AnswersNow | Privacy Policy

PART ONE: INTRODUCTION

WE AT ANSWERSNOW VALUE YOUR PRIVACY AND ARE COMMITTED TO KEEPING YOUR PERSONAL DATA CONFIDENTIAL. WE USE YOUR DATA SOLELY IN THE CONTEXT OF PARING PARENTS AND CAREGIVERS OF CHILDREN WITH AUTISM WITH A BOARD CERTIFIED BEHAVIORAL ANALYST (BCBA) BY OFFERING YOU A CONVENIENT AND HIGH QUALITY APPLICATION AND WEB SITE THAT ALLOW YOU TO EASILY AND PURPOSEFULLY GET PAIRED WITH A BCBA TO PROVIDE YOU WITH SUPPORT AND GUIDANCE.

THIS PRIVACY POLICY APPLIES TO PERSONAL DATA ANSWERSNOW COLLECTS FROM USERS OF THE ANSWERSNOW APP AND THE WWW.GETANSWERSNOW.COM WEB SITE (THE “APPLICATIONS”). “PERSONAL DATA” INCLUDES ANY INFORMATION THAT CAN BE USED ON ITS OWN OR WITH OTHER INFORMATION IN COMBINATION TO IDENTIFY OR CONTACT ONE OF OUR USERS. WE BELIEVE THAT TRANSPARENCY ABOUT THE USE OF YOUR PERSONAL INFORMATION IS OF UTMOST IMPORTANCE. IN THIS PRIVACY POLICY, WE PROVIDE YOU DETAILED INFORMATION ABOUT OUR COLLECTION, USE, MAINTENANCE, AND DISCLOSURE OF YOUR PERSONAL DATA. THE POLICY EXPLAINS WHAT KIND OF INFORMATION WE COLLECT, WHEN AND HOW WE MIGHT USE THAT INFORMATION, HOW WE PROTECT THE INFORMATION, AND YOUR RIGHTS REGARDING YOUR PERSONAL INFORMATION.

BY SUBMITTING YOUR PERSONAL INFORMATION THROUGH THE APPLICATIONS, YOU ARE ACKNOWLEDGING THAT YOU HAVE READ AND AGREE TO THE TERMS OF THIS POLICY. IF YOU DO NOT AGREE, PLEASE DO NOT LOG INTO OR ACCESS THE APPLICATIONS AND DO NOT SUBMIT ANY PERSONAL DATA TO US.

PLEASE NOTE THAT WE OCCASIONALLY UPDATE THIS PRIVACY POLICY AND THAT IT IS YOUR RESPONSIBILITY TO STAY UP TO DATE WITH ANY AMENDED VERSIONS. IF WE MODIFY THE PRIVACY POLICY, WE WILL POST A LINK TO THE MODIFIED TERMS BOTH ON THE APPLICATION AND THE WEB SITE. WE WILL ALSO NOTIFY YOU VIA EMAIL. YOU CAN STORE THIS POLICY AND/OR ANY AMENDED VERSION(S) DIGITALLY, PRINT IT, OR SAVE IT IN ANY OTHER WAY. ANY CHANGES TO THIS PRIVACY POLICY WILL BE EFFECTIVE IMMEDIATELY UPON PROVIDING NOTICE, AND SHALL APPLY TO ALL INFORMATION WE MAINTAIN, USE, AND DISCLOSE. IF YOU CONTINUE TO USE THE APPLICATION FOLLOWING SUCH NOTICE, YOU ARE AGREEING TO THOSE CHANGES.

In case you have any questions or concerns after reading this Privacy Policy, please do not hesitate to contact us at tech@getanswersnow.com. We appreciate your feedback.

PART TWO: POLICY SUMMARY

Responsible Entity

AnswersNow, Inc. (“We”, “Us”, “the Company”) is the controller of your Personal Data, and may process this data in accordance with the Privacy Policy. If we are processing Personal Data on behalf of a third party, the terms of this Privacy Policy do not apply—instead, the terms of that third party’s privacy policy will apply. You can contact Us with any questions about our Privacy Policy at tech@getanswersnow.com. You can reach our data protection officer, Morry Belkin, at morry@getanswersnow.com.

What information do We collect and why?

We ollect “PERSONAL DATA”, which includes any information that can be used on its own or with other information in combination to identify or contact one of our users. For a description of the types of personal data we collect, review this section in the full Privacy Policy. In some cases, this Personal Data may be or may include healthcare information or “protected health information”.

