Effective as of December 18, 2019
Personal Information We Collect
Information You Give Us. Personal information you may provide through a Site or otherwise communicate to us includes:
- Contact information. We collect information about you when you provide contact information to us via email, mail, or through a Site, including as a result of creating an account, completing a form to request more information about our services, or scheduling services. This information may include your first and last name, email address, mailing address, phone number, and payment information.
- Feedback and correspondence. We collect information about you when you request information, respond to surveys, or otherwise correspond with us.
- Client intake. We collect additional information about you, such as your race, gender, and information about your wellbeing, through our client intake
- Training and evaluation. We may collect information about you when you participate in our training program and interact with our coaches or otherwise engage in our service offerings.
Information We Get From Others. We may obtain additional information about you from third party sources, such as service providers, vendors, social media sites, and advertising agencies to provide you with more relevant information about our services.
Statistical Analyses. We use Google Analytics to help us gather statistical information about the visitors to our Sites and how they use the Sites on an anonymous, aggregate basis. However, we will not associate this data with your personally identifiable data unless required to do so to cooperate with law enforcement activity or other governmental request or to comply with law. We may use this information to gain a better understanding of the users of our Sites, to improve our Sites, and to improve our services. Depending on the type of browser and device that you use, you may have the ability to control the type of information that Google Analytics use. To understand how Google Analytics collects and processes data, please visit www.google.com/policies/privacy/partners/. We reserve the right to license or sell aggregate, de-identified information about the visitors to our Sites, but this information will not contain your personal information or otherwise be individually identifiable.
How We Use Your Personal Information
To Provide our Services and Communicate With You. We use your personal information:
- to provide, maintain and improve the Sites;
- to better understand your needs and interests, and personalize your experience with the Sites;
- to provide you with our training services;
- to register you for training sessions;
- to respond to your requests, questions, comments, feedback, and training results; and
- to perform website analytics and database management services.
To Send You Marketing Communications. We may send you newsletters, promotions or other marketing communications, but you may opt out of receiving them as described in the Your Choices section below.
To Create and Maintain Your Account. To utilize any of our services, you must create an account using certain personal information, including your name and email address. You have choices about the information included in your account profile. You do not have to provide additional information on your profile; however, additional profile information may help you get more from our services. It is your choice whether to include sensitive information on your profile and to make that sensitive information public. Please do not post or add personal data to your profile that you would not want to be publicly available.
For Compliance, Fraud Prevention and Safety. We may use your personal information as we believe appropriate to: (a) investigate or prevent violation of the law or your agreements with us; (b) protect our, your or others’ rights, privacy, safety or property (including by prosecuting and defending legal claims); (c) protect, investigate and deter against fraudulent, harmful, unauthorized, unethical or illegal activity; (d) comply with applicable laws, lawful requests and legal process, such as to respond to subpoenas or requests from government authorities; and (e) where permitted by law in connection with a legal investigation. For example, we may share information with law enforcement to reduce the risk of fraud or if someone uses or attempts to use our Sites for illegal reasons.
With Your Consent. In some cases we may ask for your consent to collect, use or share your personal information.
How We Share your Personal Information
Business Partners. We may share your personal information with our business partners who offer a service to you jointly with us. A list of our current business partners that have access to certain personal information we collect is available upon request.
Security, Compliance, Fraud Prevention, Safety; Compliance with Law. We may disclose your personal information as we believe appropriate to government or law enforcement officials or private parties for the purposes described above under the following sections: For compliance, fraud prevention and safety and for compliance with law.
Business Transfers. We may sell, transfer or otherwise share some or all of our business or assets, including your personal information, in connection with a business deal (or potential business deal) such as a merger, consolidation, acquisition, reorganization or sale of assets, or in the event of bankruptcy.
Opt Out of Communications. You may opt out of email notifications by sending a request via email to email@example.com.
Opt Out of Marketing Communications. You may opt out of marketing-related emails by following the opt-out prompt in the email. To opt out of other forms of marketing communications, please contact us using the contact information provided at the end of this Policy.
What are Cookies? Cookies are small data files that are placed on your computer or mobile device when you visit a website. Cookies set by the website are called “first party cookies”. Cookies set by parties other than the website are called “third party cookies”. Third party cookies enable third party features or functionality, such as advertising or website analytics, to be provided on or through the website. The parties that set these third party cookies can recognize your computer or device both when it visits the website in question and also when it visits certain other websites and/or mobile apps.
