BID-OMS-PP
rev.06‑en dated 2020-06-06
Bridge ID OMS is provided by Bridge ID, LLC (hereinafter “Bridge ID”, the “Company”, “we”, or “us”). OMS is an acronym for Offender Monitoring System, and Bridge ID OMS is a patented solution that allows authorized governmental officials to supervise an individual who is invited to and chooses to participate in OMS (the “Supervised Individual”). Supervised Individuals use the OMS mobile application (the “app”), among other tasks, to check in when requested and additionally at any other times that Supervised Individuals desire, by confirming their identities against reference biometric data that they provided us during registration. The app also identifies the physical locations of Supervised Individuals once the app is activated. The combined identification and localization can only be performed on the smartphone used during registration, which is then uniquely tied to a Supervised Individual; using the app on a different smartphone requires de-registering one smartphone first before re‑registering on another.
The OMS app is authorized for use by invitation only. Supervised Individuals are issued unique, one-time personal identification numbers (PINs), which are required to register in the app. The app is licensed for use by you, if you are a Supervised Individual, for the duration of your release from jail or prison, or for the term of any probation in lieu of incarceration, (the “Release”), to help you comply with the conditions of such Release. You explicitly and voluntarily agree to participate in the Release.
One condition of Release, to which you unequivocally consent in exchange for the privilege, is submission to monitoring by the governmental pre-trial, probation, prison, parole, or other law enforcement agency responsible for supervising your compliance with all terms of your Release (the “Agency”). The Agency will use information obtained via OMS, which includes, but is not limited to, your whereabouts (location), your identity (facial images), your smartphone details and state (device battery level; make, model and operating system; and settings), and any other information you enter in the app, to gauge your compliance with the terms of your Release. Authorized officers and staff of the Agency will have access to all OMS data for their official use both during and after your Release. By accessing the OMS app, you consent that the Company will share your personal and other OMS information with the Agency via OMS.
This Privacy Policy has been designed to help you better understand our privacy practices with respect to the information that you and the Agency provide and that we collect though OMS. The Privacy Policy is available for your review at all times: (i) prior to registration in the app, (ii) after registration in the app’s menu, and (iii) on our website here: legal.oms.bridgeid.com.
Any material changes to Company’s privacy practices related to OMS, will be made available on the Privacy Policy section of the app and on the Company’s website. The date of the latest revision will be displayed at the beginning of the Privacy Policy. We encourage you to review the Privacy Policy regularly to stay informed about our information practices and the ways you can help protect your privacy.
Your use of the OMS app signifies your acceptance of the Privacy Policy. You agree to allow the Company and its licensed Agency client to collect, use, share, disclose and retain information about you in accordance with the purposes listed herein. This Privacy Policy is incorporated by reference into the OMS Terms of Use (the “Agreement”, “Terms of Use”, or “Terms”). Both the Privacy Policy and Terms of Use are available for your review at all times: (i) prior to registration in the app, (ii) after registration in the app’s menu, and (iii) on our website here: legal.oms.bridgeid.com. If you have any questions regarding this Policy, please contact us using the details available in the Contact Us section, below. If you do not accept and agree to the Privacy Policy and to be bound by all the terms of the Agreement, do not use OMS.
The following restrictions apply to the use of OMS: (a) You shall not use, register with, or log in to the OMS app unless you, personally, have been authorized to do so by an Agency by having received a unique PIN; (b) You shall not use the app unless you agree to the Privacy Policy and to be bound by all the terms of the Agreement; (c) You shall not allow others to use your app account and accept that you are responsible for the use of your app account; and (d) You accept full responsibility for any unauthorized use of your app account. If you suspect that unauthorized access occurred or your account may have been compromised, please contact your assigned supervising officer immediately or contact our support center via support.bridgeid.com.
OMS collects information from you in two ways:
(a) Personally Identifiable Information (“PII”). We collect information about you that the Agency provides directly in OMS when you agree to participate in OMS. You may also provide PII about yourself during registration or thereafter. The types of PII we may collect about you include all or part of your full, legal name; your date of birth; details from your government-issued photo identification or from other government documents or records; your gender; photos of your face and data derived therefrom; your home and work addresses; your e‑mail address; and your mobile telephone number.
