Privacy Policy

1. Information We Collect

1.1 Information You Provide

We collect information that you provide directly to us, including:

• Account registration information (name, email address, phone number, date of birth)
• Profile information (emergency contacts, designated monitors, medical information and other information that you upload to your profile)
• Your personalized 4-digit alert code used to cancel emergency alerts
• Route information you share, including origin, destination, and chosen transit mode (transit, bike, walking, or car)
• Payment information for subscriptions (processed through Apple App Store or Google Play Store)
• Communications with us (support requests, feedback, reviews)

1.2 Location Information

• Route Monitoring: When you share a route with your designated monitors, we continuously track your real-time location from your starting point until you arrive at your chosen destination or end route sharing. Your designated monitors may receive notifications and can track your live location throughout your journey.
• Emergency Alerts (Alert Button): When you activate the alert button and the 10-second countdown expires without cancellation, we continuously track and broadcast your real-time location for up to one (1) hour. This location data is shared with your designated monitors to enable them to locate you quickly and/or respond appropriately.
• Background Location Access: To provide continuous location tracking during route monitoring and emergencies, the App requires background location access. This means the App can access your location even when you are not actively using it, but active location tracking only occurs during route monitoring or an active emergency.
• Monitor Dashboard: If you are a designated monitor, you may view the location, and, where applicable, the live audio/video broadcast of the individuals who have designated you as a monitor.

1.3 Information Recorded by You as Part of Audio and Video Recording

When you activate the alert button and the 10-second countdown expires without entry of your 4-digit cancellation code, the App automatically begins recording audio and video. This feature is designed to:

• Capture critical information about the emergency situation
• Provide evidence for law enforcement if needed
• Help emergency responders and your monitors understand the nature and severity of the situation

Recordings are automatically initiated when the countdown expires and are broadcast live to your designated monitors. Recordings, and all information processed in connection with obtaining, transmitting, storing, and otherwise handling such recordings, are saved and retained for six (6) months. By using the emergency features of the App, you consent to this automatic recording.

1.4 Recording Consent and State Law Compliance

However, certain states require the consent of all parties to a conversation before a recording is lawful ("two-party" or "all-party" consent states). As of the date of this Privacy Policy, the following states generally require all-party consent for recordings: California, Connecticut, Delaware, Florida, Illinois, Maryland, Massachusetts, Montana, Nevada, New Hampshire, Oregon (in-person conversations), Pennsylvania, and Washington. Please note that this list may change, and it is your responsibility to obtain all required consents under applicable law, as explained below.

If you or any person captured in a recording is located in a two-party or all-party consent state at the time of recording, additional legal requirements may apply. By using the emergency recording features of this App, you acknowledge the following:

• You are responsible for understanding and complying with the recording laws of your jurisdiction and any jurisdiction in which you use the App.
• In two-party or all-party consent states, activating the emergency recording feature may constitute a recording of other individuals without their prior consent. While the emergency nature of the recording may provide legal justification in many circumstances, ByPULLA, LLC does not guarantee that emergency recordings will be deemed lawful in all jurisdictions.
• ByPULLA, LLC is not responsible for any legal consequences arising from your use of the recording feature in a jurisdiction that requires all-party consent.
• We strongly recommend that users in two-party consent states consult with a licensed attorney regarding the legality of emergency recordings in their jurisdiction.

We endeavor to provide in-App notices regarding recording laws based on your detected location, but you should not rely solely on these notices for legal compliance.

1.5 Device Information

We automatically collect certain information about your device, including:

• Device type, model, and operating system
• Unique device identifiers
• Mobile network information
• App usage data and analytics
• Crash reports and performance data

We treat the device information as personal information to the extent it is required under applicable laws.

1.6 Information from Third Parties

• We may receive personal information about you from third parties, such as payment processors, advertising partners, other users of our Services, and publicly available sources, as allowed by applicable law.
• If you give us personal information about someone else, you must do so only with that person's authorization. You should inform them how we collect, use, disclose, and retain their personal information according to our Privacy Policy.

1.7 Other Information We Collect

We may also collect other information about you, your devices, or your use of our Services with your consent (where required by law).

