iAccompany Privacy Information – November 1, 2021

USA

Last modified: 11/01/2021

iAccompany Privacy Notice

I. Introduction / II. Overview / III. Data collections and uses / IV. Choice and transparency / V. Updates to this notice
I. Introduction
When you use iAccompany, you trust us with your personal data. We’re committed to keeping that trust. That starts with helping you understand our privacy practices.

This notice describes the personal data we collect, how it’s used and shared, and your choices regarding this data. We recommend that you read this along with our privacy overview, which highlights key points about our privacy practices.

II. Overview
A. Scope
This notice applies to users of iAccompany’s services anywhere in the world, including users of iAccompany’s apps, websites, features, or other services.

This notice describes how iAccompany and its affiliates collect and use personal data. This notice applies to all users of our apps, websites, features, or other services anywhere in the world, unless covered by a separate privacy notice.

This notice also governs iAccompany’s other collections of personal data in connection with its services. For example, we may collect the contact information of individuals who use accounts owned by iAccompany Business users, or other personal data in connection with our technology and features.

All those subject to this notice are referred to as “users” in this notice.

In addition, please note the following:

The personal data of those who order or receive services via partner websites or apps, or arranged by other account owners (collectively “Guest Users”) is used solely to provide such services requested through a third party, and for purposes of safety and security, patient support, research and development, enabling communication between users, and in connection with legal proceedings and requirements, each as described in “How we use personal data” below. Guest User personal data may be shared with third parties for these purposes. Such data may be associated with, and accessible by, the owner of that account. This specifically includes Guest Users who receive services ordered by owners of Business accounts, or who receive services ordered by friends, family members or others.
Our practices are subject to applicable laws in the places in which we operate. This means that we engage in the practices described in this notice in a particular country or region only if permitted under the laws of those places.

B. Data controller and transfer
iAccompany Inc. is the data controller for the personal data collected in connection with use of iAccompany’s services.

iAccompany operates, and processes personal data, in multiple nations. We may also transfer such data to countries other than the one where our users live or use iAccompany’s services. We do so in order to fulfill our agreements with users, such as our Terms of Service, or based on users’ prior consent, adequacy decisions for the relevant countries, or other transfer mechanisms as may be available under applicable law, such as the Standard Contractual Clauses.

III. Data collections and uses
A. The data we collect
iAccompany collects personal data:

provided by users to iAccompany, such as during account creation
created during use of our services, such as location, app usage, and device data
from other sources, such as other users or account owners, business partners, vendors, insurance and financial solution providers, and governmental authorities

The following personal data is collected by or on behalf of iAccompany:

1. Data provided by users. This includes:

User profile: We collect data when users create or update their iAccompany accounts. This may include their name, email, phone number, login name and password, address, profile picture, payment or banking information (including related payment verification information), medical professional’s license and other government identification documents (which may indicate document numbers as well as birth date, gender, and photo). This also includes vehicle or insurance information of medical professionals, emergency contact information, user settings, and evidence of health or fitness to provide services using iAccompany apps.

This also includes gender and/or occupation (when required for certain iAccompany services).

We may use the photos submitted by users to verify their identities, such as through facial verification technologies.

Background check and identity verification may include information such as medical professional history or criminal record (where permitted by law), license status, known aliases and prior addresses, and right to work. This information may be collected by an authorized vendor on iAccompany’s behalf. We may also verify the identities of patients.

Demographic data: We may collect demographic data about users, including through user surveys. In some countries, we may also receive demographic data about users from third parties. We may also infer demographic data from other data collected from users. We may infer gender using their first name. In such cases, we enable users to change their gender if necessary.
User content: We collect the data submitted by users when they contact iAccompany patient support, provide ratings or compliments, or otherwise contact iAccompany. This may include feedback, photographs or other recordings collected by users, including audio or video recordings (such as from dashcams) submitted by users in connection with patient support. This also includes metadata relating to the method you use to communicate with iAccompany.

