Privacy Policy

REMEMBERY Privacy Policy

This Privacy Policy was last modified on May 6, 2024.

REMEMBERY protects and connects your loved ones, pets, and important items to make your life easier and less stressful. We take your privacy as seriously as you do, and we are committed to protecting it.  This Privacy Policy explains our practices regarding the collection, use, disclosure, transfer, storage, and protection of personal information that is collected through our products and services, as well as your choices regarding the same. 

As you review our policy, keep in mind that it applies to REMEMBERY, Inc.’s (“REMEMBERY“, “we“, “our“, or “us“) websites, mobile apps (REMEMBERY, Tile, and Jiobit), help center and other associated services we provide (“Services”).  It also applies to REMEMBERY physical devices (e.g., Tile trackers and partner products that have the Tile-finding technology embedded within them) as well as other products such as Labels (“Products”).  

Before accessing or using our Products and/or Services, please ensure that you have read this Policy and understand how we collect, store, use, and disclose your personal information as described herein.

Table of Contents

I. INFORMATION WE COLLECT

     A. Information You Give Us Directly

     B. Information We Collect when You Use or Interact with our Products and Services

     C. Information Provided to Us by Third Parties

II. HOW WE COLLECT INFORMATION

     A. Cookies and Similar Technologies

     B. Analytics and Advertising Technologies

III. HOW WE USE YOUR INFORMATION

     A. Administrative Purposes

     B. Marketing REMEMBERY Products and Services

     C. Research and Development

     D. Connecting with Social Media

     E. Information Collected Automatically Through the use of Tracking Technology

IV. INFORMATION WE DISCLOSE TO THIRD PARTIES

     A. Disclosing to Others in Your REMEMBERY Circles, or Friends

     B. Information Posted to our Blogs, Community Forums or Other Public Websites

     C. Service Providers, Business Partners and Advisors

     D. Purchasers and Other Third Parties in Connection with a Business Transaction

     E. Law Enforcement, Regulators and Other Parties for Legal Reasons

     F. De-Identified Information

V. YOUR CHOICES ABOUT YOUR INFORMATION

    A. Modifying, Correcting, Reviewing and Deleting Your Information

    B. Communications from REMEMBERY

    C. Location and Movement Data Collection and Sharing in the REMEMBERY App

    D. Web-Based Personal Information Sales

VI. OUR POLICY TOWARDS CHILDREN

    A. Setting up a Child Account

    B. Personal Information we Collect about Children

    C. Information sharing about Children

    D. Contact Us Regarding your Child’s Account or Information

VII. HOW WE PROTECT YOUR INFORMATION

    A. Security

    B. Accuracy and Confidentiality of Your Email Address and Password

    C. Jiobit Device Security

    D. Fraud Prevention

    E. Onward Transfer

    F. Data Retention

VIII. ADDITIONAL STATE, COUNTRY AND REGION-SPECIFIC PRIVACY TERMS

    A. California Consumer Privacy Act (CCPA) and California Consumer Rights Act (CPRA)

    B. Legal Basis for Processing

    C. California’s “Shine the Light” Law

    D. Your Nevada Privacy Rights

    E. Australian Members

    F. International Transfer

    G. Data Privacy Framework

IX. LINKS TO OTHER WEB SITES AND SERVICES

X. CHANGES TO THIS PRIVACY POLICY

XI. CONTACT US IF YOU HAVE QUESTIONS OR CONCERNS

    A. Authorized Agents

    B. Right to Contact a Data Protection Authority

XII. PREVIOUS POLICY

I. INFORMATION WE COLLECT

The information REMEMBERY collects depends on what REMEMBERY Products or Services you use and how you use them.  

Note that failure to provide necessary information when requested may result in you not being able to fully utilize our Products and/or Services.

A. Information You Give Us Directly

When you create or modify a REMEMBERY, Tile, or Jiobit account, update your preferences, purchase and/or activate a Product, contact us (including by social media or via our Help Center), participate in an online survey, or otherwise interact with REMEMBERY’s Products and Services, we may collect a variety of information, including:

• Account Information. Your username, email address, real name, nicknames, date of birth, telephone number, password, shipping and billing addresses, and Products activated. You may also choose to provide a photo to associate with your REMEMBERY account, Tile, or Jiobit Products.
• Circle Information. When you create a Circle in your REMEMBERY app and invite a friend or family member to join your Circle, we collect their name, email address, mobile phone number, and photo if one is provided.
• Identity Verification. In certain circumstances, for instance, depending on the features of our Products and Services you use or based on your age and country of residence, we may collect additional information to verify that a parent or guardian has consented to use of the Services by a child. This information may include information from or an image of government-issued ID, an image (for example, a selfie) which may be used with facial recognition technology. (Note: the digital age of consent may vary by jurisdiction and REMEMBERY may adjust our parental consent process accordingly.) For more information, please click here.
• Payment and Transaction Information. When you place an order for a Product or upgrade to a premium subscription, you’ll need to provide an email address, a first and last name and/or a shipping address. Any payment information provided is processed by the relevant billing and/or payment processor. We may also collect information such as which version of the Product or subscription service you are using, the date and time that you activated your account, the duration of your subscription, the data related to any subscription cancellation request, and any in-app purchases you may make.
• Optional Account Information. We may collect information when you customize features within our Products (for example, labeling locations on your in-app map within REMEMBERY, using “Smart Alert” for a Tile device, or providing emergency information about the wearer of a Jiobit device, such as their, height, weight, gender, ethnicity, race, medications, allergies, and medical conditions including whether the individual is special needs and the category of such special needs, or pet breed in the case of an animal).
• Contest Prize and Tax Information. If you are the recipient of a contest or sweepstakes prize that requires tax reporting, we may collect identifiers associated with your government-issued documents (such as a social security number).
• Other Information You Provide to Us. Information you provide in response to surveys about our Products or Services, any information about your friends that you provide us through our referral services, information you provide when seeking help from us, such as your name, email address, telephone number, mailing address and records (including call recordings) and technical information related to the issues you experience.

