This Privacy Policy describes how TheKey (“TheKey”) collects, stores, uses and distributes information through TheKey App (the “App”). Capitalized terms not defined in this Privacy Policy have the meaning as set forth in the Terms of Conditions for the App, which can be found here. Any information we gather through the App that may be used to identify, contact you, are collectively referred to herein as your “Personal Information.”

By using the App, you consent to the use of your Personal Information as described in this Privacy Policy.

When registering for or using the App, we may collect the following information from you and use it for the purposes described in this Privacy Policy and our written policies:

Identifiers including real name, alias, unique personal identifier, online identifier, internet protocol (IP) address, email address, phone number, account name, password, or other similar identifiers. We use this information for identification and authentication purposes, to manage your Account, to provide the App, to maintain the quality or safety of the App, for internal research, debugging, to monitor and analyze your use of the App.

Internet or other electronic network activity information, including information regarding your interactions with this App. We use this information for the purpose of administering services to our clients. We may also use this information to maintain the quality or safety of the App, to monitor and analyze your use of the App, for internal research, debugging, to increase the App’s functionality and user-friendliness, and to advance our commercial or economic interests.

Real-time Geo-location information. When you use our App, we will periodically use GPS technology (or other similar technology) to determine your physical location. We use this information for the purpose of allowing you to clock in and clock out in real time when arriving to and leaving from a client’s location. We may also use your Geo-Location Information to maintain the quality or safety of the App, to monitor and analyze your use of the App, for internal research, debugging, to increase the App’s functionality and user-friendliness, and to advance our commercial or economic interests.

From time to time we may employ third parties to help us provide and/or improve the App. These third parties may have access to databases of user information or registered member information for the purpose of helping us to provide and/or improve the App, and they will be subject to contractual restrictions prohibiting them from using the information about our users for other purposes.

We may disclose your Personal Information to third parties without your consent if we have reason to believe that disclosing this information is necessary to identify, contact or bring legal action against someone who may be causing injury to or interference with (either intentionally or unintentionally) our rights or property, other users of the App, or anyone else (including the rights or property of anyone else) that could be harmed by such activities. We may disclose Personal Information when we believe in good faith that such disclosure is required by and in accordance with the law.

We may also disclose your Personal Information in connection with a corporate reorganization, a merger or amalgamation with another entity, a sale of all or a substantial portion of our assets or stock, including any due diligence exercise carried out in relation to the same.

The App is hosted in the United States and is intended solely for client and/or family members of a client located within the United States.

We use commercially reasonable efforts to store and maintain your Personal Information in a secure environment. We take technical, contractual, administrative, and physical security steps designed to protect Personal Information that you provide to us. We have implemented procedures designed to limit the dissemination of your Personal Information to only such designated staff as are reasonably necessary to carry out the stated purposes we have communicated to you.

You are also responsible for helping to protect the security of your Personal Information. For instance, never give out your password, and safeguard your password and personal credentials when you are using the App, so that other people will not have access to your Personal Information. Furthermore, you are responsible for maintaining the security of any personal computing device on which you utilize the App.

You may be able to share Personal Information with third parties through use of the App. The privacy policies of these third parties are not under our control and may differ from ours. The use of any information that you may provide to any third parties will be governed by the privacy policy of such third party or by your independent agreement with such third party, as the case may be. If you have any doubts about the privacy of the information you are providing to a third party, we recommend that you contact that third party directly for more information or to review its privacy policy.

We will keep your Personal Information for as long as it remains necessary for the identified purpose, or as required by law. We may retain certain data as necessary to prevent fraud or future abuse, or for legitimate business purposes, such as analysis of aggregated, non-personally-identifiable data, account recovery, or if required by law.

We reserve the right to change this Privacy Policy at any time. If we decide to change this Privacy Policy in the future, we will post or provide appropriate notice. Any non-material change (such as clarifications) to this Privacy Policy will become effective on the date the change is posted, and any material changes will become effective 5 days from their posting on this page or via email to your listed email address. Unless stated otherwise, our current Privacy Policy applies to all Personal Information that we have about you and your account. The date on which the latest update was made is indicated at the top of this document. We recommend that you print a copy of this Privacy Policy for your reference and revisit this policy from time to time to ensure you are aware of any changes. Your continued use of the App signifies your acceptance of any changes.

We will make reasonable efforts to keep your Personal Information accurate and up-to-date, and we will provide you with mechanisms to update, correct, or add to your Personal Information as appropriate.

TheKey is not a health care provider, and are therefore not an entity that is covered by the Health Insurance Portability and Accountability Act (“HIPAA”).