Privacy Policy

HCP Reach LLC (d/b/a TeamReach) and its affiliates (collectively, “Company,” “we,” “us,” or “our”) respect your privacy and are committed to protecting your Personal Information. This Privacy Policy (“Policy”) describes how we collect, use, maintain, protect, and disclose Personal Information (defined below) from or about individuals that access or use our website (“users”, “you”, or “your”), https://www.teamreach.com and any other website on which this Policy is posted (the “Website(s)”), our applications on which we may post or link to this Policy (the “Application(s)” or “App(s)”), and any associated online or mobile platforms, features, tools, products, or services that link to this Policy (collectively, the “Services”).

Your access to and use of the Services is subject to our Terms of Use, and where applicable, you may from time to time be asked to agree to additional terms and conditions.

This Policy applies to anyone who uses or accesses our Services, regardless of whether you use the Services via a computer, mobile device, tablet, or other medium (collectively, your “Equipment”).

This Policy applies only to Personal Information we collect:

1. Through the Services.
2. In communications, including email, text, chat, and other electronic messages, between you and us through the Services.
3. When you interact with our advertising on third-party websites and services, if that advertising includes links to this Policy.

This Policy does not apply to Personal Information collected by:

1. Us through any other means, including on any other website operated by us or any third party that does not link to this Policy; or
2. Any third party whether through any website, application, services, or content (including advertising) that may link to or be accessible from or through the Services.

This Privacy Policy also explains the choices available to you and, depending on in which U.S. state or country you reside, the rights you may have regarding your Personal Information under applicable law. Where required, we may provide additional, supplemental, or separate notices in connection with specific jurisdictions. Any such supplement or notice forms part of this Policy and will control in the event of a conflict as to individuals in that jurisdiction.

Children Under the Age of 13

Our Services are not intended for children under 13 years of age. No one under age 13 may provide any information to the Services. We do not knowingly collect, sell, or share (as those terms are defined by applicable law) Personal Information from children under 13. If you are under 13, do not register or use any of the interactive features on the Services, or provide any information about yourself to us. If you believe we might have any information from or about a child under 13, please contact us at legal@teamreach.com.

Please read this Policy carefully to understand our policies and practices regarding your Personal Information and how we treat it. By interacting with our Services or providing us with your Personal Information, you agree to the collection, use, and sharing of your Personal Information as described in this Policy. This Policy may change from time to time (see Changes to Our Privacy Policy). The “Last Updated” date above provides you with notice of when this Privacy Policy was most recently updated.

Personal Information We May Collect

For purposes of this Privacy Policy, “Personal Information” means any information relating to an identified or identifiable natural person (“data subject”) who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural, or social identity of that natural person.

The types and categories of Personal Information we may collect from or about you include:

• Identifiers: Such as first and last name, date of birth (for age verification purposes at account sign-up and to enable age-appropriate features within the Services), Internet Protocol (IP) address, email address, online identifiers, mobile advertising identifiers, device identifiers, username, or other similar identifiers.
• Other Personal Information (Note that information in this category may overlap with other categories): name, address, phone number, photographs or videos, and telephone number.
• Commercial information: Such as records of products or Services you have accessed, purchased, or considered.
• Geolocation data: Including general location information derived from your IP address (such as your country, state or province, city, or zip code), and, with your permission or as otherwise enabled through your Equipment settings, precise location information (such as GPS location used for event scheduling, weather forecasting, or other location-related features on the Services).
• Sensory data: Including audio, electronic, visual, or similar information such as photos and videos you upload, share, or otherwise make available through the Services, as well as any customer service call monitoring.
• Professional or employment-related information: Such as organization name, role, group affiliation, or similar information associated with your account or use of the Services.
• Internet or other similar network activity: Such as internet browsing history, search history, session information, system usage, App usage and diagnostics, electronic communications with us, or methods used to browse into or away from a page; Equipment information such as browser type and settings, operating system and version, language and time-zone, push notification preferences, mobile advertising identifiers, and other device identifiers; or network connection and usage details when you interact with our Services, such as clickstream to, through, and from our Website, page response times, error logs, pages visited and URLs viewed, timestamps of visits and actions taken, and other technical information.
• Account information: Such as login credentials, profile information, group memberships, user preferences, and account history.
• Communications and content: Such as messages, attachments, requests, inquiries, and feedback you make through the Services or emails, chats, or other communications sent to us or through group communications.
• Inferences drawn from other Personal Information we collect to create profiles, such as a profile reflecting your preferences, characteristics, predispositions, behavior, attitudes, etc.
• Sensitive Personal Information: Depending on applicable law and your interactions with the Services, this may include precise geolocation, account login credentials, contents of communications sent through the App (such as group chats and direct messages) where we are not the intended recipient, and information about children or minors as defined under applicable law.

