RespSafety Privacy Policy 

EFFECTIVE DATE: June 12, 2023

Arbor Environmental, LLC dba RespSafety (“RespSafety”) is a service that facilitates online clearance of respirators for individuals and companies. We offer a convenient online respirator medical evaluation solution to, among others, help employers protect their employees and meet OSHA requirements for fit testing in a cost-efficient way. We are not a medical service provider, health care provider, virtual clinic, pharmacy, or health insurance company. The Service itself cannot and is not intended to provide medical diagnosis, guidance, or advice. This RespSafety Privacy Policy (“Policy”) describes how RespSafety collects, uses, discloses and otherwise processes the personal information described in this Policy, as well as the choices individuals have regarding such personal information. 

For information about the privacy choices, you have regarding your personal information, review Section 7. Your Privacy Choices below. 

Your use of our Services (defined below), and any dispute over privacy, is subject to this Policy and our Terms of Service, available at https://respsafety.com/terms-of-service/, including their applicable limitations on damages and the resolution of disputes. 

1. Scope

Except as otherwise noted below, this Policy applies to the personal information that RespSafety processes as a business related to: 

• users of our websites where this Policy is posted, including at respsafety.com, the customer portal we offer, and the services we provide through these, as well as any downloadable software, applications, and other products and services provided by us that display or include a link to this Policy (collectively, the “Services”).
• individuals who register for or participate in our webinars, trainings, and other events;  
• current, former and prospective customers, vendors and partners; 
• individuals who are subscribed to receive news, information and marketing communications from us; 
• individuals who participate in surveys and research conducted by us; and
• individuals that communicate with us or otherwise engage with us related to our Services.

Not In Scope. This Policy does not apply to the personal information that we collect and process about RespSafety employees and personnel or job applicants and candidates.

2. Personal Information Collected

As further described below, we collect personal information directly from individuals, from third parties, and automatically when such data relates to the use of our Services or other interactions with us.

Personal Information Collected Directly. The personal information we collect from you depends upon how you use our Services or otherwise interact or engage with us, but generally includes: 

• Registration and profile information. When you register for an account with us, we collect certain personal information from you, such as your name and email address, as well as any personal information you post to your account, or that you otherwise submit to us through your account. 
• Health-related Information. When you submit the OSHA Respirator Medical Evaluation Questionnaire (Appendix C to § 1910.134) in order for us to assess your ability and fitness to wear a respirator at work or home.
• Payments and purchases. When you make a purchase or payment through the Services, we collect purchase and payment information in order to facilitate the processing of your payment by our third party payment processor, such as the last four digits of your credit card number, credit card type, credit card issuer, and applicable billing address. We also maintain records about your past purchases, as well as items that you view or add to your cart.  
• Communications and interactions. When you email, call, or otherwise communicate with us and with members of our team, we collect and maintain a record of your contact details, communications and our responses. We also maintain records communications and information that you post in chat sessions, forums and in other areas of the Services, well as on our social media channels, and information you provide to us related to any customer support requests.
• Promotions. If you participate in promotions that we offer, we will collect your name, email address, and other registration information related to the promotion.
• Events, training, and other requests. We may also collect personal information related to your participation in our events and trainings, as well as other requests that you submit to us related to our Services. For example, if you register for or attend an event or training that we host or sponsor, we may collect information related to your registration for and participation in such event or training. When you fill out a ‘Contact Us’ form or otherwise request information from us, we collect and maintain records of your requests.

Personal Information from Third Parties. We may collect personal information about you from third party sources, such as public databases, joint marketing partners, social media platforms or other third parties. 

• We may receive lead and prospect information from third parties, about prospective customers that may be interested in our Services. We may also engage with third parties to enhance or update our customer information.
• If you post information about us or engage with us on third party platforms or choose to link your RespSafety account to or log in to our Services with a third-party account (e.g., Facebook or Google), we may collect personal information about you from that third party platform or account. These third-party platforms and services control the information they collect and share about you. For information about how they may use and disclose your information, including any information you make public, please consult their respective privacy policies.

Personal Information Collected Automatically. We automatically collect personal information related to your use of our Services and interactions with us and others, including information we collect automatically (e.g., using cookies and pixel tags), as well as information we derive about you and your use of the Services. Such information includes:

• Device and browsing information. We use cookies, log files, pixel tags and other tracking technologies to automatically collect information when users access or use our Services, such as IP address, general location information, domain name, page views, a date/time stamp, browser type, device type, device ID, Internet service provider, referring and exiting URLs, operating system, language, clickstream data, and similar device and usage information. For more information, see Section 6. Cookies, Targeting and Analytics, below.
• Activities and usage. We also collect activity information related to your use of the Services, such as information about the links clicked, features used, items viewed, time spent within the Services, files uploaded or deleted, products and items you view and items you add to your cart, your interactions with others within the Services.
• Location information. We may collect or derive location information about you, such as through your IP address. 

