Our goal is to make sure you know how we collect, use, share, and store your personal data when you create a EVERYWHERE account, interact with our customer support team, and visit everywherecomms.com or other EVERYWHERE websites and apps covered by this privacy policy.

Your privacy is important to EVERYWHERE. We developed this Privacy Policy to provide you with information on how we process your personal data when you create an EVERYWHERE account, interact with our sales and customer support teams, visit everywherecomms.com,  the EVERYWHERE Hub, or use EVERYWHERE apps.

Privacy Policy for EVERYWHERE Products and Services Last Updated: December 6, 2021

1. INTRODUCTION 
Welcome to EVERYWHERE Communications, Inc.’s privacy policy for EVERYWHERE products and services (the “Privacy Policy”). EVERYWHERE respects your privacy and is committed to protecting your personal data. This Privacy Policy will inform you as to how we look after your personal data when you use our Services (regardless of where you use it from) and will tell you about your privacy rights and how the law protects you. The Services includes the EVERYWHERE products and services you are using as more fully described in the Definitions. “You” (whether capitalized or not) means you, the End User of the Services. “We” or “us” or "our" (whether capitalized or not) means our company, EVERYWHERE, the developer, owner, and operator of the Services. “Company” means the legal entity (typically your employer) that paid or pays the charges that enables your use of these Services under a commercial agreement with EVERYWHERE or one of its Channel Partners that resells the Services . Please see Schedule A (Definitions) for more detailed definitions for capitalized terms used throughout this Privacy Policy.

2. PURPOSE AND WHO WE ARE

2.1 Purpose Of This Privacy Policy. This Privacy Policy aims to give you information on how EVERYWHERE collects and processes your personal data through your use of the Services, including any data you may provide when you use our Services. We do not sell your personal data to any third party.

It is important that you read this Privacy Policy together with any other privacy policy we may provide on specific occasions when we are collecting personal data about you so that you are fully aware of how and why we are using your data. This Privacy Policy supplements various agreements that we have in place other notices and privacy policies and is not intended to override them.

2.2 Controller. EVERYWHERE is the controller and responsible for your personal data.

2.3 Contact Information. If you have any questions about this Privacy Policy, including any requests to exercise your legal rights, please contact the EVERYWHERE Data Privacy Manager using the details set out below.

EVERYWHERE Data Privacy Manager contact information:
Full name of legal entity: EVERYWHERE Communications, Inc.
Email address: privacy@everywherecomms.com
Postal address: 30 West Street Annapolis, Maryland 21401 USA
Telephone number: 207-370-0499

2.4 Changes To The Privacy Policy. We regularly review our Privacy Policy. This version was last updated on the date set forth at the beginning of this Privacy Policy. Historic versions of this Privacy Policy are listed in Schedule B at the bottom. 

2.5 Your Responsibility To Inform Us Of Changes. It is important that the personal data we hold about you is accurate and current. If you are a Web Administrator, you have the permissions to change information about the Device Account associated with the Device that you use in connection with the Services. If you are not a Web Administrator, then you do not have the ability to change information about the Device Account associated with the Device that you use in connection with the Services, so please contact the Web Administrator that is authorized to make changes to the Device Account associated with the Device that you use. 

2.6 Third-Party Links. The Services may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third-parties to collect or share data about you. We do not control these third-party websites, plug-ins or applications and are not responsible for their privacy statements. Our privacy policy applies only to our Services, so if you click on a link to another website or use their plug-ins or applications, you should read their privacy policy.

3. BACKGROUND AND SCOPE OF ACCOUNT TYPES

3.1 Device Accounts. While this Privacy Policy is primarily directed at you, the End User of the Services, it is important to understand that there are two different types of accounts used by the Services that impact an End User and the End User’s Devices. The first is a Device Account that tracks your Devices. A single Device Account may control two paired Devices, one that operates on the Iridium satellite network, and one that runs the EVERYWHERE App on smartphones. Since we do not expressly keep account information for each End User, some of the information that we store in the Device Account may be considered personal data of the End User who uses the Devices associated with the Device Account. In some situations, however, Devices are shared between different End Users. In these situations, the information stored in the Device Account associated with the Devices may not necessarily be your personal information, as it could very well be personal information acquired during use of the Services from another End User who is sharing the same Device.