Travel information: We collect travel itinerary information, including the times and dates of upcoming appointments. We collect such information when users manually input their information into an iAccompany appointment.

2. Data created during use of our services. This includes:

Location data (medical professional and patient): We collect medical professionals’ and patients precise or approximate location data, including, to enable appointment tracking and safety features, to prevent and detect fraud, and to satisfy legal requirements. iAccompany collects this data when the iAccompany app is running in the foreground (app open and on-screen) or background (app open but not on-screen) of their mobile device.

We collect such data from users’ mobile devices if they enable us to do so. (See “Choice and transparency” below for information on how patients can enable location data collection). iAccompany collects such data from the time an appointment begins until it is completed (and may indicate such collection via an icon or notification on your mobile device depending on your device’s operating system), and any time the app is running in the foreground (app open and on-screen) of their mobile device.

Patients and patients may use the iAccompany apps without enabling iAccompany to collect precise location data from their mobile devices. However, this may affect features in the iAccompany apps including for purposes of receipt generation, patient support, fraud detection, insurance, and litigation.

Transaction information: iAccompany collects transaction information related to the use of our services, including the type of services requested or provided, order details, payment transaction information, date and time the service was provided, amount charged, distance traveled, and payment method. Additionally, if someone uses your promotion code, we may associate your name with that person.

Usage data: iAccompany collects data about how users interact with our services. This includes data such as access dates and times, app features or pages viewed, app crashes and other system activity, and type of browser. We may also collect data regarding the third-party sites or services used before interacting with our services, which we use for marketing. (Please see “How We Use Data” below for more information on how we market our services to users).
In some cases, we collect this data through cookies, pixels, tags, and similar tracking technologies that create and maintain unique identifiers.

Device data: We may collect data about the devices used to access our services, including the hardware models, device IP address or other unique device identifiers, operating systems and versions, software, preferred languages, advertising identifiers, device motion data, and mobile network data.

Safety recordings: In certain jurisdictions, and where permitted by law, users can record the audio and/or video of their appointments through an in-app feature or using a dashcam. In app recordings are encrypted and stored on users’ devices, and are only shared with iAccompany if submitted to patient support by the users in connection with safety incidents.

3. Data from other sources. These include:

Users participating in our referral programs. For example, when a user refers to another person, we receive the referred person’s personal data from that user.
iAccompany account owners who request services for or on behalf of other users, or who enable such users to request or receive services through their accounts. This includes owners of iAccompany Business accounts and users or others providing information in connection with claims or disputes.

iAccompany business partners through which users create or access their iAccompany account, such as payment providers, social media services, or apps or websites that use iAccompany.

iAccompany business partners in connection with debit or credit cards issued by a financial institution in partnership with iAccompany to the extent disclosed in the terms and conditions for the card, vendors who help us verify users’ identity, background information, and eligibility to work, or who screen users in connection with sanctions, anti-money laundering, or know-your-patient requirements
insurance, vehicle, or financial services providers.

Publicly Available Sources
Marketing service providers or data resellers whose data iAccompany uses for marketing or research,
law enforcement officials, public health officials, and other government authorities.
iAccompany may combine the data collected from these sources with other data in its possession.

B. How we use personal data
iAccompany uses personal data to enable reliable and convenient transportation and other products and services. We also use such data:

to enhance the safety and security of our users and services for patient support
for research and development
to enable communications between users
to send marketing and non-marketing communications to users
in connection with legal proceedings

iAccompany does not sell or share user personal data with third parties for their direct marketing, except with users’ consent.