What Cookies and Other Tracking Technologies do We Use? We use several different kinds of cookies on our Sites, including strictly necessary cookies, which are cookies that are necessary for the Sites to function and cannot be switched off in our systems; performance cookies, which allow us to count visits and traffic sources so we can measure and improve the performance of our Sites; and functional cookies, which enable the Sites to provide enhanced functionality and personalization. Specifically, the cookies we use are:
Cookies are not the only way to track visitors to a website. We may use similar technologies from time to time, like web beacons (sometimes called “tracking pixels” or “clear gifs”). These are tiny graphics files that contain a unique identifier that enable us to recognize when someone has visited our Sites. These technologies often depend on cookies to function properly, and so disabling cookies may impair their functioning.
How Can You Disable Cookies and Other Tracking Technology? Most browsers let you remove or reject cookies. To do this, follow the instructions in your browser settings. Many browsers accept cookies by default until you change your settings. For more information about cookies, including how to see what cookies have been set on your computer or mobile device and how to manage and delete them, visit www.allaboutcookies.org and www.youronlinechoices.com.
Some Internet browsers also may be configured to send “Do Not Track” signals to the online services that you visit. We currently do not respond to “Do Not Track” or similar signals. To find out more about “Do Not Track,” please visit http://www.allaboutdnt.com.
Other Important Privacy Information
Health Information. If you are receiving Neurocore clinical services, Neurocore may collect certain health information about you. Details about how Neurocore collects, uses and discloses your health information is available at [insert link to Neurocore Notice of Privacy Practices].
Third Party Sites and Services. The Sites may contain links to other websites and services operated by third parties. These links are not an endorsement of, or representation that we are affiliated with, any third party. We do not control third party websites, applications or services, and we are not responsible for their actions. Other websites and services follow different rules regarding their collection, use and sharing of your personal information. We encourage you to read their privacy policies to learn more.
Security. The security of your personal information is important to us. We take a number of organizational, technical and physical measures that are designed to protect the personal information we collect. However, security risk is inherent in all internet and information technologies and we cannot guarantee the absolute security of your personal information.
International Data Use. We are located in the United States and have affiliates and service providers in other countries, and your personal information may be collected, used and stored in the United States or other locations outside of your home country. Privacy laws in the locations where we handle your personal information may not be as protective as the privacy laws in your home country.
Verifying, Changing, and Deleting Your Information. You can contact us as detailed below and ask us to change, update or fix your information in certain cases, particularly if it is inaccurate. You can also request that we erase or delete all or some of your personal information or otherwise object to, limit, or restrict the use of such information (if we have no legal right or legitimate business interest in retaining such information).
The Sites are not intended for use by anyone under the age of 13, nor do we knowingly collect or solicit personal information from anyone under the age of 13. If you are under 13, you should not attempt to use the Sites or send any information about yourself to us.
Notice to California Residents
The following section applies to California residents.
Shine the Light. Under California’s “Shine the Light” law, you have the right to ask us once a year if we have shared your personal information with third parties for direct marketing purposes. To make a request please contact us as instructed in the “How to Contact Us ” section and specify you are making a Shine the Light request.
California Consumer Privacy Act (“CCPA”). The CCPA creates consumer privacy rights and requires businesses to make disclosures about their privacy policies and practices. Pursuant to the CCPA, both our privacy practices and your privacy rights are discussed in detail in the following information.
Personal Information We Collect. We collect your personal information when you interact with our Site or otherwise communicate with us. For the purposes of this Privacy Notice, “personal information” means information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or device.
We have collected the following categories of personal information covered by the CCPA from consumers within the past 12 months, and have used it for the following business purposes:
|Category of Personal Information Collected||Business Purpose of Collection|
|Identifiers, including real name, alias, signature postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, telephone numbers.||To provide you our services, collect payment for our services, and communicate with you. In addition, we collect your IP address anonymously to provide you more relevant content, track original Site visits, and optimize your Site experience.|
|Information about children, including name, age, and gender||We collect this information only if we are providing our services to a minor child.|
|Characteristics of protected classifications under California or federal law, including age or date of birth, physical disabilities, mental disabilities, medical condition, and sex||To provide our services, specifically for evaluation and program development|
|Occupation, professional, or employment-related information||If you are referred by a company or management team, or if we are providing services intended to optimize performance related to your profession|
|Medical information, including medical condition; drugs, therapies, or medical products or equipment used; health insurance information; insurance policy numbers.||To inform evaluation data collection and feedback|
|Financial information, including credit or debit card number or debit card number||To bill you for our services|
|Biometric information||For service evaluation|
|Internet or other electronic network activity information, including browsing history, search history, and information regarding an individual’s interaction with an internet Web site, application or advertisement||To provide you more relevant content, track original Site visits, and optimize your Site experience|
|Geolocation Data||We collect anonymous general location data (city, state, country) about our Site visitors for analytics purposes|
|Audio information||Calls to our 800 number are recorded for quality assurance and training purposes with your consent|
|Any inferences drawn from the information identified above to create a profile about an individual reflecting the individual’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities and aptitudes.||To provide our services, specifically for evaluation and program development|
We will not collect additional categories of personal information or use the personal information we collected for materially different, unrelated, or incompatible business purposes without providing you notice.
