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Pear Health Labs Inc. Privacy Policy

Updated January 31, 2022

This Privacy Policy ("Policy") provides information about the data that Pear Health Labs Inc. ("Aaptiv" or "We") may collect from users of our website (the "Site") and/or our mobile application (the "App") and how we use and share such information. By using the Site or the App, you agree to the terms of this Policy. We may change this Policy from time to time, and changes are effective upon posting. Please review our Privacy Policy regularly. Your continued use of Aaptiv after changes are posted constitutes your agreement to the changes. If you do not agree to the terms of this Policy, please discontinue your use of the Site and/or App.

What Information Do We Collect?

Each time you provide or transmit information to us via the Site or App, Aaptiv may obtain and collect personally identifiable information about you, including, but not limited to, your name, email address, and any other information that may be used to identify you. We may also collect information about your IP address, browser type, cookie identifiers, Internet Service Provider, referring and exit page, operating system, clickstream data, the type of mobile device you use, your mobile device's unique device ID, and your mobile operating system (“Internet Activity Data”). We may track information regarding your use of our Site or App, including but not limited to, which classes you have taken and timestamps associated with your use of our services. We also track and analyze non-identifying and aggregate usage and volume statistical information from our visitors and customers.

How is Information Collected?

Each time you provide or transmit information to us via the Site or App, Aaptiv may obtain and collect information about you, including, but not limited to, your name, email address, and any other information that may be used to identify you. For example, and without limitation, we may collect such information from you when you create a user account on the Site or App or when you contact our support team. If you subscribe to Aaptiv through an enterprise partner, such as an employer or other third party, we may receive personal information about you from that partner. As you interact with our website, we may automatically collect Internet Activity Data about your equipment, browsing actions and patterns, through cookies and other similar technologies.

Cookies, Web Beacons and Other Similar Technologies

As further described in our Cookie Policy, we use cookies and similar technologies (e.g., web beacons, pixels, ad tags and device identifiers) to recognize you and/or your device(s) on, off and across different Services and devices. We also allow some others to use cookies as described in our Cookie Policy. You can control cookies through your browser settings and other tools.

Children

Our Site, App, and services are not directed to children under 13 (or under 16 for individuals in the European Union). We will never knowingly collect any personally identifiable information about such children. If Aaptiv obtains actual knowledge that it has collected personal information about a child under the age of 13 (under 16 in the EU), that information will be immediately deleted and will not be shared or disclosed to third parties.

How Do We Use Your Personal Data?

We may use the information we collect from and about you for any of the following business purposes: (1) to fulfill your requests for classes or other products or services; (2) to respond to your inquiries; (3) to review Site or App usage and operations; (4) to address problems with the Site or App, our business, or our services; (5) to protect the security or integrity of the Site or App and our business; (6) to monitor the Site and App for compliance with our Terms of Use and the law; (7) to help improve our Site, App, or services; (8) to register and maintain an online or offline account; (9) to analyze how the Sites and App are used, to prepare aggregated trend reports, and to perform other market research; (10) to facilitate your interaction through the App with other users, including social networking; (11) to operate, analyze and enhance the performance and functioning of our Site and App and other products and services; and (12) to contact you with updates and other informational and promotional materials from us or third party marketing offers from our trusted partners, as well as from other companies. In addition, Aaptiv may partner with third party advertisers to help deliver advertisements through the Site or App relevant to your interests.

Sharing Practices

We may disclose information collected from and about you as follows: (1) to our related companies and service providers, to perform a business, professional or technical support function for us; (2) to our enterprise partners, if you joined Aaptiv as part of a promotion sponsored by that partner; (3) to social media or other third party platforms, if you post data to these platforms through the Site or the App; (4) to our business partners to communicate with you about their products and services, and to send you promotions, solicitations, brochures, and other marketing materials regarding their products and services; (5) as necessary if we believe that there has been a violation of our Terms of Use or of our rights or the rights of any third party; (6) to respond to legal process (such as a search warrant, subpoena or court order) and provide information to law enforcement agencies or in connection with an investigation on matters related to public safety, as permitted by law, or otherwise as required by law; and (7) in the event that our company or substantially all of its assets are acquired, your personal information may be one of the transferred assets. We may share aggregate, non-personally identifiable information about Website users with third parties.

Interest-Based Advertising

We may partner with ad networks and other ad serving providers ("Advertising Providers") who serve ads on behalf of us and others on non-affiliated websites or mobile applications. Some of those ads may be personalized, meaning that they are intended to be relevant to you based on information Advertising Providers collect about your visits to this site and elsewhere over time.

You may visit www.aboutads.info to learn more about this type of advertising and how to opt-out of this form of advertising by companies participating in the Digital Advertising Alliance ("DAA") self-regulatory program. Note that electing to opt-out will not stop advertising from appearing in your browser or applications. It may make the ads you see less relevant to your interests. In addition, note that if you use a different browser or erase cookies from your browser, you may need to renew your opt-out choice.

