Psychotechnology, Inc., a New York corporation (“Company”, “LQ”, “we” or “us” or “our”) and its subsidiaries, parents and affiliated companies respects the privacy of its users (“User” or “you”), that use our mobile application, Lifestyle Intelligence (“Application”).
For EEA users: We only send marketing communications to users located in the EEA with your prior consent. Please see the section “For EEA users” below.
GATHERING, USE AND DISCLOSURE OF NON-PERSONALLY-IDENTIFYING INFORMATION
Users of the Application Generally
“Non-Personally-Identifying Information” is information that, without the aid of additional information, cannot be directly associated with a specific person. “Personally-Identifying Information,” by contrast, is information such as a name or email address that, without more, can be directly associated with a specific person. Like most mobile application operators, the Company gathers from users of the Application Non-Personally-Identifying Information of the sort that web browsers and applications, depending on their settings, may make available. That information includes the user’s Internet Protocol (IP) address, operating system, browser type and the locations of the Application the user views right before arriving at, while navigating and immediately after leaving the Application, as more fully described herein. Although such information is not Personally-Identifying Information, it may be possible for Company to determine from an IP address a user’s Internet service provider and the geographic location of the user’s point of connectivity as well as other statistical usage data. Company may analyze Non-Personally-Identifying Information gathered from users of the Application to help the Company better understand how the Application is being used. By identifying patterns and trends in usage, Company is able to better design the Application to improve users’ experiences, both in terms of content and ease of use. From time to time, Company may also release the Non-Personally-Identifying Information gathered from Application users in the aggregate, such as by publishing a report on trends in the usage of the Application.
We also collect User Content. “User Content” is defined as all text, documents, or other content or information uploaded, entered, or otherwise transmitted by you to us in connection with your use of the Application.
Automatically Collected Information
Certain data about the devices you use to connect with our Application and your use of the Application are automatically logged in our systems, including:
Mobile Device Information. When you use a mobile Device to access the Application or download any of our applications, we may collect device information (such as your mobile device ID, model and manufacturer), operating system, version information and IP address.
Log data. As with most application and technology services delivered over the internet, our servers automatically collect data when you access or use our Application and record it in log files. This log data may include the IP address, browser type and settings, the date and time of use, information about browser configuration, language preferences, and cookie data.
Usage information. This is information about the Application and how you use it. We may also obtain data from our third-party partners and service providers to analyze how users use our Application. For example, we will know how many users access a specific page on the Application and which links they clicked on. We use this aggregated information to better understand and optimize the Application.
Device information. These are data from your computer or mobile device, such as the type of hardware and software you are using (for example, your operating system and browser type), as well as unique device identifiers for devices that are using our software.
Cookies are small text files stored on your Device and used to deliver personalized content and remember logins and account settings. The Company may Cookies and similar technologies, including tracking pixels and web beacons, to collect usage and analytic data that helps us provide our Application to you, as well as to help deliver ads for relevant products and services to you when you visit certain pages on the Application and then visit certain third-party sites.
A “Web Beacon” is an object that is embedded in a page of the Application or our emails that is usually invisible to the user and allows application operators to check whether a user has viewed a particular page or an email. Company may use Web Beacons on the Application and in emails to count users who have visited particular pages, viewed emails and to deliver co-branded services. Web Beacons are not used to access users’ Personally-Identifying Information. They are a technique that the Company may use to compile aggregated statistics about Application usage. Web Beacons collect only a limited set of information, including a number, time and date of a page or email view and a description of the page or email on which the Web Beacon resides. You may not decline Web Beacons. However, they can be rendered ineffective by declining all Cookies or modifying your Device settings to notify you each time a Cookie is tendered, permitting you to accept or decline Cookies on an individual basis.
We may use third-party vendors, including Google, who use first-party Cookies (such as the Google Analytics cookie) and third-party Cookies (such as the DoubleClick cookie) together to inform, optimize and serve ads based on your past activity on the Application, including Google Analytics for Display Advertising. The information collected may be used to, among other things, analyze and track data, determine the popularity of certain content and better understand online activity. If you do not want any information to be collected and used by Google Analytics, you can install an opt-out in your web browser (https://tools.google.com/dlpage/gaoptout/) and/or opt out from Google Analytics for Display Advertising or the Google Display Network by using Google’s Ads Settings (www.google.com/settings/ads).