B. Information We Collect When You Use or Interact with our Products and Services

We may collect other information when you use our Products and Services, such as:

• Device Information. Information about your device, hardware and software information, such as your mobile device identifiers, IP address, or browser information (including browser type and language preference).
• Location and Movement Information. We collect your location and motion information through your IP address, WiFi, Bluetooth, and GPS coordinates (e.g., latitude/longitude) available through your mobile device, motion information such as altitude, heading and speed.
• Driving Event Information. We may collect sensory and motion data from your mobile device, including gyroscope, accelerometer, compass, and Bluetooth (including information related to your motion activity, such as whether you are cycling, walking, running, or driving, and information about your speed, acceleration, and deceleration).
• Messages and Member Content. We collect information when you message other members of your Circle through use of our Services, when you provide REMEMBERY with feedback, when you make a blog post, comment, or when you tag REMEMBERY, Tile, or Jiobit in a social media post, any photos or videos you send via the in-app messaging to other members of your Circles.

C. Information Provided to Us by Third Parties

We may receive information about you from other sources, including through third-party services that you connect to your REMEMBERY account, or third-party services and organizations to supplement information provided by you. For example:

• When you link your Tile account to a smart partner platform to enable interaction with our Products and Services through voice or other smart platform interactions or services (e.g. Google Assistant-enabled or Alexa-enabled devices), we may collect location information for all Tiles scanned by the smart partner device for members who have linked their account to the applicable platform.
• When you choose to connect or interact with our Services through a third-party social networking service (“Social Network”), such as when you Like us on Facebook or post a comment to our Facebook page, we may collect information that you have already made public on your Social Network account.
• We may use social plugins, widgets and other features (each, a “Social Feature”) that are made available by and/or access third-party Social Networks. These Social Features allow these Social Networks to place cookies on your browser and to collect certain information, which may be associated with your personal Social Network account such as your name, your Social Network user identification number, your Social Network username, location, gender, birth date, email, profile picture, and your contacts on the Social Network. 

II. HOW WE COLLECT INFORMATION

When you visit our websites, use our apps, read our emails or otherwise engage with us, we may automatically collect certain information about your device through a variety of technologies, including cookies, web beacons, log files, embedded scripts, location-identifying technologies, or other tracking/recording tools (collectively, “Tracking Technologies”), and we may combine this information with other personal information we collect about you. We use these Tracking Technologies to collect usage and device information, such as:

• Information about the computer, tablet, smartphone or other device you use, for example, your device’s IP address, browser type, Internet service provider, platform type, device type/model/manufacturer, operating system, phone number, mobile carrier, date and time stamp, a unique ID that allows us to uniquely identify your browser, mobile device or your account (including, for example, a UDID, IDFA, Google Ad ID, Windows Advertising ID or other persistent device identifier or Ad ID), battery life, whether the device is connected to WiFi, and other such information. With your permission, we may also access your photo or camera roll.

We also use Analytics, Advertising, and Anti-Fraud technologies in our Products and Services. These technologies may utilize the same Tracking Technologies or similar mechanisms as further described below.

A. Cookies and Similar Technologies

Cookies are pieces of code that allow for personalization of our website experience by saving your information such as user ID and other preferences – if your browser is set to accept cookies. A cookie is a small data file that we transfer to your device’s hard disk (such as your computer or smartphone) for record-keeping purposes. 

Web beacons (also known as web bugs, pixel tags or clear GIFs) are tiny graphics with a unique identifier that may be included on our Services for several purposes, including to deliver or communicate with cookies, to track and measure the performance of our Services, to monitor how many visitors view our Services, and to monitor the effectiveness of our advertising. Unlike cookies, which are stored on the member’s device, web beacons are typically embedded invisibly on web pages (or in an e-mail).

For more information about the Cookies we use and how to manage their setting please click on “Do Not Sell or Share My Personal Information” at the bottom of any of our web pages.

B. Analytics and Advertising Technologies

We may collect analytics data, or use third-party analytics tools such as Google Analytics, which may use Tracking Technologies, to help us measure traffic and usage trends for our websites, Products and Services. Some of the types of data that analytics technologies may capture are as follows:

• referral/exit pages; 
• how frequently you access our Services; 
• whether you open emails or click the links contained in emails; 
• whether you access our Services from multiple devices; 
• the features you use; 
• the links you click; 
• the ads you view and click on; 
• purchase transaction information; 
• your location when you access or interact with our Products and Services; 
• technical related information about your computer or device and operating and/or network systems (such as IP Address and device ID);
• performance data (such as app launch time, hang rate, or energy usage);
• information about your engagement with certain features and usage statistics (including app launch taps and interaction information like video views); and 
• other similar actions.

