Privacy Policy

‍Effective Date March 1, 2024

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Introduction

This Privacy Policy explains how Aware Healthcare Inc. (“Titan,” “Aware,” “we,” “us,” or “our”), doing business as Titan, collects, uses, and shares personal information across our services. This policy applies to:

1. Visitors to our website(s) (“Website Visitors”)
2. Users of the GameTape product and related services (“GameTape Users”)
3. Everyone who otherwise interacts with us (collectively, “you”)

By using our website, GameTape product, or other services that link to this policy, you agree to its terms.

‍Note: This Privacy Policy works in tandem with our Terms of Service, which describe additional conditions governing your access and use of our services. In the event of any conflict between this Privacy Policy and our Terms of Service regarding data handling, the Terms of Service may provide further detail.

We encourage you to regularly review this Privacy Policy as we may update it periodically to reflect changes in our data practices or applicable laws.

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Scope of this Privacy Policy

To help you find relevant information quickly, we’ve divided the policy into three main sections:

• Section A: Privacy Policy for Website Visitors
• Section B: Privacy Policy for GameTape Users
• Section C: General Privacy Practices (applicable to everyone)

Following these sections, you will find Your Privacy Rights, Data Protection & Security, and additional standard provisions.

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Section A

Privacy Policy for Website Visitors

This section applies to individuals who visit or interact with our website(s), whether or not they create an account or use the GameTape product.

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Information We Collect

1. Automatic Data Collection
   
   • Cookies and Similar Technologies: We use cookies, pixels, and other tracking technologies to understand website usage, enhance user experience, and potentially serve relevant advertisements.
   • Device and Usage Data: Information about your device (e.g., IP address, browser type, operating system) and how you interact with our website (e.g., pages viewed, links clicked, time spent).
2. Information You Provide
   
   • Contact details submitted through forms (e.g., name, email address).
   • Feedback or inquiries shared via our website.

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How We Use This Information

• To analyze website performance and improve usability.
• To secure our website against unauthorized access or misuse.
• We do not currently send marketing emails. Should this change, you will have the option to manage your email preferences or opt out.

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Your Choices as a Website Visitor

• Cookie Management: Configure preferences for essential vs. optional cookies through your browser or cookie banner (if required by law).
• Communications: If non-critical emails are introduced later, we will provide unsubscribe options or a “Manage Email Preferences” page.

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Section B

Privacy Policy for GameTape Users

This section applies to individuals or organizations using the GameTape product for coaching, analysis, or other purposes.

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Information We Collect

1. Account Data
   
   • Name, email address, phone number, and password.
   • No Payment Data at Present: GameTape is currently free. If we introduce paid plans, we will update this policy and comply with relevant payment security standards.

2. Recording and Participant Consent
   
   • Organizer Responsibility: The person scheduling or hosting the meeting is responsible for informing all participants that the session will be recorded. This may involve all-party consent requirements depending on local law.
   • Disclaimer: Titan provides recording & consent features but does not verify that you have obtained necessary permissions or consent. We do offer certain product features (e.g., on-screen notifications, prompts) to facilitate the gathering of participant consent. You should review and comply with any applicable recording or wiretap laws in your jurisdiction.

3. Coach Access
   
   • Users may grant a Coach permission to access specific recordings or analytics.
   • Separate Agreement: If you work with a Coach, a separate agreement applies to govern the Coach’s obligations, rights, and confidentiality requirements. This agreement is referenced in our Terms of Service.
   • You control whether a Coach can view your content and can revoke access at any time.

4. GameTape-Specific Data
   
   • Audio, Video, Transcripts, Metadata, Invitee Info: We capture and store meeting audio, video, transcripts, metadata (e.g., meeting title, timestamps, duration), and invitee identifiers (e.g., names or email addresses).
   • No Message/Annotation Ingestion: We do not capture in-meeting chat messages, direct messages, or annotations.

5. Device and Usage Data
   
   • Device details (e.g., operating system, browser type).
   • Logs on platform usage and performance metrics (e.g., connection quality).

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How We Use This Information

• To provide and enhance the GameTape product, including generating insights derived from meeting analytics.
• To troubleshoot issues, improve accuracy, and develop new features.
• To ensure compliance with our Terms of Service and to prevent misuse.

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Legal Grounds for Processing

We process personal data on the following bases:

1. Legitimate Interests: Providing, improving, and personalizing the GameTape product.
2. Service Provision: Fulfilling obligations under our Terms of Service.
3. Legal Obligations: Complying with applicable law or valid legal processes.
4. Consent: When you explicitly agree to specific data processing activities (e.g., recordings).