3.2 Web User Accounts. A primary component of the Services is the EVERYWHERE Hub, which is an online server hosted and controlled by us. The EVERYWHERE Hub performs numerous functions in the configuration and delivery of the Services. One of the Hub’s configuration functions provides the ability to add, modify and delete account information related to the operation of the Services. One type of End User that is authorized to access the Hub to perform add, modify and delete functions are called Web Administrators. Web Administrator can be thought of as an administrative type of End User who has certain rights not available to all End Users. Another type of End User, called Web Users, are only authorized to access the Hub to view account information but are not permitted to add, modify and delete it. Both Web Administrators and Web Users have a Web User Account.

4. DATA WE COLLECT ABOUT YOU AND/OR YOUR DEVICE
This section is intended to provide you with an understanding of the personal data, or personal information, that may be used or acquired by the Services in the course of your use of the Services.

Generally, information is tracked about Devices, not about individual End Users.

 As noted above in Section 3.1 (Device Accounts), while the Services do not expressly track an End User’s personal data, it does track information about a Device. So as an End User is using a Device on the Services, the End User’s personal data may be tracked under the Device Account associated with that Device. In situations where a group of End Users are sharing a Device, the personal data of more than one End User may be stored under a single Device Account.

4.1 Data Elements Table. Table 4.1 below sets forth the various data elements that are used in the course of interacting with the Services. These elements are categorized by the various activities that occur in connection with use of the Services. The purpose for collecting each data element, how and when each data element is collected, and the legal grounds for maintaining each data element are all explained in the table. The data elements are all defined terms set forth in Schedule A (Definitions), which can be found at the end of this Privacy Policy. Some data elements represent groups of individual data elements. Many of these grouped data elements are referenced in the table below.

4.2 Location Data. Devices that are connected to the Services regularly collect Location Data about the Device. Location Data for Devices are collected on the EVERYWHERE Hub, however it is collected differently on Iridium satellite-based Devices than it is on smartphones using the EVERYWHERE App.

4.2.1 Collecting Location Data on Iridium satellite-based Devices. The frequency of collection of Location Data on Iridium satellite-based Devices is determined based the subscription data plan selected by your Company, your distance travelled, and the frequency of text messages sent. The typical Location Data collection frequency for Iridium satellite-based Devices ranges from once every 2 minutes to every 4 hours. To disable Location Data collection on Iridium satellite-based Devices, select Stop Tracking or power down the Device. Otherwise, if the Device is powered on, and has a connection to the Iridium satellite network, Location Data will continue to be collected.

4.2.2 Collecting Location Data on Smartphones Running the EVERYWHERE App. The frequency of collection of Location Data on smartphones running the EVERYWHERE App is determined based on how fast you are moving, App usage, and the frequency of text messages sent. The typical Location Data collection frequency on smartphones running the EVERYWHERE App ranges from every few seconds to 10 minutes. To disable Location Data collection on smartphones running the EVERYWHERE App, the EVERYWHERE App should be configured to turn off Device Tracking on the Settings screen. You can also prevent the collection of Location Data by powering down the smartphone. Otherwise, Location Data will continue to be collected.

4.2.3 Your Agreement to Collect and Access Location Data. By using the Services, you are agreeing to the collection and storage of Location Data by the Services and access to same by your Company. You have the right to view your Location Data. 

4.2.4 Company and Your Rights to Delete Location Data. The collection of Location Data is an essential function of the Services, and if your Company is paying for your access to the Services, then the Company has a legitimate commercial interest in having access to the Location Data that are created by the Devices that are associated with the Device Accounts under your name. Your Company has the sole right to determine whether or not to delete Location Data unless the Company is prevented from doing so in order to Comply With A Legal Obligation. Unless you have a legitimate basis that would require EVERYWHERE to Comply With A Legal Obligation to delete Location Data, then your request should be directed to the Company.

4.3 Aggregated Data. We also collect, use and share Aggregated Data such as statistical data for any purpose. For example, we may aggregate your Usage Data to calculate the percentage of End Users accessing a specific feature of the Services. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this Privacy Policy and the law.

4.4 Special Categories of Personal Data. We do not collect any special categories of personal data about you. This includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health (unless provided that under the Additional Information field in the Device User Data), and genetic and biometric data. Nor do we collect any information about criminal convictions and offenses.

4.5 Children. We request individuals under the age of 13 in the U.S. and under the age of 16 in the rest of the world not provide personal data to us. If we learn that we have collected personal data from a child under the age of 13 in the U.S. or under 16 in the rest of the world, we will take steps to delete the information as soon as possible.