In addition to the above, we may collect and share your personal information, including your unique identifiers or Advertising IDs and other data such as app events, with our Service Providers and Business Partners, third-party ad networks, and Social Networks, including without limitation, to inform and improve tailored advertising, attribution, analytics or research purposes. 

These advertising partners may collect and use additional information such as:

• click stream information; timestamp; hashed email address; device ID or AdID; and
• information related to your use of third-party applications;

and may combine this information with information they collect directly through Tracking Technologies or that they receive from other third parties. These third-party partners may use the information they have gathered independently according to their own privacy policies.

You have the right to object to and opt out of certain third-party tracking and advertising. Where you have consented to REMEMBERY’s processing of your information, you may withdraw that consent at any time and opt out of certain processing activities, such as targeted marketing communications (this may not include opting out of seeing in-app advertisements). Even if you opt out, we may still collect and use information regarding your activities on our websites and/or information from the advertisements on third-party websites for non-interest-based advertising purposes, such as to determine the effectiveness of the advertisements. For more information on how to adjust your third-party tracking and advertising settings please see the following informational pages:

• Opt-out of REMEMBERY sharing data with third-parties for advertising purposes on our websites; 
• Limit information sharing with third-party partners through in-App privacy settings;
• Interest-based advertising via a Web Browser; 
• Mobile advertising; and 
• Google Analytics and advertising.

III. HOW WE USE YOUR INFORMATION

We may use your information to provide, maintain, and improve our Products and Services to develop new products and features, to determine which new products or services may be of interest to you and to promote our Products and Services, and we may disclose your information to our Service Providers and Business Partners for these purposes.

We may also de-identify, anonymize, or aggregate the information we collect, or collect it in a way that does not directly identify you. We may use and share such information for our business purposes and as permitted by applicable law.

The specific purposes for our acquisition, retention, use, and processing of your information are described in this Section III (How We Use Your Information). 

A. Administrative Purposes

We may use information about you for our administrative purposes, including to:

• Provide the Products and Service to you;
• Measure interest in REMEMBERY’s Products and Services; 
• Develop new products and Services; 
• Ensure the integrity, security and perform internal quality control and optimization of our Products and Service; 
• Verify individual identity; 
• Communicate about individual accounts and activities utilizing REMEMBERY’s Products, Services, and systems;
• Make changes to any REMEMBERY policies; 
• Send messages to the email address you provide to us to verify your Account; 
• For informational, transactional, marketing and operational purposes, such as Account management, customer service, or system maintenance; 
• To process payment for products or services purchased; 
• To process applications and transactions; 
• To prevent potentially prohibited or illegal activities; and 
• To enforce our Terms of Use and this Privacy Policy.

B. Marketing REMEMBERY Products and Services

REMEMBERY may use information, and Individuals who provide us with personal information may receive periodic emails, newsletters, mailings, or phone calls from us, as allowed by applicable law, for marketing purposes such as to:

• Provide you with information related to REMEMBERY’s or our business partners’ products and services that may be of interest to you;
• Notify you of upcoming special offers/events we believe may be of interest;
• Conduct online behavioral advertising;
• Tailor content, advertisements, and offers that may be of interest to you; 
• Introduce new content, features, Products or Services.; and 
• For other purposes disclosed at the time that you provide us your information; or otherwise with your consent. 

C. Research and Development

We may use information to create non-directly identifiable information that we may use alone or in the aggregate with information obtained from other sources as set forth herein, in order to:

• Conduct individual or market research;
• Conduct research and drive marketing analytics;
• Help us to optimally deliver our existing Products and Services;
• To develop new Products and Services; and
• For research and internal analysis.

For instance, from time to time, REMEMBERY may perform research (online and offline) via surveys. We may engage third-party service providers to conduct such surveys on our behalf (all survey responses are voluntary). The survey responses may be utilized to:

• Determine the effectiveness of our Products and Services, 
• Perform various types of communications, advertising campaigns, and/or promotional activities; and
• Learn more about our members and potential members and their individual and collective needs.

If an individual participates in a survey, the information given may be used along with that of other study participants. We may share anonymous individual and aggregate data for research and analytics purposes.

D. Connecting with Social Media 

When you choose to connect or interact with our Services through a Social Network, or if you use Social Features, the information provided to REMEMBERY via those Social Networks or Social Features may be used to verify information that you have independently provided to REMEMBERY and to enhance our ability to provide you with information about our business, products, and Services.

These Social Features are operated solely by the respective Social Networks, and their service providers, and we recommend that you carefully read their privacy policies before you decide to use them. We have no control over or access to the information collected, stored or used by such Social Networks, and the information practices of such Social Networks are not covered by this Privacy Policy.

E. Information Collected Automatically Through the use of Tracking Technology

We use information collected through the use of Tracking Technologies (e.g., cookies and web beacons) for our business purposes, or similar, including to: 

• Remember information so that you will not have to re-enter it during your visit or the next time you visit our website or use our Services; 
• Authenticate your access;
• Keep track of your in-app specified preferences or choices;
• Display a personalized browsing history
• Provide custom, personalized content and information, including targeted content and advertising;
• Record your device’s location and movements; 
• Identify and contact you across multiple devices; 
• Provide and monitor the effectiveness of our Services and our marketing campaigns; 
• Monitor aggregate metrics such as total number of visitors, members, traffic, and demographic patterns; 
• Provide specific technical support (diagnose or fix technology problems reported by our members or engineers that are associated with certain IP addresses or User IDs;
• Detect or prevent fraud or other harmful activities; 
• Automatically update our mobile application on your system and related devices; and 
• Otherwise plan for and enhance our Services.

