Effective Date: May 1, 2023

Welcome!

DUOS Living, Inc. (“DUOS”) offers a way for older adults to connect to the outside world from their own home, for both virtual and in-person services—whether it be connecting with the assigned duo (the “Duo”) for assistance with setting up grocery delivery, transportation to doctor appointments, meal prep or just simple, old fashioned companionship, we’ve got you covered! DUOS is committed to responsible information management practices. Older adult users (“Member” or “Members”), healthcare providers, health plans, employers and/or insurance providers (“ Member Network”) and all other users (all of which taken together may collectively be referred to as “User” or “Users”), are all bound by, and should read this DUOS Privacy Policy (“Privacy Policy”), very closely. As a part of that commitment, this Privacy Policy is an effort to provide Users of our services, websites (“Website”) and/or mobile application (“Mobile App”)(collectively, the “Services”), with a clear understanding of how we collect your information, how we use the information we collect, with whom we disclose such information, and the steps we take to secure the information we collect. By using our Services, you consent to the collection, use and sharing of your information by DUOS in accordance with this Privacy Policy. 

Please read the following sections carefully to learn how we collect, use, disclose and store your information.
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  1. The Information We Collect
  2. How We Collect Information
  3. How We Use Information
  4. How We Disclose Your Information to Third Parties
  5. How Your Information Is Secured
  6. How Long Your Information Is Retained
  7. HIPAA Notice of Privacy Practices
  8. Children’s Privacy
  9. California Privacy Rights
  10. Modification of Privacy Policy
  11. Contact Information
  12. Accessibility
  13. DUOS Cookie Policy
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The Information We Collect

1. Personally Identifiable Information and Sensitive Personal Information. This category includes information that would allow us to identify you personally. Some examples of personally identifiable information are:

     a. your name

      b. your address

      c. your e-mail address 

      d. your phone number(s) 

     e. your birthdate

      f. your account number

      g. your insurance information

     h. your family member or caregiver contact information.
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2. Billing Information. This category includes information, such as your credit card number, that allow us to charge you for Services that you order.

3. Health Information. This category includes information about your mental and physical health. Some examples of health information include your prescriptions, diagnoses and how you are feeling. 

‍4. Technical Information. This category includes information related to how you access the Services through your computer or mobile device. Some examples include website “traffic” data, your IP address (an IP address is a number automatically assigned to your computer in order to use the Internet), the type of computer or device you are using and the internet browser you use. 

5. Other Information: This category refers to information that does not directly identify a specific individual. Some examples of other information are: 

      a. Information relating to the total number of visitors to the Services, the number of visitors to a particular page of the Services 

     b. Certain technical information to diagnose problems with the Services 

     c. Demographic, geographic and other information that does not directly identify you, which may be used to improve our services or marketing efforts 

     d. Aggregated and/or anonymized data that is derived from Personally Identifiable Information and is no longer identifiable to you.
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How We Collect Information

  1. You provide us information. DUOS will collect information voluntarily provided to us by you, including when you:

     a. Enroll in our Services either online or via a telephone call, 

      b. Interact with your Duo via email, phone call (including a prerecorded and/or automated call), SMS text or in person, 

      c. Engage with the Member Network through the Services, 

      d. Share information with family members through the Services, 

      e. Complete a survey, information or service request, promotional contest, or participate in a give-away or by similar voluntary methods. 

  1. We collect information about you from third parties. DUOS may collect information about your from third parties, including third-party platforms and/or service providers, and your Member Network.
  1. We use technology to passively collect information. DUOS may collect information, which may include Personally Identifiable Information, automatically when you visit the Services. Information may be collected using technologies such as Google Analytics, standard server logs, cookies, pixels, and clear GIFs or Web beacons. You may block or delete cookies and control data collection through your web browser settings. To learn more about how we use cookies and your choices, please review our Cookie Policy at the end of this Privacy Policy. 

