Effective date: June 12, 2018
Cleo, in its capacity as information processor, only collects and processes consumer data on behalf of its customers (employees of its consumers). We recommend that you review your respective employers’ terms and policies for information on their collection and use of data.
When you create an Account for the our Services (“Enroll”), we may collect personal information that can identify you (“Personal Information”) such as your full name, email address, mailing address, telephone number, and credit card information for payment. The information that we collect varies depending upon how you use our Services.
WE DO NOT KNOWINGLY ENROLL OR COLLECT INFORMATION DIRECTLY FROM CHILDREN UNDER THE AGE OF EIGHTEEN.
Please keep in mind that certain features on the Services may give you an opportunity to interact with us and others. These may include forums, message boards, chats, creating community profiles, and rating, tagging and commenting on articles. When you use these features you should be aware that any information you submit, including your name, location, health issues, and email address, may be publicly available to others. We do not protect the privacy of and are not responsible for your disclosure of any information through these interactive features, including, but not limited to information that you might post related to a minor.
Also, whenever you voluntarily disclose anyone’s personal information on publicly-viewable web pages, that information can be collected and used by others. For example, if you post your email address, you may receive unsolicited messages. We cannot control who reads your posting or what other users may do with the information that you voluntarily post, so we encourage you to exercise discretion and caution with respect to information you choose to disclose through these interactive features. When an individual chooses to post information that will be publicly disclosed, he or she is responsible for all legal consequences. We are not responsible under any data protection laws for information that you voluntarily post on a site that can be accessed by others.
If you believe that Cleo has violated your privacy rights, you should contact us at the mailing address or e-mail address provided below. You may also file a complaint with the government.
Tracking and/or Analytics Services. We may use mobile application tracking and/or analytics services. These services may record unique mobile gestures such as tap, double-tap, zoom, pinch, scroll, swipe and tilt but do not collect personally identifiable information that you do not voluntarily enter in the Services. These services do not track your browsing habits across mobile applications that do not use the same services. We are using the information collected by these services to understand user behavior and optimize site performance.
Web Beacons. We may also use web beacons (invisible images often referred to as pixel tags or clear GIFs) in order to recognize users and assess traffic patterns, and we may include web beacons and cookies in our email messages in order to count how many e-mail messages have been opened.
Non-Personally Identifiable Information. We also collect Non-Personally Identifiable Information that is not health information or medical information in the form of statistics and information regarding the Services user’s statistics and metrics obtained from third-party devices (for example, steps, distance, calories burned, GPS coordinates, etc.), which may be combined with personal information you submit through the Services so that you can fully enjoy the benefits of the Services tools, if any.
Mobile Device Information. Your use of the Services may also include the collection of information from your mobile device. For example, the Services may request your permission to collect location data and/or may request access to multimedia (photos or videos) stored on your mobile device. Location data is not required for participation in activities through the Services, and you have the option of declining collection of geolocation data. If you do not wish for your location data to be shared with Cleo, please respond accordingly when prompted on your mobile device, or visit your mobile device settings. Multimedia will only be collected from your device if you affirmatively select it to upload to the Services (i.e. you choose an image or video to store within the Services). Multimedia will not be shared with other users of the Services (with the exception of your profile photo, which will appear in your user profile).
We use non-Personally Identifiable Information for purposes such as measuring the number of users of various features of the Services, making the Services more useful to users and delivering targeted advertising and non-advertising content. We may also use Non-Personally Identifiable Information (for example, statistics regarding use and metrics) for research purposes, for marketing and promotional purposes, and to develop new learning tools and solutions and we may share such information with third parties, including researchers and/or advertisers, on an aggregate and anonymous basis. We may also use IP addresses to analyze trends, administer the Services, track a visitor’s movement, and gather demographic information for aggregate, non-personally identifiable use.
We may share your information as follows:
We use commercially reasonable administrative, technical, and physical measures to safeguard Personal Information in our possession against loss, theft and unauthorized use, disclosure or modification. We follow generally accepted industry standards to protect the information submitted to us, both during transmission and once we receive it. No method of transmission over mobile application or website is 100% secure, however. Therefore, while we strive to make all reasonable efforts to use commercially acceptable means to protect your personal information, we cannot guarantee its absolute security. In the unlikely event of a data breach, you will be notified as soon as reasonably possible, in accordance with applicable law. Furthermore, we are not responsible for any breach of security or for any actions of any third parties that receive the information.
We support and comply with the Children’s Online Privacy Protection Act (COPPA) and we do not knowingly collect information from children under the age of 18, nor do we share such information with third parties. Children under the age of 18 may not use the Services. If you seek Services for a minor, you will be responsible for providing information related to the minor and for paying for Services requested for the minor.
Last Revised: June 12, 2018