(b) Non‑PII. If you use the OMS app without providing us any PII, we may gather and store information about your visit, such as your IP address; smartphone details including type, model and operating system; date; time; and the location from which you accessed the app, and/or how you interact with the app. This information will not identify you and is, therefore, considered “non‑PII.”
We may use information about you for various purposes, including, without limitation, to: (i) meet our contractual obligations to our client, the Agency; (ii) register you as an app user and manage and service your account; (iii) respond to your comments, questions and requests and contact you to provide customer service and support; (iv) send you technical notices, updates, security alerts and support and administrative messages; (v) monitor and analyze usage, activities and trends in connection with OMS; (vi) link or combine with information we receive from others to help understand your needs and provide you with better service; and (vii) administer and protect our business and OMS (including troubleshooting, data analysis, testing, system maintenance, support, security, reporting and hosting of data); (viii) comply with regulatory requirements for the maintenance of records; and (ix) provide, maintain and improve OMS.
We may share information about you as follows or as otherwise described in this Policy: (i) with the Agency or other authorized governmental officials who are using our services in connection with your Release; (ii) if we believe that the disclosure of information is necessary to comply with any applicable law, regulation, rule, or legal process, or to respond to subpoenas or warrants served on us, or to respond to lawful requests by public authorities, including to meet national security or law enforcement requirements; (iii) if we believe your actions violate the spirit or language of our user agreements or policies, or to protect the rights, property and safety of the Company; (iv) with other companies under our common control (the "Affiliates"), in which case we will require Affiliates to honor this Privacy Policy; (v) with third parties in connection with, or during negotiations of, any merger, purchase of any business assets, financing or sale of all or a portion of our business, in which case we may disclose information under confidentiality agreements at least as stringent as the terms of this Privacy Policy; and (vi) with your consent or at your direction. We may also share your information with our third-party distributors, vendors, suppliers, and other service providers who provide services to us on our behalf, such as operating and supporting the Service, and analyzing data.
11. Data Retention
and Storage
The Company will retain OMS data and make it available to Agency for its official use and records both during and after your Release. All OMS data is encrypted not only while in transit but also at rest. Since OMS data is collected and used for official governmental purposes, Company shall retain it in storage for as long as the Agency requires for their official purposes. We will retain PII for as long as necessary to fulfill the purposes for which we collected it, including for the purposes of satisfying any legal, accounting, or reporting requirements. To determine the appropriate retention period for PII, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorized use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.
We may generate additional records from PII by excluding, or irreversibly obscuring or randomizing, information (such as names, photos, ID details and contact details) that made the data personally identifiable to you (the “Anonymous Data”). Anonymous Data does not permit the identification of individual persons. We may use Anonymous Data for analytics and to analyze request and usage patterns so that we may enhance the content and functionality of OMS. We reserve the right to retain Anonymous Data indefinitely, and to use and disclose it to Affiliates and third-party companies in our discretion.
We may allow analytics companies to use tracking technologies to collect anonymous information about our users’ mobile devices and app usage. These companies analyze this information to help us understand how our apps are being used. To this end, analytics companies may use mobile device IDs, which, unlike cookies, cannot be deleted.
Flurry. The OMS app may collect a variety of anonymous analytical data using services provided by Flurry, Inc. (“Flurry”), a subsidiary of Verizon Media. These data are used to understand how users utilize the app, for instance, how often the user responds to requests made via the app within defined timeframes. The metrics are not tied to individual user accounts. Flurry may also collect data including, but not limited to what types of devices are running the app software and which versions of the operating systems are running it. For more on Flurry’s Privacy Policy, visit their website here or contact them directly at support@flurry.com.
OMS uses a variety of industry-standard security technologies and procedures to protect data during transmission and while stored. The Company takes measures to protect information about you from loss, theft, misuse as well as unauthorized access, disclosure, alteration, and destruction. However, no security or encryption method can be guaranteed to protect information from hackers or human error. We also urge you not to disclose your account details to unauthorized people and to protect your smartphone from unauthorized use by employing either hard-to-guess passcodes or biometric access control using a fingerprint reader or facial recognition. If you suspect that unauthorized access occurred or your account may have been compromised, please contact your assigned supervising officer immediately or contact our support center via support.bridgeid.com.
