Last Updated: April 30th, 2019
Cleo is headquartered in the United States and has service providers in the United States and other countries, and your personal information may be collected, used and stored in the United States or other locations outside of your home country. Data protection laws in the locations where we handle your personal information may not be as protective as the data protection laws in your home country.
Information That You Give Us
We collect information that you provide to us, which may include the following categories of information depending on 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.
Other Information We Collect
Third Party Interactions. Certain functionality on the Websites may permit interactions that you initiate between the Services and a third party website, device or service. We will collect statistics and other information obtained from those third-party websites, devices or services that you choose to share with us when you connect with those third parties (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).
Cookies and Similar Technologies
What are cookies? Cookies are small data files that are placed on your computer when you visit a site. Cookies serve different purposes, like helping us understand how a site is being used, letting you navigate between pages efficiently, remembering your preferences and generally improving your browsing experience.
Who places cookies on my device? Cookies set by the site you visit are called “first party cookies”. Cookies set by parties other than us are called “third-party cookies”. Third party cookies enable third party features or functionality within the site, such as site analytics, advertising, and social media features. The parties that set these third party cookies can recognize your computer or device both when it visits the site in question and when it visits certain other sites and/or mobile apps. We do not control how these third parties use your information, which is subject to their own privacy policies.
How long will cookies stay on my device? The length of time a cookie will stay on your device depends on whether it is a “persistent” or “session” cookie. Persistent cookies stay on your browsing device after you have finished browsing until they expire or are deleted. Session cookies will only stay on your device until you stop browsing.
What other tracking technologies should I know about? Cookies are not the only way to track visitors to a site or app. Companies use tiny graphics files with unique identifiers called web beacons (and also “pixels” or “clear GIFs”) to recognize when someone visits its sites. These technologies often depend on cookies to function properly, and so disabling cookies may impair their functioning. Mobile apps may also include third-party software development kits that provide mobile performance and analytics data, bug reporting features, and application program interfaces to third parties that help provide the apps, for social media functionality, and for marketing and advertising.
Who serves the cookies
How to control them
Analytics cookies and technologies help us understand how our Services are performing and being used. These cookies may work with clear gifs included in emails we send to track which emails are opened and which links are clicked by recipients.
See ‘your choices’ below.
Google Analytics uses its own cookies. You can find out more information about Google Analytics cookies here and about how Google protects your data here. You can prevent the use of Google Analytics relating to your use of our Service by downloading and installing a browser plugin available here.
Essential cookies and technologies are necessary to allow the technical operation of our Services (e.g., they enable you to move around on a website and to use its features).
See ‘your choices’ below.
Functionality / Performance
Functionality and performance cookies and technologies enhance the performance and functionality of our Services.
See ‘your choices’ below.
What are my choices about cookies and other technologies? Most browsers let you remove or reject cookies. To do this, follow the instructions in your browser settings. Many browsers accept cookies by default until you change your settings. Please note that if you set your browser to disable cookies, the Services may not work properly.
For more information about cookies, including how to see what cookies have been set on your computer or mobile device and how to manage and delete them, visit www.allaboutcookies.org. You can also opt-out of tracking through certain third-party advertising and analytics cookies by using the opt-out services provided by the Digital Advertising Alliance or Network Advertising Initiative. Cleo is not affiliated with and is not responsible for these third party websites.
How We Use Your Information
We may also use aggregated or anonymous 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. We may also use IP addresses to analyze trends, administer the Services, track a visitor’s movement, and gather demographic information which we may combine with other aggregated or anonymous data for the uses described above.
Sharing Your Information
We may share your information as follows:
Opt in marketing You may choose to opt in to marketing-related emails by following instructions provided in email or through the Cleo app.
You may receive service-related and other non-marketing emails.
Do Not Track. Some Internet browsers may be configured to send “Do Not Track” signals to the online services that you visit. We currently do not respond to “Do Not Track” or similar signals. To find out more about “Do Not Track,” please visit http://www.allaboutdnt.com.
Choosing not to share your personal information. Where we are required by law to collect your personal information, or where we need your personal information in order to provide the Services or our products and services to you, if you do not provide this information when requested (or you later ask to delete it), we may not be able to provide you with our products and services. We will tell you what information you must provide to use the Services or through other appropriate means.
[De-linking third party interactions. The Services enable you to interact with or connect to certain third parties and social networking sites. If you would like to discontinue these interactions and connections, please refer to the privacy settings of the third party to determine how you may adjust our permissions and manage the interactivity between the Services and your third party account.]
How We Protect Your Information
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.
If you create or use an Account, you are solely responsible for maintaining and protecting the confidentiality of your username, password and other account information in your possession.
Children’s Online Privacy Protection Act
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.
Links to Third-Party Sites
Privacy Shield Notice
As required under the Principles, if we receive personal data subject to our pending certification under the Privacy Shield and then transfer it to a third party service provider that performs services on Cleo’s behalf, we have certain liability under the Privacy Shield if both (i) the service provider processes the personal data in a manner inconsistent with the Privacy Shield and (ii) we are responsible for the event giving rise to the damage.
In compliance with the Privacy Shield Principles, Cleo commits to resolve complaints about our collection or use of your personal information. If you are a resident of a European country participating in the Privacy Shield with inquiries or complaints regarding our Privacy Shield practices, you should first contact Cleo by email at [email protected], or by mail at the address listed below in the How to Contact Us section, and we will work with you to resolve your issue.
If you are a resident of a European country participating in the Privacy Shield and have an inquiry or complaint that we have not addressed to your satisfaction, you may seek further assistance, at no cost to you, from the American Arbitration Association (AAA) and the International Centre for Dispute Resolution (ICDR)
In addition to the steps described in Your Choices, above, some residents of European countries participating in the Privacy Shield may have certain legal rights to access or limit the use or disclosure of their personal information. To exercise those rights, these users may contact us at [email protected].
The services of the American Arbitration Association are provided at no cost to you. Under certain limited conditions, individuals may invoke binding arbitration as a last resort before the Privacy Shield Panel.
Cleo’s commitments under the Privacy Shield are subject to the investigatory and enforcement powers of the U.S. Federal Trade Commission.
Cleo commits to cooperate with EU data protection authorities (DPAs) and comply with the advice given by such authorities with regard to human and non-human resources data transferred from the EU.
How to Contact Us