Privately Distributed Apps Privacy Policy

Last updated March 13, 2025

This Privately Distributed Apps Privacy Policy (“Policy”) applies to all privately distributed applications provided by JointAccounts, LLC (“Company,” “we,” “us,” or “our”) for use within designated environments. This includes, but is not limited to, apps deployed in correctional facilities. This Policy governs the collection, use, disclosure, sharing, and retention of information provided through these apps. Please note that due to legal and operational requirements, no information provided via these apps is guaranteed to remain private. All data may be subject to review by authorized personnel, including facility staff, JointAccounts employees, or government officials as required by law.

1. Applicability

This Policy applies solely to the privately distributed apps offered by JointAccounts, LLC and does not extend to any publicly accessible platforms or websites. By using these apps, you acknowledge and agree that your information may be accessed and reviewed by authorized personnel for security, legal, or operational purposes.

2. Information We Collect

A. Personal Information Provided by You

When using our privately distributed apps, you may provide personal information, including but not limited to:

• Names and identifying details

• Contact information as required for app functionality

• Biometric data, such as face data (see Section 4)

B. Automatically Collected Information

We also automatically collect technical and usage data from your device, including:

• Device type and operating system details

• Log data such as access times and usage patterns

• IP addresses and other connection details

Please be aware that all information collected is subject to review by authorized facility and JointAccounts staff as well as government officials when legally required.

3. How We Process Your Information

We process your information for the following purposes:

• Service Delivery: To provide and facilitate access to the app and its features, including authentication and communication services.

• Compliance and Monitoring: To ensure adherence to legal, facility, and operational requirements. This includes periodic reviews and audits of data by authorized personnel.

• Operational and Security Purposes: To monitor, analyze, and improve the app’s functionality, security, and user experience.

• Legal Obligations: To comply with all applicable laws and regulations governing data processing in restricted-access environments.

4. Face Data Collection, Use, and Retention

A. What Face Data Does the App Collect?

The app collects biometric information in the form of facial data. This includes still images, video recordings, and any derived facial recognition templates captured during enrollment or subsequent authentication processes.

B. Planned Uses of the Collected Face Data

Face data is collected for:

• Identity Verification & Access Control: Ensuring that only authorized individuals can access and use the app.

• Compliance and Monitoring: Meeting legal and facility-specific requirements for verifying identity and maintaining audit trails.

• Security Enhancement: Improving and maintaining the integrity and security of the app.

C. Sharing, Storage, and Disclosure of Face Data

• Sharing: Face data may be accessed and reviewed by authorized facility staff, JointAccounts employees, or government officials as necessary. It will not be shared with external third parties except when required by law.

• Storage: Face data is stored securely on our internal systems using robust security measures. However, due to the nature of the service, all stored information is subject to review.

• Legal Disclosure: We comply with all legal mandates regarding the disclosure of biometric data. Should legal requests or mandates be issued, the relevant data will be provided in accordance with applicable laws.

D. Retention of Face Data

Face data is retained for the maximum period required by applicable legal and regulatory obligations. Once the retention period expires, and if no further legal obligation exists, such data will be securely deleted or anonymized.

5. Data Sharing and Disclosure

Your data may be disclosed under the following circumstances:

• Internal Review: Authorized facility staff and JointAccounts personnel may review your data for operational, security, or compliance purposes.

• Legal Requirements: Data may be disclosed to government officials or law enforcement agencies when legally mandated.

• Service Providers: Data may be shared with third-party vendors who assist in maintaining the app, subject to strict contractual obligations and security standards.

Because these apps are privately distributed and designed for restricted-access environments, all information provided is inherently subject to review and disclosure as required by law or organizational policy.

6. Data Retention

We retain all collected information for as long as legally necessary or as required by the operating environment’s policies and regulations. When your data is no longer needed for the purposes stated in this Policy or required by law, it will be securely deleted or anonymized, subject to operational constraints such as data stored in backup systems.

7. Data Security

We implement appropriate technical and organizational measures to protect the security of your information. Despite these safeguards, no system is completely secure, and due to the nature of privately distributed apps, data provided via the app may be subject to review and disclosure as permitted or required by law.

8. Legal Compliance

We comply with all applicable local, state, and federal laws regarding privacy and data protection. By using these apps, you acknowledge that your information may be collected, stored, and reviewed in accordance with these laws and the operational requirements of your environment.

9. Changes to This Privacy Policy

We may update this Policy from time to time. Any material changes will be communicated through updated versions of this Policy, with an updated “Last Updated” date. Continued use of the app after such changes indicates your acceptance of the updated Policy.

10. Contact Information

If you have any questions or concerns about this Policy or our data practices, please contact us at:

JointAccounts, LLC

209 N Lindell St

Martin, TN 38237

Email: support@jointaccounts.com

By using our privately distributed apps, you acknowledge that you have read, understood, and agree to the terms outlined in this Privacy Policy. All information provided through these apps is subject to the operational, legal, and compliance requirements of the environments in which they are deployed.