2. How We Use Your Information

2.1 Emergency Response

• To alert your designated monitors when you activate the alert button and the countdown expires
• To provide your real-time location to your designated monitors during route sharing and emergencies
• To broadcast live recordings to your designated monitors during emergencies
• To notify your designated monitors when you arrive safely at your destination or when you turn off an active alarm
• To maintain a record of emergency incidents for safety-related analysis and improvement

2.2 Route Monitoring

• To track and share your real-time location with your designated monitors during an active route
• To send notifications to your designated monitors when you begin sharing a route and when you arrive at your destination
• To provide route information including transit mode (transit, bike, walking, or car)

2.3 Service Operation

• To create and manage your account
• To process payments and subscriptions
• To provide customer support
• To send service-related notifications
• To improve and optimize the App and our other products, content, and services and websites
• To get your feedback on our ideas for products or features

2.4 Security

• To verify user identity and prevent fraud
• To prevent misuse of the App (such as false alarms)
• To prevent or address other service errors, security, or technical issues
• To investigate potential violations of our Terms and Conditions, this Privacy Policy or other contractual terms
• To comply with legal obligations and cooperate with law enforcement

Disclosure regarding Sensitive Personal Information: We only process sensitive personal information, such as precise geolocation, for one of the following purposes: (i) To perform the services reasonably expected by an average consumer who requests those services; (ii) To prevent, detect, and investigate security incidents that compromise the availability, authenticity, integrity, or confidentiality of stored or transmitted personal information; (iii) To resist malicious, deceptive, fraudulent, or illegal actions directed at the business and to prosecute those responsible for those actions; (iv) To perform services on behalf of the business; (v) To verify or maintain the quality or safety of a product, service, or device that is owned, manufactured, manufactured for, or controlled by the business, and to improve, upgrade, or enhance the service or device that is owned, manufactured by, manufactured for, or controlled by the business; (vi) To collect or process sensitive personal information where the collection or processing is not for the purpose of inferring characteristics about a consumer.

3. How We Share Your Information

3.1 Emergency Situations and Monitoring

When you activate an emergency alert or share a route, we may share your information with:

• Your designated monitors (such as family members, friends, or other contacts you select): real-time location, live broadcasts of recordings during emergencies, route progress, and arrival or alert notifications
• Law enforcement: When necessary for emergency response, investigation, or as required by law
• Emergency medical services: When dispatched, they may receive relevant medical and location information

By designating a monitor, you authorize us to share your personal information with that individual. You represent that you have notified each designated monitor that they will receive access to your personal information through the Services and that their use of the monitor dashboard is subject to this Privacy Policy and our Terms and Conditions.

3.2 Service Providers

We share information with third-party service providers who assist us in operating the App, including:

• Cloud storage providers (for storing recordings and emergency data)
• Analytics and performance monitoring services
• Payment processors (Apple and Google)
• Communication and notification services
• Customer support and troubleshoot service providers

These service providers are contractually obligated to protect your information and only use it for the purposes we specify.

3.3 Legal Requirements

We may disclose your information when required to:

• Comply with legal obligations, court orders, or government requests
• Enforce our Terms and Conditions or other agreements
• Protect the rights, property, or safety of our Company, users, or others
• Respond to claims or investigate potential violations of law

3.4 Business Transfers

If we are involved in a merger, acquisition, sale of assets, or bankruptcy, your information may be transferred as part of that transaction. We will notify you of any such change in ownership or control of your personal information as/if required under applicable law.

4. Data Retention

We retain your information for different periods depending on the type of data:

• Account information: Retained while your account is active and for a reasonable period afterward, as permitted under applicable laws.
• Emergency recordings (audio, video, and location): Retained for six (6) months from the date of the recording, after which they are automatically deleted unless subject to a legal hold, law enforcement request, or ongoing investigation
• Route monitoring data: Retained for thirty (30) days after the route is completed
• Usage data and analytics: Retained for up to two (2) years for service improvement purposes
• Payment records: Retained as required by law for tax and accounting purposes

We may retain certain information longer if required by law, to resolve disputes, enforce our agreements, or for legitimate business purposes.

5. Your Rights and Choices

5.1 Access and Update

You can access and update your account information at any time through the App settings. If you need assistance, contact us at siena@pulla.org.