IV. INFORMATION WE DISCLOSE TO THIRD PARTIES

We may disclose your information to select third parties as well as our subsidiaries as set forth herein.

We may also disclose this information within REMEMBERY, with our subsidiaries, and with third parties for our or their purposes in an anonymized or aggregated form.

A. Disclosing to Others in Your REMEMBERY Circles, or Friends

You may choose to disclose your personal information to other members of your REMEMBERY Circles (Tiles may be shared with third parties who are not a member of your Circles upon your request, via the in-App “Unlimited Sharing” setting, which may be modified by you at any time), including your:

• Full name; 
• Email address; 
• precise location; 
• driving event data;  
• information about your use of our Service with members of your Circles (e.g., whether you have logged in on a new device); and
• Tiles.

In addition, other members of your Circles may disclose your personal information in certain circumstances, such as:

• if a member of your Circle enables voice actions on Google Assistant-enabled or Alexa-enabled devices, your personal information (including name, Tile name, and last place seen for each Tile) may be displayed to your Circle members on screen or via audio response on any device with the voice action enabled.

To prohibit this data disclosure, you must ask your Circle member to disconnect his or her account from the voice action-enabled devices, or you can leave the Circle shared with that member.

B. Information Posted to our Blogs, Community Forums or Other Public Websites

Any information or content that you voluntarily submit, or post to the REMEMBERY or Tile websites or blogs, community forums, or comments you post to our Facebook page (or other social media pages) will automatically be available to the public. We may publicly post your reviews and comments online on our website or mobile app or link your reviews to third-party websites.

We are not responsible for any information you choose to provide on social media pages, or for any content or communications you receive as a result of sharing such information.

C. Service Providers, Business Partners, and Advisors

We may disclose your personal information to our vendors and consultants who help us provide our Services or who perform services on our behalf, such as accounting, managerial, technical, email or chat services, marketing or analytic services, fraud prevention, bot detection, web hosting, and to other third-party partners or Service Providers to provide services or features to our members on our behalf or on behalf of our permitted business partners. 

We may disclose personal information, including contact information and location and movement data, mobile device information (such as information generated by the gyroscope and accelerometer in your device), application analytics (including IP address and device identifiers), technical and analytical data, and driving event data with third-party partners that provide certain features and services you elect to use through or in connection with our Products or Service, to the extent that they are available in your country or region of residence. Some examples are as follows:

• Crash Detection and Emergency Dispatch Services;
• Roadside assistance;
• Identity theft protection; and
• Driving analytics services.

If you would like more detailed information about the information we have, shared, sold, or disclosed, please refer to our Service Provider and Third-Party Processing Chart which provides more information about the entities to whom we may disclose your information. This list includes the following information: (i) the name of the third-party service provider or business partner, (ii) the name of the privacy officer, contact information and a link to the third party’s privacy policy, (iii) the purpose of the disclosure and how the information may be used by such entity, (ii) the categories or specific items of information disclosed, (iii) the country to which the information will be transferred or stored, (iv) the timing and method of transfer of information, (v) the legal basis for such sharing, and (v) the amount of time the information maywill be retained by such third parties.

We will never disclose your telephone number (in a non-obfuscated format) with any of our third-party business partners, vendors, or consultants for their independent SMS marketing purposes without your explicit, affirmative opt-in consent.

D. Purchasers and Other Third Parties in Connection with a Business Transaction

We may at any time buy or sell/divest the company, or any portion or combination of its products, services, assets and/or businesses. Personal information such as member names and email addresses, and other member information related to our Services will likely be one of the items transferred in these types of transactions. We may disclose, transfer or assign such information in the course of corporate divestitures, mergers, acquisitions, bankruptcies, dissolutions, or similar transactions or proceedings.

E. Law Enforcement, Regulators, and Other Parties for Legal Reasons

We may disclose personal information to third parties (including but not limited to, law enforcement, other government entities, or civil litigants) when required to do so by law or subpoena, or if we determine (in our sole discretion) that disclosure is necessary to: (a) conform to the law, comply with legal process, or investigate, prevent, or take action regarding suspected or actual illegal activities; (b) to enforce our Terms of Service, this Privacy Policy, to take precautions against liability, to investigate and defend ourselves against any claims or allegations, or to protect the security or integrity of our site; and/or (c) to exercise or protect the rights, property, or personal safety of REMEMBERY, our employees, members or others.

F. De-Identified Information 

Some third parties provide important services to us as our service providers and have rights to commercialize solely aggregated data for certain purposes, as set forth in our Service Provider and Third-Party Processing Chart. We may share with third parties, including advertisers, Business Partners, and Service Providers, anonymized, aggregated and/or anonymous data we collect about you and other members, such as de-identified demographic information, de-identified location information, and information about the computer or device from which you access our Services, or the results of hashing your email address.

V. YOUR CHOICES ABOUT YOUR INFORMATION

We believe in transparency and providing you with the opportunity to make important decisions about how your information is used, processed, stored and shared as outlined in this Section V (Your Choices about Your Information).