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Data Retention

• User-Defined Retention: You may delete meeting recordings via the platform at any time, and we will remove them within a commercially reasonable period unless legally required to retain them.
• Inactivity Deletion: If an account is inactive (no user interaction) for one year, we will attempt to notify you before deleting all associated data, subject to any legal retention requirements.

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Authentication via Google OAuth

We use Google OAuth for secure login. We only access essential profile details (e.g., name, email) needed to set up your GameTape account, unless additional explicit permissions are granted.

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Disclosure of Subprocessors

We engage the following trusted third-party providers (“Subprocessors”), bound by contractual obligations:

• Recall.ai: Captures audio/video under our instructions.
• Supabase: Provides database storage services.
• Replit: Handles back-end processing tasks.
• Vercel: Hosts the front-end user interface and certain API functionalities.

For a full list of subprocessors or questions on data processing, contact us at privacy@withtitan.com.

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Section C

General Privacy Practices

These practices apply to all users, including Website Visitors and GameTape Users.

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How We Share or Disclose Your Personal Information

We may share personal information with:

1. Service Providers: For analytics, hosting, and customer support (bound by confidentiality).
2. Professional Advisors: Such as lawyers, accountants, and auditors, as necessary.
3. Authorities & Law Enforcement: In response to valid legal requests, including national security or law enforcement requirements. Where feasible and lawful, we will attempt to notify you before disclosing data. We also reserve the right to challenge overly broad or unlawful requests.
4. Business Transferees: During mergers, acquisitions, or other corporate transactions under appropriate confidentiality obligations.

We do not sell personal information for monetary gain. If we ever share personal data in a way that qualifies as a “sale” under certain privacy laws, users in affected jurisdictions will be notified and given the right to opt out.

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Your Privacy Rights

This section consolidates your rights under various jurisdictions, such as the European Economic Area (EEA) and California (CCPA/CPRA). If you have any questions or wish to exercise any of these rights, please contact us at privacy@withtitan.com. We typically respond within 30 days, unless we require an extension.

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General Rights (including GDPR)

• Access: Request a copy of your personal data and information on how we process it.
• Correction: Have inaccurate or incomplete data corrected.
• Deletion: Request deletion of personal data, subject to legal or contractual exceptions.
• Restriction: Restrict certain types of processing if you dispute its accuracy or lawfulness.
• Portability: Obtain your personal data in a structured, machine-readable format.
• Objection: Object to data processing based on legitimate interests or direct marketing.
• Withdraw Consent: Where processing is based on consent, withdraw it at any time.

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California Resident Rights (CCPA/CPRA)

• Right to Know: The categories of personal information we collect, how it’s used, and with whom it’s shared.
• Right to Delete: Request deletion of personal information (with lawful exceptions).
• Right to Correct: Request correction of inaccurate data.
• Right to Opt Out: If personal information is sold or shared, opt out of such sales/sharing.
• Right to Non-Discrimination: We will not discriminate against you for exercising these rights.

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Data Protection & Security

• Security Measures: We implement industry-recognized safeguards, including encryption in transit, secure hosting, and strict access controls. While no system is entirely immune from intrusion, we have established incident response procedures to notify affected users and relevant authorities in the event of a data breach, as required by law.
• International Data Transfers: Our servers are primarily located in the United States. Where data is transferred to jurisdictions with differing privacy laws, we employ appropriate transfer mechanisms, such as Standard Contractual Clauses (SCCs), to protect your personal data in accordance with applicable legal requirements.

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Children’s Privacy

We do not knowingly offer our services to individuals under 16. If we discover that a child under 16 has provided us personal information without proper consent, we will take steps to delete that information as soon as possible and may take additional measures per local law.

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Changes to This Privacy Policy

We may modify this Privacy Policy at any time. If we make material changes, we will provide notice through our website or other appropriate channels. Continuing to use our services after any posted changes indicates your acknowledgment of those updates. We encourage you to review this Privacy Policy periodically for the latest information on our practices.

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Contact Us

For any questions, requests, or concerns regarding this Privacy Policy, please contact us at:

Email: privacy@withtitan.com

We aim to respond to all inquiries promptly. If your concern is urgent or involves sensitive information (e.g., a potential data breach), please make this clear in your communication so we can prioritize accordingly.

‍Disclaimer: While we strive to comply with all applicable privacy regulations, nothing in this policy should be construed as legal advice. If you have specific legal questions or concerns about our data practices, we encourage you to consult with an attorney.