Last Updated: March 22, 2020
I. Introduction and Overview
We may provide different or additional disclosures relating to the processing of personal information about residents of certain countries, regions or states. Listed below are additional disclosures that may be applicable to you.
If you are a resident of Canada, please see the additional privacy disclosures in Disclosure For Canada Residents.
If you are a California resident, please see the additional privacy disclosures below in Disclosure For California Residents.
If you are a Nevada resident, please see the additional privacy disclosures below in Disclosure For Nevada Residents.
II. Information we collect
1. Information you provide to us or allow others to provide to us
At various points in the Custodia experience, you may provide us with information about yourself. For example, when you create an account through the Services, you provide us with personal information like your name, email address, and zip or postal code. And if you place an order through the Services, we collect information including your address, phone number, birth date (for customized recommendations or prescription delivery, where available), credit card information and the details of your order. Your account information may be updated or corrected by accessing your account settings.
If you use the Services for prescription delivery (where available), the third-party pharmacy processing your prescription will provide us with your name, address, email address, birth date, phone number, the total amount being charged to you for the prescription drug product(s), and sales tax information for the prescription drug product(s) (if applicable). The third-party pharmacy will also share whether or not the prescription drug product you have ordered requires temperature control. If a prescription drug product delivered to you through the Services has been recalled, the third-party pharmacy will share your name, email address, the date of the prescription drug product order, and the total amount to be refunded to you with Custodia. The pharmacy will not disclose to us the name, quantity, manufacturer or distributor of the prescription drug you have ordered or any other PHI about you other than your status as a patient of the pharmacy.
We may also collect health information you provide directly to us regarding an experience with a product or service partner that may require us to contact that partner, or other retailer partners, for public health or safety reasons, or to facilitate a refund. We do not share your identity with the partners that we may contact in such a capacity, but may share the date, time and location of a transaction, which may allow a partner to independently identify you.
If you log into the Services through a third-party service, both we and that third-party may receive some information about you and your use of the services. For example, if you choose to log into the Services with your Facebook account, we may receive information from Facebook, such as your name, e-mail address, public profile information, and information about your contacts. We may also offer social sharing tools (such as the Facebook “Like” button) that let you share actions on the Services with other websites and vice versa. In those cases, the providers of those tools may receive information about you when you use those tools. You should check the privacy policies of these third-party services and your settings there for more information.
If you wish to invite your friends and contacts to use the Services, we will give you the option of either entering in their contact information manually or, for United States residents, importing it from your address books on other third-party services. In both cases, we will store this information for the sole purposes of allowing you to send your friends referral offers, for determining whether your friends use the Services after a referral is sent, and, for United States residents, to remind your friends of the referral sent on your behalf.
Our partners may let us collect information about use of their sites/apps or share such information with us. For example, if you use a 3r party referral partner, we may receive information about your purchases from that partner and the third-party site/app.
Custodia is active in local communities as part of our mission to create a world where aging in place is less of a burden on seniors, their families, and their support systems, and to make life more enjoyable at home. You may provide us your information in connection with our community affairs efforts.
When you use the Services, we may collect precise location data. For instance, if you allow the Services to access location services through the permission system used by your device’s mobile operating system or browser, we may collect the precise location of your device. We use your location information to facilitate the prompt scheduling of services (where available), to schedule weather-related alerts, to assist you in finding nearby services for which pickup or delivery are available, for other similar purposes and for analytics purposes. You can choose whether or not to enable the location tracking feature through the settings on your device or browser, or when prompted by the Custodia mobile app. We may also infer your general location information, for example by using your internet protocol (IP) address.
2. Technical information about usage of the Services
When you use the Services, or browse our sites, either through a browser or mobile app, we automatically receive some technical information about the hardware and software that is being used.
Cookies, Pixels, and Other Tracking Technologies:
We, our partners, our advertisers, and third-party advertising networks use various technologies to collect information, including but not limited to cookies, pixels, scripts, and device identifiers. Cookies are small text files that are sent by your computer when you access our services through a browser. We, our partners, our advertisers, and third-party advertising networks may use session cookies (which expire when you close your browser), persistent cookies (which only expire when you choose to clear them from your browser), pixels, scripts, and other identifiers to collect information from your browser or device that helps us do things such as understand how you use our services and other services; personalize your experience; measure, manage, and display advertising on the Services or on other services; understand your usage of the Services and other services in order to serve customized ads; and remember that you are logged into the Services. Our partners, advertisers, and third-party advertising networks may use these technologies to collect information about your online activity over time and across different websites or online services. By using your browser settings, you may block cookies or adjust settings for notifications when a cookie is set. Your browser settings may allow you to automatically transmit a “Do Not Track” signal to online services you visit. Note, however, there is no industry consensus as to what site and app operators should do with regard to these signals. Accordingly, unless and until the law is interpreted to require us to do so, we do not monitor or take action with respect to “Do Not Track” signals. For more information on “Do Not Track,” visit http://www.allaboutdnt.com.