Aggregated and Non-Personally-Identifying Information
We may share aggregated and Non-Personally Identifying Information we collect under any of the above circumstances. We may also share it with third parties and our affiliate companies to develop and deliver targeted advertising on the Application and on websites of third parties. We may combine Non-Personally Identifying Information we collect with additional Non-Personally Identifying Information collected from other sources. We also may share aggregated information with third parties, including advisors, advertisers and investors, for the purpose of conducting general business analysis. For example, we may tell our advertisers the number of visitors to the Application and the most popular features or services accessed. This information does not contain any Personally-Identifying Information and may be used to develop application content and services that we hope you and other users will find of interest and to target content and advertising.
Additional Terms for Mobile Device Users
A. Geo-Location Information.
Unless we have received your prior consent, we do not access or track any location-based information from your mobile device at any time while downloading or using the Application, except that it may be possible for Company to determine from an IP address the geographic location of your point of connectivity, in which case we may gather and use such general location data.
B. Push Notifications.
C. Mobile Analytics.
We use mobile analytics software to allow us to better understand the functionality of our mobile software on your phone. This software may record information, such as how often you use the application, the events that occur within the application, aggregated usage, performance data and where the application was downloaded from. We do not link the information we store within the analytics software to any Personally-Identifying Information you submit within the mobile application.
D. Social Media
We may use hyperlinks on the Application which will redirect you to a social network if you click on the respective link. However, when you click on a social plug-in, such as Facebook’s “Like” button, Instagram’s “follow” button, Twitter’s “tweet” button or the Google+, that particular social network’s plugin will be activated, and your browser will directly connect to that provider’s servers. If you do not use these buttons, none of your data will be sent to the respective social network’s plugin provider. So for example, when you click on the Facebook’s “Like” button on the Application, Facebook will receive your IP address, the browser version and screen resolution, and the operating system of the device you have used to access the Application. Settings regarding privacy protection can be found on the website or applications of these social networks and are not within our control.
COLLECTION, USE AND DISCLOSURE OF PERSONALLY-IDENTIFYING INFORMATION
As defined above, Personally-Identifying Information is information that can be directly associated with a specific person. Company may collect a range of Personally-Identifying Information from and about Application users. Much of the Personally-Identifying Information collected by Company about users is information provided by users themselves when (1) registering for our service, (2) logging in with social network credentials, (3) participating in polls, contests, surveys or other features of our service, or responding to offers or advertisements, (4) communicating with us, (5) creating a public profile or (6) signing up to receive newsletters. That information may include each user’s name, address, email address and telephone number, and, if you transact business with us, financial information such as your payment method (valid credit card number, type, expiration date or other financial information). We also may request information about your interests and activities, your gender, age, date of birth, username, hometown and other demographic or relevant information as determined by the Company from time to time. Users of the Application are under no obligation to provide Company with Personally-Identifying Information of any kind, with the caveat that a user’s refusal to do so may prevent the user from using certain Application features. BY REGISTERING WITH OR USING THE APPLICATION, YOU CONSENT TO THE USE AND DISCLOSURE OF YOUR PERSONALLY-IDENTIFYING INFORMATION AS DESCRIBED IN THIS “COLLECTION, USE AND DISCLOSURE OF PERSONALLY-IDENTIFYING INFORMATION” SECTION.
We may occasionally use your name and email address to send you notifications regarding new services offered by the Application that we think you may find valuable. We may also send you service-related announcements from time to time through the general operation of the Application. Generally, you may opt out of such emails at the time of registration or through your account settings, if available, though we reserve the right to send you notices about your account, such as service announcements and administrative messages, even if you opt out of all voluntary email notifications.
We will disclose Personally-Identifying Information under the following circumstances:
A. By Law or to Protect Rights.
When we believe disclosure is appropriate, we may disclose Personally-Identifying Information in connection with efforts to investigate, prevent or take other action regarding illegal activity, suspected fraud or other wrongdoing; to protect and defend the rights, property or safety of Company, our users, our employees or others; to comply with applicable law or cooperate with law enforcement; to enforce our agreements or policies, in response to a subpoena or similar investigative demand, a court order or a request for cooperation from a law enforcement or other government agency; to establish or exercise our legal rights; to defend against legal claims; or as otherwise required by law. In such cases, we may raise or waive any legal objection or right available to us.
B. Marketing Communications.
Unless users opt-out from receiving Company marketing materials upon registration, Company may email users about products and services that Company believes may be of interest to them. If you wish to opt-out of receiving marketing materials from Company, you may do so by following the unsubscribe link in the email communications, by going to your account settings (if applicable) or contacting us using the contact information below.