You may update the personal information you have provided by contacting your Agency’s supervising officer or by suggesting changes to it during registration in the app.
To ensure compliance with your use of OMS and thus with the terms of your Release, you must ensure that your smartphone permits OMS to function as intended. This includes (i) allowing OMS to send you notifications, and (ii) allowing OMS to confirm your location and identity. To this end, you agree to consent to allow the OMS app to (i) access the Internet to both send and receive data without hindrance; (ii) receive and display all OMS push notifications on screen, (iii) access the device’s cameras, (iv) access the device’s calendar; and (v) access your device’s location at all times. Your failure to do so will be detected by the app and reported to the Agency, which may be deemed a violation of the terms of your Release and may lead to revocation of the Release privilege.
California Civil Code Section 1798.83, also known as the “Shine the Light” law, permits our customers who are California residents to request and obtain from us once a year, free of charge, information about the personal information (if any) we disclosed to third parties for direct marketing purposes in the preceding calendar year. If applicable, this information would include a list of the categories of personal information that was shared and the names and addresses of all third parties with which we shared information in the immediately preceding calendar year. If you are a California resident and would like to make this type of request, please submit your request in writing to:
Bridge ID, LLC
ATTN: Legal Department (BID-OMS-PP-US.CA)
P.O. Box 381
Gates Mills, Ohio 44040-0381
United States of America
The California Consumer
Privacy Act of 2018 (CCPA), beginning January 1, 2020, provides California
residents with rights regarding personal information listed below. The CCPA
only applies to information about residents of California. To exercise these
rights please review the sections below.
Right to Request. You have the right to request that we disclose certain information to you about our collection and use of your personal information over the past 12 months. Once we receive and confirm your verifiable consumer request, we will disclose to you:
• The categories of personal information we collected about you.
• The categories of sources for the personal information we collected about you.
• Our business or commercial purpose for collecting or selling that personal information. The categories of third parties with whom we share that personal information.
• The specific pieces of personal information we collected about you (also called a data portability request).
Right to Request Deletion. You have the right to request that we delete any of your personal information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request, we will delete (and direct our service providers to delete) your personal information from our records, unless an exception applies. We may deny your deletion request if retaining the information is necessary for us or our service providers to:
• Complete the transaction for which we collected the personal information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contractual obligations.
• Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity; or to prosecute those responsible for that activity.
• Debug or repair errors in existing functionality.
• Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right.
• Comply with the California Electronic Communications Privacy Act (Cal. Penal Code 1546 seq.).
• Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information's deletion may likely render impossible or seriously impair the research's achievement, if you previously provided informed.
• Comply with a legal obligation.
• Enable solely internal uses that reasonably align with the expectations of the consumer based on the consumer’s relationship with the business.
• Make other internal and lawful uses of that information that are compatible with the context in which you provided it.
Exercising Access, Data Portability, and Deletion Rights. If you are a California Resident and wish to exercise the access, data portability, and deletion rights described above, please submit a verifiable consumer request to us in writing to:
Bridge ID, LLC
ATTN: Legal Department (BID-OMS-PP-US.CA)
P.O. Box 381
Gates Mills, Ohio 44040-0381
United States of America
Only you or a person registered with the California Secretary of State that you authorize to act on your behalf, may make a verifiable consumer request related to your personal information. You may only make a verifiable consumer request for access or data portability twice within a 12-month period.
The verifiable consumer request must provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative. Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it. We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you.
Response Timing. We endeavor to respond to a verifiable consumer request within 45 days of its receipt. If we require more time, we will inform you of the reason and extension period in writing.
If you have any questions about this Privacy Policy, please contact us by e‑mail at privacy@bridgeid.com or by writing to us at the following address:
Bridge ID, LLC
ATTN: Legal Department (BID-OMS-PP)
P.O. Box 381
Gates Mills, Ohio 44040-0381
United States of America
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