We employ some third-party services to help us understand the usage of the Services and the performance of advertising, and these third parties may also deploy cookies, pixels, or other identifiers on the Services or collect information through our mobile applications. For example, we use Google Analytics to understand, in a non-personally identifying way, how users interact with various portions of the Services — you can learn more about information that Google may collect here.
When you use the Services, or browse our sites, our servers will record information about your usage of the Services and information that is sent by your browser or device. Log information can include things like the IP address of your device, information about the browser, operating system and/or app you are using, unique device identifiers, pages that you navigate to and links that you click, searches that you run on the Services, and other ways you interact with the Services. If you are logged into the Services, this information is stored with your account information.
Interest-Based or Online Behavioral Advertising:
Custodia may use third-party advertising companies to serve interest-based advertisements to you. These companies compile information from various online sources (including mobile-enabled browsers and applications) to match you with ads that will be the most relevant, interesting, and timely for you. If you would like to opt-out of interest-based advertising, please visit http://optout.networkadvertising.org/#/ . Please note that you will be opted out of all interest-based advertising from all business members of the Network Advertising Initiative for that specific browser on that specific device. If you opt-out, you may continue to see Custodias’ or our partners’ online advertisements; however, these ads will not be as relevant to you.
Our Services are not intended for children under 13 years of age, and we do not knowingly collect personal information (as defined by the U.S. Children’s Online Privacy Protection Act, or “COPPA”) in a manner not permitted by COPPA. If we obtain actual knowledge that any information we collect has been provided by a child under the age of 13, we will delete that information to the extent required by applicable laws.
We do not knowingly “sell,” as that term is defined under the California Consumer Protect Act (“CCPA”), the personal information of minors under 16 years old who are California residents.
III. How we use your information
We may use the information we collect for various purposes, including to:
- Provide the Services to you, improve the quality of the service, and develop new products and services
- Allow your Seniors Helper (which means those that help you at your home, shop for and/or deliver items to you, including our service provider partners and their employees/agents where applicable or our third-party providers) to help you with basic maintenance, odd jobs, personal support, shopping, cleaning, delivery, and/or call or text you with any updates or issues
- Charge you for the purchase of products and services through one or more payment processing partners
- Offer you customized content (including custom maintenance items, content, local events, government initiatives, advertising, coupons, and promotions)
- Understand how users interact with the Services (including advertising both on and off the Services) as a whole and to test new features or changes in our features
- Provide customer service, respond to your communications and requests, and contact you about your use of the Services
- Send you messages related to our community affairs efforts
- Fulfill any other business or commercial purposes at your direction or with prior notice to you and your consent
- You can opt-out of receiving promotional communications from Custodia by using the settings on the Account Info page or by using the unsubscribe mechanism included in the message, where applicable.
IV. What we share
The Services comprise a platform that presents you with a customized agining in place plan from which you can select services to be delivered or performed by approved individual Seniors Helper(s) at your location. In order to make this work, we need to share information about you and your order with the other parties who help enable the service. This includes, for example, the Seniors Helper(s) who perform the services, the payment processing partner(s) that we use to validate and charge your credit card, and (where applicable) the retail partner(s) from which you are purchasing goods. To be clear, only our payment processing partner(s) receive credit card information.
We also share information under the following principles:
- With your consent or at your direction — We will share your information with entities outside of the Services when we have your consent to do so or it is done at your direction. For example:
- If you share a comment publicly on the Services, it is viewable by anyone along with your first name and last initial.
- If you invite friends to use the Services through our referral program or to share an aging in place plan, we will share some information with the friends you invite like your name and picture. Likewise, if you choose to join someone else’s aging in place plan, they will see some of your information.
- With our service provider partners — We may share your information with our service provider partners in order to provide and maintain the Services.
