Ginger.io Coaching Services LLC Privacy Statement

INTRODUCTION

Ginger.io Coaching Services LLC (“Ginger.io” or “we”) has prepared this Privacy Statement to inform recipients of our coaching services (“user” or “you”) about how we collect, use and disclose their personally identifiable information (“Personal Information”). To receive coaching services from us, you must download the Ginger.io mobile application (the “App”).

BY REGISTERING FOR AND RECEIVING OUR COACHING SERVICES, YOU ACKNOWLEDGE THAT YOU HAVE READ AND UNDERSTAND THIS PRIVACY STATEMENT, AGREE TO BE BOUND BY OUR TERMS OF USE, AND CONSENT TO THE COLLECTION, USE AND DISCLOSURE OF YOUR PERSONAL INFORMATION AS SET OUT IN THIS PRIVACY STATEMENT.

WHAT INFORMATION DO WE COLLECT?

We may collect the following types of Personal Information in connection with our delivery of coaching services to you:

When you register to receive coaching services from us, whether in your individual capacity or on behalf of an organization, we collect any Personal Information that you submit through our registration form, including your name, email address, mailing address, phone number, payment card information, and any other Personal Information you voluntarily submit through the online registration form (your “Account Data”).

When we provide our coaching services to you, we collect any Personal Information that you voluntarily provide to us and our coaches, including information about your personal goals and circumstances (your “Coaching Data”).

When you use the App, we automatically collect information about your mobile device and how and when you use our mobile application, including the manufacturer and model of the device, unique device identifiers, and IP address (“Mobile Data”).

With your prior informed consent, we may also collect information about how and when you use your device, such as the phone numbers you call and text, names of recipients, your location, the movements of your device and the actions you perform on your mobile device (“Additional Mobile Data”).

If you use the App to respond to our surveys and questionnaires, we collect the information you voluntarily provide in your responses (your “Survey Data”).

We may also collect Personal Information that you voluntarily provide to us when you contact us with a question or comment about our services.

HOW DO WE USE INFORMATION WE COLLECT?

PERSONAL INFORMATION

We use your Personal Information to provide and optimize the App and our coaching services. In particular, we use:

  • Account Data to manage your account, communicate with you in relation to your account, process your transactions, and deliver and monitor the performance of our services;
  • Coaching Data to understand your personal objectives and circumstances, help you develop and execute strategies to overcome your challenges and achieve your goals, evaluate the progress of our coaching program, and optimize our coaching services;
  • Mobile Data to monitor and enhance the performance of the App, analyze trends, usage and activities in connection with the App, and ensure its technological compatibility with users;
  • Additional Mobile Data to provide insight to coaches regarding your activity, interactions, and isolation levels so that we can better customize and optimize our coaching services to you to meet your needs; and
  • Survey Data to provide insight to your coach about your personal circumstances and to receive feedback on the quality of our services.
  • We also use the Personal Information you provide us to respond to your comments and questions and personalize our services for you.
  • We may wish to use your Personal Information to provide you with marketing communications. We will only do so with your consent and as permitted by law.

AGGREGATE INFORMATION

We create statistical, aggregate data (“Aggregate Information”) about our user base for analytical purposes. Aggregate Information includes data derived from Personal Information and obtained by us from other sources in aggregated, anonymous form. Aggregate Information cannot reasonably be used to identify any individual.

LEGAL EXCEPTIONS

Under certain circumstances, Personal Information may be subject to disclosure pursuant to judicial or other government subpoenas, warrants, or orders. As such, notwithstanding the above, we may in any event use Personal Information to the extent required or permitted by applicable law to resolve disputes, to enforce our agreements (including the Terms of Use) with you, or as reasonably necessary to protect our legal rights, to protect you against self-harm, or to protect third parties.

WHAT INFORMATION DO WE DISCLOSE TO THIRD PARTIES?

