Last Updated: May 4, 2023
We collect information about you in a variety of ways depending on how you interact with us and our websites, software, mobile applications (“Apps”) and services, including:
For a list of the categories of personal information that we collect see the chart below in the Sharing of Information Section.
The following provides examples of how we use the information that we collect.
|Context||Types of Data||Primary Purpose for Collection|
|Account Registration||We collect your name and contact information when you create an account. We also collect information relating to the actions that you perform while logged into your account.||We use this information to provide account related functionalities to our users. Account information can be used to track progress, connect with other Users, access trainings, and to save your preferences.|
|Customer Information||We collect the name, and contact information, of our customers and their employees with whom we may interact.||We have a legitimate interest in contacting our customers and communicating with them concerning normal business administration such as projects, services, and billing.|
|Cookies and Third Party Tracking||We participate in behavior-based advertising, this means that a third party uses technology (e.g., a cookie) to collect information about your use of our website, software or Apps, so that they can provide advertising about our products and services or other products and services tailored to your interests on our website, software or Apps, or on other websites, software or Apps. See our Cookie Preference Center for more information.||Where required by law, we base the use of third party cookies upon consent.|
|Demographic Information||We collect personal information, such as your age or location.||We use this information to comply with applicable laws. We also use this information to tailor services to best fit your needs and goals.|
|Distance Information||When you use one of our websites, software or Apps we collect your location from the GPS, Wi-Fi, and/or cellular technology in your device to determine your location and your distance from a store that sells products available on our websites, software or Apps.||We have a legitimate interest in understanding our users and providing tailored services. In some contexts our use is also based upon your consent to provide us with geo location information.|
|Email Interconnectivity||If you receive email from us, we use certain tools to capture data related to when you open our message, click on any links or banners it contains and make purchases.||We use this information to understand how you interact with our communications to you.|
|Employment||If you apply for a job posting, or become an employee, we collect information necessary to process your application or to retain you as an employee. This may include, among other things, your Social Security Number. Providing this information is required for employment.||We use information about current employees to perform our contract of employment, or the anticipation of a contract of employment with you. In some contexts, we are also required by law to collect information about our employees. We also have a legitimate interest in using your information to have efficient staffing and work force operations.|
|Feedback/Support||f you provide us feedback or contact us for support we will collect your name and e-mail address or other identifying information, as well as any other content that you send to us, in order to reply.||We use this information in order to receive, and act upon, your feedback or issues.|
|Mailing List||When you sign up for one of our mailing lists we collect your email address or other contact information.||We share information about our products and services with individuals that consent to receive such information. We also use this information to share information with you about our products or services.|
|Mobile Devices||We collect information from your mobile device such as unique identifying information broadcast from your device when visiting or using our websites, software or Apps.||We use this information to identify unique visitors and understand how users interact with us on their mobile devices.|
|Business Contacts||We collect name, billing address, shipping address, e-mail address, phone number, and credit card number from business contacts when they request transactions.||We use that information to perform our contract to provide such business contacts with products or services.|
|Partner Promotion||We collect information that you provide as part of a co-branded promotion with another company.||We use this information to fulfill our promotions.|
|Sweepstakes or contests||When you participate in a sweepstakes or contest we collect information about you which includes contact information to notify you if you are selected.||We use this information to operate the sweepstakes. In some contexts we are also required by law to collect information about those that enter into our sweepstakes.|
|Website, software and App interactions||We use technology to monitor how you interact with our websites, software or Apps. This may include which links you click on, or information that you type into our online forms. This may also include information about your device or browser.||We use this information to understand how you interact with our website, software and Apps to better improve them and to understand your preferences and interests in order to suggest content or features that you might find most useful. We also have a legitimate interest in detecting and preventing fraud.|
|Web logs||We collect information, including your browser type, operating system, Internet Protocol (IP) address (a number that is automatically assigned to a computer when the Internet is used), domain name, click-activity, referring website, and/or a date/time stamp for visitors.||We use this information to monitor our networks and the visitors to and users of our websites, software and Apps. Among other things, it helps us understand which content, features, or services is the most popular.|
|Coaching Services||We collect information on your health, employment and experience with habit formation in order to see if you qualify for our coaching services.||We use this information to determine if you qualify for our coaching services, to assign you to the most appropriate group or coach, and for our products and coaches to provide you with the most relevant health tips and advice.|
In addition to the purposes and uses described above, we use information in the following ways:
Although the sections above describe our primary purpose in collecting your information, in many situations we have more than one purpose. For example, if you register for an account online or through our Mobile App we may collect your information from you to verify your login attempts, but we also collect your information so that we can quickly and easily respond to any questions about your account or our products and services. As a result, our collection and processing of your information is based in different contexts upon your consent, our need to perform a contract, our obligations under law, and/or our general interest in conducting our business.