Sharing Your Information. We do not sell your personal information, but we may disclose it to third parties for a business purpose. Specifically, we disclose the following categories of personal information covered by the CCPA for a business purpose:
|Category of Personal Information Collected||Category of Third Parties with Whom Information is Disclosed|
|Identifiers, including real name, alias, signature postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, telephone numbers.||Service providers, including our customer relationship management (CRM) solution providers, Site service providers, data analytics providers, and social networks|
|Financial information, including credit or debit card number or debit card number||Third party payment proessors|
|Internet or other electronic network activity information, including browsing history, search history, and information regarding an individual’s interaction with an internet Web site, application or advertisement||Data analytics providers, marketing service providers|
|Geolocation Data||Data analytics providers|
|Audio and visual information||Audio information is shared with our CRM solution providers|
Please note that we may collect, use and share additional personal information about you that is governed by laws other than the CCPA, and that our activities related to such personal information are not disclosed here. If you are receiving Neurocore clinical services, health information collected by Neurocore is one such example. Details about how Neurocore collects, uses and discloses your health information is available here [insert link to Neurocore Notice of Privacy Practices].
Directly from You. For example, when you:
- Create an account.
- Fill out our questionnaires.
- Pay for our services
- Sign up to receive promotional emails or text messages.
- Provide your contact information to us.
- Submit a request to us.
- Participate in one of our surveys.
- Interact with our social media pages.
We collect the following categories of personal information directly from you: identifiers, including your name, postal address, user name, email address, and telephone number; information about children; characteristics of protected classifications; occupation, professional, or employment-related information; medical information; and financial information.
Passively. For example, when you:
- Visit and navigate our Site on any device.
- Click on sponsored links or third-party advertisements.
- Receive or interact with our communications and Site that may contain cookies.
- Contact use via our 800 number.
- Use our Services.
We collect the following categories of personal information directly from you: IP address, Internet or other electronic network activity information, geolocation data, biometric data, and audio information.
From Third Parties. We may receive information about you from other sources. For example, we get information from:
- Our service providers, including Myndlift
- Our business partners, including online advertising networks.
- Social media platforms, including Facebook and LinkedIn.
We collect the following categories of personal information from third parties: IP address, Internet or other electronic network activity information, biometric data.
Your Rights. The CCPA gives you certain rights regarding your personal information:
- Right to Know. You may request no more than twice in a 12-month period that we provide you with copies of specific personal information we have collected, sold, or disclosed about you. However, under California law, we cannot provide you with certain sensitive information, despite your request (for example, we will not send you copies of your social security number even if it is something we collected).
- Right to Delete. You may request that we delete certain personal information we have collected about you, with certain exceptions.
Exercising Your Rights. To exercise your rights above, please submit a request to us at [link to CCPA rights web form] or contact us using one of the methods set forth in the “How to Contact Us” section below. Please describe your request with sufficient detail so we can properly respond to your request. As part of your request, please specify which right you are exercising and be prepared to provide your name and email address. We may ask for additional information to verify your identity. The information you provide in your request and any follow up information we ask for from you will be used solely to verify your request.
After receiving your request, we may need to contact you for further information and will notify you if your request has been granted or declined, or if an exception applies to your request.
Only you or an individual designated as your authorized agent to act on your behalf may make a request related to your personal information. You may also make a request on behalf of your minor child.
We may not discriminate against you if you choose to exercise your rights.
Responding to Your Rights Request. We will try to respond to your request within 45 days. If we need more time, we will contact you with the reason we need more time and the extension period. If you have an account with us, we may deliver our written response to that account. If you do not have an account with us, we will deliver our written response by mail or electronically, at your option. In response to your request to know, we will only disclose the information we have collected in the 12 months prior to our receipt of your request. Our response will also explain the reasons we cannot comply with any request, if applicable.
We do not charge a fee to process or respond to your request unless your request is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate prior to completing your request.
How to Contact Us
201 Monroe Ave NW, Suite 300
Grand Rapids, MI 49503
United States of America
Phone: (800) 600-4096