You may always choose not to share your Personal Information with us; however, if you choose not to provide or allow us to collect certain information, we may not be able to provide you with some or all of our Services. If you have questions about what Personal Information may be required to receive our Services, please contact us as provided below.

How We Collect Personal Information

We may collect Personal Information from or about you in the following ways:

Directly from you, such as when you create, update, or use an account with us; create or join a group; purchase subscriptions or premium features; complete forms such as to sign up for our newsletter; participate in surveys, sweepstakes, contests, promotions, referral programs, or similar activities; create, upload, or post content to the Services, including reviews, photos, videos, or other information; request additional information about our Services, request customer support, or otherwise contact us or communicate with us through the Services by email, phone, social media, or other channels.

You also may provide information to be published or displayed (“posted”) on public areas of the Services or on our social media pages, such as when you tag us on social media pages or post reviews, comments, and photographs (collectively, “User Contributions”). Your User Contributions are posted on and transmitted to others at your own risk. Any such User Contributions are shared with your consent and are not subject to this Policy. Further, although we limit access to certain pages, please be aware that no security measures are perfect or impenetrable. Additionally, we cannot control the actions of other users of the Services with whom you may choose to share your User Contributions. Therefore, we cannot and do not guarantee that your User Contributions will not be viewed by unauthorized persons.

Automatically through the Services. As you navigate through and interact with our Services, and, with your consent if required and if permitted by applicable law, we may use automatic data collection technologies to collect information that may include Personal Information. Information collected automatically may include usage details, IP addresses, device identifiers, operating system, and browser type, and information collected through cookies, web beacons, SDKs, session replay technology, and other tracking technologies, including details of your interactions with our Services, such as traffic data, location data, logs, and other communication data, and which resources and Services you access and use. We may also collect metrics related to visitors, views, sessions, session duration, bounce rate, conversions, paths, and referrers. For more information about our automatic data collection technologies, please see Cookies and Other Automatic Data Collection Technologies below.

From third parties. We may receive certain information about you from business partners or service providers that we use to support our Services and business operations, such as website platform, email platform, application software, payment processors, and content providers; advertising networks and analytics providers; and security and anti-fraud services. Additionally, other users of our Services (such as group administrators, coaches, or team leaders) may provide us with information about you to invite you to access or use the Services or otherwise manage your interactions with the Services.

Cookies and Other Automatic Data Collection Technologies

With your consent if required and as permitted by applicable law, we (and our service providers performing Services on our behalf) may use automatic data collection technologies to collect information when you access or use the Services. The data collected through these automatic data collection technologies, whether connected to your Personal Information or not, help us improve our Services and deliver a better and more personalized experience by enabling us to:

1. Estimate our audience size and usage patterns.
2. Store your preferences so we may customize our Services according to your individual interests.
3. Speed up your searches.
4. Recognize you when you return to our Services.

With your consent if required and as permitted by applicable law, we may also use these technologies to collect information about your online activities over time and across third-party websites or other online services (behavioral tracking). For more information, see below.

The technologies we use for this automatic data collection may include:

1. Cookies (or browser cookies). A cookie is a small file placed on the hard drive of your computer. We use cookies to provide additional features or functionality to your experience when you use our Services, for example storing your preferences and other information about you when you use the Website or App. Some cookies are essential for the Services (such as secure login and website navigation) to function properly. Others may support preferences, analytics, performance, advertising, and measurement. You can set your browser or Equipment to refuse all or some browser cookies or other tracking technology files, or to alert you when these files are being sent. You can also choose whether to allow the Services to collect information through other automatic data collection technologies at any time through the consent management tools we may make available on the Services or by contacting us as provided below. If you have consented to the use of non-essential cookies, you may always revoke your consent. Please note that some parts of the Services and related features may become inaccessible or not function properly if you disable or refuse certain cookies.
2. Web beacons. Some parts of the Services and our emails may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit us, for example, to count users who have visited parts of our Services or opened an email and for other related statistics (for example, recording the popularity of certain content and verifying system and server integrity).
3. Embedded scripts. These are programming code designed to add functionality or interactivity to a webpage or application and to collect information about your interactions with the Services, such as links you click or pages you view.
4. Software development kits (“SDKs”) and app technologies. These are sets of tools and code on our App that collect information from or about your device and App use. These technologies support analytics, crash reporting, security, fraud prevention, performance monitoring, push notifications, advertising, attribution, and measurement. Depending on the technologies and your device settings, these tools may collect device identifiers, mobile advertising identifiers, IP address, App usage and diagnostics, crash reports, performance data, location information, and other technical information.
5. Session replay. We may use session replay technology to record interactions with our Services to support product analytics, debugging, and quality assurance.

Third-Party Use of Cookies and Other Tracking Technologies

Our Services may contain links or allow connection to third-party websites, applications, content, or services we do not own or control. These third parties may include advertisers, ad networks and servers, content providers, hosting and application providers, anti-spam and security providers, payment-processing and fraud-prevention providers, and your internet or mobile service provider. They may use automatic collection technologies to collect information about you or your Equipment when you interact with or use our Services. The information they collect may be associated with your Personal Information or they may collect information, including Personal Information, about your online activities over time and across different websites, apps, platforms, and other online services. They may use this information to provide you with interest-based (behavioral) advertising or other targeted content.

For example, all or partial advertising on our Website or App is managed by Playwire LLC. Playwire LLC and its advertising, mediation, and measurement partners (such as Google Ad Manager) may collect or receive information from or about your device and use of the Services, including IP address, device identifiers, mobile advertising identifiers (such as Apple IDFA and Google GAID), device and operating system information, app usage data, and other similar technical information to deliver, measure, and improve advertising. This information may be used for contextual advertising and/or interest-based advertising across apps and websites. To learn more about the types of data collected, how data is used and your choices as a user, please visit https://www.playwire.com/privacy-policy.

Additionally, we use PostHog to help us understand how the Services are used and to improve the Services and user experience. When you register an account or log in, PostHog may collect your email address and name for analytics purposes. For more information about PostHog’s privacy practices, please visit https://posthog.com/privacy.

Note: We do not control third parties’ tracking technologies or their collection or use of your Personal Information. If you have any questions about a third-party advertisement or other third-party targeted content, you should contact the responsible provider directly. The information you provide to any third-party applications or services will be subject to that third party’s terms and practices, and we are not responsible for the privacy, security, or data handling practices of those third parties. As such, we encourage you to read the privacy policies of any third-party links or services you access.

For more information about your rights and choices regarding targeted advertising activities, see Targeted Advertising below.

How We Use Personal Information

We may use Personal Information that we collect from or about you for the following business and commercial purposes consistent with applicable law:

1. To provide you with the Services and any contents, features, information, products, or services you request.
2. To create, maintain, authenticate, and manage your account.
3. To enable team, group, club, school, and organization communications through the Services.
4. To communicate with you, including sending in-App messages, push notifications, email, and SMS/text (with your consent if required).
5. To provide customer support and respond to your inquiries or requests when you contact us through forms, email, social media, calls, chats, video conferencing, or other channels.
6. To manage our relationship with you, including by notifying you about changes to our products or Services, Terms of Use, or this Policy, asking you to provide feedback or take a survey, or notifying you about your account or subscription status, including expiration and renewal notices.
7. To administer and improve our Services, products, or customer relationships and experiences, including to develop, maintain, analyze, improve, optimize, measure, and report on our Services and their features and how users interact with them.
8. With your consent if required, to deliver relevant content, advertisements, and messaging to you and to measure or understand the effectiveness of such content, advertisements, and messaging.
9. With your consent if required, to contact you about our own or third parties’ products and services that may be of interest to you. For more information, see Your Rights and Choices below.
10. To validate your identity or to verify communications from you, and to respond to your data subject requests.
11. To facilitate, fulfill, and manage purchases, orders, and payments.
12. To fulfill any other purposes for which you provide the information or that we disclosed when it was collected.
13. To carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collection purposes.
14. To comply with any court order, law, or legal process, including responding to any government or regulatory request.
15. To enforce our Terms of Use, this Policy, or other applicable policies or agreements with you.
16. To protect the rights, property, or safety of our business, employees, customers, or others. This includes exchanging information with other companies and organizations for the purposes of cybersecurity, fraud protection, and credit risk reduction.
17. To investigate suspected violations of any law, rule or regulation, or the terms or policies of our Services.
18. With your consent, consistent with applicable law.

