Privacy Policy

ABOUT

In-Formation, LLC (“Company,” “we,” and “us”) respects and is dedicated to protecting your privacy. This Privacy Policy is designed to help you understand how we collect, use and share your Personal Data and to assist you in exercising the privacy rights available to you. Please read this Privacy Policy carefully. By using our website, application, or other online services you are agreeing that you have read, understand, and are accepting the practices described in this Privacy Policy.

SCOPE

This Privacy Policy applies to Personal Data processed by us in our business, including on our websites (e.g., in-formation.io and any other websites that we own or operate) and web-based and mobile applications (e.g., V.A.S.T. Journey App), our behavioral change services, and our related online and offline offerings (collectively, the “Services”). “Personal Data” includes any information that can be used on its own or with other information in combination to identify or contact our user(s). Some of the Personal Data we collect and submit will, in some circumstances, be considered “Health Data” (data related to a user’s physical or mental health) or “Protected Health Information” (information that relates to past, present, or future physical or mental health or condition of a user, or the past, present, or future payment for the provision of healthcare services to a user) or medical records as defined by state law. Therefore, this Privacy Policy is intended to comply with the Health Insurance Portability and Accountability Act of 1996 (“HIPAA”) provisions regarding sensitive Personal Data, where applicable and when necessary. Additionally, we intend to comply with applicable state laws regarding Health Data. For additional information related to healthcare information, please contact us at hello@in-formation.io.

This Privacy Policy does not apply to any third-party websites, services or applications, even if they are accessible through our Services. In addition, capitalized terms not defined in this Privacy Policy will have the meaning provided in our Terms of Use.

Please note that if you use the Services on behalf of an organization (e.g., your employer), our use of your Personal Data may be governed by the agreement we have with that organization. However, we will still process your information consistent with this Privacy Policy.

PERSONAL DATA WE COLLECT

The categories of Personal Data we collect depend on how you interact with our Services.

Information You Provide to Us

Account Information. When you create an Account, we may collect personal information, such as your name, email address, personal website, and picture.

Payment Information. We may sell services or merchandise through our Services. When you make purchases through our Services, we may process your payments through a third-party application, such as the Apple App Store, Google Play App Store, Amazon App Store, social networking sites such as Facebook, or payment processing services such as Stripe. The third-party application may collect certain financial information from you to process a payment on our behalf, including your name, email address, address, payment card information, and other billing information. We do not store or receive your payment information, but we may store and receive information associated with your payment information (e.g., your billing details).

Your Communications with Us. We collect personal information from you such as email address, phone number, or mailing address when you request information about our Services, register for our newsletter, or otherwise communicate with us.

Journal Content. As part of your use of the Services you will input Personal Information detailing your journey in a private journal maintained on the Services (your “Journal”). We understand that information you input into your Journal may be highly private and sensitive in nature. Therefore, we will not share the contents of your Journal with any third party, including a parent or legal guardian in the event that you are a minor. That said, you understand that we may disclose portions of the contents of your Journal as we deem appropriate to the extent that we determine such poses a legitimate threat of harm to you or others.  

Health and Device Data. We may collect information from connected devices regarding your health conditions and fitness. We collect this information to provide you with the Services.

Surveys. We may contact you to participate in surveys. If you decide to participate, you may be asked to provide certain information, which may include Personal Data.

Interactive Features. We may offer interactive features such as collaboration tools, tagging functionalities, forums, blogs, social media pages and the ability to react, follow, observe in real-time and comment on users’ content. We, and others who use our Services, may collect the information you submit or make available through these interactive features. Any content you provide on the public sections of these features will be considered “public” and is not subject to the privacy protections referenced in this Policy. By using these interactive features, you assume the risk that the Personal Data provided by you may be viewed and used by third parties for their own purposes.

Customer Service, Training and Quality Assurance. If you call or otherwise interact with our customer service and support, we may collect the information you provide to our representatives. In addition, we may record telephone calls or video conferences between you and our representatives for training or quality assurance purposes.

Registration for Sweepstakes or Contests. We may run sweepstakes and contests. Contact information you provide may be used to reach you about the sweepstakes or contest and for other promotional, marketing and business purposes, if permitted by law. In some jurisdictions, we are required to publicly share information about the winners.

Meetups, Conferences, Trade Shows, and Other Events. We may host or attend meetups, conferences, trade shows, and other events where we collect personal information from individuals who interact with or express an interest in Company or the Services. If we collect your information at one of these events, we will use it for the purposes for which it was collected.

Business Development and Strategic Partnerships. We may collect personal information from individuals and third parties to assess and pursue potential business opportunities.

