Privacy Policy

Last Updated: March 1, 2026

Introduction
This Website and Application Privacy Policy (this “Privacy Policy”) describes how RR7345 Consulting, LLC
d/b/a Start Checkpoints (“Start Checkpoints,” “Company,” “we,” “us,” or “our”) collects, uses, stores,
discloses, and protects information when you access or use our website located at
https://www.startcheckpoints.com, our mobile application(s), and any related content, features, functionality,
communications, and services we make available from time to time (collectively, the “Platform”).

The Platform is designed to support mental wellness and peer connection for first responders and, where
applicable, their departments, agencies, or other organizations. The Platform may allow users to create profiles,
store contact information and selected important dates, send private communications, coordinate check-ins,
calendar wellness-related events, and connect with other approved users based on call activity, assignments, or
other internal workflows.

This Privacy Policy applies to information we collect through the Platform, in email, text, push notification, and
other electronic communications between you and us, and from service providers acting on our behalf. It does
not apply to information collected offline or by any third party not acting on our behalf, even if linked from the
Platform.

Please read this policy carefully to understand our policies and practices regarding your information and how we
will treat it. If you do not agree to the terms of this policy, you must not access or use any of the Platform and
further agree to delete any copies or instances thereof immediately. By accessing, using, or downloading any of
the Platform, you agree to this privacy policy and further agree to be bound by the terms incorporated herein.
This policy may change from time to time. Your continued use of the Platform after we make changes is deemed
to be acceptance of those changes, so please check the policy periodically for updates. Terms not otherwise
defined herein shall have the meaning ascribed to them in the Terms of Use, found on one or more of the
Platform websites or applications and incorporated herein as if fully set forth.

Important Notice: Not Medical Care; Not Emergency Services

Start Checkpoints is not a healthcare provider, mental health clinic, crisis line, dispatcher, emergency response
service, or public safety answering point. The Platform is intended as a wellness-support and peer-connection
tool only. It is not a substitute for medical care, therapy, clinical assessment, emergency intervention, or 911
services. Do not rely on the Platform for emergency response, suicide prevention response, welfare checks, or
immediate crisis intervention. If you or someone else may be in immediate danger or experiencing a mental
health emergency, call 911, contact emergency services, or use an appropriate crisis resource immediately.
Because the Platform may involve sensitive communications among first responders, users should exercise
judgment and avoid uploading or sharing information that is prohibited by law, employer policy, collective
bargaining requirements, CJIS or similar standards, HIPAA, or operational-security restrictions.

Eligibility; Children’s Privacy

The Platform is intended for users who are at least eighteen (18) years old and who are authorized to use the
Platform, whether individually or on behalf of an agency, department, or other organization. The Platform is not
directed to children under 13, and we do not knowingly collect personal information from children under 13. If

we learn we have collected personal information from a child under 13 without legally sufficient authorization,
we will delete that information. If you believe a child under 13 has provided personal information through the
Platform, please contact us using the information in the Contact Information section below. If any information
collected by us at any time is governed by the Children’s Online Privacy Protection Act (“Coppa”), a U.S. law
designed to protect the online privacy of children under the age of 13, we will use commercially reasonable
efforts to fully comply with Coppa before asking for any personal information of a minor unless such
information falls under an exception to Coppa. We do not intentionally collect any personal information relating
to a minor at any time, for any reason, nor do we enable children to create accounts with our Platform or permit
access thereto without parental consent. Parents may contact us at the contact information provided below in the
Contact Information Section if a parent believes we possess any personal information belonging to or related to
their child and we will review, update, or delete any such information within a reasonable time following such
request.

