Last updated October 25, 2021
“Data Privacy Laws” mean laws and regulations relating to data privacy, transborder data flow and/or data protection, data breaches, and information security, as applicable to customer data processed under the terms of our site, including, without limitation, the Gramm Leach Bliley Act of 1999 (“GLBA”) and its implementing regulations, the Fair and Accurate Credit Transactions Act of 2003 (“FACTA”), the Health Insurance Portability and Accountability Act of 1996 and its implementing regulations (45 C.F.R. Parts 160 and 164) (“HIPAA”) (if applicable), the implementing legislation and regulations of the European Union member states under the European Union General Data Protection Regulation (“GDPR”) (if applicable), the California Consumer Privacy Act (“CCPA”) (if applicable) and all other similar federal, state or international laws (if applicable) and regulations relating to data privacy, transborder data flows and/or data protection, data breaches or information security.
LifeGuides will comply with all applicable Data Privacy Laws.
USE OF YOUR INFORMATION
Having accurate information about you permits us to provide you with a smooth, efficient, and customized experience. Specifically, we may use information collected about you via the Site or our mobile application to:
- Provide and support the LifeGuides services, which are generally offered via your employer and paid in full by your employer.
- Create and manage your account.
- Generate a personal profile about you to make future visits to the Site and our mobile application more personalized.
- Email or text you regarding your account or services, including in formats like a newsletter.
- Fulfill and manage purchases, orders, payments, and other transactions related to the Site and our mobile application.
- Make improvements to the Site, our mobile application and services we provide through the Site and mobile application.
- Monitor and analyze usage and trends to improve your experience with the Site and our mobile application.
- Notify you of updates to the Site and our mobile application.
- Offer new products, services, mobile applications, and/or recommendations to you.
- Administer sweepstakes, promotions, and contests.
- Request feedback and contact you about your use of the Site and our mobile application.
- Resolve disputes and troubleshoot problems.
- Respond to product and customer service requests.
- Perform other business activities as needed to facilitate or support any of the foregoing.
We also use anonymized, non-personal information collected from our users in the aggregate to improve our services and for other business and administrative purposes.
Our Data Partners
We use the following data partners to store your digital data related to providing services to any individual uses our services, such as an employee of a client enterprise. We do not let any of these partners sell or otherwise use your personal data for their gain.
- Heroku, a wholly-owned subsidiary of SalesForce. See: https://www.heroku.com/policy/security
- Paypal (if you are paying directly as an individual) See: https://www.paypal.com/us/webapps/mpp/ua/privacy-full
- Stripe. (if you are paying directly as an individual) See: https://stripe.com/privacy
- Ontraport. See: https://ontraport.com/legal
- Intercom: See: https://www.intercom.com/legal/privacy
- Twillio. See: https://www.twilio.com/legal/privacy
- Google Drive. See: https://www.google.com/drive/terms-of-service/
- Dropbox. See: https://www.dropbox.com/privacy
Prompt Deletion of Your Data – Upon Your Request
Within one business day of your written request or a call to our customer service, LifeGuides will delete all your personally identifiable data. Of note, if you are using our services as part of an employer-provided plan, your employer might continue to provide us periodic data from their updated “employee census” for all covered Participants via our services provided under your employer’s plan. In such case, we will make commercially reasonable efforts to delete such data, even if it is provided on a date subsequent to your request for data deletion. Importantly, since spouses or civil unions are covered under our employer plans, your request will not delete your spouse or civil union’s account and data, which that person needs to request separately.
COLLECTION OF INFORMATION
We may collect information about you in a variety of ways. The information we may collect on the Site includes:
Personal Data You Provide
Personally identifiable information, such as your name, shipping address, email address, and telephone number, and demographic information, such as your age, gender, hometown, and interests, that you voluntarily, or any other party, provides to us when you register with the Site or our mobile application, or when you choose to participate in various activities related to the Site and our mobile application, such as online chat and message boards, or when an employer, or other relationship, pays for you to access our services as a benefit of such relationship. Furthermore, your Guide™ will periodically collect information during any phone calls and some of that information is entered into our database, so that, among other purposes, we can optimize the delivery of content and services. You are under no obligation to provide us with personal information of any kind, but your refusal to do so might prevent you from using certain features of the Site and our mobile application.
Financial Data We Collect From You
Financial information, such as data related to your payment method (e.g. valid credit card number, card brand, expiration date) that we may collect when you purchase, order, return, exchange, or request information about our services from the Site or our mobile application. We do not store any financial information that we collect from individual users. All financial information is stored by our payment processors: PayPal and Stripe, and you are encouraged to review their privacy policies and contact them directly for responses to your questions.
Data From Third-Party Social Networks
User information from social networking sites, such as Facebook, Google+, including your name, your social network username, location, preferred gender, birth date, email address, profile picture, and public data for contacts, if you link or connect your account to such social networks. This information may also include the contact information of anyone you invite to use and/or join our mobile application.
Data From Contests, Giveaways, and Surveys
Personal and other information you may provide when entering contests or giveaways and/or responding to surveys.
Mobile Application Information
If you connect using our mobile application:
• Mobile Device Access. We may request access or permission to certain features from your mobile device, including your mobile device’s microphone, camera, location data, SMS messages, and other features. If you wish to change our access or permissions, you may do so in your device’s settings.
• Mobile Device Data. We may collect usage data from your mobile device, including the following types of information: operating system, device serial number, log files, firmware version, battery and signal strength, settings, error rates, session counts, technical specifications, pages viewed, time spent viewing pages, time spent in mobile application, features used, internet and mobile data connection information, browser type, language and time zone, mobile phone number and IP address.
We also collect information through the use of tracking software on our Site and our mobile application in the following ways:
We do not transfer personal information to these third party vendors. However, If you do not want any information to be collected and used by tracking technologies, you can visit the third-party vendor or Network Advertising Initiative Opt-Out Tool or Digital Advertising Alliance Opt-Out Tool. Please be aware that getting a new computer, installing a new browser, upgrading an existing browser, or erasing or otherwise altering your browser’s cookies files may also clear certain opt-out cookies, plug-ins, or settings.
DISCLOSURE OF YOUR INFORMATION
We may share information we have collected about you in certain situations. Your information may be disclosed as follows:
By Law or to Protect Rights
If we believe the release of information about you is necessary to respond to legal process, to investigate or remedy potential violations of our policies, or to protect the rights, property, and safety of ourselves or others, we may share your information. This includes exchanging information with other entities for fraud protection and credit risk reduction.
Interactions with Other Users
If you interact with other users of the Site and our mobile application, those users may see your name, profile photo, and descriptions of your activity, including sending invitations to other users, chatting with other users, liking posts, following blogs.
When you post comments, contributions or other content to the Site or our mobile applications, your posts may be viewed by all users and may be publicly distributed outside the Site and our mobile application in perpetuity.
Social Media Contacts
If you connect to the Site, or our mobile application, through a social network, other contacts on the social network will see your name, profile photo, and description of your activity, as you make posts or otherwise engage.
Other Third Parties
We may share your information with advertisers and investors for the purpose of conducting general business analysis. We may also share your information with such third parties for marketing purposes, as permitted by law and subject to the terms herein.
Sale or Reorganization
We are not responsible for the actions of third parties with whom you share personal or sensitive data, and we have no authority to manage or control third party solicitations, in this circumstance. If you no longer wish to receive correspondence, emails or other communications from third parties, you are responsible for contacting the third party directly and/or simply clicking on their opt-out link in communications.
We may share anonymized, non-personal data collected from our users in the aggregate with outside analysts and other business partners.
SECURITY OF YOUR INFORMATION
We use administrative, technical, and physical security measures to help protect your personal information, which we believe meets all reasonable and customary standards. While we have taken reasonable steps to secure the personal information you provide to us, please be aware that despite our efforts, no security measures are perfect or impenetrable, and no method of data transmission can be guaranteed against any interception or other type of misuse. Any information disclosed online is vulnerable to interception and misuse by unauthorized parties. Therefore, we cannot guarantee complete security if you provide personal information.
POLICY FOR CHILDREN
We do not knowingly accept, request, or solicit information from or market to children under the age of 18. Therefore, in accordance with the U.S. Children’s Online Privacy Protection Act, if we receive actual knowledge that anyone under the age of 13 has provided personal information to us without the requisite and verifiable parental consent, we will delete that information from the Site as quickly as is reasonably practical. If you become aware of any data we have collected from children under age 13, please contact us using the contact information provided below. We do not allow users under the age of 18.
CONTROLS FOR DO-NOT-TRACK FEATURES
OPTIONS REGARDING YOUR INFORMATION
You may at any time review or change the information in your account or terminate your account by:
- Logging into user account settings and updating the user account.
- Contacting us using the contact information provided on our site.
Emails and Communications
If you no longer wish to receive correspondence, emails, or other communications from us, you may opt¬out by:
- Noting your preferences at the time you register your account with the Site.
- Logging into your account settings and updating your preferences.
- Contacting us using the contact information provided.
If you no longer wish to receive correspondence, emails, or other communications from third parties, you are responsible for contacting the third party directly.
CALIFORNIA PRIVACY RIGHTS
California residents may request and obtain from us, once a year and free of charge, information about categories of personal information (if any) we disclosed to third parties for direct marketing purposes and the names and addresses of all third parties with which we shared personal information in the immediately preceding calendar year. If you are a California resident and would like to make such a request, please submit your request in writing to us using the contact information provided below.
LifeGuides, PBC, a public benefit corporation
Mac c/o LifeGuides 1438 W Broadway Rd., #101 Tempe, AZ 85282
support at lifeguides.com