We may use de-identified or anonymized data (non-personal data as defined under applicable law) which can no longer be associated with you for any legitimate business purpose, consistent with applicable law. For example, we may aggregate usage data to calculate the percentage of users accessing our Services. However, if we combine or connect non-personal data with Personal Information so that it directly or indirectly identifies an individual, we treat the combined information as Personal Information in accordance with this Policy.

Location Data. We use location information to provide location-related features of our Services, such as event scheduling and to provide weather conditions relevant to your location.

We will not use Personal Information we have collected from you for purposes that are materially different, unrelated, or incompatible with the purposes described in this Privacy Policy without providing you with prior notice and your consent as required by law.

Legal Bases for Processing (EEA/EU/UK)

For individuals residing in the European Economic Area (EEA), European Union (EU), United Kingdom (UK), or otherwise subject to the General Data Protection Regulation (“GDPR”), we process Personal Information only where we have a legal basis to do so. We rely on one or more of the following legal bases to process Personal Information from or about users of the Services:

1. Consent: With your prior consent to use your Personal Information for one or more specified purposes (e.g., to use cookies/automatic data collected technologies or to send you a newsletter), we may use your Personal Information. For more information about related rights and choices, see Your Rights and Choices below.
2. Performance of a contract: Where it is necessary to enter into or perform a contract with you, or to take steps at your request before entering into a contract, we may use your Personal Information (e.g., name and contact information).
3. Legal Obligation: Where it is necessary for us to comply with a legal or regulatory obligation to which we are subject, we may use your Personal Information for compliance, recordkeeping, responding to lawful requests, and certain audit or governance activities.
4. Legitimate Interests: Where it is necessary for our legitimate interests (or those of a third party) and your interests or fundamental rights and freedoms do not override those interests, we may use your Personal Information. For example, we may use Personal Information to develop and improve our Services, administer our business operations, detect and prevent illegal activities, carry out market research through your voluntary participation in surveys, and, in some cases, deliver and measure our or third parties’ direct marketing with your consent. For more information on your right to object to processing where we are relying on a legitimate interest, see Your Rights and Choices below.

Disclosure of Personal Information

We may disclose Personal Information from or about you for the purposes described above as follows:

1. To coaches, group administrators, team leaders, parents, or legal guardians, if you participate in a group, in connection with the operation of that group;
2. To authorized Company personnel (on a need-to-know basis) to provide customer support, maintain security, prevent misuse, and protect the integrity of the Services;
3. To our subsidiaries and affiliates;
4. To business partners, suppliers, contractors, service providers, and other third parties (such as cloud hosting and infrastructure, analytics, app platform and notification, and advertising providers) we use to deliver our Services to you, support our business operations, market to and recruit users, and/or enhance user experience;
5. To a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which Personal Information held by us is among the assets transferred, or due diligence related to such transactions;
6. To third parties to market their products or services to you, consistent with applicable law and any consent requirements. For more information about related choices and rights, see Targeted Advertising.

During the twelve (12) months prior to the Last Updated Date of this Policy, we may have sold or shared (as those terms are defined by applicable law) Personal Information (including identifiers, commercial information, Internet or other similar network activity, and inferences drawn from other Personal Information to create a profile) with advertising networks and analytics providers for cross-context behavioral advertising, analytics, and related business purposes described above.

You may opt out of the sharing or sale (as defined by applicable law) of your Personal Information via the “Do Not Sell or Share My Personal Information” link on our Website and in the App, or via a universal opt-out signal such as Global Privacy Control. For more information, see Your Rights and Choices below.

Your Rights and Choices

Your rights may vary depending on where you reside and the nature of your interaction with us. This section describes mechanisms we provide for you to control certain uses and disclosures of your Personal Information.

