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Privacy Policy

Effective date: June 12, 2018

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 users of our 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 (, 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.

Please note that the Services are intended solely and exclusively for residents of the United States, its territories and possessions (“U.S.“) while they are located in the U.S. Accordingly, this Privacy Policy is specifically directed only towards residents of the U.S. If you are located in the European Union or elsewhere outside of the U.S. and you use the Site contrary to our Terms of Use, you do so at your own risk and initiative, and are responsible for compliance with any applicable local and national laws. Please be aware that any information you submit to us will be transferred to and processed in the U.S. and subject to U.S. law, which may not be equivalent to the laws in your country of residence. By using the Site and/or providing us with your information, you consent to this collection, transfer, storage and processing of information to and in the U.S., and waive any claims that may arise under your own local and national laws.

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.

Information That You Give Us

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.


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.

Other Information We Collect

Cookies. Our Services may use cookies and other technologies to collect information. Cookies are small bits of information that our websites place on the hard drive of your computer. We may use cookies 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.

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).

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:

  • 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;
  • To enhance or develop features, products, and services;
  • To allow us to personalize the content that you and others see on the Services;
  • To provide advertisers and other third parties with aggregate information about users of the Services and Services usage patterns;
  • To allow other select companies to send you promotional materials about their products and services.

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.

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, on an anonymous basis, 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. This sharing of information does NOT include any Personal Information;
  • 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.
How to 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.

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.

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.

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.

Last Revised: June 12, 2018

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