Privacy Policy

This privacy policy (“Policy”) describes the personal data Enably Inc (‘We”) collects via Carelu (“Service”) and how this data is used and shared.

This policy describes how we collect and use personal data. This notice applies to all users of our apps (“users”), websites, features, or other services anywhere in the world. This notice specifically applies to:

• Caregiver: individuals and sole proprietors who provide services on Carelu
• Service users: individuals who request and receive the service provided by the Caregiver on Carelu

Enably Inc. is the data controller for the personal data collected in connection with use of Carelu’s services.

A. The data we collect

We collect personal data such as:

• provided by users to Carelu, such as during account creation
• created during use of our services, such as app usage, and device data
• from other sources, such as other users or account owners, business partners, vendors, financial solution providers, and governmental authorities

We collect data provided by users such as:

• User profile: We collect data when users create or update their Carelu accounts. This may include their name, email, phone number, password, address, profile picture, dependents’ name, birthday, gender, situation, payment or banking information (including related payment verification information), and other government documents (which may indicate document numbers as well as birth date, gender, and photo). This also includes user settings to provide services using the Carelu app.
• Demographic data: We may collect demographic data about users, including through user surveys, which includes data received from third parties in some cases.
• User content: We collect the data submitted by users when they contact Carelu customer support, provide ratings or compliments for caregivers. This may include feedback, photographs or other recordings collected by users, including audio or video recordings submitted by users in connection with customer support.

Data created during use of our services. This includes:

• Transaction information: We collect transaction information related to the use of our services, including types of service, date and time the service was provided, amount charged, and payment method. Additionally, if someone uses promotion code provided by others, we may associate name of others with that person.
• Usage data: We collect data about how users interact with our services. This includes data such as access dates and times, app features or pages viewed, and other system activity, and type of browser. We may also collect data regarding the third-party sites or services used before interacting with our services, which we use for marketing.
  In some cases, we collect this data through cookies and similar tracking technologies that create and maintain unique identifiers.
• Device data: We may collect data about the devices used to access our services, including the hardware models, device IP address or other unique device identifiers, operating systems and versions, software, preferred languages, advertising identifiers, device motion data, and mobile network data.
• Communications data: We enable users to communicate with each other and Carelu through Carelu’s app and websites. For example, we enable caregivers and service users to call, text, or send other files to each other. To provide this service, we receive some data regarding the calls, texts, or other communications, including the date and time of the communications and the content of the communications. We may also use this data for customer support services (including to resolve disputes between users), for safety and security purposes, to improve our services and features, and for analytics.

Data from other sources. These include:

• Users who refer another person to Carelu. In such case, we receive the referred person’s personal data from that user.
• Carelu account owners who request services for or on behalf of other users, or who enable such users to request or receive services using their accounts.
• users or others providing information in connection with claims or disputes.
• Carelu business partners through whom users create or access their Carelu account, such as payment providers, social media services, or whose APIs Carelu uses.
• partner care service providers (for caregivers who use our services through an account associated with such a company)
• publicly available sources
• marketing service providers or data resellers whose data we use for marketing or research

B. How we use personal data

We use personal data to improve reliability and convenience on Carelu’s service. We also use such data:

• to enhance the safety and security of our users and services
• for customer support
• for research and development
• to enable communications between users
• to send marketing and non-marketing communications to users
• in connection with legal proceedings

We do not sell or share user personal data with third parties for their marketing purposes without their users’ consent.

C. Cookies and third-party technologies

We and our partners use cookies and other identification technologies on our apps, websites, emails, and online ads.

We use cookies and similar technologies for purposes such as:

• authenticating users
• remembering user preferences and settings
• determining the popularity of content
• delivering and measuring the effectiveness of advertising campaigns
• analyzing site traffic and trends, and generally understanding the online behaviors and interests of people who interact with our services

We may also allow others to provide analytics services for us to serve advertisements on our behalf, and to track and report on the performance of those advertisements. These entities may use cookies, SDKs, and other technologies to identify the devices used by visitors to our websites, as well as when they visit other online sites and services.

We collect and use personal data:

1. We uses personal data to provide, personalize, maintain, and improve our services such as the followings;
   
   • Create and update accounts
   • enable features that involve data sharing (such as ratings and compliments)
   • present users with personalized recommendations for caregivers based on their prior service usage histories.
   • perform necessary operations to maintain our services, including to troubleshoot software bugs and operational problems; to conduct data analysis, testing, and research; and to monitor and analyze usage and activity trends.