Important: The exact scope of these rights vary by country and U.S. state. There are also several legal exceptions under which we may not have an obligation to fulfill your request.

Cookies and Other Tracking Technologies

Please see Cookies and Other Automatic Data Collection Technologies above for information on how to manage these technologies.

Promotions by the Company

We may send promotional emails, advertisements, push notifications tailored to your interests and preferences, or other marketing communications to you if you have requested information from us or purchased goods or services from us and you have not opted out of receiving such communications, or with your consent if required by applicable law.

If you receive our marketing communications and do not want us to use your information to promote our own or third parties’ products or services, you can opt out or revoke your consent by following the unsubscribe instructions or opt-out link included in such communications, adjusting your communication preferences where available (such as by adjusting the permissions in your mobile device’s operating system settings or logging into the App and adjusting your notification preferences in your account profile), emailing us and requesting to opt-out using the contact information below, or contacting our email service provider directly and requesting to opt-out. This opt-out generally will not apply to information needed to provide the requested service or other service-based transactions. For additional information regarding commercial electronic messages to Canadian and Australian residents, see Canadian Residents and Australian Residents below.

Targeted Advertising

If you do not want us to use information that we collect or that you provide to us to deliver advertisements according to our or our advertisers’ target-audience preferences, or, to share your Personal Information with third parties for promotional purposes, you can opt out or revoke your consent by contacting us as provided below or using the consent management tools (such as the “Do Not Sell or Share My Personal Information” link on our Website and in the App) we may make available on the Services.

Where applicable, you can manage targeted advertising and mobile advertising identifiers through your mobile device settings, such as “Opt out of Personalized Ads” on Android devices and “Limit Ad Tracking” or App Tracking Transparency controls on iOS devices.

Please note that opting out of targeted advertising does not mean you will stop receiving ads. You may still receive contextual ads or service-related messages that are not based on targeted advertising. Your choices may be device- or browser-specific, and may need to be reset if you delete cookies, reset your device advertising identifier, use a different device or browser, or reinstall the App.

Universal Opt-out Mechanisms

In addition, some browsers and browser extensions may support an opt-out signal (such as Global Privacy Control) that can send a signal to process your request to opt out from certain types of data processing, including data “sales” or “sharing” as defined under applicable laws. Should we engage in Personal Information sales or sharing (as those terms are defined by applicable law), we will make reasonable efforts to honor your choices indicated by the signals sent through such universal opt-out controls consistent with applicable law.

Location Data

You can choose whether to allow the Services to collect and use real-time information about your Equipment’s location through the Equipment’s privacy settings. If you block the use of location information, some Services features may become inaccessible or not function properly.

Accessing, Updating, and Deleting Your Information

You can contact us as provided below to request access to, correction of, or deletion of Personal Information that you have provided to us.

If you maintain an account through our Services, you may request the deletion of your account and the associated Personal Information we have collected from or about you through your account settings on the Website and/or within the App or by contacting us as provided below. Following account deletion, we will delete or deidentify Personal Information associated with your account within thirty (30) days, subject to applicable law and our retention obligations.

If you are a parent or legal guardian of a child whose Personal Information has been provided to our Services, you have the right at any time to review the Personal Information we maintain about that child, request that we correct or delete that information, and refuse to permit our further collection or use of that information. Please note that such actions may result in our inability to provide the Services. For information about how we may verify your identity before responding to a request to access, update, or delete, see Exercising Your U.S. Data Subject Rights below.

Depending on your request, we may not accommodate your request to change information if we believe the change would violate any law or legal requirement or negatively affect the information’s accuracy. If we cannot provide you with access to your Personal Information, we will inform you of the reasons, subject to any legal or regulatory restrictions.

Subject to and as required by applicable law, we may also deny your deletion request, in whole or in part, and retain certain Personal Information, where reasonably necessary to: (i) complete the transaction for which the information was collected, provide a service you requested, or otherwise perform a contract between you and the Company; (ii) ensure security and integrity, detect or protect against fraud or illegal activity, or identify and repair errors that impair existing intended functionality of our Services; (iii) establish, exercise, or defend legal claims, resolve disputes, or enforce our agreements; (iv) enable internal uses that are reasonably aligned with your expectations based on your relationship with us and compatible with the context in which you provided the information; or (v) comply with legal or regulatory obligations.

