Privacy Notice

We at Growth Space Ltd. (or its subsidiaries, if applicable) (collectively “Growthspace”, “us”, “we”, or “our”) recognize and respect the importance of maintaining individual’s privacy rights. We have developed a platform (“Platform”) through which our customers (“Customers”) and their administrators and managers can manage programs for their employees, staff and/or consultants (each a “Participant” and collectively the “Customer Personnel”) who are eligible to receive services from qualified experts, coaches, mentors, lecturers, trainers, or consultants (“Experts”). We also maintain a website, https://www.growthspace.com (“Site”) where visitors (“Website Visitors”) can receive information about our Platform and Experts can apply to provide services through our Platform.

As part of these activities, we handle Personal Data (as defined below) of a number of different types of people – the person with whom we are in contact or who represents the Customer, as well as representatives of potential customers (both shall be referred to, as applicable, the “Customer Representative”), the Customer Personnel who are using the Platform, Experts, and Website Visitors.

This Privacy Notice describes the types of information we collect from all of these individuals, how we process, transfer, store and disclose the information collected, as well as how these individuals can control certain uses of the collected information. “You” means any adult who is a Customer Representative, Customer Personnel, Website Visitor, or an Expert.

“Personal Data” means any information that refers, is related to, or is associated with an identified or identifiable individual or as otherwise may be defined by applicable law.

If you are an individual located in the European Union, some additional terms and rights may apply to you, as detailed in this Privacy Notice.

Controllers and Processors of Personal Data Collected

Growthspace is the data controller in respect of the processing of Personal Data of Website Visitors, Experts, and/or Customer Representatives. Our registered office is at HaUmanim 7, Tel Aviv – Yafo, Israel and our registration number is 515998052. We determine what Personal Data should be collected from these individuals how it will be used and for what purpose(s). You can contact our representative in the European Union at: MaetzlerRechtsanwalts GmbH & Co KG, Attorneys at Law, c/o GrowthSpace, Schellinggasse 3/10, 1010 Vienna, Austria. Please include the subject “GDPR-REP ID: 14358136” in all correspondence. In addition, if you want to want to exercise your rights as a data subject, as described below, you can visit https://gdpr-rep.eu/q/14358136.

When we process Personal Data of Customer Personnel, we do so solely on behalf of the applicable Customer and at such Customer’s direction. If you are using the Platform as Customer Personnel, the Customer serves as a controller of your Personal Data and Growthspace serves as a processor on its behalf. If you have any questions related to your Customer Personnel Personal Data, please directly contact the relevant Customer.

Privacy Notice Key Points 

The key points listed below are presented in further detail throughout this Privacy Notice. You can click on the headers in this section in order to find out more information about any topic. These key points do not substitute the full Privacy Notice.

1. Personal Data We Collect, Uses and Legal Basis.
2. Additional Uses.
3. Sources of Personal Data, Sharing Personal Data.
4. International Transfer.
5. Security.
6. Your Rights – How to Access and Limit Our Use of Certain Personal Data.
7. Data Retention.
8. Cookies and Similar Technologies.
9. Third-Party Applications and Services.
10. Communications.
11. Children.
12. California Privacy Rights.
13. Our California Do Not Track Notice.
14. Changes to the Privacy Notice.
15. Comments and Questions.

‍1. Personal Data We Collect, Uses and Legal Basis.

Depending on your usage, we collect different types of data and we use the data we collect for different purposes, as specified below. It is your decision whether to provide us with certain Personal Data, but if you refuse to provide such Personal Data, we may not be able to provide you with the Site or Platform or part thereof.

How we obtain your consent, including whether it is express or implied, will depend on the circumstances and the sensitivity of the Personal Data in question. We collect Personal Data from you using any technology that includes functions allowing you to be identified, located or profiled, where required by law we will obtain your express consent to the activation of such functions. Generally, we will seek your consent at the time we collect your Personal Data, either orally, electronically, or in writing. If you provide Personal Data about another individual to us, it is your responsibility to obtain the consent of that individual to enable us to collect from you, use and disclose their information as described in this Privacy Notice.