We use personal data we collect:

1. To provide our services. iAccompany uses data to provide, personalize, maintain, and improve our services.

This includes using data to:

create/update accounts
enable transportation (such as using location data to facilitate a pick up or drop off), features that involve data sharing (such as ETA sharing, and ratings and compliments), and accessibility features to facilitate use of our services by those with disabilities
process payments
track and share the progress of appointments
perform necessary operations to maintain our services, including to troubleshoot software bugs and operational problems; to conduct data analysis, testing, and research; and to monitor and analyze usage and activity trends.

iAccompany performs the above activities, including the collection and use of location data for purposes of these activities, on the grounds that they are necessary to fulfill our obligations to users under our Terms of Service or other agreements with users.

2. Safety and security. We use personal data to help maintain the safety, security, and integrity of our services and users. This includes:

verifying users’ identity and eligibility to provide services, including through reviews of background checks, where permitted by law, to help prevent use of our services by unsafe medical professionals and/or patients.

Where permitted by law, this also includes performing facial verification of photographs submitted by users, or collected from public databases, to prevent identity-borrowing or to verify users’ identities.
Using device, location, user profile, usage, and other data to prevent, detect, and combat fraud. This includes identifying fraudulent accounts or uses of our services, preventing use of our services by unauthorized medical professionals, verifying user identities in connection with certain payment methods, and preventing and combating unauthorized access to users’ accounts.
Using user ratings, reported incidents, and other feedback as grounds for deactivating users with low ratings or who otherwise violated our guidelines in certain countries.
Sharing information regarding serious safety incidents or compliance with local regulations with third parties, including other companies who enable users to request or provide services, or intermediaries who collect and report such information for multiple companies, to prevent individuals who may pose a safety risk to the platform or its users from using iAccompany’s or those other companies’ services. We may also share with third parties, including those affected by such incidents, whether the incidents result in account deactivation.
iAccompany performs the above activities on the grounds that they are necessary to fulfill our obligations to users under our Terms of Service or other agreements with users, and/or for purposes of the legitimate safety and security interests of iAccompany or other parties, including users and members of the general public.

3. Patient support. iAccompany uses the information we collect (which may include call recordings) to provide patient support, including to investigate and address user concerns and to monitor and improve our patient support responses and processes.

iAccompany performs the above activities on the grounds that they are necessary to fulfill our obligations to users under our Terms of Service or other agreements with users.

4. Research and development. We may use personal data for testing, research, analysis, product development, and machine learning to improve the user experience. This helps us make our services more convenient and easy-to-use, enhance the safety and security of our services, and develop new services and features.

iAccompany performs the above activities on the grounds that they are necessary to fulfil our obligations to users under our Terms of Service or other agreements with users in improving our existing services and features, or for purposes of iAccompany’s legitimate interests developing new services and features.

iAccompany performs the above activities on the grounds that they are necessary to fulfill our obligations to users under our Terms of Service or other agreements with users.

6. Marketing. iAccompany may use personal data to market our services to our users. This includes sending users communications about iAccompany services, features, promotions, sweepstakes, studies, surveys, news, updates, and events. We may do so through various methods, including email, text messages, push notifications, in app communications and ads, and ads on third party platforms.

We may also inform users about products and services offered by iAccompany partners. For example, we may provide recommendations, promotions, or ads for iAccompany partners based on users’ past appointments. Although we inform users about products and services offered by iAccompany partners, we do not sell users’ personal data to, or share it with, such partners or others for purposes of their own direct marketing or advertising, except with users’ consent.

We may use the data we collect, including in combination with advertising partners’ data, to personalize and improve the marketing communications (including ads) that we send on and off iAccompany’s apps and websites, including based on user location, use of iAccompany’s services, and user preferences and settings.

We may also send users communications regarding elections, ballots, referenda, and other political and notice processes that relate to our services. For example, iAccompany has notified some users by email of ballot measures or pending legislation relating to iAccompany’s services in those users’ areas.

iAccompany performs the above activities on the grounds that they are necessary for purposes of iAccompany’s legitimate interests in informing users about iAccompany services and features or those offered by iAccompany partners, or on the basis of user consent. See the sections titled “Choice and transparency” and “Marketing choices” for information on your choices regarding iAccompany’s use of your data for marketing.

