January 2024

Please read this privacy policy carefully before using the Code Word (Product) mobile application.

The purpose of this policy is to provide you, as a user of the Product, with information about:

1) The type of data we collect

2) What we do with your data

Code Word is committed to protecting and respecting your privacy.

Code Word Technologies Inc is a registered S Corporation registered at 4988 143rd Court North, Hugo MN, 55038.

Our leads for data protection are: Anuj Sharma: policy@ourcodeword.com and Eric Lovold: eric@ourcodeword.com

Scope of Policy
This policy sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us. Please read the following carefully to understand our practices regarding your personal data and how we will treat it.

This policy as set out at https://www.ourcodeword.com/privacy/ applies to your use of:

All Code Word properties (App) hosted on https://www.ourcodeword.com/privacy/ (App Site(s)) with which you have not been asked to agree to a separate Privacy Policy; collectively referred to as (App(s)), once you have downloaded or streamed a copy of the App onto your mobile telephone, tablet, handheld device or computer (Device)Any of the services accessible through the App(s) or any website services provided by Code Word (Services) that are available on the App Site(s) or other websites of Ours (Services Site(s)), unless the Website Terms and Conditions states that a separate privacy policy applies to a particular Service, in which case that privacy policy only applies.

Data Collection
If you are using our app you will have the opportunity to provide information which relates to your situation, and techniques and practices which may support you in a crisis or to support someone else. We recognize that this information may be sensitive to you. We commit to protecting this data in order to protect you.

The app allows the user to input sensitive information. The only information that is collected is detailed below. We collect this information so that you can use the app to support your mental health.The following information is collected within the app:

Safety Plan
The name of the person(s) to talk to when feeling suicidal or in crisis.
• The name of the person(s) or services to seek help from when feeling suicidal or in crisis.
• How you will calm yourself when feeling suicidal or in crisis.
• Ideas for staying safe when feeling suicidal or in crisis.
• Geographic (geo-location) information.

A list of contacts (their name, phone number, or other relevant details) that the user has selected specifically for contacting in an emergency from their existing device. The actual contact data is stored by the underlying operating system’s “Contacts” app.

Protected Health Information (PHI) is any health information that includes any of the 18 elements identified by HIPAA. Personally Identifiable Information (PII) is defined as data used in research that is not considered PHI and is therefore not subject to the HIPAA Privacy and security Rules.

Some personal information is collected in order to enable application functionality. Code Word stores this data in a de-indentified, token-id environment and does not have access to individual personal data.

Sensitive Personal Information
Data Protection Law recognizes that some categories of personal information are more sensitive. If you contact us via email or leave your email address when using the application or web experience, Code Word employees may be exposed to personal details.

We will only use this information:
For the purposes of dealing with your enquiry or suggestion
• Quality monitoring
• Evaluating the services we provide
• Triaging and resolving concerns

We collect minimum data items that are necessary for the use of the Code Word app and keep them for as long as is reasonable and necessary for the relevant activity, which may be to fulfill statutory obligations.

The app uses Google Analytics to collect anonymous usage data such as which app pages are being viewed, the length of page views, crash logs, diagnostics, and other app performance data. No personally identifiable information is collected. We use this general, aggregated, non-personal data for important and ethically acceptable purposes, such as conducting fully anonymized academic research.

We are fully compliant with international data management standards and do not send any data externally.

The website uses cookies to provide you with a good browsing experience.

Data Storage and Transfer
The app stores data on the device it is entered into - e.g. your phone.

If the user has an account, the data stored on their device is synchronized to the web app. Data is encrypted, and transferred and stored securely.

Anonymous usage data is transmitted to Google Analytics data, which is transmitted securely using Transport Layer Security (TLS) to that service.

Data stored on the device is secured by the device/operating system. Please keep your device up-to-date and regularly check for software updates.

Password Management
Before downloading the Product we advise users to set up basic password management on their devices. Examples of basic password management are: a screen lock or passcode.

For users of Apple devices you can learn more about protecting your device with a passcode here.

For users of Android users you can learn more about setting a screen lock here.

General Data Protection Regulation (GDPR)
We will at all times comply with the requirements of the General Data Protection Regulation (GDPR) 2018, including ensuring that there are appropriate technological and operational procedures in place to protect your information and that of other users.

Children and Young People
Code Word can be used by children and young people. Code Word is a preventive service, therefore we require parental consent for any age of a child. Learn more.

Third-party advertisers and links to other websites
The Product includes links to third-party websites. We do not provide any personally identifiable user information to these third-party websites.

Please be aware that we are not responsible for the privacy practices or content of such other websites. We encourage our users to be aware when they leave our site and to read the privacy statements of each and every web site that collects personally identifiable information. This privacy statement applies solely to information that we collect on this Service.

All guidance and information within the app are reviewed and updated every 6-months to check all resources are updated and links are in working order.

Location Information
We do not use GPS technology to determine your current location unless access is granted within the application (Product).

Changes to our privacy policy
We reserve the right to alter our Privacy Policy at any time. We will notify you of any alterations with reasonable notice through the service, such as by posting it on our website, by newsletter, or otherwise. When we post changes to this Privacy Policy, we will revise the "Last Updated" date at the top of this Privacy Policy and the revised Privacy Policy will come into effect on the date it was posted to our site or our app or as otherwise notified by us. We recommend that you check this page from time to time to inform yourself of any changes in this Privacy Policy. If you do not agree to the altered privacy policy or change in the purpose of data collection, you may stop using our Services.

Data Breaches
We will report any unlawful data breach of the app's database or the database(s) of any of our third-party data processors to any and all relevant persons and authorities within 72 hours of being aware of the breach if it is apparent that personal data stored in an identifiable manner has been stolen.

If you have any questions or concerns about the Privacy Policy or data processing or if you would like to make a complaint about a possible breach of local privacy laws, please contact us at info@ourcodeword.com.

Data Deletion
You are able to delete your data directly from in the app. If you did not create an account, the data is removed completely. If you created an account, you can delete your data entirely by logging into your account at stayalive.app and pressing the delete account button – this then gives you 24 hours in case you change your mind, before deleting entirely.

More Information
You can find out more about the personal information we hold about you and request us to delete it at any point. You can do this by contacting info@ourcodeword.com

We will respond as quickly as possible to any requests, and this will be no later than one calendar month from the day we receive a request.