Privacy
policy

This is the privacy policy (“Privacy Policy”) for any application or web service owned or operated (collectively the “App”) provided by Coalition Network, a Delaware Company (“our”, “we”, or “Coalition”).

Nodle is the controller of your personal data collected through the Coalition App and we are committed to protecting and respecting your privacy.

1. Introduction

This Privacy Policy explains who we are, why and how we process personal data collected through your use of the App and, if you are the subject of any of the personal data concerned, what rights you have and how to get in touch with us if you need to.

When you supply any personal data to us we have legal obligations towards you in the way we use that data. We must collect the information fairly and explain to you how we will use it. For ease of reading, we have divided this Privacy Policy into several sections:

1. Introduction
2. What information we collect
3. How and why we use/share your information
4. How long we keep your information
5. Security
6. International Data Transfers
7. Your Rights
8. Contact Details

It is important that you read this Privacy Policy together with any other privacy notice or fair processing notice that we may provide at or around the time that we collect or process personal data about you so that you are fully aware of how and why we are using that data.

This Privacy Policy supplements other notices and legal documents including the NodleEnd-User Licence Agreement (“ EULA ”) and is not intended to override or replace them.

By downloading and/or using our Coalition App, you agree to its terms (including as amended from time to time) and this Privacy Policy. If, for any reason, you do not agree to the terms of this Privacy Policy, please stop using the Coalition App.

We reserve the right to revise or amend this Privacy Policy at any time to reflect changes to our business or changes in the law. However, it is your responsibility to check this Privacy Policy before each use of the App.

Please note that the Coalition App is not intended for use by, nor directed at, anyone under the age of 16 and we do not knowingly collect data relating to children. If you believe we have collected personal information about your child, you may contact us at contact@coalitionnetwork.org and request that we remove information about them.

2. What information we collect

What is personal data?

Where this Privacy Policy refers to ‘personal data’ it is referring to data about you from which you could be identified.

By law all organisations who process your personal data in many regions are obliged to process your personal data in certain ways and to ensure that you are given an appropriate amount of information about how they use it. You also have various rights to seek information from those organisations about how they are using your data, and to prevent them from processing it unlawfully.

2.2 How and what types of data we collect from you when you use the App

When you use the Coalition App to fill in forms provided on the Coalition App, subscribe to our services or report a problem with the App, we may collect, store and use certain personal information that you disclose to us.

The information we collect from you may include (but is not limited to): your IP address, email address, telephone number, feedback and log-in information.

We shall also collect information about you when you visit and interact with the App through the use of technologies such as cookies . The following are examples of information we may collect:
● information about your device, browser or operating system;
● time zone setting;
● your IP address;
● information about interactions you have with the App (such as scrolling and clicks);
● information about the way you use and the actions you take within the App;
● length of time on the App and time spent within certain sections;
● response times; and
● download errors.

Please refer to your device’s help material to learn what controls you can use to remove cookies, block cookies, or disable IDFA tracking. If you do this, it may affect your use of a Website or an App.

We may also partner with third parties who may collect anonymous usage or statistical data through your use of the App (including, for example, sub-contractors in technical, payment and/or delivery services, business partners, advertising networks, analytics providers).

3. We do not share or collect any information about you

Exceptions

We may use the personal data that you have shared with us in the following circumstances:

● Where you have asked us to do so, or consented to us doing so;
● Where we need to do so in order to perform a contract we have entered into with you;
● Where it is necessary for our legitimate interests (or those of a third party) and your fundamental rights do not override those interests; and
● Where we need to comply with a legal or regulatory obligation.

Marketing

You will only receive marketing messages from us if you have given us your consent to do so or if you have provided feedback on our App and have not opted out of receiving marketing messages.

To unsubscribe from marketing emails at any time, please click on the unsubscribe link at the bottom of any marketing email and update your account preferences. You may also contact us to inform us if you do not wish to receive any marketing materials from us.

In the event you have shared your information

Depending on how and why you provide us with your personal data, we may share it in the following ways:

● we may share your personal information with any member of our group, which means our subsidiaries, our ultimate holding company and its subsidiaries with selected third parties including business partners, suppliers and sub-contractors for the performance of any contract we enter into with them or you (see “ Service Providers ” below); or
● with analytics that assist us in the improvement and optimisation of the App.

We may also disclose your personal information to third parties in the following events:

● if Coalition or substantially all of its assets are acquired by a third party, in which case personal information held by us about our customers will be one of the transferred assets; or
● if we are under a duty to disclose or share your personal information in order to comply with any legal obligation, or in order to enforce or apply the EULA; or to protect the rights, property, or safety of our company, our customers, or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.

Service Providers

Our service providers provide us with a variety of administrative, statistical, and technical services. We will only provide service providers with the minimum amount of personal data they need to fullfil the services we request, and we stipulate that they protect this information and do not use it for any other purpose. We take these relationships seriously and oblige all of our data processors to sign contracts with us that clearly set out their commitment to respecting individual rights, and their commitments to assisting us to help you exercise your rights as a data subject.