- For external processing or service provision — We sometimes share information with third parties to process information on our behalf or to otherwise provide certain services (such as home management services, personal support services, advertising services, or information to better tailor our services to you). For the purposes of this processing or provision of services, we may share your information with such third parties under appropriate confidentiality provisions.
- For legal purposes — We may share your information when we believe that the disclosure is reasonably necessary to (a) comply with applicable laws, regulations, legal process, or requests from law enforcement or regulatory authorities, (b) prevent, detect, or otherwise handle fraud, security, or technical issues, and (c) protect the safety, rights, or property of any person, the public, or Custodia.
- On a non-personal or aggregate basis — We share information on both a non-personally identifying basis (including, but not limited to, home score and service visit details but not including credit card information) or an aggregate basis.
- For business purposes — We may share your information in connection with, or during negotiations of, any merger, sale of company assets, financing or acquisition of all or a portion of our business by another company. We may also share your information between and among Custodia, and its current and future parents, affiliates, subsidiaries, and other companies under common control and ownership.
V. Personal Health Information
Your PHI is protected under HIPAA and under certain state laws. Those laws give you rights with respect to the access, use, and disclosure of PHI by your health care providers, such as personal support workers, and us. When you place a personal support order using our Services, the personal support worker responds as we have described above under the Section entitled “Information we collect” by disclosing to Custodia your status as a client of the personal support worker. Information concerning your status as a client of the personal support worker is PHI and protected by HIPAA. As discussed above, no other PHI will be disclosed to us by your personal support worker and no other PHI will be disclosed by Custodia to other seniors helpers you many utilize other than your status as a client of the personal support worker. We will not disclose your PHI without your prior written consent with other people or non-affiliated companies unless: (i) it is needed to provide our Services, (ii) it has been “de-identified” so that it cannot identify you, (ii) we have your prior written consent, (iv) disclosure is required by law, or (v) we are acquired or file for bankruptcy.
We employ and maintain reasonable administrative, physical, and technical measures designed to safeguard and protect information under our control from unauthorized access, use, and disclosure. In addition, when we collect, maintain, access, use, or disclose your PHI, we will do so using systems and processes consistent with information privacy and security requirements under applicable federal and state laws, including, without limitation, HIPAA. All electronic PHI will be encrypted at rest and in transit. Nevertheless, transmission via the internet is not completely secure and we cannot guarantee the security of information about you.
We will make any legally required notifications of any breach of the security, confidentiality, or integrity of your PHI or PII, including, without limitation, breaches of your stored PHI or PII (as breaches are defined under applicable state or federal statutes on security breach notification). To the extent permitted by applicable laws, we will make such notifications to you without unreasonable delay, as consistent with (i) the legitimate needs of law enforcement or (ii) any measures necessary to determine the scope of the breach and restore the reasonable integrity of the data system.
VII. Changes to this Policy
VIII. Disclosures for Residents of California
These additional disclosures for California residents apply only to individuals who reside in California. The California Consumer Privacy Act of 2018 (“ CCPA ”) provides additional rights to know, delete and opt out, and requires businesses collecting or disclosing personal information to provide notices and means to exercise those rights. The words used in this section have the meanings given to them in the CCPA, which may be broader than their common meaning. For example, the definition of “personal information” under the CCPA includes your name, but also more general information like age.
A. Notice of Collection.
Although the information we collect is described in greater detail in Section II above, the categories of personal information that we have collected – as described by the CCPA – including in the past 12 months are:
- Identifiers – including name, email address, and IP address.
- Other individual customer records – including phone number , billing and shipping address, and credit or debit card information. This category includes personal information protected under pre-existing California law (Cal. Civ. Code 1798.80(e)), and overlaps with other categories listed here
- Demographics – including your age. This category includes data that may qualify as protected classifications under other California or federal laws.
- Commercial information – including purchases and engagement with our Services.
- Internet activity – including your interactions with our Service.
- Geolocation data – including location enabled services such as WiFi and GPS.
- Sensory Information – such as recordings of phone calls between you and us and surveillance video at our properties, where permitted by law.
- Inferences – including information about your interests, preferences and favorites.
- Health Information – including any information you provide to us regarding an experience with a retailer that may require us to contact that retailer or other retailer partners for public health or safety reasons, or to facilitate a refund. We do not share your identity with retailers we may contact in such a capacity, but do share date, time and location of a transaction, which may allow a retailer to independently identify you.