We will not disclose your Personal Information to any third party except as follows:

  • We may disclose your Personal Information to third parties who provide services on our behalf, such as managing our accounts, processing transactions, operating the App, or providing customer service. We enter into confidentiality agreements with such providers which require them to use the Personal Information they receive only to perform services for us.
  • Subject to applicable law, we may disclose your Personal Information to any law enforcement, judicial authority, or governmental or regulatory authority, to the extent required by law or if in our reasonable discretion disclosure is necessary to enforce or protect our legal rights, to protect you, or to protect third parties.
  • In the event of a reorganization, merger, acquisition, asset sale or similar transaction, we may transfer any and all Personal Information we collect to the relevant third party involved in the transaction, with your consent if and as required under applicable privacy laws.
  • We may otherwise disclose your Personal Information when we have your prior consent to share the information. In such cases, we will have written contracts in place with the third parties requiring them to comply with terms of confidentiality similar to the applicable terms of this Privacy Statement as well as all applicable statutes, regulations and laws pertaining to the protection of such Personal Information.
  • We may share Aggregate Information with third parties where permitted by applicable law.

INFORMATION SECURITY

We use reasonable and appropriate security precautions to protect the security and integrity of your Personal Information in accordance with this Privacy Statement and applicable law. We secure information using industry standard administrative, physical, and technical safeguards including encryption of information that is stored and transmitted. It is important for you to know that, despite using these current industry-recommended practices, we cannot guarantee against breaches in security.

You are responsible for maintaining the security of your login ID and password. If you believe that your login ID or password has been compromised, you should immediately change your password and contact our support services. We are not responsible if someone else accesses your account through registration information they have obtained from you or through a violation by you of the Terms of Use.

LINKS

The App may contain links to other websites. Ginger.io is not responsible for the privacy practices or the content of those websites. Users should be aware of this when they leave our Service and are encouraged to review the privacy statements of each third party website. This Privacy Policy applies solely to information collected by Ginger.io.

CHILDREN

Ginger.io does not knowingly collect or maintain Personal Information from persons under 18 years of age, and no part of our services is directed at persons under 18. If you are below the age of 18, you are not permitted to use our services.

If Ginger.io learns that Personal Information of persons less than 18 years of age has been collected without verifiable parental consent, then Ginger.io will take the appropriate steps to delete this information. To make such a request, please contact us at help@ginger.io.

ACCESS, CORRECTION, AND OTHER RIGHTS

To exercise the statutory rights you may have under applicable law, such as to access, correct, update or delete Personal Information we have under our control, limit our use of your Personal Information, or exercise any right to data portability, please contact us by the means noted below and clearly describe your request.

You have the right to review, amend, or correct your email address, Account Data, or other Personal Information held in our database. To do so, please contact us by sending an email to help@ginger.io with a clear description of your request. We will try to comply with your request as soon as reasonably practicable and always under the timeframes set forth by applicable laws.

If you would like your Account Data or other Personal Information permanently removed from our database, please contact us at help@ginger.io. We will then terminate your account, you will no longer be able to use our services, and you will no longer receive emails from Ginger.io. Subject to applicable law and necessary record retention requirements, your identifying Personal Information shall be deleted from our records within 30 days of your request. Please note that we may need to retain certain information for recordkeeping purposes, to complete any transactions that you began prior to your request, or for other purposes as required or authorized by law.

CHANGES

We may modify or amend this Privacy Statement from time to time. If we make any material changes in the way in which Personal Information is collected, used or transferred, this Privacy Statement will be revised to reflect such changes and the updated Privacy Statement will be made available to you. Notwithstanding any modifications we may make, any Personal Information we collect from you will be used in accordance with applicable laws and regulations. The date last revised appears at the bottom of the Privacy Statement. Changes take effect immediately upon posting.

QUESTIONS

You may also contact us if you have any questions about this Privacy Statement. Please contact us at help@ginger.io or write to us at the following address: Ginger.io Coaching Services LLC, 332 Pine Street, Suite 800, San Francisco 94104 California USA.

CROSS-BORDER TRANSFERS

In connection with your access and use of our services, your Personal Information may be transferred to and processed in the United States of America, which do not adduce an adequate level of protection from a European data protection perspective. If you are located in the European Economic Area, please note that we will take all necessary measures to ensure that transfers of your Personal Information out of the European Economic Area are adequately protected as required by applicable data protection law.

Last Updated: November 30, 2017