5.2 Location Permissions

You can manage location permissions through your device settings. However, please note:

• Disabling location access will prevent the App from functioning properly during emergencies and route monitoring
• Background location access is essential for continuous tracking during active emergencies and shared routes
• The App requires "Always Allow" or "Allow While Using App" location permissions to function

5.3 Audio and Video Recording

Recording during emergencies is an automatic alert feature that activates when the 10-second countdown expires without cancellation. By using the emergency alert function, you consent to automatic recording. If you do not consent to recording, you should not use the emergency alert features of the App.

5.4 Account Deletion

You may request deletion of your account at any time by contacting us at siena@pulla.org. Upon deletion:

• Your account information will be removed from our active systems
• Emergency recordings and incident data may be retained for the remainder of the six (6) month retention period or as otherwise required by law
• Some information may be retained in backups for a limited period

5.5 Marketing Communications

You can opt out of marketing emails by following the unsubscribe instructions in those emails or by contacting us. Note that you will still receive service-related communications necessary for your use of the App.

5.6 State-Specific Rights

Depending on your state of residence, you may have additional rights regarding the processing of your personal information. A growing number of U.S. states have enacted comprehensive consumer privacy laws that impose requirements related to transparency, data minimization, consumer rights, and — where applicable — the processing of sensitive personal information.

Not all U.S. state privacy laws apply to our operations, and the specific rights available to you depend on your state of residence and the applicability thresholds of the relevant law.

States with Comprehensive Privacy Laws

As of the effective date of this Privacy Policy, the states that have specific data privacy or disclosure laws are as follows: California, Colorado, Connecticut, Delaware, Indiana, Iowa, Kentucky, Maryland, Minnesota, Montana, Nebraska, New Hampshire, New Jersey, Oregon, Rhode Island, Tennessee, Texas, Utah and Virginia. For a current guide of state-specific data privacy laws, you can review regularly updated materials available here: https://iapp.org/resources/article/us-state-privacy-legislation-tracker/ (for information purposes only). If you are a resident of any of these states, you may have additional privacy rights available to you that are not expressly outlined in this document. Because state privacy laws continue to evolve, this list is provided for general reference and may not reflect all recent changes.

Residents of the states listed above may be entitled to the rights to:

• Confirm whether we process your personal information.
• Access and delete certain personal information (i.e., you can ask us for a copy of the personal information we have collected, and you can ask us to delete certain personal information).
• Correct inaccuracies in their personal information, taking into account the information's nature and/or processing purpose (excluding Iowa and Utah).
• Be informed about third parties with which your personal information has been shared.
• Data portability (i.e., ask us to share (port) your personal information to another entity).
• Either limit (opt-out of) or require consent to process sensitive personal data.
• Opt-out of personal data processing for: (i) sales; (ii) targeted advertising (excluding Iowa); (iii) profiling in furtherance of decisions that produce legal or similarly significant effects (excluding Iowa and Utah).
• Request the review of decisions taken exclusively based on automated processing if these decisions could affect your rights under applicable data privacy laws.

However, these rights may be limited, for example if fulfilling your request would reveal personal information of another person, where they would infringe the rights of a third party (including our rights) or if you ask us to delete information which we are required by law to keep or have compelling legitimate interests in keeping. Also, some U.S. state laws may not apply to our operations. We will inform you of relevant grounds and exemptions we rely upon when responding to any request you make.

Exercising Your Rights

To exercise these rights, contact us at siena@pulla.org. We may need to verify your identity before processing your request.

To verify your identity, we may request that you provide the following information: Full Name, Email address, Postal address, Phone number, IP address, or Device identifier.

You may also designate an authorized agent to exercise your rights on your behalf. In such instance, we may request that the agent verify that they have the authority to submit requests on your behalf. We may do so by asking the agent to submit the following information: A valid power of attorney, the requester's valid government-issued ID, and the authorized agent's valid government ID.

Please note that we may not be able to process your request if your designated agent and/or you do not provide us with the above information.

We strive to respond to most requests within 30 to 45 days of receipt, although some responses may take longer, as allowed under applicable law. In certain cases, such as in connection with legal exceptions, we may deny a request, though we will provide reasons for such denial.

If, after having contacted us, you believe that your rights regarding your data have not been respected, you may file a claim with your relevant local authority.

