Privacy Policy

LIFEDOJO, INC.
PRIVACY POLICY

Effective Date: June 14, 2021; Last Date Updated: April 2023

Applicability

This Privacy Policy describes how LifeDojo treats personal information. This includes not applying to the practices of our parent company (Ontrak, Inc.), subsidiaries, or other affiliates. This Policy does not describe our practices in other locations including sites or apps where it does not appear.

Notice at Collection
Information That We Collect

We collect various types of information from you, as described below. California law requires us to tell you if we share information for cross-contextual behavioral advertising. Described below by category is the information we may collect and if we share it for cross-contextual behavioral advertising. To learn how to modify your cross-contextual advertising preferences view our Notice of Right to Opt-out of Sale/Sharing.

Contact and account information. We collect contact and account information from LifeDojo users. This includes name and may include username. It also includes and profile images. We may also keep track of your preferred language and time zone. We also collect email addresses and phone numbers from LifeDojo users and those interested in LifeDojo. We also collect company name, address, and role from individuals interested in learning more about LifeDojo. In some cases, we may share this information for the purpose noted above. 

Wellness information. We collect information from LifeDojo users about fitness level or other health indicators. LifeDojo users can also choose to provide us information about diet, sleep, or lifestyle factors.

Usage and demographic information. If you use our websites or app, we may collect information about the browser or type of device you are using. We collect information about your interactions with and on our websites and apps. For example, we may look at what site website users came from before arriving at lifedojo.com, or what site they go to when they leave. Information we collect might also include device identifiers and operating system information. We may collect information about a device’s general location, or other general location information like zip code and country. We may collect IP addresses. We may also collect demographic information like gender or age. In some cases, we may share this information for the purpose noted above.

We do not use or disclose sensitive personal information, as defined by California law, for inferring characteristics or for purposes other than those permitted by law. We keep personal information as long as it is necessary or relevant for the practices described in this Policy. We also keep information as otherwise required by law.

Business Purposes for Collecting Information

We use information as described here. 

We use information to provide our services. We use information to process LifeDojo registrations and to let users participate in our service. Services include coaching and goal-setting tools. 

We use information to respond to requests. We use information to respond to questions from those interested in our services. We also communicate with people about our relationship. For example, we might use information to respond to customer feedback. 

We use information to improve. We use information to make our websites, apps and services better. We may also use information to customize your experience with us.

We may use information to communicate about content in which people may be interested.  We may use user information to provide updates about new features or services. This may include information about special offers or surveys. From time to time we may also offer promotions or contests and provide information about those opportunities. We may provide information by email or in our LifeDojo platform. We may also provide this information on social media platforms. 

We use information to protect our company and users. We use information to protect our company and users. For example, to identify fraud. This also includes securing and protecting accounts and protecting LifeDojo. 

Processing European information. Our basis for processing information is typically to perform a contract. This includes responding to requests like providing customer service. Where this applies, if someone chooses not to provide information, we may be unable to perform the contract or respond to the request. We also process information based on consent. When this is the basis for processing information an individual has the right to withdraw consent. We also use information when we have a legitimate purpose in doing so. For example, this includes helping secure and improve LifeDojo.

More Information

For more information about our privacy practices, read below for the rest of our privacy policy.

Methods of Collecting Information

We receive and/or collect information in the following ways: 

We collect information directly from you. We may collect and process information from users that register for our service or interact with us. We may also collect information from those who contact us or interact with us on social media. 

We collect information passively. We use common tracking tools like browser cookies and web beacons to collect analytics and information about users. Tools we use may include embedded scripts and ETags or entity tags. To learn more about cookies visit the FTC’s Online Tracking page.  We may use these tools on our websites and apps, and in our emails. From time to time we may collect information over time and across different sites. We may partner with third parties that collect information on our sites or apps in this way. 

We receive information from third parties. For example, some employers give us limited information so their employees can use LifeDojo. We might also get information about some users from social media platforms when using their interactive features. Some business partners may also provide us with information. 

We Combine Information

We combine information that we have collected offline with information we collect online. We may also combine information that we have collected across multiple sites. This may include third party sites. We combine information across devices, such as computers and mobile devices. We may also combine information we get from a third party with information we already have.

We Disclose Information To Others

We provide all categories of information with vendors who perform services on our behalf. We may share information with trusted vendors. These may include companies or persons who help us deliver our services. For example, we share information with vendors who help us send marketing or transactional communications. 

We disclose contact and account, and wellness and demographic information with your coaches you choose. LifeDojo is intended to help motivate and keep people on track for their goals. Certain contact and wellness information may be shared with coaches to help provide those services. For example, coaches may learn about your current or past program enrollment. They may also see what habits you have chosen to work on. 

We disclose certain information with partner organizations. Sometimes, LifeDojo is offered through partnership organizations, such as your employer. If your employer runs a promotion, contest or other challenge, we may share certain aggregate information with them as described here or at the time you participate in the program.

We may share information for cross-contextual behavioral advertising.  We may share information with third parties in order to provide cross-contextual behavioral advertising. In the Notice at Collection (above) we outlined which categories of information are shared for cross-contextual behavioral advertising.

We disclose all categories of information to comply with the law or protect ourselves. We share information we collect to respond to court orders or subpoenas. We also share information in response to government agency or investigatory body requests. We also share information to investigate potential fraud and protect the security of the Platform.

We may transfer all categories of information with any successor to all or part of our business. If all or part of our business is sold, we may share information as part of that transaction. We may also share information if there is a merger or acquisition. If there is a financing or bankruptcy, we may also share information.