Job Applications. We may post job openings and opportunities on the Services. If you reply to one of these postings by submitting your application, CV or cover letter to us, we will collect and process that information to assess your suitability, aptitude, skills, and qualifications for employment with us.

Information Collected Automatically

Automatic Data Collection. We may collect certain information automatically when you use the Services. This information may include your Internet protocol (IP) address, user settings, MAC address, cookie identifiers, mobile advertising and other unique identifiers, details about your browser, operating system or device, location information (including inferred location based off of your IP address), Internet service provider, pages that you visit before, during and after using the Services, information about the links you click, and information about how you interact with and use the Services.

We may use a visitor’s IP address to fight spam, malware and identity theft. With your permission, we may also collect information about your operating system’s installed fonts in connection with providing the Services to you. Combined with other system information, this information could be used to give your computer a unique fingerprint/signature and enable us to track your usage of our Services after you log out.

Cookies, Pixel Tags/Web Beacons, and Analytics Information. We, as well as third parties that may provide content, advertising, or other functionality on the Services, may use cookies, pixel tags, local storage, and other technologies (“Technologies”) to automatically collect information through the Services. Technologies are essentially small data files placed on your device that allow us and our partners to record certain pieces of information whenever you visit or interact with our Services.

  • Cookies. Cookies are small text files placed in device browsers to store their preferences. Most browsers allow you to block and delete cookies. However, if you do that, the Services may not work properly.

  • Pixel Tags/Web Beacons. A pixel tag (also known as a web beacon) is a piece of code embedded in the Services that collects information about engagement on the Services. The use of a pixel tag allows us to record, for example, that a user has visited a particular web page or clicked on a particular advertisement. We may also include web beacons in e-mails to understand whether messages have been opened, acted on, or forwarded.

Analytics. We may also use Google Analytics or other service providers to collect and process analytics information on our Services. For more information about how Google uses data, please visit www.google.com/policies/privacy/partners/. You can opt out of Google Analytics’ collection and processing of data generated by your use of our website by going to http://tools.google.com/dlpage/gaoptout.

Information from Other Sources

Company Customers. If you use our Services on behalf of an organization (e.g., your employer), that organization may provide us with information about you so that we can provision your Account.

Third Party Services and Organizations. We may obtain information about you from other sources, including from third party services and organizations. For example, if you access our Services through a third-party service, we may collect information about you from that third-party service that you have made available via your privacy settings.

HOW WE USE YOUR PERSONAL DATA

We use your Personal Data for a variety of business purposes, including:

To Provide the Services or Information Requested, such as:

  • Fulfilling our contract with you or the organization on whose behalf you use the Services;

  • Managing your information and Account;

  • Responding to questions, comments, and other requests;

  • Processing payment card or other financial information to facilitate your use of the Services;

  • Providing access to certain areas, functionalities, and features of our Services;

  • Answering requests for customer or technical support; and

  • Allowing you to register for events.

Administrative Purposes, such as:

  • Pursuing legitimate interests, such as direct marketing, research and development (including marketing research), network and information security, and fraud prevention;

  • Measuring interest and engagement in our Services;

  • Improving the Services;

  • Developing new products and services;

  • Ensuring internal quality control and safety;

  • Authenticating and verifying individual identities;

  • Carrying out audits;

  • Communicating with you about your account, activities on our Services and Privacy Policy changes;

  • Preventing and prosecuting potentially prohibited or illegal activities;

  • Enforcing our agreements; and

  • Complying with our legal obligations.

Marketing Our Products and Services. We may use Personal Data to tailor and provide you with content and advertisements. We may provide you with these materials as permitted by applicable law

If you have any questions about our marketing practices or if you would like to opt out of the use of your Personal Data for marketing purposes, you may contact us at any time as set forth below.

Consent. We may use Personal Data for other purposes that are clearly disclosed to you at the time you provide Personal Data or with your consent.

De-identified and Aggregated Information Use. We may use Personal Data and other data about you to create de-identified or aggregated information, such as de-identified demographic information, de-identified location information, information about the device from which you access our Services, or other analyses we create. De-identified or aggregated information is not Personal Data, and we may use and disclose such information in a number of ways, including research, industry analysis, analytics, and any other legally permissible purposes.

Share Content with Friends or Colleagues. Our Services may offer various tools and functionalities that allow you to share content. For example, we may allow you to provide information about your friends through our referral services. Our referral services may allow you to forward or share certain content with a friend or colleague, such as an email inviting your friend to use our Services.