We may use Personal Data to (1) provide you with the services in the Applications ; (2) communicate with you about and manage your User Account; (3) store data; (4) comply with the law; (5) respond to requests from public and government authorities; (6) to enforce our terms and conditions; (7) manage and improve our operations and applications; (8) provide additional functionality; (9) protect our rights, privacy, safety or property, and/or that of you or others; and (10) allow us to pursue available remedies or limit the damages that we may sustain. Additional uses are described in this section of the full Privacy Policy.

We only use or disclose your Personal Data when it is legally mandated or where it is necessary to fulfill the purposes described above (and in the full Privacy Policy). Where required by law, we will ask for your prior consent before doing so.

Will We share your Personal Data with anyone else?

Yes, with the BCBA with whom you choose to connect via the Application
Yes, with third parties that help us power or improve our Application
Yes, with third parties and the government when legal or enforcement issues arise
Yes, with third parties in the event of a reorganization, merger, sale, joint venture, assignment, transfer, or other disposition of all or any portion of [Company’s] corporate entity, assets, or stock (including in connection with any bankruptcy or similar proceedings).

For more details regarding the above, review this section in the full Privacy Policy.

We may, from time to time, rent or sell aggregated data and/or other information that does not contain any personal identiﬁers (i.e., if the information has been anonymized by stripping out identiﬁers such as name, address, phone number, etc.). The purpose of this type of disclosure is to provide healthcare professionals and other interested parties real world information about the demographic data about the need for autism support in different regions as well as improving user experience with the Services and the treatment of autism, ADHD and developmental disabilities.

Where is your Personal Data stored, transmitted and/or maintained?

Personal Data AnswersNow collects through the Applications will be stored on secure servers in the United States. Personal Data may also be transmitted to third parties, which parties may store or maintain the data on their secure servers. These third parties are not permitted to transfer your Personal Data outside of the United States. The iOS version of the Application is “native” to your device, meaning information you enter into the iOS version of the Application is also stored directly on the device you use to access and enter information into the iOS version of the Application.

How long will We maintain your information?

We store your Personal Information for as long as you maintain a User Account and up to seven (7) years after the account is closed. For more information on Personal Data retention, review this section of the full Privacy Policy.

How do We protect your Personal Data?

AnswersNow uses a combination of reasonable physical, technical, and administrative security controls to maintain the security and integrity of your Personal Data, to protect against any anticipated threats or hazards to the security or integrity of such information, and to protect against unauthorized access to or use of such information in our possession or control that could result in substantial harm or inconvenience to you. However, Internet data transmissions, whether wired or wireless, cannot be guaranteed to be 100% secure. As a result, we cannot ensure the security of information you transmit to us. By using the Application, you are assuming this risk. For more information on the safeguards We have in place to protect your Personal Data, review this section of the full Privacy Policy.

Your rights

You have certain rights relating to your Personal Data, subject to local data protection laws. These rights may include:

To access your Personal Data held by us (right to access);
To rectify inaccurate Personal Data and, taking into account the purpose of processing the Personal Data, ensure it is complete (right to rectification);
To erase/delete your Personal Data, to the extent permitted by applicable data protection laws (right to erasure; right to be forgotten);
To restrict our processing of your Personal Data to the extent permitted by law (right to restriction of processing);
To transfer your Personal Data to another controller, to the extent possible (right to data portability);
To object to any processing of your Personal Data carried out on the basis of our legitimate interests (right to object). Where we process your Personal Data for direct marketing purposes or share it with third parties for their own direct marketing purposes, you can exercise your right to object at any time to such processing without having to provide any specific reason for such objection;
To not be subject to a decision based solely on automated processing, including profiling, which produces legal effects ("Automated Decision-Making"); Automated Decision-Making currently does not take place on our websites or in our services; and
To the extent we base the collection, processing and sharing of your Personal Data on your consent, to withdraw your consent at any time, without affecting the lawfulness of the processing based on such consent before its withdrawal.

For more details on your rights and choices and how to exercise them, please review this section of the full Privacy Policy.

How do you contact Us with questions or concerns?

If you have any questions about this Privacy Policy, please contact us by email at tech@getanswersnow.com or please write to: AnswersNow, Inc., 1717 East Cary Street, Richmond, Virginia 23223. Please note that email communications are not always secure; so please do not include sensitive information in your emails to us.