C. Third-Party Service Providers.
We may share your Personally-Identifying Information, which may include your name and contact information (including email address) with our authorized service providers who perform services on our behalf. These services may include fulfilling orders, providing customer service and marketing assistance, performing business and sales analysis, supporting the Application’s functionality and Content, and supporting other features offered through the Application. We may also share your name, contact information and credit card information with our authorized service providers who process credit card payments. These service providers may have access to personal information needed to perform their functions but are not permitted to share or use such information for any other purpose.
D. Business Transfers; Bankruptcy.
Changing Personally-Identifying Information; Account Termination
You may at any time review or change your Personally-Identifying Information by going to your account settings (if applicable) or contacting us using the contact information below. Upon your request, we will deactivate or delete your account and contact information from our active databases. Such information will be deactivated or deleted as soon as practicable based on your account activity and accordance with our deactivation policy and applicable law. To make this request, either go to your account settings (if applicable) or contact us as provided below. We will retain in our files some Personally-Identifying Information to prevent fraud, to troubleshoot problems, to assist with any investigations, to enforce our to comply with legal requirements as is permitted by law. Therefore, you should not expect that all your Personally-Identifying Information will be completely removed from our databases in response to your requests. Additionally, we keep a history of changed information to investigate suspected fraud with your account.
Collection and Use of Information by Third Parties Generally
When you use the Application or its content, certain third parties may use automatic information collection technologies to collect information about you or your device. These third parties may include:
- Advertisers, ad networks, and ad servers.
- Analytics companies.
- Your mobile device manufacturer.
- Your mobile service provider.
These third parties may use tracking technologies to collect information about you when you use this app. The information they collect may be associated with your personal information or they may collect information, including personal information, about your online activities over time and across different websites, apps, and other online services websites. They may use this information to provide you with interest-based (behavioral) advertising or other targeted content.
We do not control these third parties’ tracking technologies or how they may be used. If you have any questions about an advertisement or other targeted content, you should contact the responsible provider directly.
We take the security of your Personally-Identifying Information seriously and use reasonable electronic, personnel and physical measures to protect it from loss, theft, alteration or misuse. However, please be advised that even the best security measures cannot fully eliminate all risks. We cannot guarantee that only authorized persons will view your information. We are not responsible for third-party circumvention of any privacy settings or security measures.
We use industry-standard encryption to protect your data in transit. This is commonly referred to as transport layer security (“TLS”) or secure socket layer (“SSL”) technology. Once we receive your data, we protect it on our servers using a combination of technical, physical, and logical security safeguards. The security of the data stored locally in any of our software installed on your computing device requires that you make use of the security features of your device. We recommend that you take the appropriate steps to secure all computing devices that you use in connection with our Application.
We are dedicated to protecting all information on the Application as is necessary. However, you are responsible for maintaining the confidentiality of your Personally-Identifying Information by keeping your password confidential. You should change your password immediately if you believe someone has gained unauthorized access to it or your account. If you lose control of your account, you should notify us immediately.
CHILDREN’S ONLINE PRIVACY
The Children’s Online Privacy Protection Act (“COPPA”) protects the online privacy of children under 13 years of age. The Application is not intended for children under 13 years of age and we do not knowingly collect or maintain Personally-Identifying Information from anyone under the age of 13, unless or except as permitted by law. Any person who provides Personally-Identifying Information through the Application represents to us that he or she is 13 years of age or older. If we learn that Personally-Identifying Information has been collected from a user under 13 years of age on or through the Application, then we will take the appropriate steps to cause this information to be deleted. If you are the parent or legal guardian of a child under 13 who has become a user of the Application or has otherwise transferred Personally-Identifying Information to the Application, please contact Company using our contact information below to have that child’s account terminated and information deleted.
NOTICE TO NEVADA RESIDENTS
Nevada law allows consumers to direct certain businesses not to sell their personally identifiable information collected on a business’s platform or other online service to third parties to license or sell that information to additional third parties. If you are a Nevada resident, you may submit such opt-out requests by email at email@example.com. To be effective, your request must include your full name, address, phone number, and email address to verify the authenticity of your request.
ADDITIONAL RIGHTS AND CHOICES FOR CALIFORNIA RESIDENTS
If you are a California resident, the following additional rights may be available to you.
Shine the Light
Users who are California residents may request (i) a list of categories of personal information disclosed to third parties during the immediately preceding calendar year for those third parties’ own direct marketing purposes; and (ii) a list of the categories of third parties to whom we disclosed such information. To exercise a request, please send us an email or a letter to the addresses in the section entitled “Contact Us” below and specify you are making a “California Shine the Light” request. We may require additional information from you to allow us to verify your identity and are only required to respond to requests once during any calendar year.
