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Privacy Policy

Effective Date: Feb 1, 2024

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At Safehill, the privacy and security of your data is paramount. This Privacy Policy outlines how we collect, use, store, and disclose the information we receive from our users. By using our platform, you agree to the practices described in this policy.

1. Information Collection

Safehill collects information about you only if we have a reason for such collection, such as to provide you with a user account, to communicate with you, or to improve our App. Information is collected in the following ways:

1.1. User-provided Information:

When creating a user account (“User Account”), we collect Name and Phone number which can be categorized as Personally Identifiable Information ("PII"). Safehill uses the phone numbers for verification and only stores a cryptographically secure hashed representation of the phone number from that point forward. 

You have the option to grant Safehill access to your contacts on your device. By doing so, Safehill will generate cryptographically secure identifiers using the phone numbers in your address book to assist you in locating your contacts within the app. These cryptographically secure identifiers are not saved anywhere. However, when you invite individuals using their phone numbers, we securely store the numbers as hashed representations on our servers to link them to you when they join Safehill.

1.2. Automatically Collected Information:

We will also collect unidentified and non-identifiable information (“Anonymous Information”) does not enable Safehill to identify the visitor or user from whom it was collected. The Anonymous Information collected by Safehill may consist of the date, time, length and non-precise location of your visit. Safehill will not aggregate, use or share Anonymous Information with third parties for marketing or advertising purposes.

You may review, amend or delete any and all information associated with your User Account by signing into your account on the App and clicking on "Destroy my lockbox". You may also request the deactivation of your User Account and any uploaded content by sending an e-mail to support@safehill.io. Please note that permanently deleting your Safehill User Account erases all of your information from our system. After completing this process your User Account and all its data will be removed permanently, and Safehill will not be able to restore your User Account or retrieve your data in the future.

We use the information we collect (both Anonymous Information and PII) to operate and improve the App. We do not share your PII with outside parties except to the extent necessary to operate our App, such as to process credit card information. We use Twilio and Apple to authenticate who you are and your payment information. Please click through for their privacy policies. In the future, we may sell to, buy, merge with, or partner with other businesses. In such transactions, Anonymous Information and PII may be among the transferred assets.

Safehill will not sell, license, rent, or otherwise disclose your PII except as stated herein, unless under the following circumstances: (1) you have affirmatively given your consent; (2) we previously notified you of the disclosure in this Privacy Policy or when you provided your information on the App; (3) we are compelled by law, legal process, or court order to disclose; (4) disclosure is required to identify, contact, or bring legal action against someone who may cause harm to, or interference with, Safehill’s rights or property, our users, or anyone else; or (5) to respond to an inquiry, request or complaint that you have made. Safehill may cooperate with Internet service providers to identify users whenever required to comply with law, to enforce compliance with this Privacy Policy or our Terms, or to protect the App, our customers and others.

A third-party payment processor collects and processes financial information on our behalf; we do not collect or retain your payment information. If any Anonymous Information is linked to PII, it will be treated as PII as long as the connection exists.

2. Information Use

Safehill is an industry leader in protecting and safeguarding your data from unauthorized use, disclosure and to prohibit possible security breaches of the App. Even though no website, application, computer system or online communication is completely secure, any unauthorized access to our systems will not disclose any unencrypted user information other than Name. In addition to standard encryption offered by protocols such as SSL and the operating system, we use and combine state of the art encryption techniques to protect any data that is stored or transferred over the network. Safehill will NOT have access to the keys.

2.1. Encryption:

All data collected by Safehill is encrypted end to end. This encryption ensures that your information is protected and only accessible by you and authorized personnel.

2.2. Service Improvement:

We may use the information we collect to enhance and improve our services, develop new features, and conduct research and analysis.

Safehill will take commercially reasonable steps to use heightened security technologies to protect the transmission and storage of transactional information to the App. Such heightened security measures may include the secure transmission and encryption of all supplied sensitive financial or other transaction-related information. Safehill does not handle any such information directly but uses Apple’s secure system. Check out Apple’s privacy policy here.

Unless otherwise specified, whenever you make a payment, your financial and other transaction-related information will only be used to process your transaction and will not be stored on our servers or used for marketing purposes.

Data will be maintained, processed and stored by Safehill in the United States of America or other jurisdictions, as necessary, for proper delivery of the services or as required by law. PII is kept only as long as necessary to provide you with access to the App and for legitimate and essential business purposes, such as maintaining your account, and making data-driven business decisions about new features and offerings.

If you are located in countries that fall under the scope of the European General Data Protection Regulation (“GDPR”), data protection laws give you rights with respect to your personal data, subject to exemptions provided by law. These rights include:

  • The right to request access to your personal data;

  • The right to request correction or deletion of your personal data;

  • The right to object to the use and processing of your personal data;

  • The right to request that Safehill limit its use and processing of your personal data;

  • The right to request portability of your personal data.