3. Personal Information Collected

Generally, we collect, use, disclose and otherwise process the personal information we collect for the following purposes:

• Services and support. To provide and operate our Services, communicate with you about your use of the Services, provide troubleshooting and technical support, respond to your inquiries, fulfill your requests, process your payments, communicate with you about the Services, and for similar service and support purposes. 
• Analytics and improvement. To better understand how users access and use the Services, and our other products and offerings, and for other research and analytical purposes, such as to evaluate and improve our Services and business operations, to develop services and features, and for internal quality control and training purposes. 
• Marketing and advertising. For marketing and advertising purposes. For example, to send you information about our Services, such as offers, promotions, newsletters and other marketing content, as well as any other information that you sign up to receive. We also may use certain information we collect to manage and improve our advertising campaigns so that we can better reach people with relevant content.
• Planning and managing events. For event planning and management, including registration, attendance, connecting you with other event attendees, and contacting you about relevant events and Services. 
• Research and surveys.To administer surveys and questionnaires, such as for market research or member satisfaction purposes.
• Security and protection of rights. To protect the Services and our business operations; to protect our rights or those of our stakeholders; to prevent and detect fraud, unauthorized activities and access, and other misuse; where we believe necessary to investigate, prevent or take action regarding illegal activities, suspected fraud, situations involving potential threats to the safety or legal rights of any person or third party, or violations of our Terms of Service. 
• Compliance and legal process. To comply with the law and our legal obligations, to respond to legal process and related to legal proceedings.  
• General business and operational support. To consider and implement mergers, acquisitions, reorganizations, bankruptcies, and other business transactions such as financings, and related to the administration of our general business, accounting, auditing, compliance, recordkeeping, and legal functions. 

4. Disclosures of Personal Information

We may disclose the personal information that we collect for the purposes described above, in order to provide our Services to you, to respond to and fulfil your orders and requests, as otherwise directed or consented to by you, and as follows: 

• Vendors and service providers. We may disclose personal information we collect to our service providers, processors and others who perform functions on our behalf. These may include, for example, IT service providers, payment processors, analytics providers, consultants, auditors and legal counsel. 
• Our affiliates. We may disclose personal information we collect to our affiliates or subsidiaries, who will use and disclose this personal information in accordance with the principles of this Policy. 
• Our business clients. Where your employer requests the completion of the OSHA Respirator Medical Evaluation Questionnaire, we may disclose to your employer that you have completed the questionnaire and your status (i.e., whether or not you are fit and able to wear a respirator).
• Third party platforms, providers and networks. We may disclose or make available personal information to third party platforms and providers that we use to provide or make available certain features or portions of the Services, or as necessary to respond to your requests. We may also make certain information that includes personal information available to third parties in support of our marketing, analytics, advertising and campaign management (see Section 6. Cookies, Targeting and Analytics for more information).
• In support of business transfers. If we or our affiliates are or may be acquired by, merged with, or invested in by another company, or if any of our assets are or may be transferred to another company, whether as part of a bankruptcy or insolvency proceeding or otherwise, we may transfer the information we have collected from you to the other company. We may also share certain personal information as necessary prior to the completion of such a transaction or corporate transactions such as financings or restructurings, to lenders, auditors, and third-party advisors, including attorneys and consultants, as part of due diligence or as necessary to plan for a transaction.
• Compliance and legal obligations. We may also disclose personal information to third parties to comply with our legal and compliance obligations and to respond to legal process. For example, we may disclose information in response to subpoenas, court orders, and other lawful requests by regulators and law enforcement, including responding to national security or law enforcement disclosure requirements. This may include regulators, government entities, and law enforcement as required by law or legal process. In addition, it may include certain disclosures that we are required to make under applicable laws, such as the names of sweepstakes and contest winners.
• Security and protection of rights. We may disclose personal information where we believe doing so is necessary to protect the Services, our rights and property, or the rights, property and safety of others. For example, we may disclose personal information in order to (i) prevent, detect, investigate and respond to fraud, unauthorized activities and access, illegal activities, and misuse of the Services, (ii) situations involving potential threats to the health, safety or legal rights of any person or third party, or (iii) enforce, and detect, investigate and take action in response to violations of, our Terms of Service. We may also disclose information, including personal information, related to litigation and other legal claims or proceedings in which we are involved, as well as for our internal accounting, auditing, compliance, recordkeeping, and legal functions.