Information We Collect

We may collect the following categories of information, depending on how you use the Platform and what
features are enabled:

(a) Account and profile information, such as your name, username, password, email address,
mobile number, mailing address, job title, employer or agency affiliation, badge or employee identifier
(if used by your organization), and profile photo.
(b) Contact and relationship data, such as trusted contacts, peer-connection lists, teammate or
officer relationships, and information you choose to use to facilitate check-ins or reminders.
(c) Calendar and reminder data, such as important dates, anniversaries, birthdays, memorial dates,
scheduled check-ins, appointments, wellness reminders, event entries, and related notes you choose to
enter.
(d) Communications data, such as messages, wellness-check requests, responses,
acknowledgments, attachments, and other content exchanged through the Platform.
(e) Activity and coordination data, such as call-related check-in prompts, assignment-related
pairing information, status selections, response timestamps, participation history, and similar workflow
data used to facilitate peer support.
(f) Device, log, and usage information, such as IP address, device identifiers, operating system,
browser type, app version, crash data, pages or screens viewed, referral URLs, access times, clicks, and
general usage analytics.
(g) We do not collect precise or approximate location information through the Platform as currently
offered.
(h) Information from third parties, such as sign-in providers, mobile platform operators, analytics
vendors, cloud hosting providers, customer support tools, or agency administrators where your
organization sponsors or administers Platform access.

We do not want Social Security numbers, driver’s license numbers, payment card data, protected health
information, active case evidence, criminal justice information that cannot lawfully be shared, or similarly
sensitive information unless expressly required for a specific feature we provide and covered by appropriate
notices. Please do not submit that information through the Platform.

How We Collect Information

We collect information: (a) directly from you when you create an account, fill out forms, send messages, create
reminders, upload content, schedule events, or communicate with us; (b) automatically through cookies, SDKs,

server logs, analytics tools, device permissions, and similar technologies; and (c) from third parties such as
authentication providers, app stores, service providers, and, where applicable, your agency or organization.

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. For example, we may use cookies or other technologies that: (a) allow you to navigate and use features provided by our Platform; (b) customize elements of the layout and/or content within the Platform and remember that you have visited us before; (c) identify the number of unique visitors we receive; (d) allow us to provide you with a customized experience; and (e) inform us how you use the Platform and where you have come to Platform from, so that we can improve the Platform and learn which functions of the Platform are most popular with users. As we adopt additional technologies, we may also gather additional information through other methods.

Web Beacons. Pages of our Platform may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit the Company, for example, to count users who have visited certain pages or features and for other related statistics (for example, recording the popularity of certain content and verifying system and server integrity).

Flash Cookies. Certain features of our Platform may use local stored objects (or Flash cookies) to collect and store information about your preferences and navigation to, from, and on our Platform. Flash cookies are not managed by the same browser settings as are used for browser cookies.

Analytics: We may choose to use Google Analytics and similar technologies and services to help analyze how users use Platform. These technologies and services use cookies to collect information such as how often users visit the Platform, what they visit, and what sites they used prior to coming to the Platform. The information collected by these technologies and services will be disclosed to or collected directly by third party service providers. To prevent Google Analytics from using your information for analytics, you may install the Google Analytics Opt-out Browser Add-on by clicking here.

How We Use Information
We may use information we collect to:
(a) create, authenticate, administer, and secure your account;
(b) provide and operate the Platform and its wellness-support, communication, reminder, and
calendar functions;
(c) connect users with each other based on Platform rules, authorized relationships, call-related
workflows, or organization settings;
(d) send operational messages, reminders, push notifications, event alerts, and account-related
communications;
(e) improve user experience, diagnose technical issues, measure engagement, and develop new
features;
(f) respond to questions, support requests, and suspected misuse;
(g) enforce our Terms of Use and other policies;
(h) protect the safety, rights, property, and security of users, organizations, and the public;
(i) comply with law, lawful process, and contractual obligations; and

(j) carry out any other purpose disclosed at the time information is collected or with your consent.
We may also use de-identified or aggregated information for analytics, reporting, training, research,
benchmarking, and program-improvement purposes, provided such information does not reasonably identify
you.

How Information May Be Shared
We may disclose information as follows:
(a) To service providers and contractors that host, support, secure, maintain, analyze, message, or
otherwise help operate the Platform, subject to appropriate confidentiality and data-processing
obligations.
(b) To other users, but only to the extent your use of the Platform is intended to share information
with them, such as private messages, check-in coordination, event participation, reminder sharing, or
other user-directed communications.
(c) To your agency, department, employer, or sponsoring organization, if your access is provided or
administered through that organization, and only as permitted by our agreement with that organization
and applicable law. Unless we expressly disclose otherwise in a separate organization agreement or
feature notice, organization administrators are limited to roster, activation, and similar account-
administration data and are not provided access to the content of private messages.
(d) In connection with a merger, acquisition, financing, restructuring, asset sale, or similar
transaction.
(e) To comply with law, regulation, subpoena, court order, legal process, or a valid governmental
request.
(f) To protect the rights, safety, security, or property of the Company, users, partner organizations,
or others, including to investigate fraud, abuse, threats, or violations of law or policy.
(g) With your consent or at your direction.
We do not sell personal information for money. We also do not use private in-app messages for public
advertising or operate any public social forum within the Platform as currently contemplated.

Electronic Communications
Notwithstanding any terms to the contrary herein, the Company may choose to electronically deliver
communications to you through email, posting messages through the Platform, updating this privacy policy or
other policies on one or more of the Platform interfaces, or through other reasonable methods. If the Company
chooses to electronically deliver messages directly to you, you understand these messages may contain,
transmit, or convey information about action taken either on your request or by or through your account. You
agree to do business with the Company electronically through any of the above means and further agree to
electronically receive notices, disclosures, communications, and information which the parties hereto stipulate
shall satisfy any legal requirement to communicate in writing. An electronic notice will be deemed to have been
received by you if sent via email upon sending by us. If you disagree with receiving electronic communications,
you must immediately stop using the Platform. You can unsubscribe from any marketing or promotional
communications at any time. If you do not want to receive messages from us, please contact us at the
information in the Contact Information section below and let us know. Unsubscribing from marketing or
promotional communications will not remove your information from our contact list in the event we need to
contact you for other purposes.

Cookies, Analytics, and Similar Technologies
We and our service providers may use cookies, pixels, SDKs, local storage, and similar technologies to
remember preferences, keep you signed in, understand feature usage, maintain security, and improve
performance. You may be able to control certain cookies through your browser or device settings, though
disabling some technologies may impair Platform functionality.

Push Notifications, Text Messages, and Email
If you provide a mobile number or enable push notifications, we may send you service-related messages such as
verification codes, account notices, reminders, check-in prompts, event notifications, and other operational
communications. We may also send marketing communications where permitted by law. You can opt out of
marketing emails by using the unsubscribe mechanism in those emails, but you may still receive transactional or
operational communications necessary to use the Platform.

Data Retention
We retain information for as long as reasonably necessary to operate the Platform, fulfill the purposes described
in this Privacy Policy, comply with applicable laws, resolve disputes, enforce agreements, and protect our
legitimate interests. Retention periods may vary depending on the type of information, the sensitivity of the
information, the nature of the relationship, organization-level requirements, and applicable law. Message data,
calendar data, and related communications records will be retained in compliance with applicable laws. We may
retain de-identified or aggregated information for a longer period.

Data Security
We use commercially reasonable administrative, technical, and organizational measures designed to protect
personal information. Even so, no method of transmission, storage, or security control is perfect, and we cannot
guarantee absolute security. You are responsible for maintaining the confidentiality of your account credentials
and for notifying us promptly of any suspected unauthorized use of your account.

Your Choices and Rights
We do not control third parties’ collection or use of your information to serve interest-based advertising.
However, these third parties may provide you with ways to choose not to have your information collected or
used in this way. You can opt out of receiving targeted ads from members of the Network Advertising Initiative
(“NAI”) on the NAI’s website. Subject to applicable law and our ability to verify your identity, you may have
the right to request access to, correction of, deletion of, or a portable copy of certain personal information, and
to object to or limit certain processing. Depending on your state of residence, you may also have the right to
appeal a denial of a privacy request and to opt out of certain targeted advertising or profiling practices, if
applicable. You may also be able to update certain profile information, reminder settings, and communication
preferences within the Platform. To exercise privacy rights, please contact us using the information below. We
may need to retain certain information where required or permitted by law, contract, or legitimate business need.
If we refuse access to the information or correcting such information, written notice will be provided to you
setting out:

the reasons for the refusal (except to the extent that, having regard to the grounds for the refusal, it would be unreasonable to do so);
the mechanisms available to complain about the refusal; and
any other matter prescribed by the regulations.

State Privacy Disclosures

Residents of certain U.S. states may have specific privacy rights under applicable state consumer privacy laws.
We will process verified privacy requests in accordance with applicable law to the extent such laws apply to our
operations. We do not knowingly sell personal information or share personal information for cross-context
behavioral advertising in a manner that would trigger opt-out rights unless we expressly disclose otherwise at
the time relevant processing begins.

International Users
The Platform is intended primarily for use in the United States. If you access the Platform from outside the
United States, you understand that your information may be transferred to and processed in the United States or
other jurisdictions where our service providers operate. By using the Platform, you consent to those transfers to
the extent permitted by applicable law.

Third-Party Services and Links
The Platform may contain links to third-party websites, tools, or services, and may allow integrations or mobile-
platform functionality provided by third parties. We are not responsible for the privacy practices or content of
third parties, and this Privacy Policy does not apply to them. Please review their privacy policies separately.

Changes to This Privacy Policy
We may update this Privacy Policy from time to time in our discretion. If we make material changes, we will
post the updated version on the Platform and revise the “Last Updated” date. Your continued use of the Platform
after an update becomes effective means you accept the revised Privacy Policy, to the extent permitted by law.

Contact Information
If you have questions about this Privacy Policy or would like to submit a privacy request, contact:
RR7345 Consulting, LLC d/b/a Start Checkpoints
Attn: Privacy
Email: info@startcheckpoints.com
Mailing Address for Notices: info@startcheckpoints.com
Website: https://www.startcheckpoints.com

For additional privacy policy information relating to California residents, please find as follows:

The California Consumer Privacy Act, as amended (“CCPA”) allows California residents to make certain requests
regarding their personal information, including rights to know, delete, correct, and opt out of “sale” or “sharing” for
cross-context behavioral advertising, and to limit use of sensitive personal information. This section describes your
CCPA rights and explains how to exercise them.

California’s Shine the Light Law: Subject to certain conditions and limitations, California residents may ask
the Company to provide them with a list of certain categories of personal data collected by us that we have

disclosed to third parties for direct marketing purposes during the previous calendar year prior to such request
and also to identify those third parties. You may make this request once per calendar year. In order to make this
request, simply contact us at the contact information provided in this Policy, affirm that you are a California
resident, provide us with a California address for our response, and ensure your request complies with the rights
afforded to you. Please allow us up to thirty (30) days to reply. We reserve the right not to respond to such
requests submitted to us in any manner other than as provided herein or for certain other reasons, as more fully
described herein.

Right to Know, Access, and Data Portability
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 (the “right to know”). You also have the right to request we
provide you with a copy of your personal information that we collected, sold, shared, or disclosed not more than
two (2) times per calendar year. Once we receive your request and confirm your identity, 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.
· If we sold or disclosed your personal information for a business purpose, two separate lists disclosing:
- · sales, identifying the personal information categories that each category of recipient purchased; and
- · disclosures for a business purpose, identifying the personal information categories that each
category of recipient obtained.
· The specific pieces of personal information we collected about you (also called a data portability
request).
We do not provide a right to know or data portability disclosure for B2B personal information.

Right to Delete
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 (the “right to delete”). Once we receive your request and confirm your
identity, we will review your request to see if an exception allowing us to retain the information applies. We
may deny your deletion request if retaining the information is necessary for us or our service provider(s) to:

1. 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, fulfill the terms of a written warranty or product recall conducted in accordance
with federal law, or otherwise perform our contract with you.
2. Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or
prosecute those responsible for such activities.
3. Debug products to identify and repair errors that impair existing intended functionality.
4. Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or
exercise another right provided for by law.
5. Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et. seq.).

6. 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
consent.
7. Enable solely internal uses that are reasonably aligned with consumer expectations based on your
relationship with us.
8. Comply with a legal obligation.
9. Make other internal and lawful uses of that information that are compatible with the context in which
you provided it.
We will delete or deidentify personal information not subject to one of these exceptions from our records and
will direct our service providers to take similar action.
We do not provide these deletion rights for B2B personal information.

Right to Opt-Out
If you are age 16 or older, you have the right to direct us not to sell your personal information at any time (the
“right to opt-out”). We do not sell the personal information of consumers we actually know are less than 16
years old. Consumers who opt-in to personal information sales may opt-out of future sales at any time. Once you
make an opt-out request, we will wait at least twelve (12) months before asking you to reauthorize personal
information sales. However, you may change your mind and opt back in to personal information sales at any
time by contacting us via the contact information provided below. You do not need to create an account with us
to exercise your opt-out rights. We will only use personal information provided in an opt-out request to review
and comply with the request.

Right to Correct
You have the right to correct personal information we maintain that you believe is incorrect.

Right to Be Free from Discrimination
You have the right to be free from discrimination and the right to equal service.

Right to Limit
You have the right to request we limit the use and disclosure of your personal information to uses / disclosures
that are reasonably necessary to provide our services to you in order to ensure security and integrity, prevent
fraud, for physical safety, for short-term transient use, to perform services on behalf of the business, and to
verity or maintain quality and safety of a device owned, manufactured for, or controlled by us, and/or to
improve the foregoing. We do not collect, sell, or share sensitive personal information for any purpose other
than as reasonably necessary, as more fully set forth herein.

Exercising Your Rights
To exercise your rights set forth above, please submit a request by either:

· Emailing us at info@startcheckpoints.com
· Mailing us at the address contained in our Contact Information Section below.

Only you, or someone legally authorized to act on your behalf, may make a request to exercise the rights set
forth above, including requests to know or delete related to your personal information.

You may also make a request to on behalf of your child by contacting us and providing reasonable information
to enable us to identify you and your authority over such child. You may only submit a request to know twice
within a 12-month period and all other requests not more than once during a 12-month period unless provided
for otherwise by applicable law. Your request(s) to us must:

· Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative. Depending on the request, we may require you to provide a signed declaration affirming your identity. If you use an authorized representative, we may require a power of attorney or other written verification allowing such individual to submit any request on your behalf.
· 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. You do not need to create an
account with us to submit a request to know or delete.
We will only use personal information provided in the request to verify the requestor’s identity or authority to
make it.

Response Timing and Format
We will confirm receipt of your request within the time requirements under applicable law, but in no case later
than thirty (30) days. If you do not receive confirmation within the 30-day timeframe, please contact us at
info@startcheckpoints.com.

We endeavor to substantively respond to a verifiable consumer request within thirty (30) days of its receipt. If
we require more time, we will inform you of the reason and extension period in writing. If you have an account
with us, we will deliver our written response to that account. If you do not have an account with us, we will
deliver our written response by mail or electronically, at your option.

Any disclosures we provide will only cover the 12-month period preceding our receipt of your request. The
response we provide will also explain the reasons we cannot comply with a request, if applicable. For data
portability requests, we will select a format to provide your personal information that is readily useable and
should allow you to transmit the information from one entity to another entity without hindrance.

We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or
manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision
and provide you with a cost estimate before completing your request.

Non-Discrimination
We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA,
we will not:

Deny you goods or services.
Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.
Provide you a different level or quality of goods or services.
Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.

However, we may offer you certain financial incentives permitted by the CCPA that can result in different
prices, rates, or quality levels. Any CCPA-permitted financial incentive we offer will reasonably relate to your
personal information’s value and contain written terms that describe the program’s material aspects.
Participation in a financial incentive program requires your prior opt-in consent, which you may revoke at any
time.

Retention of Personal Information
We keep the categories of personal information described above for as long as is necessary for the purposes
described in this Policy or otherwise authorized by law. For information about our retention policies, contact us
using the contact information set forth below.

Other California Privacy Rights
California’s “Shine the Light” law (Civil Code Section § 1798.83) permits users of our Website that are
California residents to request certain information regarding our disclosure of personal information to third
parties for their direct marketing purposes. To make such a request, please send an email to
info@startcheckpoints.com.