A. Modifying, Correcting, Reviewing, and Deleting Your Information

You may modify your account information, update or amend your personal information (e.g. name, email address, or phone number), or change your password by logging in to your App, clicking on “Settings” and then “Account” (for REMEMBERY) or “Manage Account” (for Tile or Jiobit Apps). 

You may review the information we collect or disclose about you, the categories of sources of such information, the business or commercial purpose for collecting your information, and the categories of third parties with whom we disclose personal information, or request that your information be deleted by submitting a request as described below. Please note that the information provided via the in-App links described in this section does not include technical information or support records. If you would like to request information related to your support records, please contact us directly at info@remembery.com.

In the REMEMBERY app, you may:

• Exercise your right to Opt In or Opt Out of App-based personal information sales or sharing by clicking on the “Do Not Sell or Share My Personal Information” link in your in-App Privacy & Security settings and adjusting the personal information sales toggle. 
• Request a copy or deletion of your personal information under the “Additional Data Rights” page, then, select “Request Your Personal Information” or “Delete Your Account” to submit your request. We will process your request and send a confirmation email. 

In the Tile and Jiobit apps, you may:

• Request deletion of your personal information through the Tile app by clicking on “Settings”, then “Manage Account”, and finally by clicking on “Delete Account” and following the on-screen instructions.
• Request deletion of your personal information through the Jiobit app by clicking on “Menu”, then “Account”, then “Manage Account, and finally by clicking on “Delete My Data” and following the on-screen instructions.
• To exercise your other rights related to the Tile or Jiobit Products and Services please contact us as further described below with your detailed request. 

You may also request the closure and deletion of your account by contacting us at info@remembery.com with your deletion request. Please include your full name, email address associated with your Account, the service you are using, and a detailed description of your deletion request. 

Note: prior to deletion of your Tile account, you may transfer your Tiles to another Tile customer by following the instructions found in our support pages covering the Transfer of a Tile. Tiles may only be transferred from or to active accounts.

For Tile customers: If you delete your account or other personal information, the location information associated with active Tile Products may still be collected anonymously from other Tile Community members who are running the app and are within Bluetooth range of your device. To completely disable this type of information collection we recommend you transfer the Tiles prior to account or data deletion, remove the battery from or disable your Products.

B. Communications from REMEMBERY

We may periodically send you promotional newsletters and emails. You have the ability to opt-out of these by following the unsubscribe instructions provided in the emails you receive. Certain communications, like billing information and Service updates are necessary for you to receive, you will not be able to opt-out of those communications. For more information about the types of communications REMEMBERY may send, and for detailed instructions on how to opt-out please see the following:

• Email and Telephone Communications;
• Mobile Devices and In-App Messaging; and
• “Do Not Track”, Cookies and Web Beacons.

C. Location and Movement Data Collection and Sharing in the REMEMBERY App

As described in Section 2, we collect precise location data, driving event, and movement data from your device to provide the REMEMBERY Services, and may share your personal information, including location and movement data, with other REMEMBERY members in Circles you belong to, and with third parties for crash detection, research, analytics, attribution, and tailored advertising purposes. You have many options to control this data collection and sharing activity through the App Settings. For more information on how to control these settings please see the following:

• Limit Location Sharing with Your Circle(s); 
• Limit Drive Detection; and
• Disconnect Location Data and Movement Data in Device Settings. 

If you no longer want to continue using the Products and/or Services, uninstalling the REMEMBERY, Tile, or Jiobit app (as applicable), removing the battery from or disabling the Products, and logging out from our Service will also stop us from collecting your location.

D. Web-Based Personal Information Sales

You may also exercise your Opt-In and Opt-Out rights related to web-based personal information sales or sharing via all of our websites, please click the “Do Not Sell or Share My Personal Information” link in the footer of the website and adjust the toggles as applicable.

Please note these settings must be completed for each browser on each device you use and for our website (re-membery.com) separately, and will not affect App-based settings. If you clear your cookies or your browser is set to do so, you will have to exercise the choice again.

VI. OUR POLICY TOWARDS CHILDREN

REMEMBERY takes special precautions to protect the privacy of our younger members. REMEMBERY does not knowingly collect personal information from children who do not meet applicable minimum age requirements without verifiable consent of a parent or guardian, and our Services are only intended to be used by children with significant parental or guardian involvement and approval.  

If REMEMBERY learns that we have inadvertently collected personal information of a child without parental consent as required by law, we will take appropriate steps to delete this information. If you are a parent or guardian and discover that your child has a registered account with our Services or is using our Products without your consent, please alert us immediately by emailing info@remembery.com.

By enabling your child to create a member account and/or permitting your child to use the Products or Services, you expressly agree to the practices described in this Privacy Policy and you consent to the collection, use, and disclosure of your child’s personal information as described herein.

A. Setting up a Child Account

If a parent wishes to add a member who is a child to our Services, we request the parent provide verifiable consent, through one of several methods, such as by verifying the parent’s driver’s license during sign up, or by submitting a parental consent form (available here) via mail or email. The child will then be able to participate in most aspects of the REMEMBERY Services. In some instances, our Products are intended to be worn and used by children and pets. By providing the Products to a child, you represent and warrant to REMEMBERY that you consent to such child’s use of our Products and Services and further consent as a parent to enable and permit REMEMBERY’s collection and use of the information from the Products and Services used by the child as stated in this Privacy Policy and the Terms of Service. 