Other Disclosures

During your use of the App, your app store provider and mobile network operator may also collect personal information about you regarding your use of the App such as your identity, your usage and location.

These third parties shall act as separate and independent controllers of that personal data and shall process it in accordance with their own privacy policy.

Links to third party sites

The App may, from time to time, contain links to and from the websites of our partner networks.

We may also provide links to third party websites that are not affiliated with the App. All third party websites are out of our control and are not covered by this Privacy Policy. If you access third party sites using the links provided, the operators of these sites may collect information from you that could be used by them, in accordance with their own privacy policies. Please check these policies before you submit any personal data to those websites.

4. How long we keep your information

We will hold the personal information you have shared with us on our systems only for as long as required to provide you with the products and services you have requested, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.

In some circumstances you can ask us to delete your data: see ‘Your Rights’ below for further information.

Most of the time we may anonymize your personal data (so that it can not be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.

5. Security

We take the protection of your information very seriously. We have put in place appropriate physical, electronic and managerial security measures to prevent the personal data you have shared with us from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed, including use of secure servers, passwords and industry standard encryption for data both in transit and at rest (for data in transit we use up-to-date versions of SSL and for data at rest we use AES-256).

Where we have given you a password that enables you to access certain parts of our App, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.

In addition, if you have shared personal information with us, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

6. International Data Transfers

Please note that some of our service providers may be based outside of Delaware. These service providers may work for us or for one of our suppliers and may be engaged in, among other things, the fulfillment of your request for information, products and services, the processing of your payment details and the provision of support services.

Where we transfer your data to a service provider t we seek to ensure that appropriate safeguards are in place to make sure that the personal data that you have shared with us is held securely and that your rights as a data subject are upheld. Transfers of personal data are either made:

● to a country recognized as providing an adequate level of protection; or
● to a country which does not offer adequate protection but whose transfer has been governed by the standard contractual clauses or by implementing other appropriate cross-border transfer solutions to provide adequate protection.

By submitting your personal information, you agree to this transfer, storing or processing. If you would like more information about how the mechanism via which the personal data you have shared with us is transferred please contact: contact@coalition.network

7. Contact Details

If you have any queries regarding this Privacy Policy, if you wish to exercise any of your rights set out above or if you think that the Privacy Policy has not been followed, please contact us by emailing at contact@coalitionnetwork.org

Coalition
Manifesto
Coalition is a proximity based contact tracing platform leveraging Bluetooth to fight COVID-19. 

Coalition benefits from decade-long R&D in the space of decentralized wireless networks, mobile mesh and secure identity management systems from the Nodle team. The technology was developed by the team at Nodle — the world’s largest ecosystem of connected devices, providing low cost, secure wireless infrastructure, data insights for enterprises, manufacturers and smart cities.

The Nodle founding team previously created FireChat, a peer-to-peer Bluetooth-based messaging technology that has been used to stay connected and communicate while in planes, on cruise ships, at large festivals, during internet shut down and in cases of disaster-recovery situations.

We believe that the whole of humanity is concerned by what is happening. In these times of uncertainties and of emergencies we have to act fast. It is an opportunity to use our software and expertise for good to save millions of lives.
Updates on
COVID-19
Latest government updates on COVID-19 Via the US CDC.

What to do if you have flu-like symptoms e.g. fever, cough, runny nose and sore throat Via the CDC.
How does
Coalition works?
Given that the vast majority of smartphones are Bluetooth-enabled, each time a phone passes by another phone or other Bluetooth-enabled device, it picks up anonymous device information.  
If a Coalition app user declares that they have tested positive for COVID-19, their phone then can anonymously and almost instantaneously inform all other phones that have been in its proximity over an extended period of time during the prior 2 weeks. The amount of exposure period and the length of time we trace back to can be set by epidemiologists.

Users who are notified can then immediately take necessary self-isolation measures or get tested if available. The identities of both the COVID-19 positive patient and of the people receiving the notifications are anonymized and securely encrypted.
How does
Coalition protect
your privacy?
One of the key roadblocks to wide scale adoption of “Contact tracing” apps is privacy protection.

Tracing apps to-date have unnecessarily compromised privacy; users give away identities, location and even “under-the-skin” biometric data. We believe we can achieve benefits on contact tracing  whilst being privacy conscious.

So, how is privacy protected?
Let us first clarify when privacy is breached.  It’s when: 
Users don’t have the option to opt-in into the networks;
Users have to upload their location data to the cloud which can be traced and monitored by a central entity;
Data is attached to identities, or;
Not GDPR or CCPA compliant.

To address the above-mentioned concerns that hinder the adoption, Coalition enables the following:
Users’ location data is never sent to the cloud on Coalition. By contrast, it is a prerequisite for all other platforms;
Bluetooth proximity data is encrypted and stays on your device;
The users are sole owners of the data—prior contacts are notified anonymously and securely when they fall sick to COVID-19, and;
All data is anonymized and encrypted

You can see more about how we are GDPR and CCPA Compliant below.

be safe with coalition
The more people join the Coalition, the safer it gets for everyone.
Protect your friends and family by sharing Coalition
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