PART THREE: FULL PRIVACY POLICY

Effective August 14, 2019

WE AT ANSWERSNOW, INC. (“ANSWERSNOW”) VALUE YOUR PRIVACY AND ARE COMMITTED TO KEEPING YOUR PERSONAL DATA CONFIDENTIAL. WE USE YOUR DATA SOLELY IN THE CONTEXT OF PARING PARENTS AND CAREGIVERS OF CHILDREN WITH AUTISM WITH A BOARD CERTIFIED BEHAVIORAL ANALYST (BCBA) BY OFFERING YOU A CONVENIENT AND HIGH QUALITY APPLICATION AND WEB SITE THAT ALLOW YOU TO EASILY AND PURPOSEFULLY GET PAIRED WITH A BCBA TO PROVIDE YOU WITH SUPPORT AND GUIDANCE.

THE PERSONAL DATA WE COLLECT AND TRANSMIT MAY, IN SOME CIRCUMSTANCES, BE CONSIDERED “HEALTH DATA” (data related to a user’s physical or mental health) or “Protected Health Information” (information that relates to the past, present, or future physical or mental health or condition of a user; the provision of health care to a user; or the past, present, or future payment for the provision of health care to user. THEREFORE, OUR PRIVACY PRACTICES ARE INTENDED TO COMPLY WITH BOTH THE HEALTH INSURANCE PORTABILITY AND ACCOUNTABILITY ACT (“HIPAA“) AND THE GENERAL DATA PROCESSING REGULATION (“GDPR”) PROVISIONS REGARDING SENSITIVE PERSONAL DATA. FOR ADDITIONAL INFORMATION RELATED TO YOUR HEALTHCARE INFORMATION, PLEASE CONTACT OUR PRIVACY OFFICER, JEFF BECK, AT JEFF@GETANSWERSNOW.COM.

PLEASE NOTE THAT WE OCCASIONALLY UPDATE THIS PRIVACY POLICY AND THAT IT IS YOUR RESPONSIBILITY TO STAY UP TO DATE WITH ANY AMENDED VERSIONS. IF WE MODIFY THE PRIVACY POLICY, WE WILL POST A LINK TO THE MODIFIED TERMS ON THE APPLICATION AND WEB SITE. WE WILL ALSO NOTIFY YOU VIA EMAIL. YOU CAN STORE THIS POLICY AND/OR ANY AMENDED VERSION(S) DIGITALLY, PRINT IT, OR SAVE IT IN ANY OTHER WAY. ANY CHANGES TO THIS PRIVACY POLICY WILL BE EFFECTIVE IMMEDIATELY UPON PROVIDING NOTICE, AND SHALL APPLY TO ALL INFORMATION WE MAINTAIN, USE, AND DISCLOSE. IF YOU CONTINUE TO USE THE APPLICATION FOLLOWING SUCH NOTICE, YOU ARE AGREEING TO THOSE CHANGES.

In case you have any questions or concerns after reading this Privacy Policy, please do not hesitate to contact us at tech@getanswersnow.com. We appreciate your feedback.

Responsible Entity

AnswersNow, Inc. (“We”, “Us”, “the Company”) is the controller of your Personal Data, and may process this data in accordance with the Privacy Policy. If we are processing Personal Data on behalf of a third party that is not an agent or affiliate of Company, the terms of this Privacy Policy do not apply—instead, the terms of that third party’s privacy policy will apply. You can contact Us with any questions about our Privacy Policy at tech@getansswersnow.com. You can reach our data protection officer Jeff Beck at jeff@getanswersnow.com.

What information do we collect and why?

Demographic Data

We collect demographic information, such as your name, birth year, gender, and email address. Primarily, the collection of your Personal Data assists us in creating your User Account, which you can use to securely provide information regarding your child’s history and other information that will assist Us in paring you with the best possible BCBA match.

Payment Data

In order to pay your subscription fees for the App, we may require that you provide to us your financial and billing information, such as billing name and address, credit card number or bank account information. We will use such financial information solely to process the payment of your subscription fees.

Support Data

If you contact AnswersNow for support or to lodge a complaint, We may collect technical or other information from you through log files and other technologies, some of which may qualify as Personal Data. (e.g., IP address). Such information will be used for the purposes of troubleshooting, customer support, software updates, and improvement of the Application and related services in accordance with this Privacy Policy. Calls with AnswersNow may be recorded or monitored for training, quality assurance, customer service, and reference purposes.

Web Site Data

If you use and interact with our website or emails, We automatically collect information about your device and your usage of our website or email through cookies, web beacons or similar technologies, such as Internet Protocol (IP) addresses or other identifiers, which may qualify as Personal Data. We may use this data to track the actions of Application users and email recipients, and compile statistics about Application usage and response rates. We may use cookies to maintain your signedon status as you navigate through the features of the Applications and remember your username when you access the Applications. If you enable a do not track (DNT) signal that prevents us from collecting cookies, you will need to reenter your user name each time you visit the login page. We do not use cookies to collect and store any additional information or for any other purpose than described above. To learn more about cookies, please visit http://www.allaboutcookies.org/.

Health Data

In addition to demographic information, We will collect information regarding your health conditions, age, gender, and other information relevant to determining an appropriate BCBA match. We collect this information to provide you the best possible pairing of a BCBA.

We use the Personal Data we collect to (1) provide you with the services in the Applications; (2) communicate with you about and manage your User Account; (3) store data; (4) comply with the law; (5) respond to requests from public and government authorities; (6) to enforce our terms and conditions; (7) manage and improve our operations and applications; (8) provide additional functionality; (9) protect our rights, privacy, safety or property, and/or that of you or others; and (10) allow us to pursue available remedies or limit the damages that we may sustain.

We only use or disclose your Personal Data when it is legally mandated or where it is necessary to fulfill the purposes described above. Where required by law, we will ask for your prior consent before doing so.

Monitoring

AnswersNow is permitted, but not obligated, to review and/or retain information and/or communications stored and/or transmitted using the Applications (“User Content”). AnswersNow may monitor User Content for data collection purposes and/or to evaluate the quality of service you receive, your compliance with the Terms of Use, the security of the Applications, or for other reasons.

You agree that such monitoring activities, if in compliance with applicable privacy laws, will not entitle you to any cause of action or other right with respect to the manner in which AnswersNow monitors your User Content and enforces or fails to enforce the terms of this Privacy Policy. In no event will AnswersNow be liable for any costs, damages, expenses, or any other liabilities incurred by you as a result of monitoring activities by AnswersNow.

Will We share your Personal Data with anyone else?

Yes, with the BCBA with whom you choose to connect via the Application

AnswersNow will share your Personal Data with the BCBA with whom we pair you to provide support, guidance and feedback. The BCBA is legally and contractually bound to protect your Personal Data and to use it only for the limited purpose(s) for which it is shared.

Yes, with third parties that help Us power our Site

AnswersNow has a limited number of service providers and other third parties (“Business Partners”) that help us run various aspects of our Applications. These Business Partners are contractually bound to protect your Personal Data and to use it only for the limited purpose(s) for which it is shared. Such thirdparty uses may include, but are not limited to, the provision of services such as data hosting, IT services, messaging services, and billing management.

Yes, with third parties and the government when legal or enforcement issues arise

We may share your Personal Data, if reasonable and necessary, to (i) comply with legal processes or enforceable governmental requests, or as otherwise required by law; (ii) cooperate with third parties in

investigating acts in violation of this Privacy Policy; or (iii) bring legal action against someone who may be violating the Terms of Use or who may be causing intentional or unintentional injury or interference to the rights or property of AnswersNow or any third party, including other customers.

Yes, with third parties in the event of a reorganization, merger, sale, joint venture, assignment, transfer, or other disposition of all or any portion of AnswersNow’s corporate entity, assets, or stock (including in connection with any bankruptcy or similar proceedings).

If we share your Personal Data with a third party other than as provided above, you will be notiﬁed at the time of data collection or transfer, and you will have the option of not permitting the transfer.

Where is your Personal Data stored, transmitted and/or maintained?

Personal Data AnswersNow collects through the Applications will be stored on secure servers in the United States. Personal Data may also be transmitted to third parties, which parties may store or maintain the data on their secure servers. These third parties are not permitted to transfer your Personal Data outside of the United States. The Application is “native” to your device, meaning information you enter into the Application is also stored directly on the device you use to access and enter information into the Application.

How long will we maintain your Personal Data?

We store your Personal Data for as long as you maintain a User Account and up to ﬁve (5) years after the account is closed. At the end of this ﬁveyear retention period, we will remove your Personal Data from our databases and will request that our Business Partners remove your Personal Data from their databases.