6. Data Security

We strive to implement appropriate technical and organizational measures to protect your information, including:

• Encryption of data in transit and at rest
• Secure cloud storage with access controls
• Regular security assessments and updates
• Limited access to personal information on a need-to-know basis
• Secure authentication and authorization protocols

However, no method of transmission or storage is 100% secure. While we strive to protect your information, we cannot guarantee absolute security. You are responsible for maintaining the confidentiality of your account credentials and your 4-digit alert code.

7. Children's Privacy

The Services are intended for users who are at least 18 years old. We do not knowingly collect personal information from individuals under 18. If you are under 18, you are not permitted to use or register for the Services.

If we become aware that we have collected information from a person under 18, we will take steps to delete that information as quickly as possible. If you believe we have collected information from someone under 18, please contact us at siena@pulla.org.

8. International Data Transfers

The Services are hosted and provided in the United States. If you access the Services from outside the United States, you do so on your own initiative and agree that your information will be transferred to, stored, and processed in the United States. By using the Services, you consent to the transfer of your information to the United States and acknowledge that the United States may have different data protection laws than your country of residence.

9. Monitor-Specific Privacy Disclosure

If you are designated by a user as a monitor, you may receive access to that user's personal information, including real-time location, route details and progress, emergency alert status, arrival or alert notifications, and, during an active emergency, live audio and video broadcasts and related information made available through the Services.

Any information you receive as a monitor may be used solely for the purpose of assisting with the emergency response as instructed by the user.

• You may not record, copy, screenshot, photograph, download, stream, retransmit, rebroadcast, publicly display, publish, distribute, or otherwise share any live audio feed, live video feed, recording, image, or other content received through the Services, except as reasonably necessary to assist the user or as expressly permitted below.
• You may not disclose, provide, or communicate any information received through the Services to any third party, except to the user's legal guardian (if any), law enforcement, or emergency services, and only to the extent reasonably necessary to protect the user, respond to an emergency, or comply with applicable law.
• You may not use information received through the Services for any purpose unrelated to the user's alert or emergency response, including for entertainment, commercial purposes, harassment, surveillance unrelated to the route tracking or emergency, or any unlawful purpose.
• Except as required for an active emergency response or as required by applicable law, you must not retain, store, archive, or further disseminate information you receive as a monitor.

We may limit, suspend, or terminate your access as a designated monitor, and may preserve or disclose relevant information, if we believe you have misused information obtained through the Services, violated this Privacy Policy or applicable law, or created a risk to the user, the Company, or others.

10. Third Party Sites and Services

The Services may contain links to other websites or online services that are operated and maintained by third parties and that are neither under the control of nor maintained by us. In addition, when you are on our Services you may be directed to other services that are operated and controlled by third parties, some of whom may be users of our Services, that we do not control. Such links do not constitute an endorsement by us of those other websites, the content displayed therein, or the persons or entities associated therewith. This Privacy Policy does not apply to such linked third-party websites, communications and content.

Such third-party operators may collect information from you including your personal information, and may employ tracking technology and advertising technologies, particularly when content is served to you, and may share your personal information with others and/or us or our other users. Our inclusion of links to such websites or services does not imply any endorsement of the material on such websites or any association with their operators. We encourage you to review the privacy policies of these third-party websites or services and exercise caution in connection with them and before submitting any personal information to them.

11. Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our practices, technology, legal requirements, or other factors. We will notify you of any material changes by:

• Posting the updated Privacy Policy in the App
• Sending you a push notification or email
• Displaying a prominent notice in the App

Your continued use of the Services more than thirty (30) days after the effective date of the updated Privacy Policy constitutes your acceptance of the changes. If you do not agree to the updated Privacy Policy, you must stop using the Services before the effective date of such changes.

12. Contact Us

If you have questions, concerns, or requests regarding this Privacy Policy or our privacy practices, please contact us:

13. Consent and Acknowledgment

By using PUSH! by PULLA, you acknowledge that you have read and understood this Privacy Policy and consent to:

• The collection and use of your personal information as described herein
• Continuous location tracking during active emergencies and route sharing
• Automatic audio and video recording when the emergency countdown expires without cancellation
• The live broadcast of your location and recordings to your designated monitors during emergencies
• The storage and retention of emergency recordings for six (6) months
• The sharing of your emergency information with designated monitors, authorities, and emergency services

You further acknowledge that you have reviewed Section 1.4 regarding recording consent and state law compliance, and that you understand your responsibility to comply with recording laws in your jurisdiction.