To the extent we maintain and use personal information in a deidentified form, we will not attempt to reidentify the information, except for the purpose of determining whether our deidentification processes satisfy our legal obligations.
In addition to the specific situations discussed elsewhere in this policy, we may disclose personal information in the following situations:
Some states require that organizations disclose whether the following categories of personal information are collected, disclosed to third parties for a “business purpose,” or “sold” or transferred for “valuable consideration,” or transferred for an organization’s “business purpose.” The table below indicates the categories of personal information we collect and transfer in a variety of contexts. Note that we do not “sell” your personal information.
|Categories of Personal Information We Collect||To Whom We Disclose Personal Information for a Business Purpose||To Whom We Sell or Share for Targeted Advertising|
|Identifiers – this may include real name, alias, unique personal identifier, online identifier, email address, account name, or other similar identifiers.|
|Government Issued Identification – this may include social security number, driver’s license number, or state issued identification number, passport number.||N/A|
|Financial Information – this may include bank account number, credit card number, debit card number, and other financial information.||N/A|
|Health Related Information – this may include medical information; mental or physical health condition or treatment information; height, weight, and body mass index information; or other health information.||N/A|
|Characteristics of protected classifications – this may include age, sex, race, ethnicity, physical or mental disability, etc.||N/A|
|Commercial information – this may include information about products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.|
|Biometric information – this may include imagery of the iris, retina, fingerprint, face, hand, palm, vein patterns, and voice recordings, from which an identifier template, such as a faceprint, a minutiae template, or a voiceprint, can be extracted, and keystroke patterns or rhythms, gait patterns or rhythms, and sleep, health, or exercise data that contain identifying information||N/A|
|Internet or other electronic network activity information – this may include browsing history, search history, and information regarding an individual’s interaction with an internet website, application, or advertisement.|
(e.g., information that can be used to identify an electronic device’s physical location.)
|Audio, electronic, visual, thermal, olfactory, or similar information||N/A|
|Professional or employment-related information||N/A|
|Non-public education information (as defined in the Family Educational Rights and Privacy Act)||N/A|
|Inferences drawn from any of the information listed above||N/A||N/A|
|Additional categories of personal information described in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)) – this may include signature, physical characteristics or description, insurance policy number.||N/A|
Some jurisdictions give you a right to make the following choices regarding your personal information:
You may exercise the rights described above by contacting us as indicated in the “Contact Information” section below. We do not discriminate against individuals that exercise state-conferred rights. If you disagree with how we handled a request, you may appeal our decision by contacting us with the subject line “Data Request Appeal.”
Note that, as required by law, we will require you to prove your identity. We may verify your identity by phone call or email. Depending on your request, we will ask for information such as your name, email address, phone number, or other account information. We may also ask you to provide a signed declaration confirming your identity. Following a request, we will use reasonable efforts to supply, correct or delete personal information about you in our files.
In some circumstances, you may designate an authorized agent to submit requests to exercise certain privacy rights on your behalf. We will require verification that you provided the authorized agent permission to make a request on your behalf. You must provide us with a copy of the signed permission you have given to the authorized agent to submit the request on your behalf and verify your own identity directly with us. If you are an authorized agent submitting a request on behalf of an individual you must attach a copy of the following information to the request:
If we do not receive both pieces of information, the request will be denied.
No method of transmission over the internet, or method of electronic storage, is fully secure. While we use reasonable efforts to protect your personal information from unauthorized access, use, or disclosure, we cannot guarantee the security of your personal information. In the event that we are required by law to inform you of a breach to your personal information we may notify you electronically, in writing, or by telephone, if permitted to do so by law.
Some of our websites, our software and Apps permit you to create an account. When you do, you will be prompted to create a password. You are responsible for maintaining the confidentiality of your password, and you are responsible for any access to or use of your account by someone else that has obtained your password, whether or not such access or use has been authorized by you. You should notify us of any unauthorized use of your password or account.
California law requires us to disclose the following information related to our privacy practices:
|Categories of Sensitive Personal Information We Collect||Purposes for which it is collected||Is information sold or shared for the purpose of cross-context behavioral advertising|
|Social security, driver’s license, state identification card, or passport number.||No|
|Contents of a consumer’s mail, email, and text messages unless the business is the intended recipient of the communication||No|
The following additional information relates to our privacy practices:
If you have any questions, comments, or complaints concerning our privacy practices please contact us at the appropriate address below. We will attempt to respond to your requests and to provide you with additional privacy-related information.
P.O. Box 1217, Felton, CA 95018