How We Use Information

Information we collect is used for the following purposes:

  1. To provide you with the services you request;
  2. To address Member inquiries or issues;
  3. To maintain Member accounts and dealings;
  4. To process Member payments;
  5. To customize and improve the Services;
  6. To facilitate connections and communications between you and DUOS, your Duo, your Member Network and/or third party service provider to which you request (e.g., Uber)
  7. To provide marketing and promotional efforts, including retargeting;
  8. To enforce agreements and comply with laws; 
  9. For administrative purposes, including to notify you when updates to the Services are available or if there are any changes to these terms; 
  10. To communicate and interact with social networking services (“SNS”) as further described herein;
  11. To create aggregate and anonymous information which may be used to create benchmark reports or analyze use of the Services and/or with respect to reporting obligations with DUOS’ Third Party Partners; and
  12. For any other purpose for which you consent. 
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You may opt out of receiving future promotional communications from us by emailing us at support@getduos.com.
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Third Party Advertising Partner Opt-out: Our third-party advertising partners may collect data about your visits to the Services to help them better understand your advertising preferences, and provide you with offers they believe you will be interested in. You may opt out of receiving certain advertising tailored to you from third parties. If you would like to opt out of behavioral advertising or to learn more, please visit 

 

How We Disclose Your Information to Third Parties

DUOS may share your information in the following situations:
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  1. DUOS Operational Service Providers: We may share your information, including Personally Identifiable Information, with third parties or affiliates to assist in our business operations or to provide the services you have requested. Examples include disclosing your information to our vendors that process payments, host our customer relationship management tool, or disclosing information to our cloud data warehouse provider to store your data. These service providers enter into contractual relationships with DUOS requiring these service providers to only use this information as necessary to provide the services to you and DUOS. 
  2. Third Party Service Providers: In connection with the Services, we may help you obtain the services of other third parties, such as car-sharing services or grocery delivery services. We may share your information with these third party service providers upon your request. However, please note that these third party services are not under the control of DUOS and if you click on any links to such services, you understand and agree that those linked websites and services are subject to and governed by their own separate terms and privacy policies. 
  3.  Member Network: DUOS may share your information, including your Personally Identifiable Information, with your Member Network, family members or other caregivers, as authorized by you, and as necessary to provide you with the Services. If you are a Member Network, information you provide may be shared with the Member, and subject to the Member’s consent, may also be shared with other third parties (e.g., family members or caregivers of the Member).
  4. Business Transfers: We may share your information, including Personally Identifiable Information, as part, of or in connection with, a merger, acquisition, assignment, as part of debt financing, the sale of company assets, or in any similar transaction, or to the extent as may be required in the unlikely event of insolvency bankruptcy, or a receivership.
  5. Social Networks: Certain SNS may link-to the Services (e.g., Instagram, Facebook and/or LinkedIn). These SNS maintain their own privacy policies and policies relating to data collection, retention and use, and to the extent that you elect to utilize the SNS linking within the Services, you acknowledge and agree to comply with any of these third party terms, in addition to acknowledging, that except where prohibited by law, DUOS is not liable or responsible for any use of the SNS that you elect to engage in. These SNS may receive your data when you visit or use their services or through third parties they work with. 

How Your Information Is Secured

  1. We employ safeguards designed to help preserve our Users’ security and privacy and to help prevent the misuse of any Personally Identifiable Information. These safeguards are consistent with industry standards. In addition to other procedural safeguards, we use security software (SSL, or Secure Sockets Layer, technology) and firewalls to protect your information.
  2. Unfortunately, no data transmission over the Internet or any wireless network can be absolutely secure. As a result, while we strive to protect your Personally Identifiable Information, we can make no representations or warranties regarding the security of any data exchanged through the Services. There are potential security risks beyond our control. With this in mind, by using the Services you acknowledge that you are transmitting data through the Services at your own risk.