We disclose information as permitted by law and for other reasons we may describe to you.

You may decide to share information publicly. LifeDojo users can upload information publicly that others can see. This includes in message boards, local communities or in groups. This includes being able to participate in group chats. Those chats may not be anonymous and content you upload may be associated with profile information.  Your use of these features is subject to Terms and we recommend caution when using these or other public forums. 

Your Choices

You can opt out of certain communications. To stop receiving promotional emails follow the instructions in any such message you get. If you opt out you will continue to receive messages about your relationship with us and as otherwise permitted by law. Users who choose not to receive promotional messages may still use our services but may not receive, or may be unable to use, certain services that involve our interaction with you.

OUR COOKIE AND AD POLICY

You can control cookies and tracking tools. Our browser may give you the ability to control cookies or other tracking tools. How you do so depends on the type of tool. Certain browsers can be set to reject browser cookies. If you block cookies, certain features on our sites may not work. If you block or reject cookies, not all of the tracking described here will stop.

Cross-contextual behavioral advertising. To opt out of cross-contextual behavioral advertising, read our Notice of the Right to Opt-Out of Sale/Sharing for Cross-Contextual Behavioral Advertising, below. Additionally, the Self-Regulatory Program for Online Behavioral Advertising provides consumers with the ability to manage certain choices online here and provides a tool for managing mobile choices here.

Our Do Not Track Policy: Some browsers have “do not track” features that allow you to tell a website not to track you. These features are not all uniform. We do not currently respond to those signals.

Options you make are browser and device specific.

Your Rights

Access, deletion and correction of information. Depending on where you live, you may have certain rights related to the information we collect about you. This may include the right to access, correct, or delete personal information we have about you. We may need more information to process a request and to verify your identity. To exercise your rights to access, correct, or delete your information, you can contact us as noted at the end of this policy. You can designate someone else to make a request by having them execute a power of attorney to act on your behalf, or provide them with a signed letter of permission. Certain exceptions may apply to your request or you may not be eligible. If you are a California resident, we will not discriminate against you because you have exercised any of your rights under the California Consumer Privacy Act. 

Certain additional rights exist if European law applies. If you reside in the EEA, UK, or Switzerland, you may have certain rights in addition to those described above. This may include requesting a portable copy of your information. It may also include requesting that we restrict how we process your information. It may also include if you object to profiling or direct marketing. You can also withdraw your consent (see choices section, above, for details.) You may also be able to object to having your information used for other purposes. You also have the right to direct complaints about our privacy practices to your local Data Protection Authority. To exercise your rights, you can contact us as noted below.

Sales of information. Under California law we are required to tell California residents if we “sell” information as that term is defined by applicable law. Sell means to share personal information with a third party for monetary or other valuable consideration. California residents, we do not do this based on our understanding of that term. We do not sell personal information of minors under the age of 16. We also have disclosure obligations in Nevada. There, we do not exchange Nevada residents’ personal information for money. Nevada residents may opt out of the future sale of their information to a third party so that they may license or sell information by contacting us as described below.

Notice of Right to Opt-out of Sale/Sharing for Cross-Contextual Behavioral Advertising: You can opt out of the sharing of your personal information for cross-contextual behavioral advertising by clicking here. Some browsers also allow you to tell websites not to share your information for cross-contextual behavioral advertising. We will respond to these signals in a frictionless manner. If you configure this setting on your browser, certain features on our site may not work and you will receive less targeted advertising. To learn how to configure this setting, view here.

Our Website and App is Not Intended for Children

Our sites and apps are meant for adults. We do not knowingly collect personally identifiable information from children under 13. If you are a parent or legal guardian and think your child under 13 has given us information, you can write to us or email us at the addresses provided at the end of this policy. Please mark your inquiries “COPPA Information Request.” Parents, you can learn more about how to protect children’s privacy on-line here.

We Use Reasonable Security Measures 

We use reasonable security measures as required by relevant law. The Internet is not 100% secure. We cannot promise that your use of our sites will be completely safe. We encourage you to use caution when using the Internet. This includes not sharing your passwords.

We Store Information in the United States

Information we collect may be stored in the United States. If you live outside of the United States and choose to use LifeDojo or our sites and apps, you understand that it is at your own risk. You also understand that your information will be sent to the United States. The United States may not afford the same level of protection as laws in your own country. We keep personal information as long as it is necessary or relevant for the practices described in this Policy. We also keep information as otherwise required by law. 

By submitting your information to us, you agree to the processing of it in the United States as permitted by law. Information we transfer from Europe to the United States will be subject to appropriate safeguards under applicable law.

Links to Third Party Sites

We may link to third-party sites or apps. Our website or app may also include third party content that collects information. We do not control these third parties. This policy does not apply to the privacy practices of these third-party websites or apps. Please read the privacy policies of other websites carefully. We are not responsible for the practices of these third-party sites or apps.

Contact Us

If you have questions the Privacy Policy, you can email us at complianceteam@ontrakhealth.com or call the business number on the LifeDojo website, lifedojo.com

You may be eligible to exercise certain rights requests depending on where you reside. Please contact us at complianceteam@ontrakhealth.com to make a request. For the purposes of applicable data protection laws, LifeDojo, Inc. is the controller of the personal information you provide to us.

Updates

From time to time we may change our privacy policies. We will notify you of any material changes to our Policy as required by law. We will also post an updated copy on the sites where this appears. Please check our website periodically for updates.