Last updated & effective date: September 13th, 2021
We only ask you to share the information needed to fulfill the mission of LooK SPOT and LooK PASS apps. We will be clear about what information you’re choosing to share. We will never share your name, phone number or any other information that specifically identifies you with other LooK SPOT and LooK PASS users unless you specifically authorize us to do so. We will be open and clear about why features exist, what they do, and how they use your information.
LooK SPOT and LooK PASS apps are tools developed in coordination with epidemiologists and public health officials to help stop the spread of communicable diseases like COVID-19. It uses information that you share through the apps along with third-party data to help local, state and federal governments, public health organizations, as well as other entities a user authorizes, identify communicable disease transmission networks and deploy testing and containment efforts to research and combat the pandemic.
LooK SPOT app:
Allow the COVID-19 rapid antigen test operator to clamp the LooK SPOT reader to a mobile phone and use the camera to take pictures of the rapid test antigen cassette to screen for the COVID-19 for those patients within eight days of the symptom onset
LooK PASS app:
Allows people to log and scan the QR code of the rapid antigen test cassette and to receive the test results in real-time. LooK PASS can also collect information of symptoms, vaccines and the contact information of individuals they identify as potentially exposed by them with local, state, province and federal government organizations and public health organizations; these government and public health organizations have committed to using this information solely for public health intervention and response efforts. It retains personally identifiable health-related information regarding communicable disease symptoms that you share with us no longer than 30 days after you provide it. After 30 days, we will de-identify this information by removing any details that directly identify you, such as your name and phone number. It puts you in control of your information by letting you request deletion of all personal information we have received through the apps at any time.
Your use of LooK PASS is voluntary. You can, at any time, direct us to delete your personal information by choosing to deactivate your account. Please note we may not be able to determine if you delete or uninstall the app, or block the email that delivers the communications, and therefore may be unable to automatically stop you from receiving email communications.
2. Information We Collect About You
A. This policy applies to all information we collect about you, including:
- via www.LocationNow.com (our “Website”), LooK SPOT mobile app and LooK PASS mobile app for (our “Apps”);
- via email, text, and other electronic messages between you and Us (or our Website and Apps);
- when you interact with our advertising and applications on third-party websites and services;
- and/or from healthcare providers or other third parties who send us information about you (e.g., related to test results).
B. The specific types of information we collect depend upon the products and Services you use, how you use them, and the information you choose to provide via our Website, the App, or otherwise. The types of data we collect from or about you (“Personal Data”) may include the following:
- Name, address, telephone number, date of birth, email address, nickname, preferred pronouns, and/or photos you send us or upload to our Apps;
- Log-in credentials, if you create an account;
- Billing information, such as shipping address, credit or debit card number, verification number, expiration date, and identity verification information, collected by our payment processors on our behalf;
- Information about purchases or other transactions with us; Information about your medical history and your test results when you use one of our diagnostic tests;
- Information about your customer service and maintenance interactions with us;
- Demographic information such as your gender, age, race, legal sex, and ethnicity; and Any other information you choose to directly provide to us in connection with your use of the Services, via surveys or otherwise.
C. Information We Collect Through Automated Means
In addition to the above information, we may collect certain information about your use of the Services and the devices you use to access the Services, as described in this Section. As discussed further below, we and third party companies that work on our behalf may use a variety of technologies, including cookies and similar tools, to assist in collecting this information.
i. Our Website. When you use our Website, we collect and analyze information such as your IP address, browser type, browser language, operating system, the state or country from which you accessed the Services, software and hardware attributes (including device IDs), referring and exit pages and URLs, platform type, the number of clicks, files you download, domain names, landing pages, pages viewed and the order of those pages, the amount of time spent on particular pages, the terms you use in searches on our sites, the date and time you use the Services, error logs, and other similar information.
ii. Our Apps. When you use our Apps, we automatically receive certain information about the mobile phone, tablet, or computer used to access the App, including a mobile device identifier, IP address, operating system, version, Internet service provider, browser type, domain name and other similar information, whether and when you update the Apps, date and time of use, and how you use the Apps, including time spent in different portions of the Apps. Our apps for the COVID-19 response only access personal and sensitive data required to directly support the public health emergency, and may only use the data collected to support COVID-19-related efforts or epidemiological research. Our apps request permission to access your device’s camera to scan the antigen test cassettes QR code or to take picture of the antigen cassette, also use the photos from camera as the profile picture for the user account. You can grant or deny these permissions.
iii. Location Information. When you use the Services, we and our service providers may automatically collect general location information (e.g., IP address, city/state and or postal code associated with an IP address) from your computer or mobile device. This information allows us to enable access to content that varies based on a user’s general location (e.g., to provide you with accurate sales tax information and to deliver content customized to your location). We will ask your permission before collecting your precise GPS location information. If you no longer wish for us and our service providers to collect and use GPS location information, you may disable the location features on your device by going to your device manufacturer settings.
