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Privacy Policy

Last Updated: April 30th, 2019

We at Cleo Labs, Inc. (“Cleo”, “we” or “us”) know you care about how your personal information is used and shared, and we take your privacy seriously. Please read the following to learn more about our Privacy Policy. The purpose of this Privacy Policy is to explain the types of information we may obtain about individuals who participate in our referral, coaching and/or guidance services, visit our website at www.hicleo.com, use our mobile application, or interact with our other online products and services (the “Services”), how the information is obtained, how it is used, how it is disclosed, how you can get access to this information, and the choices you have regarding our use of, and your ability to review and correct, the information. By using or accessing the Services in any manner, you acknowledge that you accept the practices and policies outlined in this Privacy Policy, and you hereby consent that we will collect, use, and share your information in the following ways.

Remember that your use of the Services is at all times subject to the Terms of Use (https://app.hicleo.com/terms-of-use), which incorporates this Privacy Policy. Any terms we use in this Policy without defining them have the definitions given to them in the Terms of Use.

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. In the event that we receive personal data transferred to us from the European Economic Arena (“EEA”), the United Kingdom [or Switzerland], we have submitted our self-certification to the EU-U.S. [and Swiss-U.S.] Privacy Shield. For more information, see our Privacy Shield Notice, below.

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:

  • Information that identifies you, such as your full name, email address, mailing address, and telephone number
  • Work information such as the identity of your employer or your job title
  • Family planning and health information that you share with us when using, signing up for, or requesting more information about the Services

If you provide health information or other sensitive personal information to us, you consent to our use of this information as described in this Privacy Policy.  If you do not consent to our processing and use of such sensitive personal information, you must not submit such sensitive personal information to us.

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

Usage information and automatic collection. Our servers and third party service providers may automatically record certain information about how you use the Services and the computers or devices you use to access the Services, such as [your Internet Protocol (IP) address, domain name, device and browser type, operating system, Internet service provider, referring/exit pages, the website you visited before browsing to our websites, general location information such as city, state or geographic area, information about where you browse on the Site and the time you spend on those pages or features, the links that you click on or use and other statistics]. We collect this information in server logs and by using cookies and other technologies. Cookies are small bits of information that our websites place on your device. We may use cookies and other technologies to facilitate your login processes; allow you to personalize and store your settings; collect usage information; determine our total audience size and traffic, and help us improve our sites by measuring which areas are of greatest interest to users. For more information about the technologies we use, see the Cookies and Similar Technologies section, below.

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.

The information we collect in connection with third-party interactions is subject to this Privacy Policy. The information collected and stored by the third party remains subject to the third party’s privacy practices, including whether the third party continues to share information with us, the types of information shared, and your choices with regard to what is visible to others on that third party website or service.

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).

Information from third parties. We may also receive personal information about you from third parties such as [your employer, joint marketing partners, social media platforms, publicly-available sources or analytics or data providers].  We may add this information to the information we have already collected from you and will handle it in accordance with this Privacy Policy. 

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.

What types of cookies and similar technologies does Cleo use? We use cookies and similar technologies in the following categories described in the table below.

Type

Description

Who serves the cookies

(link to privacy policy/site)

How to control them

Analytics

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.

Google Analytics

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

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).

Google Tag Manager

See ‘your choices’ below. 

Functionality / Performance

Functionality and performance cookies and technologies enhance the performance and functionality of our Services.

Facebook

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

Subject to this Privacy Policy, the Terms of Use, and applicable terms and conditions of third-party applications, all data transmitted through the Services is owned by Cleo. To the extent Cleo is precluded from owning data transmitted through the Services, you grant Cleo a perpetual, worldwide, royalty-free license to use such data to the extent necessary to enable the use of the Services. Generally, we may use information in the following ways and as otherwise described in this Privacy Policy:

  • For the purposes for which you specifically provided it including, without limitation, to enable us to process and fulfill your Account, provide the Services or other requests;
  • To communicate with an expert;
  • To send you information about your relationship or transactions with us;
  • To otherwise contact you with information that we believe will be of interest to you, including marketing and promotional communications;
  • To enhance or develop features, products, and services;
  • To allow us to personalize the content that you and others see on the Services;
  • To create aggregated and other anonymous data by removing information that makes the data personally identifiable, which we may provide to advertisers and other third parties or use for other lawful business purposes;
  • To allow other select companies to send you promotional materials about their products and services.

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.

