Guam Covid Alert Privacy Policy

Guam Department of Public Health and Social Services (DPHSS) Guam Covid Alert- Privacy Policy

Effective as of August 19, 2020
This “Privacy Policy” explains how the Guam Department of Public Health and Social Services (DPHSS) collects, uses, discloses and otherwise processes end users’ data in connection with the PathCheck Guam mobile application (“Guam Covid Alert”). This Application Provider for Guam Covid Alert is the Government of Guam Office of Technology (OTECH). This Privacy Policy also describes the choices available to individuals with respect to data when using the Guam Covid Alert.

ABOUT DPHSS AND THE GUAM COVID ALERT

DPHSS oversees public health efforts throughout Guam. The Guam Covid Alert is intended for use to facilitate contact tracing in response to COVID-19. Contact tracing consists of notifying and monitoring individuals who have been in close contact with someone who is infected with a virus and could potentially infect others. The Guam Covid Alert allows users to store data collected and processed by the App for the purposes of contact tracing locally on the respective user’s mobile device. The Guam Covid Alert can notify users if they have been exposed to a COVID-19-infected individual and provide instructions on how and where to get tested.

HOW IT WORKS

DPHSS never collects or processes any personally identifiable information from the Guam Covid Alert. Bluetooth random IDs are assigned to each device using the Guam Covid Alert. Each user’s random code changes frequently to further protect their identity. When a Guam Covid Alert user comes into close contact with another Guam Covid Alert user, their random codes are exchanged using Bluetooth. Random codes for close contacts are stored in a user’s device for 14 days. No personally identifiable or location information is collected, stored, or exchanged.

If a user tests positive for COVID-19, they may choose to notify other Guam Covid Alert users who may have had close contact with them. To trigger such notification, a user who tests positive for COVID-19 must enter a valid, 8-digit PIN provided by a DPHSS contact tracer. This PIN is randomly generated by DPHSS and only used to enter a positive diagnosis in the Guam Covid Alert. Once a valid PIN is entered into the Guam Covid Alert, a risk calculation is made using the time, duration, and Bluetooth signal attenuation (proximity indicator) collected by the Guam Covid Alert for each contact event between Guam Covid Alert users, and other Guam Covid Alert users who are calculated to have been in close contact with the user who tested positive will be alerted.  Users may receive exposure notifications in the Guam Covid Alert to let them know they encountered a possible exposure.

YOUR CHOICES USING THE APP

Using the Guam Covid Alert is completely voluntary, and you may choose to install and uninstall the Guam Covid Alert at any time. The Guam Covid Alert will never collect, track or store your location, GPS information, or personal information.

ENABLING EXPOSURE NOTIFICATIONS

Enabling exposure notification in the Guam Covid Alert is your choice. You can enable and disable such notification at any time. It must be enabled for the Guam Covid Alert to exchange the random codes with other Guam Covid Alert users who you come into close contact with, for you to receive exposure notifications, or for you to notify other Guam Covid Alert users if you test positive for COVID-19 by sharing your random codes through a positive report.

 NOTIFYING OTHER APP USERS IF YOU TEST POSITIVE

If you test positive for COVID-19, you may choose to notify other Guam Covid Alert users who you have been in close contact with. Providing notification to other Guam Covid Alert users with whom you have had close contact is completely voluntary. The notification will not disclose your identity or any personally identifying information. To enable such notifications, you will need a valid, 8-digit PIN provided by the DPHSS contact tracer. This PIN is used to verify your positive diagnosis and prevent false reports. This PIN is not associated with your identity. Once a valid PIN is entered into the Guam Covid Alert and you confirm that you wish to anonymously notify other users you may have encountered, after you confirm, all Guam Covid Alert users who have enabled their app configuration to receive notifications will receive your Bluetooth random IDs to determine if there has been any close contact with you. Such notifications will not include your identity or the date, time, or location of the exposure.

 TERMINATING APP PARTICIPATION

Participation in the Guam Covid Alert may be terminated at any time by deleting or uninstalling the Guam Covid Alert from your device. After the Guam Covid Alert is deleted or uninstalled, your device will no longer generate or exchange Bluetooh random IDs with other users. Any Bluetooth random IDs that were previously shared with other Guam Covid Alert users will be automatically deleted after 14 days from the date the PIN was generated.

SHARING OF INFORMATION

The following event data may be processed and collected in the Guam Covid Alert:
  • Installing the Guam Covid Alert
  • Enabling and disabling Exposure Notifications
  • Receiving an Exposure Notification
  • Submitting a verified PIN
  • Sharing a positive result
  • Downloading anonymous tokens for positive users that have chosen to notify others
  • Deleting the app
  • We use the above event information to understand how the Guam Covid Alert is being used. This data may be shared with other entities. It may be used in aggregate and anonymous form for statistical or scientific research purposes. This information will not include any personal or location information nor can it be used to identify any Guam Covid Alert user.

    OPTING OUT OF PUSH NOTIFICATIONS

    If you opt-in to receive push notifications within the Guam Covid Alert, it may send push notifications or alerts to your mobile device from time to time. You can deactivate push notifications and alerts at any time by deleting the Guam Covid Alert, changing your device settings, or changing the push notification settings within the Guam Covid Alert.

    AGE REQUIREMENTS

    Guam Covid Alert is not intended for children under the age of 13, and we do not knowingly allow a child under 13 to use the App. If you are between the ages of 13 and 17, you can only use Guam Covid Alert if your parent or legal guardian has reviewed and agreed to the Terms of Service on your behalf.

    CHANGES TO OUR PRIVACY POLICY

    We may update this Privacy Policy from time to time. If we make material changes to our Privacy Policy, we will notify you by posting the changes on Guam Covid Alert or by using the contact information you provide to the Guam Covid Alert. The notification will indicate when such changes will become effective. If you object to a new Privacy Policy, you may terminate participation in the Guam Covid Alert by deleting or uninstalling the Guam Covid Alert.

    CONTACTING US

    If you have any feedback, or any questions, comments, or concerns relating to this Privacy Policy or our privacy practices, please contact us at our Contact Us page or write to us at the following address:

    Department of Public Health & Social Services ITC Building Ste 219.

    590 S. Marine Corps Drive, Tamuning, Guam 96913-3532

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