4.6 If You Fail To Provide Personal Data. Where we need to collect personal data either because we need to Comply With A Legal Obligation or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to ensure our Performance of a Contract we have or are trying to enter into with you or your Company (for example, to provide you with access to the Services). In this case, we may have to cancel the Services you have with us but we will notify you or your Company if this is the case at the time.

5. HOW YOUR PERSONAL DATA IS COLLECTED
In addition to the information in Table 4.1 (Data Elements Table) under the “How/When Collected” column on how personal data is collected, we also use different methods to collect data from and about you and your Company including through:

5.1 Direct Interactions. You or your Company may give us your personal data by filling in forms or by corresponding with us by mail, phone, email or otherwise. This includes personal data you or your Company may provide when you or your Company:
• Request additional information about our Services; or
• Give us feedback or contact us.

5.2 Third Parties or Publicly Available Sources. We do not collect personal data about you from third parties or publicly available sources.

6. HOW WE USE YOUR PERSONAL DATA
We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
• Where we need to Perform the Contract we are about to enter into or have entered into with you or your Company.
• Where it is necessary for our Legitimate Interests and we (or a third party) has a Lawful Basis and your interests and fundamental rights do not override those interests.
• Where we need to Comply With A Legal Obligation.

6.1 Cookies

6.1.1 What Are Cookies? Cookies are text files placed on your computer to collect standard Internet log information and visitor behavior information. When you visit our websites, we may collect information from you automatically through cookies or similar technology. For further information, visit allaboutcookies.org.

6.1.2 How We Use Cookies. Our Company only uses cookies to manage security within the EVERYWHERE Hub. Therefore only Web Administrators and Web Users will use cookies placed by us. 

6.1.3 How to manage cookies. You can set your browser not to accept cookies, and the allaboutcookies.org website tells you how to remove cookies from your browser. However, if you are a Web Administrator or a Web User, some of our EVERYWHERE Hub features may not function as a result.

6.2 How We Store Your Data. Our Company securely stores your data on cloud-based servers operated by our Hosting Service Provider in an encrypted format. Our Company will keep your Message and Location Data for the Data Retention Period specified for each Device Account. Once this time period has expired, we will delete your Message and Location Data.

6.3 How We Use Your Data for Marketing

6.3.1 Periodically, our Company would like to send you information about products and services of ours that we think you might like, as well as those of our partner companies.

6.3.2 If you have agreed to receive Marketing Data from us, you may always opt out at a later date. You have the right at any time to stop our Company from contacting you for marketing purposes. If you no longer wish to be contacted for marketing purposes, please contact us and let us know that you wish to opt-out for marketing purposes.

6.3.3 We do not sell your personal data, including Location Data, to any third party. 

6.4 Application Analytics. We collect data from End Users about their usage of the Services. The types of analytical information that are collected include the date and time the EVERYWHERE App accesses our servers, App version, the location of the Device, what information and files have been downloaded to the App, End User behavior (e.g., features used, frequency of use), Device state information, Device model, hardware and operating system information, and information relating to how the App functions. We use this data to improve the quality and functionality of these and other apps; to develop and market products and features that best serve you and other users; and to help identify and fix the App’s stability issues and other usability problems as quickly as possible. The legal ground for processing this analytical information is our legitimate interest in understanding how our customers interact with our products and apps so we can enhance the user experience and functionality of our products and apps. Here are examples of third-party providers we currently use:

Google Firebase: Google Firebase is used to better understand the usage of the EVERYWHERE App as well as provide real time reporting of App crashes to improve App quality.

DataDog: Datadog is used to provide real time performance metrics and error logging of the EVERYWHERE Hub to improve system performance.

6.5 Automated Decision-Making, Including Profiling. EVERYWHERE does not make any decisions based on algorithms or other automated processing that significantly affect you.

