Safekeeping & Hows Mom™

Privacy Policy

Last Updated May 03, 2022

SafeKeeping, Inc. ("SafeKeeping", “we”, “us” and “our”) respects your privacy and is
committed to protecting your privacy through our compliance with this Privacy Policy.
This Privacy Policy should be read in conjunction with our Terms of Use, into which this
Privacy Policy is incorporated by reference.

SafeKeeping operates the website, SafeKeeping web
portal websites, How's Mom application for use by Covered Entities
(defined below) and other Authorized Users, and the SafeKeeping mobile application
(collectively, the "Services"). This Privacy Policy informs you of our policies regarding
the collection, use and disclosure of personal information when you use our Service and
the choices you have associated with that information.

By using the Services, you agree to the collection and use of information in accordance
with this Privacy Policy. This Privacy Policy may change from time to time (see below,
“Changes to this Privacy Policy”). Unless otherwise defined in this Privacy Policy, the
terms used in this Privacy Policy have the same meanings as in our Terms of Use. If
you do not agree with our policies and practices, then please do not use our Services.

HIPAA; Relationship with Covered Entities; and PHI

Important Information Relating to Health Information. SafeKeeping is not a Covered
Entity as defined by the Health Insurance Portability and Accountability Act (“HIPAA”).
SafeKeeping may be a Business Associate under HIPAA of certain Covered Entities, as
that term is defined under HIPAA. Covered Entities can include senior care, nursing
homes, and other healthcare facilities that enlist the services of SafeKeeping. Under
the terms of any Business Associate Agreement ("Agreement" or “Business Associate
Agreement”) by and between SafeKeeping and a Covered Entity, SafeKeeping provides
services to Covered Entity that may involve individually identifiable health information
constituting Protected Health Information (“PHI”). Additionally, the Services are
provided to you, as an Authorized User (defined below), in order to access certain
information regarding an individual under the care of a Covered Entity (a “Patient”).
SafeKeeping's uses and disclosures of PHI and other actions under each Agreement
are and shall be consistent with the Covered Entity's privacy policies, as stated in
Covered Entity's notice, and which may be modified or altered by the Covered Entity
from time to time.

Authorized Users. The Services may be accessed by third parties, however, PHI may
only be accessed by third parties authorized by the Covered Entity ("Authorized Users").
Authorized Users may include, but is not necessarily limited to, Covered Entity
employees, family members of a Patient, and a Patient’s power of attorney. Authorized
Users have been, directly or indirectly, authorized by the Patient to receive information
from the Covered Entity.

Not For Medical Advice. SafeKeeping does not provide medical advice, diagnosis, or
treatment. You acknowledge and agree that the Covered Entities are solely responsible
for and have complete authority, responsibility, supervision, and control over the
provision of medical services, advice, instructions, treatment decisions, and other
professional health care services performed for any Patient whose information you are
authorized to access under this Agreement, and that all diagnoses, treatments, procedures, and other professional health care services are provided and performed
exclusively by or under the supervision of Covered Entities as they, in their sole
discretion, deem appropriate. You further acknowledge and agree that SafeKeeping
does not provide or endorse any medical advice or treatment on or through the Services
and no information obtained through the Services can be so construed or used.

Terms of Use; Covered Entity Employees and Agreements
This Privacy Policy should be read in conjunction with any applicable Terms of Use, into
which this Policy is incorporated by reference. This Privacy Policy also applies to your
use of the Services, including as an employee of a Covered Entity. Your use of the
Services and our processing of your information may be subject to a Business
Associate Agreement, written contract with your employer, or other agreement with a
Covered Entity specific to the nature of any transaction in which you are participating, in
which such agreement may supersede this Privacy Policy.

Information SafeKeeping Collects

Information given by Covered Entity, Authorized Users, or third-party
users. Services provided may require you to sign up for a SafeKeeping or How's Mom
account(s) ("SafeKeeping Account"). When you do, certain information about you, the
related facilities, staff, and residents may be collected. This information will only be used
to authorize your access and provide such information to you through the Services.