How We Use Automatic Collection Technologies. We, as well as third parties that may provide content, advertising, or other functionality on the Services, may use cookies, pixel tags, local storage, and other technologies to automatically collect information through the Services. Our uses of these Technologies fall into the following general categories:

  • Operationally Necessary. This includes Technologies that allow you access to our Services, applications, and tools that are required to identify irregular site behavior, prevent fraudulent activity and improve security or that allow you to make use of our functionality;

  • Performance Related. We may use Technologies to assess the performance of our Services, including as part of our analytic practices to help us understand how our visitors use the Services;

  • Functionality Related. We may use Technologies that allow us to offer you enhanced functionality when accessing or using our Services. This may include identifying you when you sign into our Services or keeping track of your specified preferences, interests, or past items viewed;

  • Advertising or Targeting Related. We may use first party or third-party Technologies to deliver content, including ads relevant to your interests, on our Services or on third party sites.

Please note that this Privacy Policy covers only our use of Technologies and does not govern the use of Technologies by any third parties.

Cross-Device Tracking. Your browsing activity may be tracked across different websites and different devices or apps. For example, we may attempt to match your browsing activity on your mobile device with your browsing activity on your laptop. To do this our technology partners may share data, such as your browsing patterns, geo-location and device identifiers, and we may match the information of the browser and devices that appear to be used by the same person.

DISCLOSING YOUR INFORMATION TO THIRD PARTIES

We may share any Personal Data we collect with the following categories of third parties:

Service Providers. We may share any Personal Data we collect about you with our third-party service providers. The categories of service providers to whom we entrust personal information include service providers for: (i) the provision of the Services; (ii) the provision of information, products, and other services you have requested; (iii) marketing and advertising; (iv) payment and transaction processing; (v) customer service activities; and (vi) the provision of IT and related services.

Third-Party Platforms and Services. We will share your Personal Data with third-party platforms or services if you have expressly consented or requested that we do so. Please note we do not endorse, screen or approve, and are not responsible for, the practices or conduct of such third-party services.

Business Partners. We may provide Personal Data to business partners to provide you with a product or service you have requested. We may also provide Personal Data to business partners with whom we jointly offer products or services.

Allies. We may share your Personal Data with your friends, family, and acquaintances (“Allies”) who you invite to assist you in your journey using the Services. We will anonymize your Personal Data before sharing it with your Allies.

Affiliates. We may share Personal Data with our affiliated entities.

Advertising Partners. Through our Services, we may allow third party advertising partners to set Technologies and other tracking tools to collect information regarding your activities and your device (e.g., your IP address, cookie identifiers, page(s) visited, location, time of day). These advertising partners may use this information (and similar information collected from other websites) for purposes of delivering targeted advertisements to you when you visit third party services within their networks. This practice is commonly referred to as “interest-based advertising” or “personalized advertising.” If you prefer not to share your Personal Data with third party advertising partners, you may follow the instructions below.

Disclosures to Protect Us or Others. We may access, preserve, and disclose any information we have associated with you if we believe doing so is required or appropriate to: (i) comply with law enforcement or national security requests and legal process, such as a court order or subpoena; (ii) protect your, our or others’ rights, property, or safety; (iii) to enforce Company’s policies and contracts; (iv) to collect amounts owed to us; (v) when we believe disclosure is necessary or appropriate to prevent financial loss or in connection with an investigation or prosecution of suspected or actual illegal activity; or (vi) if we, in good faith, believe that disclosure is otherwise necessary or advisable.

Disclosure in the Event of Merger, Sale, or Other Asset Transfer. If we are involved in a merger, acquisition, financing due diligence, reorganization, bankruptcy, receivership, purchase or sale of assets, or transition of service to another provider, then your information may be sold or transferred as part of such a transaction, as permitted by law or contract.

INTERNATIONAL DATA TRANSFERS

All information processed by us may be transferred, processed, and stored anywhere in the world, including but not limited to, the United States or other countries, which may have data protection laws that are different from the laws where you live. We endeavor to safeguard your information consistent with the requirements of applicable laws.

YOUR CHOICES

General. You may have the right to opt out of certain uses of your Personal Data.

Email. If you receive an unwanted email from us, you can use the unsubscribe link found at the bottom of the email to opt out of receiving future emails. Note that you will continue to receive transaction-related emails regarding products or Services you have requested. We may also send you certain non-promotional communications regarding us and our Services, and you will not be able to opt out of those communications (e.g., communications regarding the Services or updates to our Terms of Use or this Privacy Policy).

Mobile Devices. We may send you push notifications through our mobile application. You may at any time opt-out from receiving these types of communications by changing the settings on your mobile device. With your consent, we may also collect precise location-based information if you use our mobile application. You may opt-out of this collection by changing the settings on your mobile device.