How Long Your Information Is Retained

We retain relevant Personally Identifiable Information related to your account and/or your business relationship with us pursuant to applicable federal and state rules and regulations and so long as retaining said Personally Identifiable Information is necessary including, but not limited to, the duration of time that you utilize the Services, the duration for which any amounts owed to DUOS are due by you, and a reasonable period after termination of any business relationship. Information may persist in copies made for backup and business continuity purposes for additional time.
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HIPAA Notice of Privacy Practices

The Health Insurance Portability and Accountability Act (“HIPAA”) may apply to information disclosed to DUOS directly from Covered Entities (as defined under HIPAA), including your healthcare provider and health plans. DUOS’ use of Protected Health Information (as defined under HIPAA) collected directly from your healthcare provider or health plan will comply with the applicable HIPAA Notice of Privacy Practices. Please contact your health care provider or health plan for a copy of its HIPAA Notice of Privacy Practices. For clarity, information that you provide directly to us is not governed by HIPAA.
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Children’s Privacy

We do not intentionally collect data from children under the age of 13. The Services is not directed to children under 13 and children under 13 should not use the Services. If we learn that we have inadvertently collected any such data, we will delete it as soon as possible.
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US State Privacy Rights Generally,
and Data Privacy Law overlap with other laws governing Sensitive Information and Member Consents

States have enacted, and continue to enact, data privacy regulations and laws to protect their resident Consumers from misuse of their personal data by large companies or companies that process personal information to make profits (“Data Privacy Laws”). Although DUOS does not meet the criteria and minimum thresholds under respective Data Privacy Laws to face enforcement actions, DUOS complies with Data Privacy Laws because such regulations and laws are consistent with DUOS’ business philosophy of respect for a person’s rights. Further, there are other applicable laws, where DUOS is required to comply.

The other regulations and laws that overlap with the content and protections in Data Privacy Laws include the Health Insurance Portability and Accountability Act of 1996 (“HIPAA”) and the Telephone Consumer Protection Act of 1991 (the “TCPA”) as amended. As a result of this growing body of regulations, laws and requirements, including Data Privacy Laws, HIPAA and the TCPA, DUOS may ask for certain Member and Member Network consents periodically during your association with DUOS (“Consents”). Such Consents may seem duplicative, but they are required by law and intended to ensure Members and your friends and family understand and agree to DUOS uses of your Personal Information and Sensitive Information. Many laws have specific requirements for the form of Consents which may lead to an appearance of duplication. We may ask for periodic confirmations. Thank you for understanding this is the intent behind the Consents, and please understand that Member and Member Network Consents are a vital precondition for receiving some or all features of the DUOS services.

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California Privacy Rights 

If you are a California resident, please review our California-specific privacy practices, available here: https://www.getduos.com/ccpa-policy

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Virginia Privacy Rights 

If you are a Virginia resident, you have rights similar to the California-specific privacy practices, except with different procedures and some additional  rights. You may file claims with the Virginia Attorney General’s Office and they will investigate and process claims directly with the company on your behalf. In addition, Virginia has a process granting you the right to appeal decisions.  

For Virginia residents, more information may be found by following this link: https://law.lis.virginia.gov/vacodefull/title59.1/chapter53/

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Emerging US Jurisdictions' Privacy Rights 

Colorado and Connecticut have data privacy laws that are coming on-line soon. Colorado’s law was passed in July 2021 and will be effective beginning July 1, 2023.  Connecticut’s law was passed in May 2022 and will be effective beginning July 1, 2023.  If you are a Colorado or Connecticut resident, more information may be found by following the applicable links below:

Colorado: https://leg.colorado.gov/bills/sb21-190

Connecticut: https://portal.ct.gov/AG/Sections/Privacy/The-Connecticut-Data-Privacy-Act

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Privacy — Telephone Consumer Protection Act 

The Telephone Consumer Protection Act of 1991 (TCPA) amended the Communications Act of 19341 and was enacted to address telephone marketing calls and certain telemarketing practices. The Federal Communications Commission (FCC) has regulatory authority under the statute. The FCC revised its regulations twice in 2019 to provide a safe harbor from liability for making calls to reassigned telephone numbers and to eliminate the requirement for an opt-out notice on fax advertisements sent with the recipient’s prior express permission or consent. The FCC further revised its regulation in 2021 to implement the Pallone-Thune Telephone Robocall Abuse Criminal Enforcement and Deterrence Act (TRACED Act), in which it codified exemptions for calls to wireless numbers, amended exemptions for artificial or prerecorded voice calls made to residential telephone lines, and included exemptions for calls by financial institutions provided the call is not charged to the called person’s plan limits on minutes or texts. Finally, there are new updates signed into law at the end of 2022, to be effective 6/27/2023, that further refine your rights and 3rd party obligations under the exemptions that are not applicable where you have given consent.