   We perform the above activities, including the collection and use of location data for purposes of these activities, based that they are necessary to fulfill our obligations to users.

2. Safety and security. We use personal data to help maintain the safety, security, and integrity of our services and users. This includes:
   
   • using device, location, user profile, usage, and other data to prevent, detect, and combat fraud. This includes identifying fraudulent accounts or uses of our services, preventing use of our services by unauthorized users, verifying user identities in connection with certain payment methods, and preventing and combating unauthorized access to users’ accounts.
   • sharing information regarding serious caregivers’ or users’ safety incidents or compliance with local regulations with third parties, including business partners who enable users to request or provide care services, or intermediaries who collect and report such information for multiple companies. We may also share with third parties, including those affected by such incidents, whether the incidents result in account deactivation.
3. Customer support. We use the information we collect (which may include call recordings) to provide customer support, including to investigate and address user concerns and to monitor and improve our customer support responses and processes.
4. Research and development. We may use personal data for testing, research, analysis, product development, and machine learning to improve the user experience. This helps us make our services more convenient and easy-to-use, enhance the safety and security of our services, and develop new services and features.
5. Enabling communications between users. For example, a caregiver and service users may message or call to confirm a location where the service needs to be provided.
6. Marketing. We may use personal data to market our services to our users. This includes sending users communications about our services, features, promotions, sweepstakes, studies, surveys, news, updates, and events. We may do so through various methods such as email, SMS, push notifications, and in app communications and ads.
   We may also inform users about products and services offered by our partners. For example, we may provide recommendations, promotions, or ads for our partners based on users’ service request behaviors and order histories. Even though we inform users about products and services offered by our partners, we do not sell users’ personal data to, or share it with, such partners or others for purposes of their own direct marketing or advertising, except with users’ consent.
   We may use the data we collect (including in combination with advertising partners’ data) to personalize and improve the marketing communications (including ads) that we send on and off Carelu app and website, including based on use of our services, and user preferences and settings.
7. Legal proceedings and requirements. We may use personal data to investigate or address claims or disputes relating to use of our services, to satisfy requirements under applicable laws, regulations, or operating licenses or agreements, or pursuant to legal process or governmental request, including from law enforcement.
8. Automated decision-making
   We use personal data to make automation relating to use of our services. This includes:
   • recommending available caregivers to users requesting services. Caregivers can be recommended based on availability, proximity, and other factors such as likelihood to request a service based on their past behavior or preferences.
   • flagging users who are identified as having engaged in fraud, unsafe activity, or other activities that may harm us, our users, and others.

D. Data disclosure

We share personal data with other users if requested by users. We may also share such data with our affiliates, subsidiaries, and partners, for legal reasons or in connection with claims or disputes.

We may share personal data:

1. With other users
   
   • Service users’ address where the service needs to be provided, and order information with their service requests.

   We also provide service users with receipts containing information such as a breakdown of amounts charged and service details. We also include other information on those receipts if required by law.

2. With our service providers and business partners
   

   We provide personal data to vendors, consultants, marketing partners, research firms, and other service providers or business partners. These include:

   • payment processors and facilitators
   • cloud storage providers
   • Google, in connection with the use of Google Maps in Carelu’s app (see Google’s privacy policy for information on their collection and use of data)
   • social media companies, including Facebook, in connection with Carelu’s use of their tools in Carelu app and websites (see Facebook’s privacy policies for information on their collection and use of data)
   • Marketing partners and marketing platform providers, including social media advertising services, advertising networks, third-party data providers, and other service providers to reach or better understand our users and measure advertising effectiveness
   • research partners
   • consultants, lawyers, accountants, and other professional service providers
3. For legal reasons or in the event of a dispute
   

   We may share users’ personal data if we believe it’s required by applicable law, regulation, operating license or agreement, legal process or governmental request, or where the disclosure is otherwise appropriate due to safety or similar concerns.

   This also includes sharing personal data with others in connection with, or during negotiations of, any merger, sale of company assets, consolidation or restructuring, financing, or acquisition of all or a portion of our business by or into another company.

4. With consent
   

   We may share a user’s personal data other than as described in this notice if we notify the user and they consent to the sharing.

We may update this notice as needed. When we do, we will notify users in advance of the changes through our app or through other means, such as email. We encourage users to periodically review this notice for the latest information on our privacy practices.

Please send questions, comments, and complaints about our data practices to legal@carelu.co.