Authorized User’s may provide personal information while using the Services, including,
but not limited to, the following:

  • First and last name;
  • Email address;
  • Telephone number;
  • Date of birth;
  • Mailing address;
  • Geolocation data; and
  • Comments or messages provided in free text boxes.

Covered Entity employees may provide personal information while using the Services,
including, but not limited to, the following:

  • First and last name;
  • Covered Entity information (i.e. mailing address and company name);
  • Geolocation data; and
  • Comments or messages provided in free text boxes.

The information that you provide in each case will vary. In some cases, you may be
able to provide personal information via email or free text boxes or uploading
documents to the Services, such as contacting SafeKeeping to request further
information. When providing your personal information in these situations, please
provide only relevant information and do not provide unnecessary sensitive information,
such as Social Security numbers, credit card information or other sensitive personal data, unless required by the Services. Additionally, we may ask you to create a
username and password that should only be known to you.

Information of Other Individuals. As a user of the Services, you (as an employee of a
Covered Entity or an Authorized User) may have the opportunity to provide information
of other individuals, such as providing Patient or Authorized User personal information.
When providing such information, you are solely responsible for obtaining the necessary
consents and authorizations from any individuals in accordance with applicable data
security laws and regulations, and SafeKeeping shall not be responsible or held liable
for your failure to obtain the necessary consents.

Information we get from your use of our services. We may collect information about
the services that you use and how you use them, like when you visit our website or
access our Services. This information includes:

  • Device Information. We may collect device-specific information (such as your
    hardware model, operating system, and mobile network information).
  • Log information. When you use the Services or view content provided by
    SafeKeeping, we may automatically collect and store certain information in our
    server logs. This may include:

    • details of how you used the Services.
    • Internet protocol addresses
    • device event information such as crashes, system activity, hardware
      settings, browser type, browser language, the date and time of your
      request and referral URL.
    • cookies that may uniquely identify your browser or your Authorized User
  • Location information. When you use a location-enabled SafeKeeping Services,
    we may collect and process information about your actual location, like GPS
    signals sent by a mobile device. We may also use various technologies to
    determine location, such as sensor data from your device that may, for example,
    provide information on nearby Wi-Fi access points and cell towers.
  • Cookies and anonymous identifiers. We use various technologies to collect and
    store information when you visit SafeKeeping Services, and this may include
    sending one or more cookies or anonymous identifiers to your device. Cookies
    are sent to your browser from a website and stored on your device. Other
    tracking technologies are also used such as beacons, tags and scripts to collect
    and track information and to improve and analyze our Services. You can instruct
    your browser to refuse all cookies or to indicate when a cookie is being sent.
    However, if you do not accept cookies, you may not be able to use some portions
    of our Service.

How SafeKeeping uses collected information
SafeKeeping uses the information collected from the Services to provide, maintain,
protect and improve them, to develop new ones, and to protect SafeKeeping and the
users of the Services. SafeKeeping may also use your information to provide service
and support communications, marketing communications that are effective and optimized for you, and to prevent malicious activity and provide you with a secure
experience. Information collected from cookies and other technologies may be used to
improve the user experience and overall quality of the Services.

How We May Share Your Information
We do not sell or lease your personal information to any third party. We may disclose
your personal information to our trusted third-party business partners in accordance with
this Privacy Policy. We work with a number of partners that help us process your
requests, deliver customer service and support, send email marketing communications,
and provide experiences that you have come to expect from us. We will share your
personal information with these third parties in order to fulfill the service that they
provide to us. These third-party partners are under contract to keep your personal
information secure and not to use it for any reason other than to fulfill the service we
have requested from them. Additionally, we may share your personal information for the
following reasons:

  • Covered Entities. The Services and SafeKeeping may share, provide or otherwise
    disclose your personal information to Covered Entities in accordance with this
    Privacy Policy. Additionally, the Services and SafeKeeping may receive from such
    Covered Entities certain personal information, including PHI. The sharing of your
    information by these third-parties will be subject to an authorization and release
    form executed between you and the applicable Covered Entity. Personal information shared by these Covered Entities will be governed by that
    Covered Entity’s privacy policy and not necessarily the terms of this Privacy
    Policy once shared. In the event that personal information contains PHI, such
    PHI will be stored, processed, and transmitted in accordance with any applicable
    Business Associate Agreement.
  • Vendors, Subcontractors and other Third-Party Service Providers. When
    necessary, SafeKeeping discloses to its subcontractors, agents or other third
    parties, and requests from the Covered Entity, only the minimum PHI necessary
    to performing or fulfilling a specific required or permitted function. SafeKeeping
    establishes and maintains all appropriate safeguards to prevent any use or
    disclosure of PHI other than pursuant to the terms and conditions of any
    applicable Business Associate Agreement.
  • Domain/IT administration. If you create a SafeKeeping Account and it is
    managed by an IT administrator then your IT administrator may have access to
    your SafeKeeping Account information (including your data, email, and personal
    information). Your IT administrator may be able to:

    • view statistics of the account;
    • change the account password;
    • suspend/terminate account access;
    • access information retained on the account;
    • access or receive other information or data of your account or adjust
      settings within your account; and
    • refer to the IT/Domain administrator's own privacy policy.
  • Legal Concerns. Personal information may be shared with companies,
    organizations, or individuals outside of SafeKeeping if there is a good-faith belief
    that access, use, preservation or disclosure of the information is reasonably
    necessary to:

    • enforce applicable Terms of Use;
    • meet applicable laws, regulations, legal processes or enforceable
      governmental requests;
    • detect, prevent, or otherwise address fraud, security or technical issues
      and defend rights or property of SafeKeeping;
    • investigate wrongdoing in connection with the Services; and
    • protect personal safety of users of the Services or the public.
  • Merger or Acquisition. There are circumstances where SafeKeeping may decide
    to buy, sell, or reorganize its business in selected countries. Under these
    circumstances, it may be necessary to share or receive personal information with
    prospective or actual partners or affiliates. In such circumstances, SafeKeeping
    will ensure your information is used in accordance with this Privacy Policy.

We may aggregate or otherwise anonymize the data we collect for purposes of
analytics, research, marketing and other business interests of SafeKeeping. Such use
shall not include Personal Information or information that can identify you as an
individual or reasonably be used to identify you.

Your Choices and Selecting Your Privacy Preferences

We want to provide you with relevant information that you have requested.

If we provide subscription-based services, such as email newsletters, we will allow you to
make choices about what information you provide at the point of information collection or
at any time after you have received a communication from us while you are subscribed.
Transactional or service-oriented messages are usually excluded from such preferences,
as such messages are required to respond to your requests or to provide goods and
services, and are not intended for the purposes of marketing.

We will not intentionally send you email newsletters and marketing emails unless you
consent to receive such marketing information. After you request to receive these
emails, you may opt out of them at any time by selecting the “unsubscribe” link at the
bottom of each email. Please note that by opting out or unsubscribing you may affect
other services you have requested we provide to you, in which email communication is
a requirement of the service provided.

Push Notifications. You may receive push notifications in accordance with the features
and policies of the application. You can control these tools on your mobile devices; for
72139614v1example, you can turn off the GPS locator or push notifications on your phone. To
modify the push notifications you get from our app, you can alter your preferences in
your profile. You may not be able to use our application to its full extent by disabling
certain features and tools.

Text Messaging. You may have the opportunity to receive SMS or "text" messages, pre-
recorded voice messages or auto-dialed phone calls from SafeKeeping, its affiliates and
related entities as well as third parties. Such messaging may be used to authenticate
your identity or mobile device, as well as provide you informational updates about
services you may have requested. In providing your mobile device number or cell
phone number to SafeKeeping, you knowingly consent to such communications from
SafeKeeping or for SafeKeeping to use your cell phone number or mobile device
number in accordance with the Privacy Policy. In providing your number and accepting
this Privacy Policy, you represent that you have the authority to agree to receive text
messages at the telephone number that you provide to SafeKeeping, or from which you
sent the text message request to us. You further acknowledge that no purchase is
required to opt into this service, and you may opt out at any time by following
instructions below.

  • You can cancel the SMS service at any time. Just text "STOP" to the short code.
    After you send the SMS message "STOP" to us, we will send you an SMS
    message to confirm that you have been unsubscribed. After this, you will no
    longer receive SMS messages from us. If you want to join again, contact your
    loved one's facility to sign up as you did the first time and we will start sending
    SMS messages to you again.
  • If you are experiencing issues with the messaging program you can reply with
    the keyword HELP for more assistance, or you can get help directly at
  • Carriers are not liable for delayed or undelivered messages.
  • As always, message and data rates may apply for any messages sent to you
    from us and to us from you. You will receive occasional messages for COVID-19
    updates and other facility notifications. If you have any questions about your text
    plan or data plan, it is best to contact your wireless provider.

Accuracy and Access to Your Personal Information.

We strive to maintain and process your information accurately. We have processes in
place to maintain all of our information in accordance with relevant data governance
frameworks and legal requirements. We employ technologies designed to help us
maintain information accuracy on input and processing.

Where we can provide you access to your personal information in our possession, we
will always ask you for a username and password to help protect your privacy and security. We recommend that you keep your password safe, that you change it
periodically, and that you do not disclose it to any other person or allow any other
person to use it.

To view and change the personal information that you have provided to us, you can log
in to your account and follow the instructions on that webpage, or contact us directly for

Third-Party Websites

This Privacy Policy does not apply to websites or other domains that are maintained or
operated by third parties or our affiliates. Our Services may link to third-party websites
and services, but these links are not endorsements of these sites, and this Privacy
Policy does not extend to them. Because this Privacy Policy is not enforced on these
third-party websites, we encourage you to read any posted privacy policy of the third-
party website before using the service or site and providing any information.

Your California Rights.

Pursuant to California Civil Code Section 1798.83, we will not disclose or share your
personal information with third parties for the purposes of third-party marketing to you
without your prior consent.
“Do Not Track” Signals. We do not support Do Not Track (“DNT”). Do Not Track is a
preference you can set in your web browser to inform websites that you do not want to
be tracked. You can enable or disable Do Not Track by visiting the Preferences or
Settings page of your web browser.
If you are a California consumer, as defined by the California Consumer Privacy Act of
2018 (“Act”), please be advised that SafeKeeping does not currently meet the regulatory
thresholds of a “business” as that term is defined under the Act and therefore is not
required to comply with the Act. Regardless, all Personal Information will be processed
in accordance with this Privacy Policy.


SafeKeeping does not knowingly collect personal information from children under the
age of 13, and our Service is not directed at users under the age of 13. If we find that
personal information has inadvertently been collected for an individual under the age of
13, we will immediately delete it. You hereby acknowledge and agree that children
under the age of 13 are prohibited from using our Services. A parent, guardian, or
personal representative may use the Software on behalf of a child under the age of 13.
Furthermore, you acknowledge and agree that minors between the ages of 13 and 17
may use our Software, but that a parent, guardian or personal representative must
consent to this Agreement and our Privacy Policy on their behalf.

Safeguarding the Information We Collect

We use reasonable technical, administrative, and physical safeguards in order to
protect your personal information against accidental loss and from unauthorized access,
use, alteration, and disclosure. In addition, for any PHI provided to the Service or
SafeKeeping, we utilize all appropriate safeguards as agreed to in any applicable
Business Associate Agreement executed with the applicable Covered Entity. However,
we can never promise 100% security. You have a responsibility, as well, to safeguard
your information through the proper use and security of any online credentials used to
access your personal information, such as a username and password. You are solely
responsible for any use of your account under your assigned credentials, including if
you share those credentials with an advocate, surrogate or other party to act on your
behalf. If you believe your credentials have been compromised, please change your
password. Please also notify us of any unauthorized use.

Changes to This Privacy Policy

The SafeKeeping Privacy Policy may change from time to time. We will not reduce your
rights under this Privacy Policy without your explicit consent. We will post any privacy
policy changes on this page and, if the changes are significant, we will provide a more
prominent notice (including, for certain services, and email notification of privacy policy

Contact Us

If you have any questions about this Privacy Policy, please contact us
at: or 318 Main Street, Evansville, In 47708