- For more information on our collection practices, including the sources we receive information from, please review “ Information We Collect ” (Section II above). We collect and use these categories of personal information for the business purposes described in “ How We Use Your Information ” (Section III above), including to provide and manage our Services.
We disclose the following categories of personal information to third parties for our commercial purposes: identifiers, demographic information, commercial information, relevant order information, internet activity, geolocation data, sensory information, and inferences. We partner with different types of entities to assist with our daily operations and manage our Services. Please review “ What We Share ” (Section IV above) for more detail about the third parties we have shared information with and the underlying principles the guide our sharing practices.
B. Right to Know and Delete.
California residents have the right to delete the personal information we have collected from you, and the right to know certain information about our data practices in the preceding twelve (12) months. In particular, you have the right to request the following from us:
The categories of personal information we have collected about you;
The categories of sources from which the personal information was collected;
The categories of personal information about you we disclosed for a business purpose or sold;
The categories of third parties to whom the personal information was disclosed for a business purpose or sold;
The business or commercial purpose for collecting or selling the personal information; andThe specific pieces of personal information we have collected about you.
If you would like to download or delete your personal information, you can email us at email@example.com. In the request, please specify which right you are seeking to exercise and the scope of the request. We will confirm receipt of your request within 10 days. We may require specific information from you to help us verify your identity and process your request. If we are unable to verify your identity, we may deny your requests to know or delete.
C. Right to Opt-Out.
We do not generally sell information as the term “sell” is traditionally understood. However, if and to the extent “sale” under the CCPA is interpreted to include advertising technology activities such as those implemented specifically for interest-based advertising, we will comply with applicable law as to such activity.
D. Authorized Agent.
You can designate an authorized agent to submit requests on your behalf. However, we will require written proof of the agent’s permission to do so and verify your identity directly.
E. Right to Non-Discrimination.
You have the right not to receive discriminatory treatment by us for the exercise of any your rights.
F. Financial Incentives.
Financial incentives are programs, benefits, or other offerings, including payments to consumers as compensation, for the disclosure, deletion, or sale of personal information about them. We offer a number of promotions and other incentives at any given time, each with their own individual terms. Your intentional participation in any of the programs, benefits, or other offerings under this Section will be interpreted as affirmative consent to the terms of such incentive.
For example, we offer a referral rewards program to our users who recommend our services to their contacts as prospective customers, when those prospective customers sign up for, and make a purchase using our Services. We generally do not treat consumers differently if they exercise a right under California law. However, in certain circumstances, discounted prices or rewards will require you to be part of the particular program. In such circumstances, we may offer a price difference because the price is reasonably related to the value of your data.
G. Shine the Light.
If you are a California resident, you may ask Custodia for a notice describing what categories of personal information Custodia shares with third parties or affiliates for those third parties or affiliates’ direct marketing purposes and identify the name and address of the third parties that received such personal information. Please submit a written request to the address provided below and specify you want a copy of your California Shine the Light Notice. We may require additional information from you to allow us to verify your identity and are only required to respond to requests once during any calendar year.
H. Consumer Affairs
Under California Civil Code Section 1789.3, California residents are entitled to the following specific consumer rights notice: If you have a question or complaint regarding the Website, please send an email to firstname.lastname@example.org. You may also contact us by writing to us at the address provided below under the Section entitled “Contact Information”. California residents may reach the Complaint Assistance Unit of the Division of Consumer Services of the California Department of Consumer Affairs may be contacted in writing at 400 R Street, Suite 1080, Sacramento, California 95814, or by telephone at (916) 445-1254 or (800) 952-5210.
IX. Disclosure for Residents of Nevada
If you are a Nevada resident, you may ask Custodia to add you to our opt-out list for possible future sales of certain information we have collected or will collect about you. A sale under Nevada law is the exchange of personal information for monetary consideration by the business to a third-party for the third-party to license or sell the personal information to other third parties. To submit such a request, please contact our designated request email address: email@example.com.
X. Disclosure for Residents of Canada
You may request access to or correction of your personal information, or withdraw consent to our collection, use or disclosure of your personal information, by writing to our Global Privacy Team. These rights are subject to applicable contractual and legal restrictions and reasonable notice. We may take reasonable steps to verify your identity before honoring any such requests.
XI. Contact Information
14 Cavell Avenue, Lower Level
Etobicoke, Ontario M8V 1P2
If you have comments concerning this website’s accessibility, please contact us at the email address firstname.lastname@example.org.