“Do Not Track”. Do Not Track (“DNT”) is a privacy preference that users can set in certain web browsers. Please note that we do not respond to or honor DNT signals or similar mechanisms transmitted by web browsers.

Cookies and Interest-Based Advertising. You may stop or restrict the placement of Technologies on your device or remove them by adjusting your preferences as your browser or device permits. Please note that cookie-based opt-outs are not effective on mobile applications. However, you may opt-out of personalized advertisements on some mobile applications by following the instructions for Android and iOS.

The online advertising industry also provides websites from which you may opt out of receiving targeted ads from data partners and other advertising partners that participate in self-regulatory programs. You can access these websites and learn more about targeted advertising and consumer choice and privacy, at www.networkadvertising.org/managing/opt_out.asp, http://www.youronlinechoices.eu/, https://youradchoices.ca/choices/, and www.aboutads.info/choices/.

Please note you must separately opt out in each browser and on each device.

YOUR PRIVACY RIGHTS

For purposes of the California Privacy Rights Act, we do not “sell” your “sensitive personal information.”

In accordance with applicable law, you may have the right to: (i) request confirmation of whether we are processing your Personal Data; (ii) obtain access to or a copy of your Personal Data; (iii) receive an electronic copy of Personal Data that you have provided to us, or ask us to send that information to another company (the “right of data portability”); (iv) object to or restrict our uses of your Personal Data; (v) seek correction or amendment of inaccurate, untrue, incomplete, or improperly processed Personal Data; (vi) withdraw your consent and (vii) request erasure of Personal Data held about you by us, subject to certain exceptions prescribed by law. If you would like to exercise any of these rights, please contact us as set forth below.

We will process such requests in accordance with applicable laws. To protect your privacy, we will take steps to verify your identity before fulfilling your request.

If you are a California resident, you have the right not to receive discriminatory treatment by Company for the exercise of your rights conferred by the California Privacy Rights Act.

Please note that if you use our Services on behalf of an organization (e.g., your employer), that organization may be responsible for fulfilling the individual rights requests referenced above.

DATA RETENTION

We store the Personal Data we receive as described in this Privacy Policy for as long as you use our Services or as necessary to fulfill the purpose(s) for which it was collected, provide our Services, resolve disputes, establish legal defenses, conduct audits, pursue legitimate business purposes, enforce our agreements, and comply with applicable laws.

SECURITY OF YOUR INFORMATION

We take steps to ensure that your information is treated securely and in accordance with this Privacy Policy. Unfortunately, no system is 100% secure, and we cannot ensure or warrant the security of any information you provide to us. To the fullest extent permitted by applicable laws, we do not accept liability for unauthorized disclosure.

By using the Services or providing Personal Data to us, you agree that we may communicate with you electronically regarding security, privacy, and administrative issues relating to your use of the Services. If we learn of a security system’s breach, we may attempt to notify you electronically by posting a notice on the Services, by mail or by sending an email to you.

THIRD PARTY WEBSITES/APPLICATIONS

The Services may contain links to other websites/applications and other websites/applications may reference or link to our Services. These third-party services are not controlled by us. We encourage our users to read the privacy policies of each website and application with which they interact. We do not endorse, screen or approve, and are not responsible for, the privacy practices or content of such other websites or applications. Visiting these other websites or applications is at your own risk.

CHILDREN’S INFORMATION

The Services are not directed to children under the age of 14 (or other age as required by local law), and we do not knowingly collect Personal Data from children. If you learn that your child has provided us with Personal Data without your consent, you may contact us as set forth below. If we learn that we have collected a child’s (under 14 years of age) Personal Data in violation of applicable law, we will promptly take steps to delete such information and terminate the child’s account.

SUPERVISORY AUTHORITY

If you are located in the European Economic Area or the United Kingdom, you have the right to lodge a complaint with a supervisory authority if you believe our processing of your Personal Data violates applicable law.

CHANGES TO OUR PRIVACY POLICY

We may revise this Privacy Policy from time to time at our sole discretion. If there are any material changes to this Privacy Policy, we will notify you as required by applicable law. You understand and agree that you will be deemed to have accepted the updated Privacy Policy if you continue to use the Services after the new Privacy Policy takes effect.

DELETING YOUR ACCOUNT

You may delete your account and all associated personal data at any time. To delete your account, please fill out our Request to Delete Account form so that we can oversee the process and ensure that all of your personal data is completely removed from the system.

CONTACT US

If you have any questions about our privacy practices or this Privacy Policy, or if you wish to submit a request to exercise your rights as detailed in this Privacy Policy, please contact us at:

In-Formation, LLC

1 Central Street #31

Norwood, MA 02062

Via Email: hello@in-formation.io