Privacy Policy

1. Introduction

Wren Care Inc., a Delaware corporation (“Wren” or the “Company” or “We” or “Us”) respects your privacy and is committed to protecting it through our compliance with this policy.

This privacy policy (the “Privacy Policy” or “Policy”) describes the types of information we may retrieve or collect from you or that you may provide when you visit and use our website www.carewithwren.com as well as any other media form, media channel, mobile website or mobile application related, linked, or otherwise connected thereto (collectively, the “Platform”) and our practices for collecting, using, maintaining, protecting, and disclosing that information.

Please read this Policy carefully to understand our policies and practices regarding your information and how we will treat it.

By accessing or using this Platform, you agree to this Privacy Policy and our accompanying Terms of Use (our “Terms of Use”) and Platform Services Agreement (our “PSA”) – together with our Privacy Policy and Terms of Use, the “Legal Terms”). This Policy may change or be modified from time to time. Your continued use of this Platform after we make changes is deemed to be acceptance of those changes, so please check the Policy periodically for updates. If you do not agree with our Policy and practices, you must discontinue use of the Platform immediately.

2. Information Covered by Our Privacy Policy

This Policy applies to information we collect:

• On this Platform.
• In the course of completing our registration forms as required to register for an account with Wren (an “Account”), which may include identity verification and a background check.
• In email, text, and other electronic messages between you and the Platform.
• Through mobile and desktop applications and/or browser extensions you download from this Platform, which provide dedicated non-browser-based interaction between you and this Platform.

This Policy does not apply to information collected by:

• Us offline or through any other means, including on any other website operated by the Company or any third party (including our affiliates and subsidiaries); or
• Any third party (including our affiliates and subsidiaries), including through any application or content (including advertising) that may link to or be accessible from or through the Platform.

3. Information We Collect About You

We collect several types of information from and about users of our Platform (“Users”), including information:

• By which you may be personally identified, such as name; postal/mailing address; email address; telephone number; date of birth; government-issued identification; household information (e.g., the number of children in your household, and their ages and genders); additional information we may request and collect for the purpose of verifying your identity and conducting a background check; and any other identifier by which you may be contacted online or offline (collectively, “Personal Information”);
• Provided by you if register for an Account with Wren as an individual or family seeking certain care services (a “Customer”), which may include without limitation your care needs and preferences; special care instructions; location; and schedule (collectively, “Customer Information”);
• Provided by you if register for an Account with Wren as an independent caregiver or service provider (a “Caregiver”), which may include without limitation your profile picture; educational history; work experience and background; educational history; work experience; relevant credentials, certifications and/or specialized trainings; third-party references; care preferences; and the Care Services (as hereinafter defined) you intend to offer through the Platform (which can be modified at any times in the Caregiver’s Account settings), which, if applicable, must include the ages of children you are willing to provide care for (collectively, “Caregiver Information”);
• That is about you but individually does not identify you, such as information relating to the childcare and related household support services you desire to offer through the Platform, which may include without limitation services consisting of backup childcare, babysitting, mother’s helper services, light household support and other family support services offered through the Platform from time to time (collectively, the “Care Services”).
• About your location (“Geolocation Information”), which may be provided by you directly when sharing your home address or collected automatically by the Platform, provided that you have enabled the location services and authorized the Platform to utilize your location services on the specific device you are accessing the Platform from.
• Provided by you if you register or sign in through your email provider, you are authorizing us to collect, store, and use, in accordance with this Privacy Policy, any and all information that you agreed that such third-party email provider would provide to us through their respective Application Programming Interface (“API”). Such information may include, without limitation, your first and last name, your username, profile picture, headline, unique identifier and access token, and e-mail address, as may be the case depending on the third-party API.
• About your operating system, your IP address(es), browser type and language, referring and exit pages and URLs, keywords, date and time, amount of time spent on particular pages, what sections of a website you visit, and similar information concerning your use of the Platform (the “Usage Information”).