7. Non-marketing communications. iAccompany may use personal data to generate and provide users with receipts; inform them of changes to our terms, services, or policies; or send other communications that aren’t for the purpose of marketing the services or products of iAccompany or its partners.

iAccompany performs the above activities on the grounds that they are necessary to fulfill our obligations to users under our Terms of Service or other agreements with users, or for purposes of iAccompany’s and it’s users legitimate interests in informing users about events that may have an impact on how they can use iAccompany services.

8. Legal proceedings and requirements. We may use personal data to investigate or address claims or disputes relating to use of iAccompany’s services, to satisfy requirements under applicable laws, regulations, or operating licenses or agreements, or pursuant to legal process or governmental request, including from law enforcement.

iAccompany performs the above activities on the grounds that they are necessary for purposes of iAccompany’s legitimate interests in investigating and responding to claims and disputes relating to use of iAccompany’s services and features, and/or necessary for compliance with applicable legal requirements.

9. Automated decision-making

We use personal data to make automated decisions relating to use of our services. This includes:

Matching available medical professionals to patients requesting services. Users can be matched based on availability, proximity, and other factors such as likelihood to accept an appointment based on their past behavior or preferences.

Determining user ratings, and deactivating users with low ratings. In the European Union or where otherwise required by law, such deactivation occurs only after human review and/or the possibility to appeal.

Flagging users who are identified as having engaged in fraud, unsafe activity, or other activities that may harm iAccompany, its users, and others. In some cases, such as when a user is determined to be abusing iAccompany’s referral program or has submitted fraudulent documents, such behavior may result in automatic deactivation, or in the European Union or where otherwise required by law, deactivation after human review.

Using medical professional location information, and communications between patients and medical professionals, to identify cancellation fees earned or induced through fraud. For example, if we determine by using such information that a medical professional is delaying a patient pickup in order to induce a cancellation, we will not charge the patient a cancellation fee and will adjust the amounts paid to the medical professional to omit such a fee.

Using medical professional data (such as location, rating and gender) and patient data (such as rating, origin and destination) to help avoid pairings of users that may result in increased risk of conflict.

iAccompany performs the above activities on the grounds that they are necessary to fulfill our obligations to users under our Terms of Service or other agreements with users, or on the grounds that they are necessary for purposes of the legitimate interests of iAccompany, its users and others.

C. Cookies and third-party technologies
iAccompany and its partners use cookies and other identification technologies on our apps, websites, emails, and online ads for purposes described in this notice, and iAccompany’s Cookie Notice.

Cookies are small text files that are stored on browsers or devices by websites, apps, online media, and advertisements. iAccompany uses cookies and similar technologies for purposes such as:

authenticating users
remembering user preferences and settings
determining the popularity of content
delivering and measuring the effectiveness of advertising campaigns
analyzing site traffic and trends, and generally understanding the online behaviors and interests of people who interact with our services
We may also allow others to provide audience measurement and analytics services for us, to serve advertisements on our behalf across the Internet, and to track and report on the performance of those advertisements. These entities may use cookies, web beacons, SDKs, and other technologies to identify the devices used by visitors to our websites, as well as when they visit other online sites and services.

D. Data sharing and disclosure
Some of iAccompany’s services and features require that we share personal data with other users or at a user’s request. We may also share such data with our affiliates, subsidiaries, and partners, for legal reasons or in connection with claims or disputes.

iAccompany may share personal data:

1. With other users

This includes sharing:

patients’ first name, rating, and pickup and/or drop off locations with medical professionals
for medical professionals we may share data with the patient(s) including name and photo; average rating provided by patients; total number of appointments services; period of time since they signed up to be a medical professional; contact information (if permitted by applicable laws); and medical professional personal profile, including compliments and other feedback submitted by past users.