6.6 Change Of Purpose. We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the Lawful Basis which allows us to do so or we will request your consent to do so. Please note that we may process your data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

7. DISCLOSURES OF YOUR DATA; ACCESS TO YOUR AND YOUR COMPANY’S DATA

7.1 We may share or provide access to your data or your Company’s data with the parties set out below for the purposes set out in the Table 4.1 (Data Elements Table): 

EVERYWHERE Employees
• EVERYWHERE System Administrators
• EVERYWHERE Billing Staff
• EVERYWHERE Support Staff

Authorized Third Parties
• EVERYWHERE’s third party Hosting Service Provider
• A Channel Partner who has sold your Company a license to use the Services
• An Emergency Monitoring Service Provider with whom your Company has agreed to purchase emergency monitoring services
• Professional advisers including lawyers, bankers, auditors and insurers who provide consultancy, banking, legal, insurance and accounting services

We require all our employees and Authorized Third Parties to respect the security of your personal data and to treat it in accordance with this Privacy Policy and to Comply With All Legal Obligations. We only permit our employees and the employees of our Authorized Third Parties to access your data who have a need to access your data in order to Perform the Contract or otherwise have a Lawful Basis to access your data. We do not allow our employees or Authorized Third Parties to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

7.2 Other Disclosures. We may disclose personal data about you to others: (a) if we have your valid consent to do so; (b) to comply with legal obligations, such as a valid subpoena, court or judicial order, or other valid legal process; (c) to enforce any of our terms and conditions or policies; (d) as necessary to pursue available legal remedies or defend legal claims; or (e) as we deem necessary or appropriate for purposes of attempting to get you help in the event you are involved in an emergency situation. We may also transfer your personal data to an affiliate, a subsidiary, or a third party in the event of any reorganization, merger, sale, joint venture, assignment, transfer, or other disposition of all or any portion of our business, assets, or stock, including, without limitation, in connection with any bankruptcy or similar proceeding, provided that any such entity that we transfer personal data will not be permitted to process your personal data other than as described in this Privacy Policy without providing you notice and, if required by applicable laws, obtaining your consent.

8. INTERNATIONAL TRANSFERS All data (except for Billing Information Data Elements) provided to EVERYWHERE by you and your Company is maintained on servers located in the United States and are operated and maintained by EVERYWHERE’s Hosting Service Provider. All Billing Information Data Elements provided to EVERYWHERE or a Channel Partner by you and your Company or created by EVERYWHERE is maintained either on (a) EVERYWHERE’s corporate and email servers located in the United States; or (b) the Channel Partner’s corporate and email servers (contact Channel Partner for location of their servers). Except as set forth in this section, we do not transfer your personal data outside the European Economic Area (EEA). When you use the Services in the EEA, data is transferred out of the EEA as follows:

• When you use the Services on Devices, it is transmitted back to our servers in the United States.
• If you are a Web Administrator or a Web User, when you use a browser to access the EVERYWHERE Hub, data is transmitted back our servers in the United States.
• If your Company is contracting with a Channel Partner located outside of the EEA, then any Company data provided to the Channel Partner by the Company will be transferred to the Channel Partner outside of the EEA.

9. DATA SECURITY We have put in place appropriate security measures to prevent your data from being accidentally lost, used or accessed in an unauthorized way, altered or disclosed. In addition, we limit access to your data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your 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 or your Company and any applicable regulator of a breach where we are legally required to do so. 10. YOUR LEGAL RIGHTS Under certain circumstances, you have rights under data protection laws in relation to your personal data.

10. YOUR LEGAL RIGHTS
Under certain circumstances, you have rights under data protection laws in relation to your personal data.

10.1 Your Rights. You have the right to:

10.1.1 Request information from us. You have the right to know whether your personal data is being processed, what personal data is gathered, from where it is obtained and why and by whom it is processed. This information is shared with you in Table 4.1 (Data Elements Table), above.

10.1.2 Request access to your personal data (commonly known as a "data subject access request"). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.

10.1.3 Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though the accuracy of the new data you provide may need to be verified. If you are a Web Administrator, you may change or update information associated with your accounts by logging into the Hub and editing the appropriate accounts. If you are not a Web Administrator, you may request to have personal data that we maintain returned or removed by contacting your Web Administrator. If you’re unable to obtain the results you expected from your Web Administrator after having escalated the matter within your Company, you can also contact the EVERYWHERE Data Privacy Manager at privacy@everywherecomms.com. EVERYWHERE reserves the right to validate requests to ensure legitimacy and refer the issue back to your Company. Valid requests will typically be handled within 30 days.

10.1.4 Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. Subject to limited rights regarding deletion of Location Data (see Section 4.2.4 (Company and Your Rights to Access and Delete Location Data), you also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.