Please note that if you delete your User Contributions from the Services, copies of your User Contributions may remain viewable in cached and archived pages or might have been copied or stored by other users of the Services. Proper access to and use of information provided to the Services, including User Contributions, is governed by our Terms of Use.

Additional Data Subject Rights

Subject to applicable law and depending on your country or U.S. state of residency, you may have certain additional rights related to your Personal Information as described below.

U.S. State Data Subject Rights

Depending on your U.S. state of residency and subject to applicable law, you may have some or all of the following rights related to your Personal Information:

1. The right to know what Personal Information we process about you.
2. The right to request certain Personal Information that we process about you be deleted.
3. The right to request we correct Personal Information we have about you which you believe is incorrect.
4. The right to have certain Personal Information we process about you returned to you in an accessible and useable format upon your request, if such request is technically feasible.
5. The right to opt-out of using Personal Information for targeted advertising, profiling, and sales, where applicable.
6. The right to limit certain use of your sensitive Personal Information, where applicable.
7. The right to exercise the privacy rights above without discrimination.

California Residents. If you are a California resident, you may have additional personal rights and choices with regard to your personal data. For example, California’s “Shine the Light” law (Civil Code Section § 1798.83) permits users of covered websites that are California residents to request certain information regarding the disclosure of their personal data to third parties for their direct marketing purposes. This law applies to companies with 20 or more full or part-time employees. We are not subject to this law at this time.

Nevada Residents. If you are a Nevada resident, you may have the right to opt-out of the sale of certain covered Personal Information. Please note that we do not currently sell covered information, as “sale” is defined by Nevada law.

Exercising Your U.S. Data Subject Rights

You may exercise your applicable U.S. state data subject rights by submitting a request using the contact details provided below. We will process your requests in a manner consistent with applicable law. We do not charge a fee to process or respond to your verifiable 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 processing your request.

Verification of Your Requests. We may require that your identity be verified prior to processing a verifiable rights request. We may verify your identity by comparing the information we have about you against the information we receive when you submit your request. If we do not have enough information to verify your identity, we may request additional information from you depending on the nature of your request and the Personal Information at issue, consistent with applicable law. We may deny a rights request if we are unable to verify your identity.

Authorized Agents. Some states permit their residents to designate an authorized agent to submit requests to exercise certain data subject rights on their behalf. Even if you use an authorized agent to submit a request on your behalf, pursuant to applicable law, we may still require that you verify your identity depending on the nature of the request and sensitivity of the information at issue. If you are an authorized agent submitting a request on behalf of an individual, you must include a copy of the written, signed permission indicating that you are permitted to act on that person’s behalf.

Appealing a Denied Data Subject Rights Request. In some circumstances, we may deny your request to exercise one or more of the rights described above. Some states grant their residents a right to appeal such decisions. If you disagree with our decision to deny your request or any portion of your request, you may appeal our decision within sixty (60) days of receipt of notice that your request has been denied. If you submit an appeal to a denied request more than sixty (60) days after you have been notified of our decision to deny the request, we may deny your appeal. If you submit a timely appeal, we will respond within forty-five (45) days of our receipt of your appeal.

If you wish to appeal a decision, please clearly and plainly describe your basis of disagreement with our decision by responding through the same means by which we communicated our decision or by submitting your appeal by contacting us as described below. We will review your appeal and either amend or uphold our decision. In either case, we will provide a written explanation of the reason for the decision. This decision will be final.

EEA, EU, and UK Residents’ Data Subject Rights

If you reside in the EEA, the EU, or the UK, you have the following rights regarding your Personal Information:

1. Right to request access to your Personal Information;
2. Right to request rectification (correction) of your Personal Information;
3. Right to request erasure of your Personal Information (right to be forgotten);
4. Right to object to our processing of your Personal Information, where we are relying on a legitimate interest (or that of a third party). Should your Personal Information be processed solely for direct marketing purposes, you can object to that processing at any time without providing any justification;
5. Right to request restrictions of processing your Personal Information;
6. Right to request portability of your Personal Information (note that under the GDPR, this right only applies to automated data where our legal basis for processing it was either your prior consent or for the performance of a contract with you);
7. Where we are relying on consent to process your Personal Information, the right to withdraw your consent at any time, without affecting the lawfulness of any processing based on consent before its withdrawal;
8. Right to lodge a complaint with your supervisory authority; and
9. If we make automated decisions about you based on your Personal Information that may affect your access or Services provided to you, and subject to certain limitations and exceptions, you have the rights:
   1. To know the existence of automated decision-making, including profiling, and meaningful information about the logic involved, as well as the significance and the envisaged consequences of such processing for the data subject;
   2. To opt-out of any profiling in furtherance of decisions that produce legal or similarly significant effect;
   3. Not to be subject to the automated decision-making so long as the decision is not necessary for the performance of the contract with you or required by legal obligation; and
   4. To contest the decision and request human intervention in the decision-making process, if such decision making is necessary.

Exercising Your EEA/EU/UK Data Subject Rights

You can exercise any of the rights set out above by contacting us as provided below. We will respond to all requests in accordance with applicable data protection laws. We may need to request specific information from you to help us confirm your identity. If we reject your data subject request, we will notify you of our reason for doing so.

If you believe that we have not used your Personal Information in accordance with the applicable data protection laws, you have the right to lodge a complaint at any time with your local Data Protection Authority (contact information for EU member authorities is available here) or supervisory authority (such as the UK Information Commissioner’s Office (ICO), here) and to seek judicial remedy.

Please note there are some instances where we cannot honor these requests and may be required by law or other legitimate reasons to continue processing your Personal Information.

Canadian Residents

If you are a Canadian resident, subject to applicable law and exceptions, you have the right (i) to access and correct (rectify) the Personal Information we hold about you, (ii) where we are relying on consent to process your Personal Information, to withdraw your consent at any time, subject to reasonable notice and any legal and contractual restrictions; and (iii) to lodge a complaint with the Office of the Privacy Commissioner of Canada (OPC) or your provincial privacy regulator, as applicable. You may have additional data subject rights depending on your residency and to the extent applicable to our data processing activities.

Commercial Electronic Messages. Consistent with applicable law, we will only send you commercial electronic messages (such as promotional emails or SMS text messages) if we have obtained your express consent or if we have a valid basis for contacting you, such as an existing business relationship with you. You may unsubscribe or revoke your consent at any time by using the opt-out mechanism provided in such message, and we will honor your opt-out request in a timely manner consistent with the law.

Québec Residents. If you reside in the province of Québec and to the extent applicable to our data processing activities, you may have the following additional rights:

1. Right to De-indexation (Right to be Forgotten). You may request that we cease disseminating your Personal Information or de-index any hyperlink attached to your name that provides access to your information if the dissemination contravenes the law, violates a court order, or causes serious injury, subject to applicable legal standards.
2. Right to Data Portability. You may request to receive your computerized Personal Information in a structured, commonly used, and technological format, or request that we transfer it to another person or organization.
3. Automated Decision-Making. If we use your Personal Information to render a decision based exclusively on automated processing (including profiling), you have the right to be informed of that fact and, where applicable, to learn the reasons and factors leading to the decision and to submit observations to a human staff member to challenge the decision.
4. Consent. We will obtain your (opt-in) consent before deploying tracking technologies that identify, locate, or profile you, or before processing sensitive Personal Information.

Exercising Your Canadian Data Subject Rights. You can exercise any of your applicable rights set out above, subject to certain exceptions and as required or permitted by applicable law, by contacting us as provided below. To discuss this Policy or our privacy practices with respect to Canada, please contact us using the contact information provided below.

Australia Residents

If you are an Australian resident, subject to applicable law and exceptions, you have the right (i) to access and correct the Personal Information we hold about you; (ii) where lawful and practicable, to interact with us without identifying yourself or by using a pseudonym (please note that if you choose not to identify yourself, we may be unable to provide you with certain requested services); (iii) to request that we do not use or disclose your Personal Information for the purpose of direct marketing by using the unsubscribe mechanism described above or by contacting us as provided below.

Commercial Electronic Messages. Consistent with applicable law, we will only send you commercial electronic messages (such as promotional emails or SMS text messages) if we have obtained your express consent or where consent can be reasonably inferred from our existing relationship with you. We will process and honor any opt-out or unsubscribe request in a timely manner consistent with the law.