However, once we disclose your Personal Data to third parties, we may not be able to access that Personal Data any longer and cannot force the deletion or modiﬁcation of any such information by the parties to whom we have made those disclosures. Written requests for deletion of Personal Data other than as described should be directed to tech@getanswersnow.com. We retain anonymized data indeﬁnitely.

How do We protect your Personal Data?

AnswersNow is committed to protecting the security and conﬁdentiality of your Personal Data. We use a combination of reasonable physical, technical, and administrative security controls to maintain the security and integrity of your Personal Data, to protect against any anticipated threats or hazards to the security or integrity of such information, and to protect against unauthorized access to or use of such information in our possession or control that could result in substantial harm or inconvenience to you. However, Internet data transmissions, whether wired or wireless, cannot be guaranteed to be 100% secure. As a result, we cannot ensure the security of information you transmit to us. By using the Applications, you are assuming this risk.

Safeguards

The information collected by AnswersNow and stored on secure servers, is protected by a combination of technical, administrative, and physical security safeguards, such as authentication, backups, and access controls. If AnswersNow learns of a security concern, we may attempt to notify you and provide information on protective steps, if available, through the email address that you have provided to Us or by an inapp notiﬁcation. Depending on where you live, you may have a legal right to receive such notices in writing.

NOTWITHSTANDING ANY OF THE STEPS TAKEN BY US, IT IS NOT POSSIBLE TO GUARANTEE THE SECURITY OR INTEGRITY OF DATA TRANSMITTED OVER THE INTERNET. THERE IS NO GUARANTEE THAT YOUR INFORMATION WILL NOT BE ACCESSED, DISCLOSED, ALTERED, OR DESTROYED BY BREACH OF ANY OF OUR PHYSICAL, TECHNICAL, OR ADMINISTRATIVE SAFEGUARDS. THEREFORE, WE DO NOT AND CANNOT ENSURE OR WARRANT THE SECURITY OR INTEGRITY OF ANY INFORMATION YOU TRANSMIT TO US AND YOU TRANSMIT SUCH INFORMATION AT YOUR OWN RISK.

Steps you can take to keep your Personal Data safe

We will NEVER send you an email requesting conﬁdential information such as account numbers, usernames, passwords, or social security numbers, and you should NEVER respond to any email requesting such information. If you receive such an email purportedly from AnswersNow, DO NOT RESPOND to the email and DO NOT click on any links and/or open any attachments in the email, and notify AnswersNow support at tech@getanswersnow.com.

You are responsible for taking reasonable precautions to protect your user ID, password, and other User Account information from disclosure to third parties, and you are not permitted to circumvent the use of required encryption technologies. You should immediately notify AnswersNow at tech@getanswersnow.com if you know of or suspect any unauthorized use or disclosure of your user ID, password, and/or other User Account information, or any other security concern.

Your rights

You have certain rights relating to your Personal Data, subject to local data protection laws. These rights may include:

To access your Personal Data held by us (right to access);
To rectify inaccurate Personal Data and, taking into account the purpose of processing the Personal Data, ensure it is complete (right to rectification);
To erase/delete your Personal Data, to the extent permitted by applicable data protection laws (right to erasure; right to be forgotten);
To restrict our processing of your Personal Data to the extent permitted by law (right to restriction of processing);
To transfer your Personal Data to another controller, to the extent possible (right to data portability);
To object to any processing of your Personal Data carried out on the basis of our legitimate interests (right to object). Where we process your Personal Data for direct marketing purposes or share it with third parties for their own direct marketing purposes, you can exercise your right to object at any time to such processing without having to provide any specific reason for such objection;
To not be subject to a decision based solely on automated processing, including profiling, which produces legal effects ("Automated Decision-Making"); Automated Decision-Making currently does not take place on our websites or in our services; and
To the extent we base the collection, processing and sharing of your Personal Data on your consent, to withdraw your consent at any time, without affecting the lawfulness of the processing based on such consent before its withdrawal.

You can change your email address and other contact information by emailing tech@getanswersnow.com. Please note that in order to comply with certain requests to limit use of your Personal Data, we may need to terminate your account with us and your ability to access and use the Applications, and you agree that we will not be liable to you for such termination or for any refunds of prepaid fees paid by you.

How do you contact Us with questions or concerns?

If you have any questions about this Privacy Policy, please contact us by email at tech@getanswersnow.com or please write to: 1717 Cary Street, Richmond, Virginia 23223. Please note that email communications are not always secure; so please do not include sensitive information in your emails to us.