4. How We Collect Your Information

We collect the information detailed above in the following ways:

• Directly from you when you provide it to us, including information provided in the process of registering for an Account with the Platform.
• Directly from you when you provide it to us or upload it to the Platform, including Customer Information and Caregiver Information;
• From your email provider during Account registration or sign in to our Platform, limited to the information that you agree to provide and that your email provider elects to share.
• From our third-party service providers and business partners for the purposes set forth in this Privacy Policy.
• Automatically as you use and navigate through the Platform. Information collected automatically, including Usage Information, may include usage details, IP addresses, and information collected through cookies, web beacons, and other tracking technologies.

Information You Provide to Us

The information we collect on or through our Platform may include:

• Information that you provide by filling in forms on our Platform. This includes information (including Personal Information) provided at the time of registering for an Account on the Platform or when requesting further services or assistance from us. We may also ask you for information when you enter a contest or promotion sponsored by us and when you report a problem with our Platform.
• Customer Information and Caregiver Information that you provide when first registering for an Account on the Platform and creating your Account page on the Platform.
• Information that you provide when making or accepting a booking (a “Booking”) for Care Services through the Platform.
• Records and copies of your correspondence (including messages) when you contact other Users on the Platform to request, offer or make a Booking for Care Services.
• Records and copies of your correspondence (including email addresses), if you contact us, including without limitation correspondence to us regarding Platform feedback, complaints and incident reports.
• Details of transactions you carry out through our Platform and of the fulfillment of your requests for Care Services made through the Platform. You may be required to provide payment information before placing a request for Care Services through the Platform.

Information We Collect Through Automatic Data Collection Technologies

As you access, use, navigate through, and interact with our Platform, we may use automatic data collection technologies to collect certain Usage Information about your equipment, browsing actions, and patterns, including:

• Details of your visits to our Platform, including traffic data, location data, logs, and other communication data and the resources that you access and use on the Platform.
• Information about your computer and internet connection, including your IP address, operating system, and browser type.

We do not use these technologies to collect information about your online activities over time and across third-party websites or other online services (behavioral tracking).

The information we collect automatically, including Usage Information, may include Personal Information. It helps us to improve our Platform and to deliver a better and more personalized service, including by enabling us to:

• Provide tailored recommendations for relevant Customers seeking Care Services and Caregivers offering Care Services.
• Estimate our audience size and usage patterns.
• Store information about your preferences, allowing us to customize our Platform according to your individual interests.
• Speed up your searches.
• Recognize you when you return to our Platform.

The technologies we use for this automatic data collection may include:

• Cookies (or browser cookies). A cookie is a small file placed on the hard drive of your computer. You may refuse to accept browser cookies by activating the appropriate setting on your browser. However, if you select this setting you may be unable to access certain parts of our Platform. Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies when you direct your browser to our Platform. Please be advised that shutting off cookies on your browser or mobile device may limit access to some or all of the Platform and may restrict the Platform’s full range of features and services.
• Web Beacons. Pages of our Platform and our emails may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit us, for example, to count Users who have visited those pages or opened an email and for other related website statistics (for example, recording the popularity of certain website content and verifying system and server integrity).

5. Third-Party Use of Cookies and Other Tracking Technologies

We do not permit third-party use of cookies, other automatic tracking technologies or other automatic data collection practices by third-parties on the Platform.

6. How We Use Your Information

We use information that we collect about you or that you provide to us, including any Personal Information:

• To present our Platform and its contents to you.
• To provide you with information, products, or services that you request from us and/or from other Users of the Platform.
• To enhance and improve the Platform, such as through personalized features and content.
• To better understand the needs of Customers, evaluate Caregivers, and help match Caregivers offering requested Care Services to Customers seeking those Care Services.
• To allow you to participate in the interactive features on our Platform, including messaging other Users and requesting or offering Care Services from or to other Users.
• To analyze the Platform’s use and the details about the Users visiting the Platform to help us improve the Platform and our content and services.
• To fulfill any other purpose for which you provide it.
• To identify you when you sign into your Account with Wren.
• To provide you with notices about your Account with the Platform.
• To carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including our Legal Terms.
• To notify you about changes to our Platform or any products or services we offer or provide though it.
• To provide direct marketing and administer our promotional programs.
• To solicit your feedback about the Platform.
• To prevent fraud, misconduct, illegal activity and abuse of the Platform.
• In any other way we may describe when you provide the information.
• For any other purpose with your consent.