- A web server log is a file where website activity is stored.
- An SDK is a set of tools and/or code that we embed in our App and software to allow third parties to collect information about how users interact with the Services.
- A cookie is a small text file that is placed on your computer or mobile device when you visit a site, that enables us to: (i) recognize your computer/device; (ii) store your preferences and settings; (iii) understand the parts of the Services you have visited and used; (iv) enhance your user experience by delivering and measuring the effectiveness of content and advertising tailored to your interests; (v) perform searches and analytics; and (vi) assist with security and administrative functions.
- Tracking pixels (sometimes referred to as web beacons or clear GIFs) are tiny electronic tags with a unique identifier embedded in websites, online ads and/or email that are designed to: (1) collect usage information like ad impressions or clicks and email open rates; (2) measure the popularity of the Services and associated advertising; and (3) access user cookies.
v. Information We Collect From Social Media and Other Content Platforms. When you “like” or “follow” us on Facebook, Instagram, Twitter, LinkedIn, or other social media sites, we may collect some information from (or about) you including your name, email address, and any comments or content you post relevant to us. We also collect your information if you sign up for one of our promotions or submit information to us through social media sites.
vi. Information We Receive From Other Sources. We work closely with third parties (including, for example, third party intermediaries, such as the physicians, medical professionals, government health agencies and pharmacies with whom we partner to provide you with the Services and their health care services, sub-contractors in technical, advertising networks, analytics providers, and search information providers). Such third parties will sometimes provide us with additional information about you.
D. The information we collect automatically may include Personal Data or we may maintain it or associate it with Personal Data we collect in other ways or receive from third parties. This information helps us to improve our Website and Apps and to deliver a better and more personalized service by, for example, enabling us to: estimate our audience size and usage patterns; verify your location to ensure we can provide you with our Services; store information about your preferences, allowing us to customize our Website and our Apps according to your individual interests; or recognize you when you return to our Website and our Apps.
3. How We Use Your Information
A. We use information that we collect about you or that you provide to us, including your Personal Data:
- to carry out, improve, and manage the Services (including presenting our Website and App to you and sharing your diagnostic test results with you);
- to facilitate the provision of health care services to you by providing physicians or other health care providers, including telehealth providers, with your data;
- to provide diagnostic test results obtained as part of the Services to your health care provider(s) and/or to federal, state, and local public health authorities and/or other governmental authorities (if required by law) and/or research institutions (in the case of provider-initiated tests in the context of research studies);
- to provide you with information, products, and/or Services that you request from us or that we think might be of interest to you;
- to engage in research and data analysis to understand the effectiveness of our products and Services, to improve our products and Services, and to better understand our customer base.
- to communicate with you about our products and/or Services, your use of our products and/or Services, or your inquiries related to products and/or Services and send you communications on behalf of physicians or other health care providers in connection with our Services;
- to communicate with you by email, postal mail, or phone about surveys, promotions, special events or our products and Services and those of our subsidiaries, affiliates any of their related businesses and those of our third-party partners;
- to provide you with technical support and customer service;
- to verify your identity and administer your account, including processing your payments and fulfilling your orders;
- to measure or understand the effectiveness of advertising and content we serve to you and others, and to deliver and customize relevant advertising and content to you;
- to help us better understand your interests and needs, such as by engaging in analysis and research regarding use of our products and/or Services;
- to comply with applicable laws, regulations, court orders, subpoenas and/or governmental requests, where we believe it is necessary to do so;
- to protect the rights, property, or safety of Laipac, our customers, or others;
- to establish, exercise, or defend our legal rights;
- to fulfill any other purpose for which you provide it;
- to carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collection purposes;
- to notify you about changes to our Website, our Apps, or our products / Services;
- in any other way we may describe when you provide the information; and
- for any other purpose with your consent.