1.1. Website Visitors.

1.1.1. Contact Information. When you request information from us or contact us for any other reason, we will collect any data you provide, such as your full name, phone number, company name, email address and the content of your inquiry/message and any other Personal Data that you decide to provide us with.‍

How we use this data. To respond to your request or inquiry. To communicate with you and for marketing purposes.

Legal Basis (GDPR only, if applicable). Depending the context, we process this Personal Data  based on performance of the contract when we respond to your inquiry or legitimate interest (e.g., to assist you with your request) or subject to your consent.

1.1.2 Automatically Collected Data

When you visit the Site, we automatically collect information about your computer or mobile device, including non-Personal Data such as your operating system, and Personal Data such as your IP address and device ID. For more information about the cookies and similar technologies we use and how to adjust your preferences, see the section “Cookies and Similar Technologies” below.

How we use this data. (1) To review usage and operations, including in an aggregated non-specific analytical manner, develop new products or services and improve current content, products, and services; and (2) to prevent fraud, protect the security of our Site and address any problems with the Site.

Legal Basis (GDPR only, if applicable). Consent or legitimate interest (e.g., necessary cookies).

1.2 Experts

1.2.1 Application Information

When you apply to be an Expert on our Platform, you will be required to provide your full name, email address, phone number, a link to your resume or LinkedIn profile, country, time zone, languages spoken, and details of your professional experience, the company for which you work, start date, educational history, expertise, a biographical summary, whether or not you have coaching certification, whether or not you have professional development certification, and the services you would like to provide. We may also request access to your calendar, time zone, availability and capacity, rates, additional information on your expertise (such as skills and background). You will also be required to create a password. In addition, we monitor your usage of the Platform and collect information regarding your viewing and usage history on the Platform and reporting on Sessions performed (date, rating, freetext notes) and feedback on Sessions. In addition, when and if applicable, you will need to provide payment information. For the avoidance of doubt, we use third parties to process the payment information. In some cases, and to the extent permitted by law, we may run background checks / screening checks via third parties (e.g., agencies).

How we use this data. (1) To assess whether to engage with you as an Expert; (2) to provide services to our Customers (including, through the Platform); (3) to fulfill our obligations under our contract with you, such as our payment obligations; (4) to provide support and assistance, (5) to communicate and send follow-ups; (6) to ensure the quality of our Platform and services; and (7) to send marketing communications to you.

Legal Basis (GDPR only, if applicable). We process this Personal Data for performance of our contract with you, for our legitimate interests in managing our business and services, and for our recordkeeping and protection of our legal rights. In certain circumstances, we rely on consent.

1.3 Customer Representative

1.3.1 Contact Information. If you are a Customer Representative, we will collect your full name, email address, and any additional details you provide, such as your phone number, or your position within the Customer’s organization, or when our partners share your contact details with us (e.g., when an ambassador gives us your information and/or when you complete a LinkedIn form). We also collect the information you provide us within our introductory meeting or other meetings you have with us or with our partners, which may be recorded with your consent. In addition, we collect the contact and billing information of our customers (to the extent considered Personal Data).

How we use this data. (1) to establish business connection with you or your company and to respond to your request or inquiry; (2) To engage the Customer for the provision of services through the Platform; (3) to provide updates on the product; and (4) to send you marketing materials; (5) to customize the offers and potential services to you (6) to improve sales operation and training purposes.

Legal Basis (GDPR only, if applicable). Depending the circumstances, we process this Personal Data based on your consent, in order to take the necessary steps to enter into an agreement with you or your company, or in pursuit of a legitimate interest (e.g., to assist you with your request) or we process this Personal Data based on performance of a contract with the relevant Customer, for compliance with a legal obligation to which the controller is subject. In certain circumstances, we rely on consent (e.g., to record the call).