TCPA Law: https://www.fdic.gov/resources/supervision-and-examinations/consumer-compliance-examination-manual/documents/8/viii-5-1.pdf

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Modifications to Privacy Policy

From time to time, we may update this Privacy Policy to reflect changes to our information practices. If we make changes to this Privacy Policy, they will be reflected in an updated Privacy Policy that will be posted on the Services, and all changes will be effective upon such posting or upon any later date specified by us in writing. We encourage you to periodically review this page for the latest information on our privacy practices. You can determine when this Privacy Policy was last revised by referring to the "Effective Date" at the top of this Privacy Policy. By continuing to use the Services or any services following the effective date of any updated Privacy Policy, you understand the applicability of the terms and conditions of such updated Privacy Policy.
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Contact Information

If you have any inquiries regarding our Privacy Policy, you may email us or write us at the addresses noted below, though please note that emails typically have a much quicker response time than snail mail (it is called snail mail for a reason ☺!) 

Email us at: support@getduos.com

Write us at: DUOS Living, Inc., 218 Washington Avenue North, Suite 240, Minneapolis, MN 55401
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Accessibility

If you have a disability and need access to our privacy policy in a different format, please:

Email us at: support@getduos.com or write us at: DUOS Living, Inc., 218 Washington Avenue North, Suite 240, Minneapolis, MN 55401


DUOS Cookie Policy

https://www.getduos.com (the “Site”) uses cookies to distinguish you from other users of our site. This helps us to provide you with a good experience when you browse our site and also allows us to improve it. A cookie is a small file of letters and numbers that we store on your browser or the hard drive of your computer. Cookies contain information that is transferred to your computer’s hard drive. DUOS’ Privacy Policy explains how we collect and use information from and about you when you use our Site and our products and services. This Cookie Policy explains more about how we use cookies and your related choices.

We use the following Cookies:
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  1. Strictly Necessary Cookies
    These are cookies that are required for the operation of our site. They include, for example, cookies that enable you to log into secure areas of our site or use a shopping basket.
  2. Analytical/Performance Cookies
    These allow us to recognize and count the number of visitors and to see how visitors move around our site when they are using it. This helps us to improve the way our site works, for example, by ensuring that users are finding what they are looking for easily.
  3. Functionality Cookies
    These are used to recognize you when you return to our site. These cookies also help the site remember where you were in the registration process so you don’t have to start over! These cookies also enable us to personalize our content for you and remember any preferences (for example, your choice of language or region). Please note that third parties (including, for example, certain third party providers, advertising networks and providers of external services like web traffic analysis services) may also use cookies, over which we have no control. These cookies are likely to be analytical/performance cookies or targeting cookies.

In addition, DUOS’ Site, the services and the Mobile App may use both session cookies (which expire once you close your web browser) and persistent cookies (which stay on your computer or mobile device until you delete them).

We may use two broad categories of cookies: (1) first party cookies, served directly by us to your computer or mobile device, which we use to recognize your computer or mobile device when it revisits our Site; and (2) third party cookies, which are served by service providers or business partners on our Site, and can be used by these parties to recognize your computer or mobile device when it visits other websites. Third party cookies can be used for a variety of purposes, including site analytics, advertising and social media features.

Your Choices About Cookies

You can block cookies by activating the setting on your browser that allows you to refuse the setting of all or some cookies. However, if you use your browser settings to block all cookies (including essential cookies) you may not be able to access all or parts of our site. Cookies will expire after a period of time. For more information about cookies, including information on how to block cookies on your browser (including third party cookies) please visit www.aboutcookies.org (this is an external link and we are not responsible for its content). 

We may alter this CookiePolicy at any time. You are therefore advised to check the policy on our website from time to time. If you would like to know more about how we use cookies, please contact us at support@getduos.com.

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