California Consumer Privacy Act of 2018 (CCPA)
Beginning January 1, 2020, the CCPA provides California residents with additional rights as described below. Please note your right to know and right to delete are subject to certain exceptions under the CCPA.
Notice of Collection
During the past twelve (12) months, we have collected the following categories of personal information that the CCPA covers:
- Identifiers, including name, email address, date of birth, phone number, account name, IP address, and an ID or number assigned to your account.
- Consumer records, billing and delivery address, and credit or debit card information.
- Commercial information, including purchases and engagement with our platforms and mobile applications.
- Internet activity, including your interactions with our platforms and mobile applications.
- Audio data, including information collected for customer care quality assurance.
- Geolocation data, including location enabled services such as GPS.
- Inferences, including information about your interests, preferences and favorites.
Right to Know
You have the right to know certain information about our data practices in the preceding twelve (12) months. You have the right to request the following information from us:
- The categories of personal information we have collected about you;
- The categories of sources from which the personal information was collected;
- The categories of personal information about you we disclosed for a business purpose or sold;
- The categories of third parties to whom the personal information was disclosed for a business purpose or sold;
- The business or commercial purpose for collecting or “selling” the personal information; and
- The specific pieces of personal information we have collected about you.
Right to Delete
You have the right to request the deletion of personal information that we collect or maintain about you and your account.
Right to Opt-Out of “Sale”
Company does not sell information as the term “sell” is traditionally understood. However, Company may disclose certain information about you when you use our Application for purposes that may be considered a “sale” under the CCPA. For example, we may disclose information to advertising partners, advertising technology companies, and companies that perform advertising-related services in order to provide you with more relevant advertising tailored to your interests. This information may include identifiers such as your IP address, advertising identifiers, commercial information, your internet or other electronic network information such as your interaction with an ad, geolocation data and inferences. To the extent Company sells your personal information as the term “sell” is defined under the CCPA, you have the right to opt-out of the sale of your personal information by us to third parties at any time. You may submit a request to opt-out by clicking Do Not Sell My Personal Information, where applicable, and following the instructions, or by contacting us as set forth below.
How to Exercise Your CCPA Rights
To exercise any of these rights, please click here to contact us. 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 ten (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.
If you choose to exercise any of these rights, you will not receive different prices or quality of services unless permitted by applicable law, including if those difference are reasonable related to your information.
Please note that if you opt out of receiving marketing communications from us, we may still send communications to you about your transactions, any accounts you have with us, and any contests, competitions, prize draws or sweepstakes you have entered. Opting out of one form of communication does not mean you’ve opted out of other forms as well. For example, if you opt out of receiving marketing emails, you may still receive marketing text messages if you’ve opted in to receiving them.
If you wish to exercise any of the rights set above, please contact us by email at firstname.lastname@example.org or at the address below. See the “Contact Us” section below. We will need you to provide specific information to help us confirm your identity. This is a security measure to help ensure that your personal information is not disclosed to someone that does not have the right to receive it.
FOR EEA USERS
Users located in the European Economic Area (EEA) have certain rights in respect to their personal information, including the right to access, correct, or delete Personally-Identifying Information we process through your use of the Application. If you’re a user based in the EEA, you can:
- Request a Personally-Identifying Information report by submitting a support ticket through your user account. This report will include the Personally-Identifying Information we have about you, provided to you in a structured, commonly used, and portable format. You must be signed into your user account to submit this request. Please note that the Company may request additional information from you to verify your identity before we disclose any information.
- Have your Personally-Identifying Information corrected or deleted. Some Personally-Identifying Information can be updated by you. You can update your name and email address, as well as language preference, through your user account settings. If you registered for the Application using Google or Facebook, or if you otherwise have problems updating this information, please contact us. You can remove your Personally-Identifying Information from the Application by deleting your user account.
- Object to us processing your Personally-Identifying Information. You can ask us to stop using your Personally-Identifying Information, including when we use your Personally-Identifying Information to send you marketing emails. We only send marketing communications to users located in the EEA with your prior consent, and you may withdraw your consent at any time by clicking the “unsubscribe” link found within our emails and changing your contact preferences. Please note you will continue to receive transactional messages related to our service, even if you unsubscribe from marketing emails.
- Complain to a regulator. If you are based in the EEA and believe that we have not complied with data protection laws, you have a right to lodge a complaint with your local supervisory authority.
Most web browsers and some mobile operating systems include a Do-Not-Track (“DNT”) feature or setting you can activate to signal your privacy preference not to have data about your online browsing activities monitored and collected. Because there is not yet a common understanding of how to interpret the DNT signal, the Application currently does not respond to DNT browser signals or mechanisms.
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Last Updated: June 25, 2020