1.4 Customer Personnel.

1.4.1 Clarification. We collect, process, and transfer this data solely for the purpose of providing services to our Customers, at their instruction, and on their behalf. Certain types of data listed below will be shared with the Customer or an Expert assigned to you, all at the direction of the Customer. Therefore, the Customer is responsible party for the security, integrity and authorized usage of Customer Personnel Personal Data in the context of the services and the Platform and also for obtaining consents, permissions and providing any required data subject rights and fair processing notices required for the collection and usage of such Customer Personnel Personal Data. We have a contractual relationship with the Customers. For more information about these processing activities or to exercise any rights you may have as a data subject, please contact the applicable Customer directly.

1.4.2 Information collected.

• Administrator. If you use the Platform as an administrator (“Administrator”), you will be required to register and provide your full name, email address, and a password you create as well as the company’s name, industry. The Administrator can invite another Administrators and add Customer Personnel (including employees and consultants).
• Direct Manager of Participant. If you use the Platform as the direct manager of a Customer Personnel receiving services from an Expert in connection with the Platform (“Direct Manager”), you will be required to register and provide your full name, email address.
• Participant. If you use the Platform to participate in coaching, training, mentoring, or similar sessions as a Participant, we will collect the following Personal Data: (1) data provided by the Administrator such as your full name, email address, level of seniority, identity of your Direct Manager, geographical location, and language; (2) data provided by your Direct Manager including relevant background and your Direct Manager’s assessment of your strengths and weaknesses, challenges, and, in some cases, specific business goals; and (3) information that you provide including your job function, years of experience within the organization, number of employees you manage, your phone number (optional), details about your personality (based on a list of questions), any additional information about your goals. In addition, we will collect any answers you, your Direct Manager, or the applicable Expert provide on feedback forms.

1.4.3 How we use this data. (1) to create an account; (2) to provide you the services and the Platform and to process your requests; (3) communicate with you about your use of the services and the Platform and for support purposes; (4) fulfill any instruction and/or request made by you in the context of the Platform and/or services; (5) send you push notifications and/or emails and notifications regarding your account or certain features of the services, including, updates pertaining to your subscription, and related to the services we provide you with; (6) to personalize your experience with our services; (7) for Administrators, to allow you to create more users and administrate your users; and (8) to generally administer and improve the services.

1.5 Information of our partners

1.5.1 Contact Information. We collect your information from you or from your employers that are our Partners. We also collect the information you provide us within our introductory meeting or other meetings you have with our potential customers, which may be recorded with your consent. The information we collect from you in this use case is: your full name, phone number, company name, email address and the content of your inquiry/message and any other Personal Data that you decide to provide us with.

How we use this data. In pursuit of our relationship with our Partners (you or your employer, as applicable), to communicate with you for partner-related purposes.

Legal Basis (GDPR only, if applicable). Depending the circumstances, we process this Personal Data based on your consent, processing is necessary for the performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract, for compliance with a legal obligation to which the controller is subject and/or in pursuit of a legitimate interest (e.g., in pursuit of a contract we have with our partner, you or your employer, as applicable).

1.6. Information of our service providers and subcontractors

1.6.1. Contact Information. We collect your Personal Data from you or from your employers that are our service providers and subcontractors. We also collect the Personal Data you provide us within our meetings. The Personal Data we collect from you in this use case is: your full name, phone number, company name, email address and the content of your inquiry/message and any other Personal Data that you decide to provide us with.

1.6.2. How we use this data. In pursuit of our relationship with our service providers and subcontractors (you or your employer, as applicable), and to communicate with you for service-related purposes.

1.6.3. Legal Basis (GDPR only, if applicable). Depending the circumstances, processing is necessary for the performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract, for compliance with a legal obligation to which the controller is subject and/or in pursuit of a legitimate interest (e.g., in pursuit of a contract we have with our service providers and subcontractors, you or your employer, as applicable).

‍2. Additional Uses.