B. Aggregate/De-Identified Data. We may aggregate and/or de-identify any information collected about you so that such information can no longer be linked to you or your device (“Aggregate/De-Identified Information”). We may use Aggregate/De-Identified Information for any purpose, including for research and marketing purposes, and may also share such data with any third parties, including advertisers, promotional partners, and sponsors.
4. How We Share Your Information
A. Affiliates and Other Third Parties. We may share your information with our affiliates as well as with third parties who provide certain services to us related to billing, sales, marketing, advertising, analytics, research, customer service, shipping and fulfillment, data storage, IT and security, fraud prevention, payment processing, and auditing and legal services.
B. Business Transfers. In connection with any possible business transaction or corporate restructuring, we may transfer customer data to a buyer (or potential buyer) or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which Personal Data held by Laipac about our customers is among the assets transferred.
C. Public Forums. Certain features of our Services make it possible for you to share comments publicly with other users. Any information that you submit through such features is not confidential, and we may use it for any purpose (including in testimonials or other marketing materials). For example, if you submit a product review via our Website or Apps, we may display your review (along with the name provided, if any) on our online properties as well as on third-party websites. Any information you post openly in these ways will be available to the public at large and potentially accessible through third-party search engines. Accordingly, please take care when using these features.
D. Legal Rights. We may share your information when we believe in good faith that doing so is necessary to protect, enforce, or defend the legal rights, privacy, safety, or property of Laipac, our affiliates, employees, agents, licensors, users, or any third party, or to comply with applicable law or legal process, including responding to requests from public and government authorities.
E. Consent/At Your Direction. We may share your information with your consent or at your direction, such as if you direct us to disclose your information to a healthcare provider.
5. Choices About How We Use and Disclose Your Information
A. We do not control the collection and use of your information collected by third parties described above in How We Share Your Information. When possible, these organizations are under contractual obligations to use this data only for providing the services and to maintain this information as strictly confidential. These third parties may, however, aggregate the information they collect with information from their other customers for their own purposes.
B. In addition, we strive to provide you with choices regarding the Personal Data you provide to us. We have created the following mechanisms to provide you with control over your Personal Data:
- Promotional Offers from Laipac. If you do not wish to have your email address used by Laipac to promote our own products and Services, you can opt-out at any time by clicking the unsubscribe link at the bottom of any email or other marketing communications you receive from us. This opt-out does not apply to information provided to Laipac as a result of a product purchase or your use of our Services.
6. Your Rights Regarding Your Information and Accessing and Correcting Your Information
You can review and change most portions of your Personal Data by logging into our Apps and visiting your account profile screen. You may also notify us through the email address provided in Section 15 below of any changes or errors in any Personal Data we have about you to ensure that it is complete, accurate, and as current as possible or to delete your account. We cannot delete your Personal Data except by also deleting your account. We may also not be able to accommodate your request if we believe it would violate any law or legal requirement or cause the information to be incorrect.
7. Do Not Track Signals
We may use automated data collection technologies to collect information about your online activities over time and across third-party websites or other online services (behavioral tracking). Some web browsers permit you to broadcast a signal to websites and online services indicating a preference that they “do not track” your online activities. At this time, we do not honor such signals and we do not modify what information we collect or how we use that information based upon whether such a signal is broadcast or received by us.
8. Information About Children
While we may collect information about children under the age of 16 from such children’s parent(s) or legal guardian(s), and we may allow parents and legal guardians to authorize their children who are 16 – 17 years of age to use a sub-profile created by the applicable parent or legal guardian, the Services are not otherwise designed for minors under the age of 18. We do not knowingly collect or solicit personal information from anyone under the age of 16. If you are under the age of 16, please do not attempt to register for the Services or send any personal information about yourself to us. If we learn that we have collected personal information from a child under the age of 16, we will delete that information as required by law. If you believe that a child under the age of 16 may have provided us personal information, please contact us at firstname.lastname@example.org .
9. Data Security
We have implemented measures designed to secure your Personal Data from accidental loss and from unauthorized access, use, alteration, and disclosure. We use encryption technology for information sent and received by us.
The safety and security of your information also depends on you. Where you have chosen a password for the use of our Apps, you are responsible for keeping this password confidential. We ask you not to share your password with anyone.
Unfortunately, the transmission of information via the internet is not always secure. Although we do our best to protect your Personal Data, we cannot guarantee the security of your Personal Data transmitted to our Website or on or through our Apps. Any transmission of Personal Data is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on the Website, in your operating system, or in the Apps.
10. Privacy Information for California Residents
A. If you are a California resident, California law requires us to provide you with some additional information regarding how we collect, use, and share your “personal information” (as defined in the California Consumer Privacy Act (“CCPA”)).
- Identifiers and contact information (e.g., name, address, email address, account names)
- Commercial and transactional information (e.g., information about your purchases)
- Financial information (e.g., credit card info collected by our payment processors)
- Internet or other network or device activity (e.g., IP address, browsing history, app usage)
- Geolocation information (e.g., general location and precise location, with your permission)
- Demographic and statistical data (e.g., your gender, interests based on products and services you use)
- Physical characteristics (e.g., photos of you)
- User-generated content (e.g., information you choose to post in our online forums)
- Customer service data (e.g., information you provide through a chat or call with Laipac’s Support Team)
D. We collect the categories of personal information identified above from the following sources: (1) directly from you; (2) through your use of the Services; (3) affiliates; and/or (4) third parties such as social networks and third-party intermediaries such as physicians, medical professionals, and pharmacies.
E. The business purposes for which we use the personal information we collect are: to manage, facilitate, and improve the Services; for research, marketing, and analytics; to communicate with users; for technical support and customer service; for security and fraud prevention; and for legal compliance and defense.
G. Your California Privacy Rights CCPA Rights Disclosure. If you are a California resident, the CCPA allows you to make certain requests about your personal information. Specifically, the CCPA allows you to request us to:
- Inform you about the categories of personal information we collect or disclose about you; the categories of sources of such information; the business or commercial purpose for collecting your personal information; and the categories of third parties with whom we share/disclose personal information.
- Provide access to and/or a copy of certain information we hold about you.
- Delete certain information we have about you.
The CCPA further provides you with the right to not be discriminated against (as provided for in applicable law) for exercising your rights. Please note that certain information may be exempt from such requests under California law. For example, we need certain information in order to provide the Services to you. We also will take reasonable steps to verify your identity before responding to a request.
H. If you are a California resident and you would like to exercise any of your data rights under California law, please email us at email@example.com or visit our request portal at https://www.Laipac.com. Please include your full name, email address and residential address associated with your use of our Services, along with the rights you would like to exercise, so that we can process your request in an efficient manner.
I. Sale of Personal Information. Laipac is not in the business of selling your personal information such as your name, email address, phone number, or postal address. Like many companies with an internet presence, we do work with third parties that provide marketing and advertising services to us, including interest-based advertising services, and these third parties may place tags, pixels, cookies, beacons, and other similar tracking mechanisms on our Website and Apps and collect your online identifiers. While we do not believe use of these vendors constitutes a “sale,” we do provide mechanisms for you to opt out of such tracking. To opt out of sharing your information with participating third parties for interest-based advertising, please visit the Network Advertising Initiative’s Consumer Opt-Out link, the Digital Advertising Alliance’s Consumer Opt-Out link, and Your Online Choices provided above in Section 5. Please note that these opt-outs are device and browser based, so you will need to opt out on each of your devices and browsers.
12. Third Party Privacy Practices
The European Union’s General Data Protection Regulation is an international standard for protecting the privacy of EU citizens. This law establishes important terms and definitions for whose data should be protected (data subjects), what types of data that entails (personal data), and how that data should be managed and secured. We comply with this regulation for data collected from EU citizens.
15. CAN SPAM Act
The CAN‐SPAM Act is a law that sets the rules for commercial email, establishes requirements for commercial messages, gives recipients the right to have emails stopped from being sent to them, and spells out tough penalties for violations.
We collect your email address in order to:
Send information, respond to inquiries, and/or other requests or questions.
Process orders and send information and updates pertaining to orders.
We may also send you additional information related to your product and/or service.
To be in accordance with CAN SPAM we agree to the following:
NOT use false or misleading subjects or email addresses.
Identify the message as an advertisement in some reasonable way.
Include the physical address of our business or site headquarters.
Monitor third‐party email marketing services for compliance if one is used.
Honour opt‐out/unsubscribe requests quickly.
Allow users to unsubscribe by using the link at the bottom of each email.
If at any time you would like to unsubscribe from receiving future emails, you can email us at firstname.lastname@example.org and we will promptly remove you from ALL correspondence.
Laipac Technology Inc.
25 Valleywood Drive Unit 11
Markham Ontario L3R 5L9 Canada