We may also use your information to contact you about our own goods and services that may be of interest to you (e.g., direct marketing). If you do not want us to use your information in this way, please adjust your user preferences in your Account settings.

We will not use the information we have collected from you to display advertisements from any third-parties.

7. Disclosure of Your Information

We may disclose Personal Information and certain Customer Information and Caregiver Information that we collect or you provide as described in this Privacy Policy:

• To our subsidiaries and affiliates.
• To our third-party service providers, vendors and other third parties we use to support our business, and who are bound by contractual obligations to keep Personal Information confidential and use it only for the purposes for which we disclose it to them. These third-parties include: Stripe, as our payment processor, for the purpose of processing payments made through the Platform; Revyrie Global, as our web developer and analytics provider; CheckR, as our background check and identity verification provider; OpenAI, as we allow Caregivers to utilize ChatGPT to generate biographies for their Account pages; and Twilio, as our SMS messaging and cloud communication provider.
• To an actual or prospective buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of the Company’s assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which Personal Information held by the Company about our Platform Users is among the assets transferred. In the event that information about our Users, including Personal Information, is disclosed to an actual or prospective buyer or successor in the context of one of the foregoing transactions, such actual or prospective buyer or other successor shall be bound by contractual obligations to keep Personal Information confidential.
• To third parties approved by you.
• To fulfill the purpose for which you provide it.
• For any other purpose disclosed by us when you provide the information.
• With your consent.

We may also disclose your Personal Information:

• To comply with any court order, law, or legal process, including to respond to any government or regulatory request.
• To enforce or apply our Terms of Use or our Platform Services Agreement and other agreements you are party to, including for billing and collection purposes.
• If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of the Company, our Users, or others. This may include exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction.

Additionally, we may disclose aggregated information about our Users, and information that does not identify any individual or household, without restriction. Such aggregated information will be anonymized and non-identifiable to any individual User or household.

We will NOT disclose the following categories of information to any third parties:

• Personal Information of children or household members under the age of 18.
• Child-specific care notes, instructions and requests.
• Information about a child’s medical considerations, treatment, or allergies.
• Home or property access information.
• Results of a Caregiver’s background check.

8. Choices About How We Use and Disclose Your Information

We strive to provide you with choices regarding the Personal Information you provide to us. We have created mechanisms to provide you with the following control over your information:

• Tracking Technologies and Advertising. You can set your browser to refuse all or some browser cookies, or to alert you when cookies are being sent. If you disable or refuse cookies, please note that some parts of this Platform may then be inaccessible or not function properly.
• Promotional Offers from the Company. If you do not wish to have your contact information used by the Company to promote our own products or services, you can opt-out by adjusting your user preferences in your Account settings by checking or unchecking the relevant boxes. You can also opt-out of promotional offers from the Company by sending an email stating your request to support@carewithwren.com. If we have sent you a promotional email, you may send us a return email asking to be omitted from future email distributions or click “unsubscribe” in our promotional email. This opt out does not apply to information provided to us as a result of a purchase, service experience or other transactions.

9. Accessing and Correcting Your Information; Requests Related to Your Information

We strive to ensure that our Users have a safe experience while using our Platform. Users can review any Personal Information collected about them, request corrections to their Personal Information, have their Personal Information deleted, request that there be no further collection or use of their Personal Information, and/or allow for our collection and use of their Personal Information while withholding consent for us to disclose it to third parties. To request access to, correct or request the deletion of your Personal Information, you must contact us by email to support@carewithwren.com with your request. Residents of certain states may have additional Personal Information rights and choices. Please see Section 10 below for more information.