2.1. Statistical Information. By analyzing information we receive, including all information concerning users of the Platform we may compile statistical information across a variety of platforms and users (“Statistical Information”). Statistical Information helps us understand trends and customer needs so that new products and services can be considered and so that existing products and services can be tailored to customer desires. Statistical Information is anonymous and aggregated and we will not link Statistical Information to any Personal Data. We may share such Statistical Information with our partners, without restriction, on commercial terms that we can determine in our sole discretion.

2.2. Analytics. We use analytics tools (“Tools”) to collect information about your use of the Site. Such Tools collect information such as how often users visit the Site, what pages they visit when they do so, and what other sites and mobile applications they used prior to visiting the Site. We use the information we get from the Tools to improve our Site and Platform. We reserve the right to remove or add new analytic tools.

2.3. Marketing. If you no longer want to receive marketing-related e-mails from us, you may opt out of receiving marketing-related e-mails by clicking the “unsubscribe” link at the bottom of any e-mail you receive from us. You may also opt out by contacting us directly using the contact information in the “Comments and Questions” section below. Please note that if you opt out from receiving marketing-related e-mails, we may still need to send you service-related communications as detailed in the “Communications” section below.

2.4. Security purposes. Some of the abovementioned information will be used for detecting, taking steps to prevent and prosecuting fraud or other illegal activity; to identify and repair errors; to conduct audits; and for security purposes. Information may also be used to comply with applicable laws, with investigations performed by the relevant authorities, law enforcement purposes, and/or to exercise or defend legal claims.

2.5. De-identified and Aggregated Information Use. In certain cases, we may or will anonymize or de-identify your information and further use it for internal and external purposes, including, without limitation, to analyze and improve our services and/or Platform and for research purposes. We will use this anonymous or de-identified information and/or disclose it to third parties without restrictions (for example, in order to improve our services and enhance your experience with them and/or to develop new product features and improve existing offerings).

3. Sources of Personal Data. Sharing Personal Data.

3.1. The sources of the Personal Data subject to this Privacy policy are:

3.1.1. Directly from you (e.g., when you complete a website form, signing up to the Platform or filling-in an onboarding form)

3.1.2. From the Customer Personnel (e.g., when your manager sends us your Personal Data)

3.1.3. From the Experts (e.g., when the Expert writes a feedback about you)

3.1.4. From our vendors and service providers (e.g., when you browse our Website, our vendors collect Personal Data via cookies and other tracking technologies on our behalf)

3.1.5. Third party sources (such as lead-generation companies).

3.2. We may share information , including Personal Data, as follows:

3.2.1. Service providers, and subcontractors. We disclose information, including Personal Data we collect from and/or about you, to our trusted service providers and subcontractors, who have agreed to comply with confidentiality restrictions and applicable privacy and data protection laws and who use such information solely on our behalf for the limited purposes for which the Personal Data was provided, including to: (1) help us provide you with the Site and/or Platform; and (2) aid in their understanding of how users are using our Site and/or Platform.

Such service providers and subcontractors provide us with website hosting, IT and system administration services, data backup, security, and storage services, and data analysis.

3.2.2. Experts. If you are Customer Personnel, we share your Personal Data in the direction of the Customer, who serves as a controller. We share certain Personal Data with Experts to allow them to provide you with services. Experts serve as sub-processors on our behalf and are subject to undertakings relating to their use of your Personal Data, including undertakings not to use your Personal Data for any purpose other than providing their services and not to disclose your Personal Data to external third parties.

3.2.3. Partners. If you are referred to us by our partners, we share certain Personal Data with such Partners to allow them to improve their services.

3.2.4. Controllers. If you are Customer Personnel, we share your Personal Data in the direction of the Customer, who serves as a controller. We will share certain Personal Data with the Customer or other Customer Personnel. For example, if you are a Participant, we may share details of the number of coaching sessions in which you have participated with your Direct Manager or with the Administrator. For more information regarding these controllers’ processing activities, please contact the relevant controller.