B. Personal Information we Collect about Children

We take special precautions to collect only as much information as is reasonably necessary for the child to use our Products and Services.

C. Information sharing about Children

REMEMBERY may disclose a child’s personal information to our third-party vendors, Service Providers, and business partners as described in this Privacy Policy. We do not share or sell personal information of members we know to be children. Profile and location information for children using the Service may be shared with other members of any Circle the child joins. Please note the child may exchange messages with those Circle members. You are responsible for monitoring your child’s account and location-sharing activity through our Products and Services and for blocking or permitting location-sharing features.

D. Contact Us Regarding your Child’s Account or Information

The parent or legal guardian has a right to request to review or have deleted the child’s personal information and may withdraw consent for our Products and Services to collect any further personal information from the child. Please contact us at info@remembery.com to request to review and/or delete any personal information we may have collected from the child, or to withdraw permission for REMEMBERY to collect any additional information from the child. We will require the parent or guardian to provide us with sufficient identification before providing access to, or acting upon, such personal information.  

VII. HOW WE PROTECT YOUR INFORMATION

REMEMBERY cares about the security of your information. The actions we take to protect your personal information are described below.

A. Security 

We have implemented appropriate standards to reduce the risk of unauthorized or unlawful access of your personal information. No security system is impenetrable and we cannot absolutely guarantee the security of our systems and your information. 

We will never send you unsolicited messages or contact you by phone to request sensitive information, such as your account ID, password, payment, or national ID numbers. Please note that e-mails and other communications you send to us are not encrypted, and we strongly advise you not to share any sensitive information through these means. 

If any information under our control is compromised as a result of a breach of security, we will take reasonable steps to investigate the situation and where appropriate, notify any impacted individuals and take steps in accordance with any applicable laws and regulations.

B. Accuracy and Confidentiality of Your Email Address and Password

You are responsible for the secrecy of your password and ensuring the email address associated with your account(s) is accurate. We use your email address to contact you about service updates, changes to our policies, and account activities such as requests for your information. We recommend using a strong password unique to this service. If you believe your account has been compromised, change your password immediately via the applicable app or website. 

REMEMBERY is not responsible for information or data transmitted to a third party as a result of a member providing an incorrect phone number or email address.

C. Jiobit Device Security

Jiobit devices use unique hardware to deliver unmatched security and encryption. Our devices include a dedicated security chip required to communicate with our secure servers and are intrusion resistant. Unlike most other connected devices, it cannot be reprogrammed – part of the circuit board is physically burned away during manufacturing. Jiobit location data is encrypted at rest and while in transit. 

D. Fraud Prevention

To prevent the misuse of our Services by bots or other nefarious means, we use anti-bot services to ensure the integrity of our service, for more information click here.

E. Onward Transfer 

With respect to onward transfers to third-party agents acting on our behalf, REMEMBERY remains responsible should its agents process information in a manner inconsistent with the Data Privacy Framework Principles or other applicable laws. We may be required to disclose personal data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements. 

F. Data Retention

REMEMBERY retains the information we receive as described in this Privacy Policy for as long as you use our Products or Services or as otherwise necessary to fulfill the purpose(s) for which it was collected, to resolve disputes, establish legal defenses, conduct audits, pursue legitimate business interests, enforce our agreements, and to comply with applicable laws. The purposes for which we process information may dictate different retention periods for the same types of information. 

VIII. ADDITIONAL STATE, COUNTRY, AND REGION-SPECIFIC PRIVACY TERMS

A. California Consumer Privacy Act (CCPA) and California Consumer Rights Act (CPRA)

California residents can make certain requests about their personal information under the CCPA. Specifically, if you are a California resident, you have the right to request any or all of the following information relating to your personal information we have collected and used in the last 12 months, upon verification of your identity:

• provide you with the specific pieces of personal information we have collected about you and information about: the categories of personal information we have collected about you; the categories of sources of the personal information; the categories of personal information that we have disclosed to third parties for a business purpose, and the categories of recipients to whom this information was disclosed; the categories of personal information we have sold or shared and the categories of third parties to whom the information was sold or shared; and the business or commercial purpose for collecting or selling/sharing the personal information.

You also have the following rights with regards to your personal information as further described in our Notice of Collection:

• the right to opt-out of personal information sales and shares for cross-context behavioral advertising; 
• the right to limit our use of your sensitive personal information;
• the right to correct inaccurate personal information about you;
• the right to delete certain information we have about you;
• the right for us to provide you with information about the financial incentives that we offer to you, if any; and
• the right to not receive discriminatory treatment for exercising these rights.

Certain information may be exempt from such requests under applicable law. For example, we may retain certain information for legal compliance and to secure our Services. We may need certain information in order to provide our Services to you; if you ask us to delete it, you will no longer be able to use our Services.