To the extent we use computer programs or automated decision-making technology to make decisions that could reasonably be expected to significantly affect your rights or interests, we will process this data in accordance with applicable law.

Exercising Your Australian Data Subject Rights. To exercise your right to access or correct your Personal Information, please contact us as provided below. We will respond to your request within a reasonable period after the request is made. We do not charge a fee for making a request, though we may impose a reasonable charge for the administrative costs of providing access. If you wish to make a complaint regarding how we have handled your Personal Information, please contact us in writing.

If you are not satisfied with our response or how we handled your complaint, you have the right to lodge a complaint with the Office of the Australian Information Commissioner (OAIC) here.

How We Safeguard Personal Information

We use commercially reasonable administrative, physical, and technical measures designed to safeguard Personal Information from accidental loss or destruction and from unauthorized access, use, alteration, and disclosure. However, no website, mobile application, system, electronic storage, or online service is completely secure, and we cannot guarantee the security of your Personal Information transmitted to, through, using, or in connection with the Services. Any transmission of Personal Information is at your own risk. Further, the safety and security of your information also depend on you. You are responsible for taking steps to protect your Personal Information against unauthorized use, disclosure, and access.

Data Retention

Except as otherwise permitted or required by applicable law or regulation, we will retain your Personal Information described in this Policy for as long as reasonably necessary to fulfill the purposes for which we collect it. We may retain your Personal Information for a longer period, for example, in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you. This means that when deciding how long to retain Personal Information, we consider our legal and business obligations, potential risks of harm, and the nature of the Personal Information and the purposes of processing it.

International Data Transfers

We are a U.S. company and maintain the Personal Information we collect in the United States. The United States may have privacy laws that offer different levels of protection from the privacy laws of where you live. If you are located outside the United States and choose to provide Personal Information to us, please note that we transfer the data to the United States and process it there. Please note that the governments, courts, law enforcement, or regulatory agencies of the United States may be able to obtain access to your Personal Information through applicable law. By submitting your Personal Information through our Services, you consent to our collection, transfer, processing, and use of your Personal Information in the United States.

If you are a resident of the EEA, EU, UK, we will ensure that your Personal Information is adequately protected when it is transferred to the United States, for example, by implementing relevant standard contractual clauses approved by the European Commission. We have put in place appropriate measures to comply with the applicable laws and regulations to ensure that the transfer of Personal Information to countries outside of those jurisdictions provides an adequate level of data protection.

If you are a Canadian resident, we will ensure that appropriate contractual and other safeguards are in place to protect your Personal Information, consistent with applicable Canadian privacy laws. You are welcome to contact us if you have questions regarding the collection, use, disclosure, or storage of Personal Information by our service providers and affiliates outside Canada, and/or to obtain access to information about our policies and practices with respect to service providers outside Canada.

If you are an Australian resident, we take reasonable steps to ensure that your Personal Information transferred to the United States is handled consistent with applicable Australian privacy laws, for example, by implementing contractual arrangements with our service providers outside Australia, consistent with Australian data protection standards.

Notice of Financial Incentives

From time to time, we may offer coupons or other price reductions for our products and services in exchange for enrolling in email updates, newsletter delivery, contests, or similar services we provide to communicate with you. To provide these services, we utilize the identifiers you have provided to us and may use the details from your commercial relationship with us (from your commercial information). Specific portions of our Services may provide financial incentives. To receive these financial incentives (or opt in), you will be asked to provide Personal Information through an online form, contest submission, or via social media.

We do not assign monetary value to the data that we collect and strive to only use that information to further our business in accordance with our Privacy Policy. To the extent that we are required to assign monetary value to your Personal Information, it is equal to the value of the discount or financial incentive that we have provided to you, if any.

To opt out of any financial incentive, please see Your Rights and Choices above. If you opt out, we will not reduce the value of any financial incentives you previously received from us.

Changes to Our Privacy Policy

We may update this Policy from time to time, and we will provide notice of any material changes to the Policy as required by law. The date the Privacy Policy was last updated is identified at the top of the page. We will notify you of changes to this Policy by updating the “Last Updated” date and posting the updated Policy on the Services. Please check our Services periodically to review the current Policy and any changes we have made to it. If you do not agree with any changes, please stop using our Services.

Contact Us

If you have any questions about this Policy or about our privacy practices in general, please contact us: