Legal Document
Privacy Policy
1. Introduction
This Privacy Policy explains how SafePhone Inc. (“SafePhone,” “we,” “us,” or “our”) collects, uses, discloses, retains, and otherwise processes personal information when our services are used in connection with websites, dashboards, enrollment tools, support channels, managed Android devices, and related services (collectively, the “Services”).
For the use case covered by this Policy, SafePhone provides device-management services to organizational customers, including recovery centers or program providers that own Android devices and issue them to active participants within a structured inpatient or supervised residential recovery program.
2. Scope
This Privacy Policy applies to personal information processed in connection with organizational customers, program administrators and authorized staff, active participants who are issued organization-owned devices, support requests and communications, pilot and onboarding activities, and website visitors and prospective customers.
3. Roles and Ownership
For this deployment model, the organizational customer owns the managed devices, determines how those devices are issued within its program, and uses SafePhone to provide enrollment, policy configuration, management, support, and related services for the organization-owned device environment.
Program participants are not the owners of the managed devices. Issuance of a device to a participant does not transfer ownership of the device to that participant.
4. Information We Collect
We may collect information provided by organizational customers or authorized representatives, including organization name, administrator name, business email address, business phone number, billing and account information, support and implementation communications, and deployment, device, and program configuration information.
Where applicable, we may collect information provided by participants or collected during device issuance or support, including participant name or identifier, contact information, support requests, acknowledgments or acceptance of required disclosures, and other information voluntarily submitted through support or onboarding flows.
When a device is enrolled and managed through SafePhone, we may collect information reasonably necessary to provide, secure, support, and troubleshoot the Services, including device identifiers, model and manufacturer, Android version and related system details, enrollment status, last-seen or check-in information, device name, applied policies, restrictions, or configuration state, and security and operational status information needed to provide the Services.
Depending on device capability and enabled features, this may include information such as serial number, battery status, rooted status, network information, and other device-state information relevant to management and support.
5. How We Use Information
We may use personal information to create and manage customer accounts, authenticate administrators and users, enroll and manage devices, apply, maintain, and display policies, restrictions, and configurations, provide participant communication and program-related device functionality, operate support, onboarding, and pilot workflows, maintain security and prevent abuse, monitor device status and compliance, troubleshoot and improve the Services, send service, security, support, and administrative communications, process billing and subscription information, and comply with law, enforce our agreements, and protect rights and safety.
6. Disclosures to Participants
Where this deployment model is used, participants are provided disclosures regarding SafePhone’s access to and use of service data in connection with the managed device environment.
Participation in the program and use of the device may require acceptance of those disclosures, as determined by the organizational customer and applicable law.
7. How We Share Information
We may share information with the organizational customer and its authorized administrators; with service providers that help us provide the Services, such as hosting, support, security, authentication, payment, and infrastructure providers; in connection with a merger, financing, acquisition, or sale of assets; to comply with law, legal process, or government request; and to protect rights, property, safety, security, or enforce our agreements.
We do not sell personal information in exchange for money. We do not use third-party ad networks to serve third-party ads through the Services.
8. Monitoring Boundaries
SafePhone is not intended to be used for covert monitoring, unlawful interception, or undisclosed surveillance.
Information processed through the Services is intended to support the managed device environment authorized by the organizational customer and disclosed to participants as required.
9. Post-Participation, Collection, and Reassignment
When a participant’s use of an organization-owned device ends, or when the organization requires collection of the device, the device may be collected by the organization for wipe, re-enrollment, reconfiguration, or reassignment.
We may continue to process information reasonably necessary to document enrollment and device lifecycle events, support collection, wipe, re-enrollment, or reassignment workflows, maintain security, comply with legal obligations, resolve disputes, and retain appropriate business records.
Participants should not assume that information stored on an organization-owned device will remain available after the device is collected, wiped, or reassigned.
10. Retention
We retain information only as long as reasonably necessary for the purposes described in this Privacy Policy, including to provide the Services, support enrollment and device lifecycle management, maintain security, comply with law, resolve disputes, enforce our agreements, and keep appropriate business and legal records.
Retention periods may vary by information type and account state. Some information may remain in backups or archives for a limited time before deletion.
11. Security
We use reasonable administrative, technical, and organizational measures designed to protect personal information. No system can be guaranteed 100% secure.
12. International and Cross-Border Processing
We may process information in Canada and other jurisdictions where we or our service providers operate. Information may be subject to lawful access by courts, regulators, or authorities in those jurisdictions.
13. Your Choices
Depending on your role and applicable law, you may be able to update account information, manage subscriptions and billing, manage cookie preferences, contact us regarding privacy questions, and exercise applicable privacy rights.
Participants who use organization-owned devices should also refer to the organizational customer’s program rules and notices, since the organization controls device issuance and administration within the program.
14. Children
The Services are not directed to children as account holders. Where devices are issued within a program environment, the organizational customer is responsible for lawful use and any required notice or consent.
15. Changes to This Policy
We may update this Privacy Policy from time to time. If we make material changes, we will provide notice as appropriate and as required by law.
16. Contact Us
Company: SafePhone Inc.
Mailing Address: 30 Powerhouse Street, Suite 101, Toronto, Ontario, M6H 0C6, Canada
Privacy: privacy@safephone.net