We also provide patients with receipts containing information such as a breakdown of amounts charged, medical professional first name, photo, and route map. We also include other information on those receipts if required by law.
For those who participate in iAccompany’s referral program, we share certain personal data of referred users, such as appointment count, with the user who referred them, to the extent relevant to determining the referral bonus.
2. At the user’s request

This includes sharing data with:

Other people at the user’s request. For example, we share a user’s ETA and location with a friend when requested by that user.

iAccompany business partners. For example, if a user requests a service through a partnership or promotional offering made by a third party, iAccompany may share certain data with those third parties. This may include, for example, other services, platforms, apps, or websites that integrate with our APIs; vehicle suppliers or services; those with an API or service with which we integrate; or restaurants, merchants or other iAccompany business partners and their users in connection with promotions, contests, or specialized services.
Emergency services: We offer features that enable users to share their data with police, fire, and ambulance services in the event of an emergency or after certain incidents. For more information, please see the sections below titled “Choice and Transparency” and “Emergency Data Sharing”.

3. With the general public

Questions or comments from users submitted through public forums such as iAccompany blogs and iAccompany social media pages may be viewable by the public, including any personal data included in the questions or comments submitted by a user.

4. With the iAccompany account owner

If a user requests services using an account owned by another party, we may share their information, including location data, with the owner of that account. This occurs, for example, when:

a patient uses their employer’s iAccompany for Business profile
a medical professional uses an account owned by or associated with an iAccompany partner company
a patient’s appointment is arranged by a friend or under a Family Profile

5. With iAccompany subsidiaries and affiliates

We share personal data with our subsidiaries and affiliates to help us provide our services or conduct data processing on our behalf. For example, iAccompany processes and stores such data in the United States on behalf of its international subsidiaries and affiliates.

6. With iAccompany service providers and business partners

iAccompany provides personal data to vendors, consultants, marketing partners, research firms, and other service providers or business partners. These include:

payment processors and facilitators
background check and identity verification providers
cloud storage providers
Google, in connection with the use of Google Maps in iAccompany’s apps (see Google’s privacy policy for information on their collection and use of data)
social media companies, including Facebook and TikTok, in connection with iAccompany’s use of their tools in iAccompany’s apps and websites (see Facebook’s and TikTok’s privacy policies for information on their collection and use of data)
Marketing partners and marketing platform providers, including social media advertising services, advertising networks, third-party data providers, and other service providers to reach or better understand our users and measure advertising effectiveness
research partners, including those performing surveys or research projects in partnership with iAccompany or on iAccompany’s behalf
vendors that assist iAccompany to enhance the safety and security of its apps
consultants, lawyers, accountants, and other professional service providers
insurance and financing partners

7. For legal reasons or in the event of a dispute

iAccompany may share users’ personal data if we believe it’s required by applicable law, regulation, operating license or agreement, legal process or governmental request, or where the disclosure is otherwise appropriate due to safety or similar concerns.

This includes sharing personal data with law enforcement officials, public health officials, other government authorities, or other third parties as necessary to enforce our Terms of Service, user agreements, or other policies; to protect iAccompany’s rights or property or the rights, safety, or property of others; or in the event of a claim or dispute relating to the use of our services. In the event of a dispute relating to use of another person’s credit card, we may be required by law to share your personal data, including appointment information, with the owner of that credit card.

This also includes sharing personal data with others in connection with, or during negotiations of, any merger, sale of company assets, consolidation or restructuring, financing, or acquisition of all or a portion of our business by or into another company.

8. With consent

iAccompany may share a user’s personal data other than as described in this notice if we notify the user and they consent to the sharing.

E. Data retention and deletion
iAccompany retains user data for as long as necessary for the purposes described above.

Users may request deletion of their accounts at any time. iAccompany may retain user data after a deletion request due to legal or regulatory requirements or for reasons stated in this policy.

iAccompany retains user data for as long as necessary for the purposes described above. This means that we retain different categories of data for different periods of time depending on the type of data, the category of user to whom the data relates, and the purposes for which we collected the data.