5. Aggregate Data and Non-identifiable Data

We may use and disclose aggregate and other non-identifiable data related to our business and the Services for quality control, analytics, research, development and other purposes.

6. Cookies, Targeting and Analytics

We and our third-party service providers use cookies, pixels, local storage objects, log files, APIs, and other mechanisms to automatically collect information browsing, activity, device and similar information within our Services and to target advertising and content across our Services and third-party sites and services. We use this information to, for example, analyze and understand how users access and use our Services, as well to identify and resolve bugs and errors in our Services and to assess secure, protect, optimize and improve the performance of our Services. You have certain choices about our use of cookies and tracking within the Services, as described in this section. For more information on the types of personal information we collect via cookies and similar mechanisms, please see Section 2. Personal Information Collected.

Cookies. Cookies are alphanumeric identifiers that we transfer to your device’s hard drive through your web browser for record-keeping purposes. Some cookies allow us to make it easier for you to navigate our Services, while others are used to enable a faster log-in process, support the security and performance of the Services, or allow us to track activity and usage data within Service.  

Pixel tags. Pixel tags (sometime called web beacons or clear GIFs) are tiny graphics with a unique identifier, similar in function to cookies. While cookies are stored locally on your device, pixel tags are embedded invisibly within web pages and online content. We may use these, in connection with our Services to, among other things, track the activities of users, help us manage content and compile usage statistics. We may also use these in HTML e-mails we send, to help us track e-mail response rates, identify when our e-mails are viewed, and track whether our e-mails are forwarded.

Third-Party Analytics and Tools. We use third party tools, such as Google Analytics, which are operated by third party companies. These third-party analytics companies may collect usage data (using cookies, pixels and similar tools) about our Services in order to provide us with reports and metrics that help us to evaluate usage of our Services and improve performance and user experiences. To learn more about Google’s privacy practices, please review the Google Privacy Policy at https://www.google.com/policies/privacy/partners/. You can also download the Google Analytics Opt-out Browser Add-on to prevent their data from being used by Google Analytics at https://tools.google.com/dlpage/gaoptout.

Cross-device Tracking. We and our third-party providers may use the information that we collect about you within our Services and on other third-party sites and services to help us and these third parties to identify other devices that you use (e.g., a mobile phone, tablet, other computer, etc.). This information may be used as set forth in this section and Section 6. Cookies, Targeting and Analytics.

Targeted Advertising. We work with third parties, such as ad networks, channel partners, mobile ad networks, analytics and measurement services and others (“third-party ad companies”) to manage our advertising on third-party sites, mobile apps and online services. We may share certain information with these third-party ad companies, and we and they may use cookies, pixels tags, and other tools to collect usage and browsing information within our Services, as well as on third-party sites, apps and services, such as IP address, location information, device ID, cookie and advertising IDs, and other identifiers, as well as browsing information. These third-party ad companies use this information to provide you more relevant ads and content within our Services and on third-party sites and apps, and to evaluate the success of such ads and content. 

Custom Lists and Matching. We may share or make available certain customer list information (such as your name, email address and other contact information) with third parties (i) so that we can better target ads and content to you across third party sites, platforms and services, and (ii) in some cases, these third parties may help us to enhance our customer lists with additional demographic or other information, so we can better target our advertising and marketing campaigns. 

Managing Your Preferences. We make available several ways for you to manage your preferences regarding targeted advertising and cookies within our Services. Many of these are browser and device specific, which means that you need to set the preference for each browser and device you use to access our Services; in addition, if you delete or block cookies, you may need to reapply these preferences. Further, opting out of cookies and advertising as discussed below does not mean that you will no longer receive advertising content from us. You may continue to receive generic or “contextual” ads from us.

• Industry ad choice programs. You can also control how participating third-party ad companies use the information that they collect about your visits to our websites, and those of third parties, in order to display more relevant targeted advertising to you. If you are in the U.S., you can obtain more information and opt out of receiving targeted ads from participating third-party ad networks at aboutads.info/choices (Digital Advertising Alliance). You may also download the DAA AppChoices (https://youradchoices.com/appchoices) tool in order to help control interest-based advertising on apps on your mobile device. 

Please note that opting out of participating ad networks does not opt you out of being served advertising. You may continue to receive targeted ads on other websites, from companies that do not participate in the above programs.

• Browser settings. If you wish to prevent cookies from tracking your activity on our website or visits across multiple websites, you can set your browser to block certain cookies or notify you when a cookie is set; you can also delete cookies. The Help portion of the toolbar on most browsers will tell you how to prevent your device from accepting new cookies, how to have the browser notify you when you receive a new cookie, or how to delete cookies. Visitors to our Services who disable cookies will be able to browse the website, but some features may not function.