In certain cases, we may not be able to delete your Personal Information except by also deleting your User account. We may not accommodate a request to change information if we believe the change would violate any law or legal requirement or cause your information to be incorrect.

If you have submitted any request(s) related to your Personal Information or other information we have collected about you in accordance with the procedures set forth in this Privacy Policy, we reserve the right to request additional information in order to verify your identity and confirm the legitimacy of your request. Upon receiving your request, we may require you to provide additional information and/or documentation (which may include a copy of your government identification) to verify your identity and will respond to your request within forty-five (45) days of your request. If we need more time to process your request or verify your identity, we will notify you of the extension, explain why it is necessary and fulfill your request as soon as possible.

10. Your State Privacy Rights

California Privacy Rights.

This Section provides additional information on how we collect, use and share the Personal Information of California residents.

California Consumer Privacy Act

Under the California Consumer Privacy Act, as amended by the California Privacy Rights Act of 2020 (collectively, the “CCPA”), California residents have the following rights with respect to their Personal Information (as defined in the CCPA):

• Right to Know and Access; Data Portability: you have the right to obtain a copy of the Personal Information we have collected about you in the past twelve (12) months. You also have the right to know, in the last twelve (12) months: what categories of Personal Information we have collected from you; the sources from which we collected your Personal Information; our commercial purpose for collecting and/or sharing your Personal Information; the categories of Personal Information we have shared and/or sold to third parties; and the categories of third parties to whom we have shared and/or sold your Personal Information.
• Right to Delete: you have the right to request that we delete any Personal Information we have collected about you in the past twelve (12) months. Please note that depending on the specifics of your deletion request, we may be required to delete your Account and Subscription.
• Right to Correct: you have the right to correct any inaccurate Personal Information that we have collected about you in the past twelve (12) months.
• Right to Opt Out of Sharing or Selling: you have the right to opt out of the sharing, disclosure or sale of your Personal Information.
• Nondiscrimination: you have the right to exercise your rights under the CCPA without discrimination from us.

To exercise any of your rights under the CCPA, please contact us via email to support@carewithwren.com.

California Shine The Light Law

Under California Civil Code § 1798.83, California residents who have an established business relationship with Wren may request a list of the categories of Personal Information that we have disclosed to third parties in the past twelve (12) months and the third-party business partners to whom we have disclosed your Personal Information in the past twelve (12) months. Additionally, California residents who have an established business relationship with Wren may choose to opt out of our sharing their contact information with third parties for direct marketing purposes. If you are a California resident and you wish to request such information or opt out, please send an email to support@carewithwren.com.

California Do Not Track Law

Your mobile device may be configured to deliver “Do Not Track” signals to websites and applications that you access. As of the date of this Privacy Policy, we do not monitor, recognize and honor any opt-out or do not track mechanisms, including a general “Do Not Track” setting established on your mobile device.

Additional State Privacy Rights

State consumer privacy laws may provide their residents with additional rights regarding our use of their Personal Information. Colorado, Connecticut, Delaware, Florida, Indiana, Iowa, Kentucky, Maryland, Minnesota, Montana, Nebraska, New Hampshire, New Jersey, Oregon, Rhode Island, Tennessee, Texas, Utah, and Virginia provide (now or in the future) their state residents with rights to:

• Confirm whether we process their Personal Information.
• Access and delete certain Personal Information.
• Correct inaccuracies in their Personal Information, taking into account the information’s nature processing purpose.
• Data portability.
• Opt-out of personal data processing for: targeted advertising; sales; or profiling in furtherance of decisions that produce legal or similarly significant effects.
• Either limit (opt-out of) or require consent to process sensitive personal data.

The exact scope of these rights may vary by state. To exercise any of these rights please reach out to us via email to support@carewithwren.com. To appeal a decision regarding a consumer rights request, please reach out us via email to support@carewithwren.com.