3.2.5. Business Transfers. Your Personal Data may be disclosed as part of, or during negotiations of, any merger, sale, leasing of company assets or acquisition, reorganization (including in cases of liquidation), we will disclose your Personal Data to such third party (whether actual or potential) in connection with the foregoing events. In the event that we are acquired by, or merged with, a third party entity, or in the event of bankruptcy or a comparable event, or if we obtain a loan or any form of financing of the company, we reserve the right to transfer, disclose or assign your Personal Data in connection with the foregoing events, including, in connection with, or during negotiations of, any merger, sale of company assets, consolidation or restructuring, financing, or acquisition of all or a portion of our business by or to another company.

3.2.6. Disclosures Permitted or Required by Law. We may share your Personal Data with third parties: (i) if we believe in good faith that disclosure is appropriate to protect our or a third party’s rights, property or safety (including the enforcement of this Privacy Notice); (ii) when required by law, regulation subpoena, court order or other law enforcement related issues, agencies and/or authorities (including, without limitation, federal, state or local laws); or (iii) as is necessary to comply with any legal and/or regulatory obligation.\

3.2.7. Legal Uses. We may use your Personal Data as required or permitted by any applicable law, for example, to comply with audit and other legal requirements. 

4. International Transfer.

4.1. External transfers: We use subcontractors and service providers, including Experts, who are located in countries other than your own and we may send them information we receive (including Personal Data). We conduct such international transfers for the purposes described above. We will use commercially reasonable efforts to ensure that these third parties will be subject to written agreements. We primarily host your Personal Data in Switzerland, Europe, Israel and the United States. Whenever we transfer your Personal Data to third parties based outside of the European Economic Area (“EEA”) and/or the United Kingdom (“UK”) and/or Canada, we ensure a similar degree of protection is afforded to it as required under applicable law: for example: we will rely on Adequacy Decisions (for example, when we access Personal Data from Israel), Standard Contractual Clauses, or any other approved transfer mechanism. We continually monitor the circumstances surrounding such transfers to ensure that these maintain, in practice, a level of protection that is essentially equivalent to the level of protection guaranteed by the GDPR

4.2. Internal transfers: Transfers within the Growthspace group will be covered by an internal processing agreement entered into by members of the Growthspace group (an intra-group data processing agreement) which contractually obliges each member to ensure that Personal Data receives an adequate and consistent level of protection wherever it is transferred to. 

5. Security.

We have implemented and maintain appropriate physical, technical and organizational security measures, policies and procedures designed to reduce the risk of accidental destruction or loss, theft, or the unauthorized use, release, disclosure or access to Personal Data or other breach of the protections for Personal Data, that are appropriate to the nature of such data. The measures we take include:

5.1. Safeguards – The physical, electronic, and procedural safeguards we employ to protect your Personal Data include secure servers, firewalls, antivirus software, and SSL encryption of data.

5.2. Access Control – We dedicate efforts to proper management of system entries and limit access only to authorized personnel on a need-to-know basis of least privilege rules, review permissions quarterly, and revoke access immediately after employee termination. 

5.3. Internal Policies – We maintain and regularly review and update our privacy and information security policies.

5.4. Personnel – We require new employees to sign non-disclosure agreements according to applicable law and industry customary practice.

5.5. Encryption – We encrypt the data in transit using secure https protocols.

5.6. Database Backup – Our databases are backed up on a periodic basis for certain data and are verified regularly. Backups are encrypted and stored within the production environment to preserve their confidentiality and integrity, are tested regularly to ensure availability, and are accessible only by authorized personnel.

5.7. No Guarantee – No method of transmission over the Internet or method of electronic storage is 100% secure. Therefore, while we strive to use commercially acceptable means to protect your Personal Data, we cannot guarantee its absolute security.
As the security of information depends in part on the security of the computer you use to communicate with us and the security you use to protect user IDs and passwords, please take appropriate measures to protect this information. 