You acknowledge that unless you request in writing otherwise, Cleo, in its sole discretion, has the right but not the obligation to store any information, whether it is Personal Identifiable Information or otherwise, perpetually, to the extent permitted by law. If you wish for any information about you to be removed from our database, please contact us through the contact information provided below in the “How to Contact Us” section of this Privacy Policy. We will not use your health-related information for any purpose other than to provide you with the Services and/or customer support services you request from us.

Sharing Your Information

Except as otherwise described in this Privacy Policy, or if we inform you otherwise at the time of data collection and receive your consent where required, we will not sell, trade, or share your information with third parties.

We may share your information as follows:

  • With Affiliates: We may share your personal information with affiliated companies and businesses;
  • With Service Providers: We may use other companies to perform services including, without limitation, facilitating some aspects of our Services such as processing credit card transactions sending emails, and fulfilling purchase requests. These other companies may be supplied with or have access to your personal information solely for the purpose of providing these services to you on our behalf. Such service providers shall be bound by appropriate confidentiality and security obligations, which may include, as applicable, business associate contract obligations;
  • With Business Partners: When you make purchases or engage in promotions offered through our Services, we may share personal information with the businesses with which we partner to offer you those products, services, and promotions. When you accept a particular business partner’s offer, you authorize us to provide your information to that business partner;
  • With other Service Providers: We occasionally will share information and data on users of the Services with third-party providers who provide targeted services, such as advertising or data analysis on our behalf;
  • With your employer or health plan: We may share your enrollment status as a user of the Services.
  • With experts and coaches: We may share your personal information with experts and coaches enlisted to provide the Services.
  • Special Circumstances: We also may disclose your Personal Information:
    • In response to a subpoena or similar investigative demand, a court order, or other request from a law enforcement or government agency where required by applicable law;
    • When disclosure is required or allowed by law in connection with efforts to investigate, prevent, or take other action regarding illegal activity, suspected fraud or other wrongdoing; to protect and defend the rights, property or safety of our company, our users, our employees, or others; to comply with applicable law or cooperate with law enforcement; or to enforce our Terms or other agreements or policies;
    • In connection with a corporate transaction, such as the sale of all or a portion of our business, a divestiture, merger, consolidation, or asset sale, or in the event of bankruptcy, as required or allowed by law.

Your Choices

Access or update your information. You have the ability to review and update your personal information that Cleo may handle for you through your Account by visiting the account management section in the Services. You can also review and update your personal information by contacting us at the email address provided below in the “How to contact us” section of this Privacy Policy.

Opt out of marketing. You may opt out of marketing-related emails by following the unsubscribe instructions in the email.  You may continue to receive service-related and other non-marketing emails.  Opting out of emails or other communications related to contests or promotions may terminate your eligibility to participate in those contests or promotions.  Be sure to check the relevant contest or promotion rules before you opt out. 

Cookies.  We may allow service providers and other third parties to use cookies and similar technologies to track your browsing activity over time and across the Services and third party websites.  For more details, see the Cookies and Similar Technologies section. 

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. 

Changes To Our Privacy Policy

From time to time we may revise this Privacy Policy. If we make revisions that change the way we collect or use your Personal Information those changes will be posted in this Privacy Policy and the effective date will be noted at the end of the Privacy Policy. Therefore, you should review it periodically so that you are up to date on our most current policies and practices. If we make material changes to our practices regarding use of your Personal Information, your Personal Information will continue to be governed by the Privacy Policy under which it was subject prior to those changes, unless you have been provided notice of, and have not objected to, the changes.

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

Our Services may contain links to websites or applications operated and maintained by third-parties, over which we have no control. Privacy policies for these third-party sites and applications may be different from our Privacy Policy. You access these third-party sites and applications at your own risk. You should always read the privacy policy of a linked site or applications before disclosing any personal information on such site and/or through such applications. Cleo is not responsible for information you submit to third-parties.

Privacy Shield Notice

Cleo complies with the EU-U.S. Privacy Shield Framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information transferred from the EEA and the United Kingdom to the United States (the “Privacy Shield”).  Cleo has submitted an application to become certified to the Department of Commerce that it adheres to the Privacy Shield Principles.  If there is any conflict between the terms in this Privacy Policy and the Privacy Shield Principles, the Privacy Shield Principles shall govern.  To learn more about the Privacy Shield program, and to view our pending certification, please visit https://www.privacyshield.gov/.

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

If you have any questions, comments or concerns about our Privacy Policy, you may contact us at [email protected] or by writing a letter to Cleo Labs, Inc., 85 2nd Street, Suite 710, San Francisco, CA 94105.

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