LifeGuides Privacy Policy

LifeGuides, PBC, a public benefit corporation (“we” or “us” or “our”) respects the privacy of our users (“user” or “you”). This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you visit our website www.lifeguides.com and our mobile application, and any other media form, media channel, mobile website, or mobile application related or connected thereto, or use any services provided through our website or such media forms (collectively, the “Site”). Please read this Privacy Policy carefully. IF YOU DO NOT AGREE WITH THE TERMS OF THIS PRIVACY POLICY, YOU MAY NOT ACCESS OR USE THE SITE.

We reserve the right to make changes to this Privacy Policy at any time. We will alert you about any changes by updating the “Revised” date of this Privacy Policy. Any changes or modifications will be effective immediately upon posting the updated Privacy Policy on the Site, and you waive the right to receive specific notice of each such change or modification. You are encouraged to periodically review this Privacy Policy to stay informed of updates. You will be deemed to have been made aware of, will be subject to, and will be deemed to have accepted the changes in any revised Privacy Policy by use of the Site ten (10) business days after the date such revised Privacy Policy is posted.

“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 to:

• Provide and support the LifeGuides services, which are generally offered via your employer and often paid in full by your employer.
• Create and manage your account.
• Generate a personal profile about you to make future visits to the Site more personalized.
• Email or text you regarding your account or services.
• Fulfill and manage purchases, orders, payments, and other transactions related to the Site.
• Make improvements to the LifeGuides services.
• Monitor and analyze usage and trends to improve your experience.
• Notify you of updates to the Site, as well as provide customer service.
• Offer new products, services, and/or recommendations to you.
• Administer promotions, plus micro-activities for intended behavioral change.
• Resolve disputes and troubleshoot problems.
• Make improvements to the services provided

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. 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: https://www.heroku.com/policy/security
• Stripe. (if you are paying directly as an individual): https://stripe.com/privacy
• Intercom: https://www.intercom.com/legal/privacy
• Twilio: https://www.twilio.com/legal/privacy
• Google Drive: https://www.google.com/drive/terms-of-service/
• Dropbox: https://www.dropbox.com/privacy
• Sentry: https://sentry.io/privacy/
• Grafana: https://grafana.com/legal/privacy-policy/
• Neon.Tech: https://neon.tech/privacy-policy
• Clerk: https://clerk.com/legal/privacy

Prompt Deletion of Your Data – Upon Your Request

Within five business days 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 when you choose to participate in various activities related to the Site, 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.

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. 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 Site.

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.

TRACKING TECHNOLOGIES

We also collect information through the use of tracking software on our Site in the following ways:

Cookies

We may use cookies, web beacons, tracking pixels, and other tracking technologies on the Site to help customize the Site and improve your experience. For more information on how we use cookies, please refer to our Cookie Policy posted on the Site, which is incorporated into this Privacy Policy. By using the Site, you consent to the terms of our Cookie Policy.

Website Analytics

We may also partner with selected third-party vendors, such as Google Analytics, to allow tracking technologies and remarketing services on the Site through the use of first party cookies and third party cookies, to, among other things, analyze and track users’ use of the Site, determine the popularity of certain content and better understand online activity. By accessing the Site, you consent to the collection and use of your information by these third party vendors. You are encouraged to review their privacy policy and contact them directly for responses to your questions.

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, 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.

Online Postings

When you post comments, contributions or other content to the Site, your posts may be viewed by all users and may be publicly distributed outside the Site in perpetuity.

Affiliates

We may share your information with our affiliates, in which case we will require those affiliates to honor this Privacy Policy. Affiliates include our parent company and any subsidiaries, joint venture partners or other companies that we control or that are under common control with us.

Business Partners

We may share your information with our business partners to offer you select products, services or promotions, including third-party service providers to facilitate our provision of services to you and to support such services. We require such business partners to comply with the terms of this Privacy Policy. Naturally, all information in the public domain may be shared freely by us with any party.

Social Media Contacts

If you connect to the Site 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

If we reorganize or sell all or a portion of our assets, undergo a merger, or are acquired by another entity, we may transfer your information to the successor entity. If we go out of business or enter bankruptcy, your information would be an asset transferred or acquired by a third party. You acknowledge that such transfers may occur and that the transferee conceivably could decline to honor commitments we made in this Privacy Policy.

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.

Anonymized Data

We may share anonymized, non-personal data collected from our users in the aggregate with outside analysts and other business partners.

THIRD-PARTY WEBSITES

The Site may contain links to third party websites and applications of interest, including advertisements and external services, that are not affiliated with us. Once you have used these links to leave the Site, any information you provide to these third parties is not covered by this Privacy Policy, and we cannot guarantee the safety and privacy of your information. Before visiting and providing any information to any third party websites, you should inform yourself of the privacy policies and practices (if any) of the third party responsible for that website, and should take those steps necessary to, in your discretion, protect the privacy of your information. We are not responsible for the content or privacy and security practices and policies of any third parties, including other sites, services or applications that may be linked to or from the Site.

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

Most web browsers and some mobile operating systems include a Do Not Track (“DNT”) feature or setting you can activate to signal your privacy preference not to have data about your online browsing activities monitored and collected. No uniform technology standard for recognizing and implementing DNT signals has been finalized. As such, we do not currently respond to DNT browser signals or any other mechanism that automatically communicates your choice not to be tracked online. If a standard for online tracking is adopted that we must follow in the future, we will inform you about that practice in a revised version of this Privacy Policy.

OPTIONS REGARDING YOUR INFORMATION

Account 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.

Upon your request to terminate your account, we will deactivate or delete your account and information from our active databases. However, some information may be retained in our files to prevent fraud, troubleshoot problems, assist with any investigations, enforce our Terms of Use and/or comply with legal requirements.

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.

If you are under 18 years of age (which is not allowed under our terms of use), reside in California, and have a registered account with the Site, you have the right to request removal of unwanted data that you publicly post on the Site. To request removal of such data, please contact us using the contact information provided below, and include the email address associated with your account and a statement that you reside in California. We will make sure the data is not publicly displayed on the Site, but please be aware that the data may not be completely or comprehensively removed from our systems.