6. Your Rights – How to Access and Limit Our Use of Certain Personal Data.

Subject to certain exemptions, and in some cases dependent upon the processing activity we are undertaking, you have certain rights in relation to the Personal Data that we hold about you, as detailed below. We will investigate and attempt to resolve complaints and disputes and make every reasonable effort to honor your wish to exercise your rights within the timescales provided by applicable data protection laws. We reserve the right to ask for reasonable evidence to verify your identity before we provide you with any information and/or comply with any of your requests, as detailed below. If you are one of the Customer Personnel, for any requests to exercise such rights with respect to information held by the Customer, who serves as a controller of your Personal Data, please contact the applicable Customer directly. Subject to applicable law, we may charge you with a fee after first providing you with an estimate of the approximate fees. Please note that we may not be able to provide you with all the information you request, and, in such case, we will endeavor to explain to you why. The following rights (which may be subject to certain exemptions or derogations) shall apply to certain individuals (some of which only apply to individuals protected by the GDPR): 

6.1. Right of Access. You have a right to know what Personal Data we collect about you and, in some cases, to have such Personal Data communicated to you. We will provide you with any such Personal Data to the extent required by applicable laws.

6.2. Right to Data Portability. If the processing is based on your consent or performance of a contract with you and processing is being carried out by automated means, you may be entitled to (request that we) provide you or another party with a copy of the Personal Data you provided to us in a structured, commonly-used, and machine-readable format.

6.3. Right to Correct Personal Data. Subject to the limitations in applicable law, you may request that we update, complete, correct or delete inaccurate, incomplete, or outdated Personal Data.  We will not routinely update your Personal Data unless such a process is necessary. 

6.4. Deletion of Personal Data (“Right to Be Forgotten”) In certain cases, you have a right to request that we delete your Personal Data. We cannot restore information once it has been deleted. Please note that to ensure that we do not collect any further Personal Data, you should clear our cookies from any device where you have visited our Site. We may retain certain Personal Data (including following your request to delete) for audit and record-keeping purposes, or as otherwise permitted and/or required under applicable law. 

6.5. Right to Restrict Processing. You can ask us to limit the processing of your Personal Data if either: (i) you have contested its accuracy and wish us to limit processing until this is verified; (ii) the processing is unlawful, but you do not wish us to erase the Personal Data; (iii) it is no longer needed for the purposes for which it was collected, but we still need it to establish, exercise, or defend of a legal claim; (iv) you have exercised your Right to Object (below) and we are in the process of verifying our legitimate grounds for processing. We may continue to use your Personal Data after a restriction request under certain circumstances.

6.6. Right to Object. You can object to any processing of your Personal Data which has our legitimate interests as its legal basis, if you believe your fundamental rights and freedoms outweigh our legitimate interests. If you raise an objection, we have an opportunity to demonstrate that we have compelling legitimate interests which override your rights and freedoms.

6.7. Withdrawal of Consent. You may withdraw your consent in connection with any processing of your Personal Data based on previously granted consent by using the contact information in the “Comments and Questions” section below. This will not affect the lawfulness of any processing prior to such withdrawal. We will accommodate your request to withdraw consent, subject to legal or contractual restrictions. Withdrawal of your consent may mean that we will no longer be able to provide you with certain products or services.

6.8. Right to Lodge a Complaint with Your Local Supervisory Authority. You may have the right to submit a complaint to the relevant supervisory data protection authority or applicable privacy commissioner if you have any concerns about how we are processing your Personal Data, though we ask that as a courtesy you please attempt to resolve any issues with us first.

6.9. Deleting your account. Should you ever decide to delete your account, you may do so by emailing [email protected]. If you terminate your account, any association between your account and Personal Data we store will no longer be accessible through your account. However, given the nature of sharing on certain services, any public activity on your account prior to deletion will remain stored on our servers and will remain accessible to the public.