Categories of Personal Information Collected

Depending on your use of our Services, the following categories of personal information may have been collected in the preceding 12 months (as these processing activities are defined under applicable privacy laws, such as the California Consumer Privacy Act “CCPA” and the California Privacy Rights Act “CPRA”):

• Identifiers; such as a real name, user name, account name, account information, ID verification information, telephone number, email address, online identifiers, device identifiers, IP address, mobile device identifiers, shipping address;
• Purchase information; such as payment card number, payment account details, billing address, and other payment information;
• Characteristics of Protected Classifications under state or federal law; such as age, gender, ethnicity, and race;
• Commercial Information; such as products or services interaction, motion, and fitness information, and purchase history;
• Internet or Electronic Network Activity information; such as browsing history, search history, and information regarding interactions with our Products and Services, websites, mobile apps, and/or advertisements;
• Geolocation Information; such as location data derived from IP address or device settings;
• Inferences; such as consumer preferences drawn from the above.

California Consumer Information Sold or Shared in the Last 12-Months

In the previous 12 months, if you were a REMEMBERY member (excluding information related to our Tile and Jiobit Products) we have sold or shared the following categories of personal information to third-party partners and advertising partners for targeted marketing, attribution, analytics, and research purposes (subject to your settings and opt-outs): Identifiers, Internet/Network information, Geolocation, Inferences, and Other personal information, including driving event and movement data. These third-party businesses may use such information for their own purposes in accordance with their own privacy statements, which may include reselling this information to additional third parties, including other advertising networks.

Other Ways to Exercise Your California Rights

Alternatively, you may submit a request to exercise your California privacy rights via email by contacting us at info@remembery.com and including your account name and mobile telephone number as well as the consumer right you would like to exercise. To protect your privacy and security, we take reasonable steps such as verifying your email address and specific information to verify your identity and request. For faster response times, we recommend members submit all requests through the in-App Privacy & Security Settings.

B. Legal Basis for Processing

Our legal basis for processing your personal information varies depending on the type of information we collect and the context in which we collect it as well as our records of your country of residence. Depending on where you reside, we may rely on different legal bases to process your information.

If you are a resident of the European Economic Area or of a jurisdiction where similar legal requirements may apply such as Brazil, Switzerland, and the United Kingdom, we rely on a number of legal bases to process information about you. We will process information about you where we have your consent, where we have a legitimate interest to do so, where the processing is necessary for the performance of a contract with you, and/or where we have a legal obligation to process your information. For example, we typically rely on:

• necessity to meet an actual contractual obligation when you create a REMEMBERY, Tile, or Jiobit account to enable us to provide you with our Products and Services.
• consent when placing cookies on your device on the web (through our cookie consent manager), to send you email marketing, or to deliverthird-partyy targeted advertising to you related to our Products and Services;
• our legitimate interests to process your information when providing you with customer service support, to serve targeted marketing of our Products and Services, for fraud prevention and security purposes; 
• to fulfill our contractual obligations; and
• necessary for compliance with a legal obligation to which we are subject.

C. California’s “Shine the Light” Law 

California’s “Shine the Light” law (Civil Code Section § 1798.83) provides certain rights to California residents that have an established business relationship with us with regard to the disclosure of certain types of personal information to third parties for their direct marketing purposes. To opt-out of having your personal information disclosed to third parties for their direct marketing purposes, please click the “Do Not Sell My Personal Information” link available in the in-App Privacy & Security Settings and adjust the Personal Information Sales toggle.

D. Your Nevada Privacy Rights

Chapter 603A of the Nevada Revised Statutes permits a Nevada resident to opt-out of future sales of certain covered information that a website operator has collected or will collect about the resident. To exercise your Nevada opt-out rights: you may click on the “Do Not Sell My Personal Information” link in your in-App Privacy & Security Settings and adjust the Personal Information Sales toggle. Alternately, you may send an email to info@remembery.com with the subject line “Nevada Privacy Rights” and include your account name and mobile telephone number. We may need to contact you to request additional information to verify your request. For faster response times, we recommend members submit all requests through the in-App Privacy & Security Settings.

E. Australian Members

Use and Disclosure of Personal Information

In Australia, we will only use and disclose your personal information for the purposes of marketing REMEMBERY Products and Services or the services of third-party organizations where you have consented to us doing so, or as otherwise permitted by law.

Security Liability for Australian Members 

Except to the extent liability cannot be excluded due to the operation of statute, we exclude all liability (including in negligence) for the consequences of any unauthorized access to, disclosure of, misuse of, or loss or corruption of your personal information. Nothing in this Privacy Policy restricts, excludes or modifies, or purports to restrict, exclude or modify any statutory consumer rights under any applicable law including the Competition and Consumer Act 2010 (Cth).

F. International Transfer

You agree that all information collected via or by REMEMBERY may be transferred, processed, and stored anywhere in the world, including but not limited to, the United States, the United Kingdom, the European Union, in the cloud, on our servers, on the servers of our affiliates or the servers of our service providers. Your information may be accessible to law enforcement or other authorities pursuant to a lawful request. By providing information to REMEMBERY, you explicitly consent to the storage of your information in these locations, this may mean that your personal information will be stored in a jurisdiction that offers a level of protection that may, in certain instances, be less protective of your personal information than the jurisdiction you are typically resident in. We will implement appropriate safeguards to ensure that your personal information is treated securely and in accordance with this privacy policy, including: (i) ensuring that we use your personal information in accordance with standard data protection clauses adopted by the European Commission for transfers of personal data to recipients outside the EEA and UK; and (ii) ensuring that any recipients of your personal information commit to the same standards. If you wish to enquire further about the safeguards used, please contact us using the details set out at the end of this privacy notice.

Except in some cases where we may rely on an exception under the Australian Privacy Act 1988 (Cth), we will take reasonable steps to ensure that such overseas recipients do not breach the Australian Privacy Principles in the Privacy Act 1988 (Cth) in relation to such information.

G. Data Privacy Framework

REMEMBERY complies with the requirements of the EU-U.S. Data Privacy Framework (“EU-U.S. DPF”) and the UK Extension to the EU-U.S. DPF and the Swiss-U.S. Data Privacy Framework (“Swiss-U.S. DPF”) (collectively “DPF”), as set forth by the U.S. Department of Commerce and the Federal Trade Commission (“FTC”), regarding the collection, use, and retention of personal information transferred from the European Economic Area (“EEA”) and the United Kingdom (“UK”) and Switzerland to the United States. We have certified to the Department of Commerce that we adhere to the DPF Principles and Supplemental Principles with respect to personal information transferred to us in reliance on the DPF. To the extent that the DPF applies to your information, if there is any conflict between the terms in this Privacy Policy and the DPF Principles, the DPF Principles shall govern. We are subject to the investigatory powers of the FTC with respect to our DPF compliance. To learn more about the DPF program, and to view REMEMBERY or Tile’s certifications, please visit https://www.dataprivacyframework.gov/s/. REMEMBERY may also protect information through other legally valid methods, including international data transfer agreements.

If you are an EEA or UK or Swiss citizen you may be able to exercise certain choices under the DPF regarding how some of your personal data is used and disclosed, and may access, correct or delete certain personal data by following the instructions in Section V of this Privacy Policy.

When we receive personal information under the DPF and then transfer it to a third-party service provider acting as our agent on our behalf, we may have certain responsibility under the DPF if both (a) the agent processes the information in a manner inconsistent with the DPF and (b) we are responsible for the event giving rise to the damage. 

If you are an EEA or UK or Swiss citizen and feel that REMEMBERY is not abiding by the terms of this Privacy Policy, or is not in compliance with the DPF Principles, please contact REMEMBERY at the contact information provided below.

If we are unable to resolve your concerns, REMEMBERY has agreed, in compliance with DPF, to refer unresolved complaints concerning our handling of personal data received in reliance to DPF to JAMS, an alternative dispute resolution provider based in the United States. If you do not receive timely acknowledgment of your DPF-related complaint from us, or if we have not addressed your DPF-related complaint to your satisfaction, please visit https://www.jamsadr.com/DPF-Dispute-Resolution for more information or to file a complaint. The services of JAMS are provided at no cost to you.

If any request remains unresolved, you may contact the national data protection authority for your jurisdiction of residence. In certain conditions, if your DPF complaint has not been resolved after raising it with us following the JAMS procedure above and taking certain other steps, complaints may be resolved through binding arbitration, as described in Annex I of the DPF, available here: https://www.dataprivacyframework.gov/s/article/ANNEX-I-introduction-dpf?tabset-35584=2.

IX. LINKS TO OTHER WEBSITES AND SERVICES

Our Services may contain links to websites and services that are owned or operated by third parties. Any information that you provide on or to a third-party service, or that is collected by a third-party service, is provided directly to the owner or operator of the third-party service and is subject to the owner’s or operator’s privacy policy. Please remember that when you use a link to go from the REMEMBERY, Tile, or Jiobit Services to another website or app, or engage with a third-party service, our Privacy Policy does not apply to those third-party websites or services. Your browsing and interaction, on any third-party website or service, including those that have a link on our website, are subject to that third party’s own rules and policies, and REMEMBERY is not responsible for the practices employed by those apps, websites, or services, nor the information or content contained therein. 

X. CHANGES TO THIS PRIVACY POLICY

We may update this Privacy Policy from time to time, so please review it frequently. If we are required by applicable data protection laws to give you enhanced notice or seek out consent to any such changes, we will do so. Otherwise, changes to this policy will be effective when posted. 

If you object to any of the changes to this Privacy Policy, you must cease using our Products and/or Services, and may request us to erase your personal information. Any information that is collected through your use of our Products or Services is covered by the Privacy Policy in effect at the time such information is collected.

XI. CONTACT US IF YOU HAVE QUESTIONS OR CONCERNS

If you have any questions about our privacy practices, this Privacy Policy, our Products, or Services, please contact us at info@remembery.com

A. Authorized Agents

You may authorize another person (your “agent”) to contact us on your behalf. Authorized agents must submit the request via email to info@remembery.com and include a signed letter from the REMEMBERY member confirming the agent has permission to submit the request on the member’s behalf. In certain circumstances, we may need to request additional information to verify the identity of the member about whom the request is being made and/or to verify that the member has provided the authorized agent permission to submit the request, and it may take additional time to fulfill agent-submitted requests. Please note that for privacy and security reasons, we will direct future communications to the REMEMBERY member on whose behalf the request was made. We may deny a request in the event we are not able to verify the authorized agent’s authority to act on your behalf.

B. Right to Contact a Data Protection Authority

You also have the right to contact your local Data Protection Authority if you prefer. We are subject to the investigatory and enforcement powers of the US Federal Trade Commission (“FTC“), and contact details for the EU Data Protection Authorities are available at http://ec.europa.eu/justice/data-protection/bodies/authorities/index_en.htm.