Users may request deletion of their account at any time.

Following an account deletion request, iAccompany deletes the user’s account and data, unless they must be retained due to legal or regulatory requirements, for purposes of safety, security, and fraud prevention, or because of an issue relating to the user’s account such as an outstanding credit or an unresolved claim or dispute. Because we are subject to legal and regulatory requirements relating to medical professionals, this generally means that we retain their account and data for a minimum of 7 years after a deletion request. For patients their data is generally deleted within 90 days of a deletion request, except where retention is necessary for the above reasons.

IV. Choice and transparency
iAccompany enables users to access and/or control data that iAccompany collects, including through:

privacy settings
device permissions
in-app ratings pages
marketing choices
iAccompany also enables users to request access to or copies of their data, changes or updates to their accounts, or deletion of their accounts, or that iAccompany restricts its processing of user personal data.

1. Privacy settings

Emergency Data Sharing
Patients may enable iAccompany to share real-time location data from their mobile devices with emergency police, fire, and ambulance services. Such data may include approximate location at the time the emergency call was placed; the car’s make, model, color, and license plate information; the patient’s name and phone number; pickup and dropoff locations; and the medical professional’s name.

Notifications: account and appointment updates
iAccompany provides users with appointment status notifications and updates related to activity on their account. These notifications are a necessary part of using the iAccompany app and cannot be disabled.

2. Device permissions

Most mobile device platforms (iOS, Android, etc.) have defined certain types of device data that apps cannot access without the device owner’s permission, and these platforms have different methods for how that permission can be obtained. Please check the available settings on your device or check with your provider.

3. In-app ratings pages

After every appointment, medical professionals and patients may be able to rate each other on a scale from 1 to 5. An average of those ratings is associated with a user’s account and is displayed to other users for whom they provide or receive services. For example, patient ratings are available to medical professionals from whom they request services, and medical professional ratings are available to their patients.

This 2-way system holds everyone accountable for their behavior. Accountability helps create a respectful, safe environment for medical professionals and patients.

Patients can see their average rating in the main menu of the iAccompany app.

Medical professionals can see their average rating after tapping their profile photo in the iAccompany Medical Professional app.

4. Marketing choices

Users may opt out of certain marketing communications (including ads) and use of their data for marketing in the following ways:

Ad settings: These settings enable users to choose whether their data is shared with iAccompany’s advertising partners to deliver personalized ads, and/or to measure the effectiveness of such ads.
Marketing emails and messages: Users may also opt out of receiving emails and other messages from iAccompany by following the unsubscribe instructions in those messages. We may still send users who have opted out non-promotional communications, such as receipts for services or information about their account.

5. User personal data requests

iAccompany provides users with a variety of ways to learn about, control, and submit questions and comments about iAccompany’s handling of their personal data.

Accessing data: Users can access data including their profile data and appointment history through the iAccompany apps or via iAccompany’s website.
Receiving data: Users can request a copy of their personal data.
Changing or updating data: Users can edit the name, phone number, email address, payment method, and photo associated with their account. Users may also request to update or correct their data.
Deleting data: Users may request deletion of their account at any time.
Objections, restrictions, and complaints: Users may request that we stop using all or some of their personal data, or that we limit our use of their data. This includes objecting to our use of personal data that is based on iAccompany’s legitimate interests. iAccompany may continue to process data after such objection or request to the extent required or permitted by law.

In addition, depending on their location, users may have the right to file a complaint relating to iAccompany’s handling of their personal data with the data protection authority in their country. For example, users in the European Union and South America may submit such requests to the data protection authorities in the country in which they live.

V. Updates to this notice
We may occasionally update this notice.

We may occasionally update this notice. If we make significant changes, we will notify users in advance of the changes through the iAccompany apps or through other means, such as email. We encourage users to periodically review this notice for the latest information on our privacy practices.

Use of our services after an update constitutes consent to the updated notice to the extent permitted by law.