  • The right to make a complaint to a governmental supervisory authority.

Safehill strives to provide these rights to all visitors and users. Please email us at support@safehill.io with any requests, questions, or concerns.

In accordance with Article 77 of the General Data Protection Regulation, you have the right to lodge complaints about the data processing activities carried out to the UK Information Commissioner’s Office, or the data protection regulator in the country where you actually live and work, or where an alleged infringement of the GDPR has taken place. Alternatively, you may seek a remedy through the courts if you believe your rights have been breached.

3. Legal Basis Under EU General Data Protection Regulation for Processing Information of EU Residents.

Where you have consented to data processing, by using this App, your consent provides the legal basis to process your PII. You may withdraw your consent at any time by emailing support@safehill.io.

We may process your PII where it is necessary to use such PII in order to perform our obligations under any contract with you (for example, to comply with the Terms and Conditions, which you accept by browsing our website and/or in order to provide the App to you).

We may process your PII on the basis of our legitimate interests, such as providing and developing interesting features for our Users, operating and improving the App, developing new services, providing customer service, and market research. We also use your PII to keep our App safe and secure, to protect against fraud, spam and abuse. Where we rely on legitimate interests to process your PII, you have the right to object to such processing (you can ask us to stop).  You can contact us at support@safehill.io to object to such processing. We may also process your PII on the basis of our legal obligations.

4. Cookies and Third-Party Providers

Safehill does not use cookies.

This Privacy Policy does not govern the privacy practices of third parties who gather information directly from you when you visit their site or app. The App may embed or contain links for third party websites. Similarly, third-party websites may embed or contain links and advertisements for the App. Safehill cannot control and is not responsible for the privacy practices or content on any non- Safehill websites. Safehill is therefore not liable for your use of and exposure to such third-party websites and any content or advertisements they contain. You should familiarize yourself with the privacy policies and terms of use of these third parties to better understand their information management policies.

If you choose to opt in to receive communications from a third party, any information you provide to said third party, will be subject to the privacy policy of the third party. If you later decide to opt out, you should contact the third party directly.

Where permitted by local data laws, Safehill may disclose or otherwise allow others to access your PII pursuant to a legal request, such as a subpoena, legal proceedings, search warrant or court order, or in compliance with applicable law.  If we have a good faith belief that the law requires disclosure, we may disclose your PII, with or without notice to you.

5. Children and Privacy

This App is NOT intended to be used by children under the age of 17 in the United States and under the age of 17 in the European Union. Safehill recognizes the importance of maintaining the privacy of children, especially those under the age of 16. Safehill is committed to complying with all applicable laws and regulations regarding children, including the Children’s Online Privacy Protection Act (“COPPA”), 15 U.S.C. § 6501, et seq.

Except in limited circumstances allowed by COPPA, Safehill does not and will not knowingly request, collect, store, maintain, or share any personally identifiable information of children under the age of 16, without first obtaining the consent of a legal guardian. In those limited instances, Safehill will only collect reasonably necessary information, and Safehill will not share with third parties any personally identifiable information of a child under the age of 16 without the explicit consent of a legal guardian, or as permitted by COPPA or other applicable law.

You may revoke your consent and request the removal of your child’s information at any time. If you are the legal guardian of a child under the age of 16 and discover that your child has submitted their personally identifiable information without securing your consent, Safehill will use commercially reasonable efforts to remove this information. If at any point you wish to review, amend, or request the removal of your child’s information, please send an e-mail to support@safehill.io and provide the name and account information for your child’s user account.

6. Notification of Changes

Safehill may at any time and in its sole discretion, add, modify, or remove any feature, function or portion of the App, the Terms, and/or the Privacy Policy, in whole or in part, with or without notice to you, prior or otherwise. Any changes to the Privacy Policy will be effective as of the posting date. Safehill will provide prominent notice on the App of any major changes to the Privacy Policy. Your continued use of the App after Safehill posts any modifications to the Privacy Policy shall be deemed your explicit acceptance of those modifications and shall constitute your agreement to comply with the Privacy Policy, as modified.

7. Notice to California Users

California Civil Code Section 1798.83 permits users who are California residents and who have provided 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 with questions regarding this, or how the Safehill reviews and processes any request from you to amend your personal information, please contact us as support@safehill.io.

8. Contacting Us

If there are any questions regarding this Privacy Policy you may contact us using the information below.

9. Notice to EU Users

The GDPR of the European Union permits users who are residents and who have provided with personal information to request certain information about the disclosure of that information to third parties for their direct marketing purposes. If you are a EU resident you have the right to complain to national or local data protection offices (you can find a list here https://edpb.europa.eu/about-edpb/about-edpb/members_en) and with any questions regarding this, or how the Safehill reviews and processes any request from you to amend your personal information, please contact us as support@safehill.io.

Safehill Inc.,

Attn: Legal Department‍ support@safehill.io

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