10.1.5 Object to processing of your personal data. Where there is something about your particular situation which makes you want to object to processing your personal data on the grounds that you feel it impacts one of your fundamental rights and freedoms, you may object to such processing. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which overrides your rights and freedoms such as those set forth in Section 4.2.4 (Company and Your Rights to Access and Delete Location Data).

10.1.6 Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios:

• If you want us to establish the data's accuracy.
• Where our use of the data is unlawful but you do not want us to erase it.
• Where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims.
• You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

10.1.7 Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to during the Performance of a Contract with you or your Company.

10.1.8 Withdraw consent. You may withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to continue to provide the Services to you or your Company. We will advise you and your Company if this is the case at the time you withdraw your consent. If you wish to exercise any of the rights set out above, please contact us.
 
10.2 Your Rights Under the General Data Protection Regulation. If you reside in the EEA, U.K., or Switzerland, you have the right, subject to the conditions set out in the General Data Protection Regulation ("GDPR") or other applicable laws, to request from EVERYWHERE access to and rectification or erasure of your personal data, data portability, restriction of processing of your personal data, the right to object to processing of your personal data, and the right to lodge a complaint with a supervisory authority. For more information about these rights, please visit the European Commission’s “My Rights” page relating to GDPR, which can be displayed in a number of languages. If you reside outside of the EEA, U.K., and Switzerland, you may have similar rights under your local laws.

10.3 No Fees Usually Required. You will not have to pay a fee to access your personal data or to exercise any of the other rights. However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.

10.4 What We May Need From You. We may need to request specific information from you or your Company to help us confirm your identity and ensure your right to access your personal data or to exercise any of your other rights. This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you or your Company to ask you or the Company for further information in relation to your request to speed up our response.

10.5 Time Limit To Respond. We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

10.6 California Consumer Privacy Act. If you are a California resident, you have rights under the California Consumer Privacy Act of 2018 (the “CCPA").

10.6.1 Your Rights and How to Exercise Them under the CCPA.
 
10.6.1.1 Right To Know About The Personal Information We Collect And Share. The CCPA gives you the right to request that we disclose the specific pieces of personal information we have collected about you. The categories of personal information we collect about you and the sources from which we collect such personal information are described in the main Privacy Policy. EVERYWHERE does not sell, and has not sold, your personal information.

10.6.1.2 Right of Deletion. You have the right to request that we delete your personal information, subject to certain exceptions.
 
10.6.1.3 How To Exercise Your Rights. To request access to or deletion of your personal information, contact the EVERYWHERE Data Privacy Manager. You will need to provide your account credentials in order to access your account to exercise your rights. Subject to limited rights regarding access and deletion of Location Data (see Section 4.2.4 (Company and Your Rights to Access and Delete Location Data), no one else can request access to or deletion of your personal information without providing sufficient evidence of your authorization. The method for verifying your identity varies based on the identifying information we hold about you. You may be asked to reply to an email sent to the email address on record or to provide the serial number of a Device.

10.6.2 Disclosures About Your Personal Information

10.6.2.1 Categories Of Information We Collect And Disclose For A Business Purpose. We collect the categories of personal information from you in connection with the Services, as defined in the CCPA, that are described in the main Privacy Policy.

10.6.3 Nondiscrimination. EVERYWHERE will not discriminate against you for exercising any of your CCPA rights.

10.6.4 Contact Us. Please see Section 2.3 (Contact Information) to contact us if you have any questions regarding EVERYWHERE’s privacy practices.
  

Schedule A Definitions

“Aggregated Data” means de-identified data that could be derived from your personal and other data but is not considered personal data in law as this data will not directly or indirectly reveal your identity.

“Authorized Third Parties” means the parties listed under the heading of Authorized Third Parties in Section 7 (Disclosures Of Your Data; Access To Your And Your Company’s Data).

“Channel Partner” means a third party distributor or reseller of the Services who has entered into a channel partner agreement with EVERYWHERE.

“Company” shall have the meaning ascribed to it in Section 1 (Introduction).

“Comply With A Legal Obligation” (or similar wording) means compliance with a legal obligation that we or another party is subject to pursuant to any applicable statute, regulation, ordinance, rule, judgment, decree, or court order.

“Contact Data” means the following data elements that are used to identify an individual that you may contact using the Services: First Name, Last Name, Organization, Phone number or Email address.

“Data Retention Period” means the period of time that Messages and Location Data are retained for a particular Device Account.