7. Data Retention.

Subject to applicable law, we retain Personal Data as necessary for the purposes set forth above. We may delete information from our systems without notice to you once we deem it is no longer necessary for these purposes. Retention by any of our processors may vary in accordance with the processor’s retention policy. In some circumstances, we may store your Personal Data for longer periods of time, for instance where we are required to do so in accordance with legal, regulatory, tax, audit, accounting requirements and so that we have an accurate record of your dealings with us in the event of any complaints or challenges, or if we reasonably believe there is a prospect of litigation relating to your Personal Data or dealings.

8. Cookies and Similar Technologies.

We use cookies and similar technologies for a number of reasons, including to help personalize your experience when visiting the Site, you shall be notified of the use of and placement of cookies and other similar technologies on your device as specified herein and, where required by law, we will obtain your consent with respect to our use of cookies or similar technologies. Please find a detailed list and configuration options for the cookies used on our Site at the bottom right corner of its main page.

8.1. What are Cookies? A cookie is a small piece of text that is sent to a user’s browser or device. The browser provides this piece of text to the device of the originating user when this user returns.

• A “session cookie” is temporary and will remain on your device until you leave the Site.
• A “persistent” cookie may be used to help save your settings and customizations across visits. It will remain on your device until you delete it.
• First-party cookies are placed by us, while third-party cookies may be placed by a third party. We use both first and third-party cookies.
• We may use the terms “cookies” to refer to all technologies that we may use to store data in your browser or device or that collect information or help us identify you in the manner described above, such as web beacons or “pixel tags”.

8.2. How We Use Cookies. We use cookies and similar technologies for a number of reasons, as specified in this Privacy Notice. The specific names and types of the cookies, web beacons, and other similar technologies we use may change from time to time. However, the cookies we use generally fall into one of the following categories: Necessary, Preferences, Statistics, Marketing. For further information please check out our cookie settings.

8.3. How to Adjust Your Preferences.   Please find a detailed list and configuration options for the cookies used on our Site at the bottom right corner of its main page. Please note that some features of the Site may not function properly when cookies are disabled or removed.

9. Third-Party Applications and Services.

All use of third-party websites, mobile software applications and products or services that are not owned or controlled by us (“Third-Party Applications and Services”) is at your own risk and subject to such third party terms and privacy policies. We are not responsible for the privacy practices or the content of such Third-Party Applications and Services. Accordingly, we encourage you to read the terms and conditions and privacy policies of all Third-Party Applications and Services.

10. Communications.

We reserve the right to send you service-related communications, including service announcements and administrative messages, without offering you the opportunity to opt out of receiving them. Should you not wish to receive such communications, you may cancel your account (in case you are a Participant,  please reach out to your Administrator to cancel your account and request removal from the program). Please note that you may still opt out from receiving marketing-related emails.

11. Children.

We do not knowingly collect Personal Data from children under the age of eighteen (18). In the event that you become aware that an individual under the age of eighteen (18) has enrolled without parental permission, please advise us immediately.

12. California Privacy Rights:

California Civil Code Section 1798.83 permits our customers who are California residents to request certain information regarding our disclosure of Personal Data to third parties for their direct marketing purposes. To make such a request, please send an email to [email protected]. Please note that we are only required to respond to one request per customer each year.

13. Our California Do Not Track Notice.

Do Not Track (“DNT”) is a privacy preference that users can set in certain web browsers. Please note that we do not respond to or honor DNT signals or similar mechanisms transmitted by web browsers. Third parties, such as companies that provide us with analytics tools, may also collect personally identifiable information about an individual’s online activities over time and across different websites when an individual uses the Website.

14. Changes to the Privacy Notice.

We may update this Privacy Notice from time to time, and we will place any updates on this webpage. Please come back to this page every now and then to make sure you are familiar with the latest version. If we make changes to this Privacy Notice, we will seek to inform you by notice on our Site, via email or via any other means.

15. Comments and Questions. 

If you have any comments or questions about this Privacy Notice or if you wish to exercise any of your legal rights as set out herein, please contact us at [email protected].

Last updated: April 2024