Apple Health Information

In order to provide our services, such as recommending classes you may enjoy, we may read and/or write data to the Apple Health database on your Apple device with your consent. We will not use this information for marketing or advertising purposes or share it with third parties.

Opting Out

You may "opt-out" of receiving marketing or promotional communications from us at any time. Contact us at [email protected] to unsubscribe.

Data Security

We maintain reasonable and appropriate measures designed to maintain information we collect in a secure manner. We have taken certain physical, electronic, and administrative steps to safeguard and secure the information we collect from Site visitors and App users. We likewise require that our vendors who process data for us, some of whom are located outside of the United States, take appropriate measures to secure data. Even though we follow reasonable procedures to try to protect the information in our possession, no security system is perfect and we cannot promise, and you should not expect, that your information will be secure in all circumstances.

Data Retention

We will only retain your personal data for as long as necessary to fulfill the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorized use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.

How to Access your Information

If you would like to access, update, or delete any information we have about you, or exercise any right you might have, please send an email to [email protected] with your request.

Contact Us

If you have any questions regarding our Policy, contact us at [email protected]

Additional California Privacy Disclosures

If you are a California resident, the processing of certain personal data about you may be subject to the California Consumer Privacy Act (“CCPA”) and other applicable California state privacy laws. The CCPA gives you certain rights with respect to the processing of your personal data (known as “personal information”, as defined in the CCPA).

This supplement provides additional privacy disclosures and informs you of your additional rights as a California resident, and should be read in conjunction with Aaptiv’s Privacy Policy.

Personal Information Collected and Disclosed

The categories of Personal Information collected and disclosed by Aaptiv in the last 12 months are described in the “What Information Do We Collect?” and “Sharing Practices” section of the Privacy Policy. For the purposes of the CCPA, this information corresponds to the following categories of Personal Information listed in the CCPA:

CategoriesHow shared
Personal identifiers (such as your name, email address, and other information you provide when subscribing to Aaptiv’s services)With our service providers, for professional and technical support; with enterprise partners as required by our agreements
Protected classifications (such as your age and gender)With Apple devices if you choose to disclose to Apple Health, for purposes of determining target heartrate
Commercial information (information about your purchases of services from us)With enterprise partners as required by our agreements
Biometric information (such as weight and height and heartrate and other information if you choose to share through Apple Health)With Apple devices if you choose to share through Apple Health
Internet Activity Data (including your IP address, browser type, cookie identifiers, Internet Service Provider, referring and exit page, operating system, clickstream data, the type of mobile device you use, your mobile device's unique device ID, and your mobile operating system)With service providers, for analytic and security purposes
Geo-location (the IP address of your computer)With service providers, for analytic and security purposes
Inferences (information you provide about yourself in the onboarding process to identify recommended services on the Site or the App)Not shared

Requests to Exercise Your Rights

RIGHT TO KNOW - Under the CCPA, you have a right to request information about our collection, use, and disclosure of your personal information over the prior 12 months, and ask that we provide you with the following information:

  1. Categories of and specific pieces of personal information we have collected about you.
  2. Categories of sources from which we collect personal information.
  3. Purposes for collecting, using, or selling personal information.
  4. Categories of third parties with which we share personal information.
  5. Categories of personal information disclosed about you for a business purpose.
  6. If applicable, categories of personal information sold about you and the categories of third parties to which the personal information was sold, by category or categories of personal information for each third party to which the personal information was sold.

RIGHT TO DELETE - You also have a right to request that we delete personal information, subject to certain exceptions.

EXERCISING YOUR RIGHTS - You may exercise your right to know and your right to delete by emailing us at [email protected] or calling 1-877-290-2815. In the request, please specify which right you are seeking to exercise and the scope of the request. We will confirm receipt of your request within 10 days. We may require specific information from you to help us verify your identity and process your request. If we are unable to verify your identity, we may deny your requests to know or delete.

REQUEST POLICIES - We currently do not collect household data. If all the members of a household make a Right to Know or Right to Delete request, we will respond as if the requests are individual requests. You may make a verifiable consumer request related to your personal information twice per 12-month period. We will not discriminate against you for exercising any of your rights under the CCPA. You may designate, in writing or through a power of attorney, an authorized agent to make requests on your behalf to exercise your rights. Before accepting such a request from an agent, we will require the agent to provide proof you have authorized it to act on your behalf, and we may need you to verify your identity directly with us.

Sale of Personal Information

Based on our understanding of the term “sell” under the CCPA, we do not “sell” your personal information. We do, however, use services provided by Google, Facebook and other Advertising Providers that help deliver interest-based ads to you as described in the section above entitled Interest-Based Advertising. If and to the extent “sale” under the CCPA is interpreted to include advertising technology activities such as those implemented specifically for interest-based advertising, we will comply with applicable law as to such activity.

Contact Us

You may contact us by emailing us at [email protected].