 2024, unless you agree to it before then by establishing a new CareCrew account/Crew. You can review our current Privacy Policy by clicking here.
CareCrew is an application that helps you and your family, friends, colleagues, and professional caregivers keep an elderly loved one safe and independent. It is delivered via mobile or web-based application, and it generally stores its collected data in a cloud-based database. Users enter information such as appointments, tasks, notes, and messages relating to the the elder, and these can be shared with other members of the “crew.” Collectively, these features and applications represent the “Services” that CareCrew provides.
This Privacy Policy explains what information we collect when you use the Services, how we use this information, how this information is disclosed, and your rights and choices regarding your information.
Please read this Privacy Policy carefully. By using our Services, you acknowledge and agree to the collection, use, and disclosure of your information as described in this Privacy Policy. We have also provided a summary of this Privacy Policy for quick reference, but you should read this Privacy Policy in its entirety. If you do not want us to handle your information as described in this Privacy Policy, please do not use the Services.
If you are a California resident, click here to see our Supplemental Notice for California Residents for information about our practices in accordance with California law.
1. Information we collect
We collect information that you provide to us, such as when you create an account, fill out a form on the Services, or interact with customer support; information that we automatically collect when you use the Services, including when you visit our Site; and information from other sources. Depending on your interaction with the Services, we may collect all or some of the following information about you.
a. Information that you provide to us
Account information. When you sign up for an CareCrew account, the information you provide to us may include your name, email address, phone number, billing information, and a password. You may also choose to upload a profile photo.
Transaction information. We may collect information about what products or services you purchase from us. Please note that we do not collect your payment information – this information is collected and processed by our authorized payment vendors, and we do not directly collect or store payment information in the ordinary course of processing transactions. If we allow purchase through a third-party platform (i.e. in-app purchase), the payment method stored with the third-party platform will be charged, and we will not collect information about this payment method such as card number.
Location information. We collect your general location information to determine the time zone you are in.
User Content. We collect content you create using the Services, including appointments, tasks, notes, contact information for others, and any information you input into the News Feed/Messages area, such as photos or yourself or others (collectively, “User Content”).
Other information you submit. You may submit information to us (including name, email address, and other types of information) for limited purposes, such as requesting customer support, providing feedback on our Services, participating in user research, entering contests or sweepstakes, participating in surveys, or signing up to receive communications from us.
b. Information we collect automatically
We and our vendors may automatically collect certain types of information when you use our Services, including when you use our mobile or web app. This information includes, but is not limited to, the type of device you use, your device unique ID, the IP address of your device, your operating system, the type of Internet browser you use, unique device identifiers, and other diagnostic data. Some of this information is collected using cookies, pixels, software development kits (“SDKs”), and other similar technologies. For more information about our use of cookies and other technologies, please see our Cookie Policy.
2. How we use information
We use the information we collect for the following purposes:
Identification, authentication and access.We use your information to verify your identity when you access your account. Your information is also used to help administer your account.
Operating our Services.We use your information to provide and maintain our Services, and to allow you to participate in interactive features of our Services.
Processing transactions. We use your information to process transactions on the Services. As explained above, payment information is collected and processed by third-party payment processors, not by us.
Customizing your experience.We use your information to customize our Services to you, which may include remembering your preferences, such as volume level or language preferences.
Account management.We may use your information to help administer, maintain or improve management of accounts. For example, we may use an email address for another to invite them into the system.
Analysis.We analyze your information in order to improve our Services and enhance your experience. We also use information collected from cookies and other similar technologies to improve our Services and enhance your experience with them.
Monitor usage of our Services.We use your information to monitor how our Services are being used, including to detect, prevent and address technical issues.
Marketing communications and advertising.We may use your information to advertise and market the Services to you and others (for example, to create lookalike audiences), and conducting contests, sweepstakes, or surveys.
Providing customer support.We use your information to help resolve and respond to customer support requests.
User outreach, feedback and research. We may use your information to reach out to you about your experience with the Services, respond to feedback, engage in research, and improve the Services.
Exercising and protecting our rights.We may use your information to enforce our Terms of Service and other usage policies. We may use your information to protect and defend our rights or property, and to prevent fraud or abuse. We may also use information to prevent or investigate fraud or other unauthorized, illegal, or wrongful activity. We may use your information to protect the personal safety of users or others.
Legal compliance.We may use your information when legally required to do so, such as to respond to legal requests (e.g. court or government agency order, subpoena, etc.). We may use your information to comply with a legal obligation and to protect ourselves against legal liability, including to obtain legal advice.
Business transfers. We may use your information where necessary to facilitate a potential transaction, such as a merger, acquisition or asset sale.
For any other lawful purpose. We may use your information for any other purpose consistent with applicable law, subject to your consent where legally required.
We may combine information that we collect from and about you (including automatically generated information) with information that we obtain about you from other sources and use such combined information in accordance with this Policy.
We may aggregate and/or de-identify information collected through the Services. We may use and disclose appropriately aggregated or de-identified data for any purpose.
The laws in some jurisdictions require companies to tell you about the legal grounds they rely on to process your information. Our legal bases for processing your information as described in this Privacy Policy are:
Contract.We may process your information as necessary to perform a contract with you, such as to process orders and allow you to set up an account.
Legitimate interest. We may process your information for purposes of our or another party’s legitimate interests, such as when we process your information for security, debugging, and analytics purposes.
Legal obligation. We may process your information to comply with a legal obligation or request, such as to respond to requests where required by law.
Consent. Where you consent to our processing of your information, we may process your information consistent with your consent.
3. How we disclose information
We may disclose your information in the following ways:
At your direction. We disclose your information to persons with whom you have granted account-level access. For example, adding a message to the News Feed area that includes a targeted user directive (e.g. “@David Bean”) will send a notification of that message to that user.
With your consent. We may also disclose your information where we have obtained your express consent to do so.
To other users of the Services. Your information, such as name, avatar, comments and reactions may be disclosed to other members of the account/Crew. When you create a new Note, for example, application roles will define which types of users can view and/or edit or delete that Note.
Vendors. We may disclose your information to companies that provide us with services, such as payment processors, data management services, content delivery networks (CDNs), cloud-based hosting services, monitoring services, email service providers, quality assurance and testing vendors, customer relations management (CRM) vendors, and analytics providers.
Legal compliance and rights. We may disclose your information if we believe in good faith that this is required or appropriate to (i) comply with applicable law, regulations, or legal process; (ii) exercise our legal rights, including to enforce our agreements, terms, and policies and to defend against legal claims; (iii) seek legal representation or advice; or (iv) protect and defend the rights, property or safety of CareCrew, our users, our personnel, or others.
Corporate transactions. We may disclose your information as part of, or to take steps in anticipation of, a sale of all or a portion of our business, a divestiture, merger, consolidation, asset sale, bankruptcy, or other significant corporate event.
Other disclosures. We may also disclose your information as otherwise permitted or required by law.
4. Security
We take a variety of steps to protect information collected by us, both during transmission and once we receive it, so that your information is treated securely and in accordance with this Privacy Policy. More details can be found in our Data Security Policy and Consumer Health Data Policy.
However, no method of transmission over the Internet or method of electronic storage is 100% secure. While we strive to use commercially acceptable means to protect your information, we cannot guarantee its absolute security.
5. Retention
We may retain your information until we determine that it is no longer necessary to fulfill the purpose for which it was collected (which may be any of the purposes set out in this Privacy Policy, including to comply with our legal obligations) and as required by applicable law. Retention periods may vary depending on the type of information and the context and purposes for its collection and use.
6. Your Rights and Choices
a. Your Rights
The laws of your jurisdiction of residence may provide you with certain rights with regard to your information. These rights may include the right to request:
Access to, or a copy of, your information.
Confirmation that we are processing your information and information about how we use and disclose your information.
Correction or amendment of your information.
Deletion of your information.
Transfer of your information to a third party.
Restriction or objection to certain uses or disclosures of your information.
Withdrawal of consent previously provided for the handling of the information (without affecting the lawfulness of prior use and disclosure of the information).
To exercise any of these rights, please email us at privacy@carecrew.app. Please explain the right you want to exercise and the data with respect to which you want to exercise that right. You may be able to exercise some of these rights on your own – for example, you can access, download, change, and delete certain information via your account.
Many of the rights described above are subject to limitations or exceptions under applicable law. For example, if you ask us to delete information that we are legally required to retain, we may deny your request. We may take reasonable steps to verify your identity before responding to your request, including by asking you to provide us with information necessary to reasonably verify you.
In some cases (e.g., if you are a resident of the European Economic Area or United Kingdom), you have the right to lodge a complaint with the data protection authority in your country of residence, but we encourage you to contact us first, as we would like to do our best to resolve any concerns you may have.
b. Marketing Emails
If you create an account, you may receive marketing or promotional emails from us. You may opt-out from receiving such emails by following the unsubscribe instructions at the bottom of such messages. Please note that opt-out requests may take several days to process. You will continue to receive transactional emails from us (for example, emails regarding transactions related to our Services, updates to this Privacy Policy or other terms, and emails about your account).
c. Mobile Device Communications
We may send push notifications in our apps. Notifications may be disabled by declining them at the device level, or changing the app settings. We may also send SMS messages to your mobile telephone for authentication and security purposes, with your consent. You may opt-out of receiving such messages at any time.
d. Cookies
We and third parties use cookies and other similar technologies (such as web beacons and pixels) to collect information on the Services. You may be able to set your internet browser or device to stop accepting new cookies, notice when you receive a new cookie, or disable existing cookies. Please consult the “Help” section of your browser for more information. The setting will apply only to the browser or device you are using, so you will need to reset the setting on a different browser or device. If you disable some or all cookies, the Services may not function as intended and some features may be unavailable. For more information, see our Cookie Policy.
e. Online analytics
We and our vendors may use third-party analytics services on the Services to help us understand how users engage with the Services, including Google Analytics. These parties may use cookies and other technologies to help collect, analyze, and provide us with reports and/or data. For more information about Google Analytics and how it collects and processes data, please visit: https://policies.google.com/technologies/partner-sites. To opt out of Google Analytics using your information for analytics purposes, see: https://tools.google.com/dlpage/gaoptout.
g. “Do Not Track”
Do Not Track (“DNT”) is a setting that users can enable in certain web browsers. DNT signals do not have a commonly agreed-upon meaning and we do not currently recognize or respond to DNT signals.
7. Third Party Integrations and Sites
Our Services may be used through apps on third party application platforms. Additionally, our Services may include links to third party websites, which are provided for informational purposes only and are not an endorsement of any third party or its website, services, or practices. We make no representations about the accuracy of any third-party information.
This Privacy Policy applies only to your use of our Services and not to your use of or interaction with any third parties or any products, services, websites, or applications such third parties provide. We do not have control over how third parties collect or use your information. We therefore encourage you to review the terms and privacy policies of third parties before you interact with them.
8. International Transfers of Data
CareCrew is based in the United States. Your information may be collected, stored, or transferred to the United States or other countries outside which you live.
Whenever we transfer information outside of where you live, we use reasonable efforts to make sure an appropriate transfer mechanism is in place, when we are legally required to do so. By using the Services, you acknowledge such transfer and processing of your information.
9. Children's Privacy
Our Service is not intended for children under the age of 13. Accordingly, we do not knowingly collect personally identifiable information from anyone under the age of 13. If you are a parent or guardian and you are aware that your child has provided us with personal information, please contact us at privacy@carecrew.app, and we will take steps to remove that information from our servers. Please refer to our Terms of Service for any applicable age restrictions on using our Services.
10. Supplemental Notice for California Residents
This Supplemental Privacy Notice for California Residents (“Notice”) supplements the information in our Privacy Policy above, and except as provided herein, applies solely to California residents (as defined by the California Consumer Privacy Act (“CCPA”)). It applies to “personal information” (as defined in the CCPA) that we collect through the Services and other means (such as information collected offline, in person, and over the phone). It does not apply to personal information we collect from current or former employees or independent contractors of CareCrew or job applicants to jobs at CareCrew.
a. How we collect, use, disclose, and retain personal information
Section 1 of this Privacy Policy describes the sources and types of personal information we collect, Section 2 describes the purposes for which we use such information, and Section 3 describes how we disclose such information. Under the CCPA, we must provide you with the "categories" of personal information we collect and disclose for “business or commercial purposes” (as those terms are defined by applicable law), and the categories of parties to which we disclose such information.
Categories of personal information we collect. In the 12 months leading up to the effective date of this Privacy Policy, we collected the following categories of personal information about California residents:
Identifiers, such as name, email address, phone number, and billing address.
Commercial information, such as transaction data.
Internet or other electronic network activity information, such as IP address, unique device identifiers, the operating system or browser you use (see section 1(b) above titled “Information we collect automatically”).
Eldercare information: appointments, notes, messages, comments, images, and other information used to describe the health and needs of the elder.
Login information, such as username and password.
Geolocation information, such as your general location (e.g., time zone).
Other information that identifies or can be reasonably associated with you, such as User Content (e.g., feedback and comments).
How we use and disclose your personal information. We use the categories of personal information listed above for the business and commercial purposes described in Section 2 of the Privacy Policy, and we may disclose such categories of personal information as described in Section 3 of the Privacy Policy.
Retention. We retain your personal information as described in Section 5 of the Privacy Policy above.
b. Your CCPA Rights
If you are a California resident, the CCPA may permit you to request that we:
- Provide you the categories of personal information we have collected or disclosed about you in the last twelve months; the categories of sources of such information; the business or commercial purpose for collecting or (if applicable) selling your personal information; and the categories of third parties to which we disclosed personal information, and more specific information about what categories of personal information were “sold,” “shared,” or disclosed to particular categories of third parties, similar to the detail in the sections of this Privacy Policy.
- Provide access to and/a copy of certain information we hold about you.
- Delete certain information we have about you.
- Correct certain information we have about you.
Certain information is exempt from such requests under applicable law. You also may have the right to receive information about the financial incentives that we offer to you (if any). You also have certain rights under the CCPA not to receive "discriminatory treatment" (within the meaning of the CCPA) for the exercise of the privacy rights conferred by the CCPA.
To request to exercise these CCPA rights, please email us at privacy@carecrew.app and explain the right you want to exercise and the personal information with respect to which you want to exercise it. To verify your identity, we may request further information before processing your request. For security and legal reasons, we may not accept requests that require us to access third-party websites or services.
You are also permitted to designate an authorized agent to submit certain requests on your behalf. In order for an authorized agent to be verified, you must provide the authorized agent with signed, written permission to make such requests or a power of attorney. We have no obligation to honor requests from purported agents if we lack sufficient confidence that this has occurred and that they are actually submitting the request on your behalf. We may require you to verify your identity directly with us before processing an agent's request.
Please note, in the limited circumstances that we process “sensitive personal information” as defined in the CCPA, we do not use or disclose it other than for disclosed and permitted business purposes for which there is not a right to limit under the CCPA.
The CCPA also provides the right to opt out of “sales” or “sharing” of your personal information, as such terms are defined in the CCPA. See below for how to exercise those rights.
c. Notice of Right to Opt Out
While we do not “sell” personal information in the traditional sense (i.e., for money), we may use your anonymized identity to identify how our users use the system (i.e., analytics) and to send you notifications when certain actions happen inside the application. You can opt out of both analytics and notifications in the user settings screen within the application. Alternatively, you can send an opt-out request to privacy@carecrew.app.
Please note that we also respond to and abide by opt-out preference signals sent through the Global Privacy Control. Any opt out preferences you have exercised through these methods will only apply to the specific device/browser on which you made them. For more information on how to use the Global Privacy Control, see www.globalprivacycontrol.org.
d. Notice of Financial Incentives
We may offer financial incentives, such as discounts and other offers, to new and existing users from time to time. When you participate in a financial incentive, we collect personal information from you, such as identifiers (like your name and email address) and commercial information (like your purchase history). We value your personal information as the value of the offer or discount provided to you, and the value of your personal information is reasonably related to the value of the discount or other offer presented to you. You can opt in to a financial incentive by following the sign-up or participation instructions provided. You can opt out of a financial incentive, or our subsequent use of your personal information in connection with a financial incentive, at any time by contacting us at privacy@carecrew.app with an explanation of your request. In some cases, we may provide additional terms and conditions for a financial incentive, which we will present to you when you sign up.
e. California “Shine the Light” Disclosure
The California “Shine the Light” law gives residents of California the right under certain circumstances to opt out of the sharing of certain categories of personal information (as defined in the Shine the Light law) with third parties for their direct marketing purposes. We do not disclose your personal information with third parties for their own direct marketing purposes within the meaning of that law.
11. Changes to This Privacy Policy
We may update our Privacy Policy from time to time. We will notify you of any changes by posting the new Privacy Policy on this page, with the date of update. By continuing to use the Services after we post any updates to the Privacy Policy, you agree to these updates. If we change the Privacy Policy in a way that materially reduces our commitments to you, we will provide notice in accordance with applicable law.
12. How to Contact Us
If you have any questions about this Privacy Policy, please contact us via email at privacy@carecrew.app.