11. Data Retention Practices

We will retain your Personal Information while you have an Account with Wren and thereafter, upon the deletion of your Account, we will retain your Personal Information for up to one (1) year unless you request that we permanently delete your Personal Information prior to such time. Please note that we may refuse a request to delete a User’s Account and/or Personal Information if the User has unresolved bookings, pending payments due (whether owed or receivable) or open disputes until such matters are resolved.

Following the deletion of your Account, unless you request otherwise, we may archive your Personal Information for up to one (1) year before its final, permanent deletion as part of our ordinary business procedures. We archive Users’ Personal Information and other information for the purposes of: completing Platform transactions; maintaining financial, tax, and Platform transaction records; maintaining records on background checks, safety reviews and Account restrictions and removals; investigating User complaints and disputes; investigating and enforcing suspected or actual violations of our Legal Terms, including conduct prohibited by our Terms of Use; otherwise safeguarding the rights, safety and security of our Users; and ensuring compliance with applicable legal requirements and/or where required by law, court order, or other governmental or law enforcement authority or agency. Such information will be retained by us only for as long as reasonably necessary for the purpose(s) set forth herein unless a longer retention period is otherwise required or permitted by applicable law. Except for such archival as part of our ordinary business procedures, we will not retain your Personal Information for longer than necessary for the purposes for which we collected your Personal Information (as described more particularly in this Privacy Policy).

12. Age Restrictions

The Platform is not directed to children under the age of 18 and we do not knowingly permit children under the age of 18 to create an Account or otherwise use the Platform. We adhere to the Children’s Online Privacy Protection Act (COPPA) and will not knowingly collect Personal Information from any child under the age of 18. If a child under the age of 18 has provided us with any Personal Information, a parent or guardian of that child may contact us by email to support@carewithwren.com and request that such information be deleted from our records and not used for any further uses and/or processing. We will evaluate and respond to any requests regarding a child’s Personal Information or other information in accordance with the timeframe set forth in Section 9 above.

13. Important Notice to Users Outside the United States

The Company operates the Platform in the United States. If you are located outside of the United States, please be aware that you will not be able to create an Account or use or access the Platform.

14. External Websites

The Application may contain links to third-party websites. We have no control over the privacy practices or the content of these websites. As such, we are not responsible for the content or the privacy policies of those third-party websites. You should check the applicable third-party privacy policy and terms of use when visiting any other websites.

15. How We Protect Your Information; Data Security

We take commercially reasonable steps to protect your Personal Information from loss, misuse, and unauthorized access, disclosure, alteration, or destruction. Please understand, however, that no security system is impenetrable. We cannot guarantee the security of our databases, nor can we guarantee that the information you supply, including your Personal Information, will not be intercepted while being transmitted to and from us over the Internet. Unfortunately, the transmission of information via the internet is not completely secure. Although we do our best to protect your Personal Information, we cannot guarantee the security of your Personal Information transmitted to our Platform. Any transmission of Personal Information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on the Platform.

The safety and security of your information also depends on you. Where we have given you (or where you have chosen) a password for access to certain parts of our Platform, you are responsible for keeping this password confidential. We ask you not to share your password with anyone.

16. Changes to Our Privacy Policy

It is our policy to post any changes we make to our Privacy Policy on this page with a notice that the Privacy Policy has been updated on the Platform’s home page. If we make material changes to how we treat our Users’ Personal Information, we will notify you by email to the email address specified in your account or through a notice on the Platform home page. The date the privacy policy was last revised is identified at the top of this Privacy Policy. You are responsible for ensuring we have an up-to-date active and deliverable email address for you, and for periodically visiting our Platform and this privacy policy to check for any changes.

17. Contact Information

To ask questions or comment about this Privacy Policy and our privacy practices, contact us by email to support@carewithwren.com.

You can also reach out to us by mail to:

Wren Care Inc.

502 Monroe Street, Apartment 202

Hoboken, New Jersey 07030

To register a complaint or concern, please contact us via email to support@carewithwren.com.