“Device” means either (a) a mobile device capable of receiving and transmitting satellite signals using the satellite service which is powered by the Iridium constellation of low-earth orbiting (LEO) satellites, the ground network and Iridium communication equipment; or (b) a smartphone capable of installing and operating an EVERYWHERE App.

“Device Account” means an account within the Services for each Device provided that if a particular Iridium satellite Device is paired with a smartphone Device that is running an EVERYWHERE App, there is a single Device Account for both of those paired Devices. For more information on Device Accounts, see Section 3.1 (Device Accounts).

“Device User Data” means the following data elements that are used to identify the End User of a particular Device: First Name, Last Name, Address, City, Address, City, State/Province, Zip/Postal Code, Country, Citizenship, Phone number, Email address, and Additional Information (comment field).

“Emergency Contact Data” means the following data elements that are used to identify an emergency contact when you generate an emergency signal on a Device while using the Services: Name, Country, Phone number, Email address.

“Emergency Monitoring Service Provider” means a third party who operates a SOS emergency monitoring service who receives emergency signals from the Services and coordinates rescue with a public safety answering point (PSAP), an emergency response center or a law enforcement agency.

“End User” means an end user of the Services, whether or not they are part of your Company.

“EVERYWHERE” means EVERYWHERE Communications, Inc., a Delaware, USA corporation with corporate offices located at 30 West Street Annapolis, Maryland 21401.

“Geofence Coordinates” mean the data elements that are used to define a virtual geographic boundary that enables the Services to trigger a geofence notification when a Device enters or leaves the defined geographic boundary.

“Hosting Service Provider” means a third party provider that hosts the EVERYWHERE Hub on servers owned or operated by the provider.

“Lawful Basis” or “Legitimate Interest” means the interest of our business in conducting and managing our business to enable us to give you and your Company the best products and services and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our Legitimate Interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our Legitimate Interests against any potential impact on you in respect of specific activities by contacting us.

“Location Data” means certain information about the physical location and direction of a Device such as the Device’s current latitude, longitude, heading, course, speed, and altitude or information such as waypoints, routes, courses, or tracks. For more information on Location Data, see Section 4.2 (Location Data).

“Login Credentials” means the username and password that you use to gain access to the Services.

“Marketing Data” means data used for marketing purposes.

“Message” means the content a message that the Services allows you to send and receive from a Device. A Message may contain pre-defined messages as well as user created messages. Message may also contain voice recordings, videos, pictures or other images created by you or another End User of the Services with whom you are communicating with.

“Other User Access” means a list of Web User Accounts that are permissioned for a Device Account to either have read-only access to the Device Account or have read-write access to the Device Account.

“Performance of a Contract” or “Perform the Contract” means processing your data where it is necessary for the performance of a contract to which you or your Company is a party or to take steps at your request before entering into such a contract.

“Quick Messages” means pre-defined message text defined by an End User that may be selected and sent as a Message on a Device.

“Services” means one or more of the following EVERYWHERE products and services to the extent they are being sold or licensed to you or your Company under a commercial agreement between your Company and EVERYWHERE or one of EVERYWHERE’s Channel Partners that resells the Services: (a) the EVERYWHERE Smartphone App; (b) the EVERYWHERE Hub; or (c) the Iridium® satellite service.

 “Team” means a logical organization within the Services. A Team could be an individual company, a division of a company, an government agency, etc.

“Usage Data” means the number of Messages you send and receive, the number of reports of Location Data, and the total amount of data you send and receive each month over the Iridium satellite network. 

“Web Administrator” means an End User that is authorized by the Company to add, modify and delete account information stored on the EVERYWEHERE Hub related to the operation of the Services, including Device Accounts. For more information on Web Administrators, see Section 3.2 (Web User Accounts).

“Web User” means an End User that is authorized by the Company to view account information stored on the EVERYWEHERE Hub but are not permitted to add, modify or delete account information. For more information on Web Users, see Section 3.2 (Web User Accounts).

“Web User Data” means the following data elements that are used to identify the Web User or Web Administrator: Email address. In addition, Web User Data also contains various permissioning: Device Accounts the Web User is authorized to have read-only access to or, in the case of a Web Administrator, read-write-access to, and Teams the Web Administrator is authorized to administer.

Schedule B Revision History

Previous published versions of the EVERYWHERE Privacy Policy can be found by clicking on the links below:


Initially Published: November 11, 2018

Revised: November 11, 2021