Updated September 24, 2020
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
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 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.
You may "opt-out" of receiving marketing or promotional communications from us at any time. Contact us at firstname.lastname@example.org to unsubscribe.
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.
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@example.com with your request.
If you have any questions regarding our Policy, contact us at firstname.lastname@example.org
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).
Personal Information Collected and Disclosed
|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:
- Categories of and specific pieces of personal information we have collected about you.
- Categories of sources from which we collect personal information.
- Purposes for collecting, using, or selling personal information.
- Categories of third parties with which we share personal information.
- Categories of personal information disclosed about you for a business purpose.
- 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@example.com 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.
You may contact us by emailing us at firstname.lastname@example.org.