JOOL Privacy Notice

Welcome to JOOL Health! The JOOL Health mobile application, website and the Customer Reporting and Insights Dashboard (the “Dashboard”), including all the tools, services, content and information available on or through the application, the website and the Dashboard (including access to and information available through joolhealth.com and joolapp.com and information in your JOOL account, if you have one) is a service made available by JOOL Health Inc.

Application of this Privacy Notice

 

This Privacy Notice (“Privacy Notice”) describes how we collect, use, store, disclose, and dispose of the information you (“User” or “you”) provide to us when you use the JOOL Health services, either through the Website, the Mobile App or the Dashboard.

 

The Application, the Website and the Dashboard are owned and operated by JOOL Health Inc. or one or more of its direct or indirect affiliates (collectively, the “JOOL Health", “we” or “us”). The JOOL website is referred to in this Privacy Notice as the “JOOL Site", “Website” or “Site”. The JOOL mobile application is referred to in this Privacy Notice as the “JOOL Mobile App”, “JOOL App”, “JOOL” or “App”. The JOOL Mobile App, the Website and the Dashboard are referred to together as “JOOL”.

 

This Notice applies only to information we collect in the App, the Website, the Dashboard and in e-mail, text and other electronic communications sent through or in connection with the App, the Website and/or the Dashboard.

 

This Notice DOES NOT apply to information that:

  • We collect offline or on any other apps or websites, including websites you may access through JOOL.

  • You provide to, or is collected by, any third party (see below Third-Party Information Collection).

  • Any other sources.

 

Such third parties may have their own privacy policies, which we encourage you to read before providing information on or through them.

 

Please read this Privacy Notice carefully to understand our policies and practices regarding your information and how we will treat it. By using any part of JOOL, you understand and agree that we are providing a platform for you to post content and other materials to JOOL. If you do not agree with our policies and practices, do not download, install, register with, access or use JOOL. By downloading, installing, registering with, accessing or using JOOL, you agree to this Privacy Notice. This Privacy Notice may change from time to time (see below “Changes to Our Privacy Notice”). Your continued use of JOOL after we make changes is deemed to be acceptance of those changes, so please check the Notice periodically for updates. Notwithstanding the foregoing, if we make material changes to this Notice, we will post a notice of such changes in accordance with the paragraph below entitled “Changes to Our Privacy Notice”.

Information We Collect and How We Collect

We collect information through JOOL both directly from you when you provide it to us, and also automatically when you use JOOL. Below are more details about each type of information we collect.

 

Information You Provide to Us

When you use JOOL, you may provide us with different kinds of information, including personal information. “Personal Information” is information that identifies you, and includes things like your name or e-mail address, but also information that, when used together, could potentially be used to identify you, such as age, gender, and educational information. You do not have to give us any Personal Information, but if you don’t, some or all of JOOL’s functionalities might not work as intended. Again, it’s completely optional for you to use JOOL and to provide us your information.

The following are samples of the kinds of information we collect, and how we use that information. For example, we request information from you:

  • When you sign up for a JOOL account
     

  • When you use JOOL to compose a purpose and define your values
     

  • When you use JOOL to record information such as your energy, will-power, sleep, presence, creativity, eating or alignment.
     

  • When the JOOL app asks for permission to send you notifications or access the location of your device

 

Information Collected Automatically

Additionally, we collect other information automatically that is about you and your use of JOOL. In some cases, such automatically collected information may be Personal Information (e.g., your device’s unique device identifier, or your IP address). In other cases, we automatically collect information that does not identify you (“Anonymous Information”). This Anonymous Information might be collected on a group basis, to measure use of JOOL. When you browse JOOL or download information, we may automatically collect and store the following kinds of information:

  • Device Information. We may collect information about the type of browser, device and operating system used, and type of mobile device and internet connection, including mobile network information, etc.
     

  • Usage Details. We may collect the date and time you visited JOOL, the web pages or services you accessed through JOOL (or the website you visited prior to coming to JOOL), traffic data, logs and the resources that you access and use on or through JOOL.
     

  • Location Information. We may collect real-time information about the location of your mobile device.

In some of the cases above, if you do not want us to collect such information you may opt out at any time by changing your privacy preferences within JOOL, or by adjusting your browser settings. For more information, see below Your Choices about Our Collection, Use and Disclosure of Your Information. Note, however, that in some cases (e.g., the collection of Anonymous Information) the only way to prohibit collecting such information is to stop using JOOL. Additionally, opting out JOOL’s collection of location information will cause its location-based features to be inaccurate or not work as intended.

We also may collect information about your activities over time and across third-party websites, apps or other online services (e.g., behavioral tracking). For information on how you can opt out of behavioral tracking on or through JOOL and how we respond to browser signals and other mechanisms that enable consumers to exercise choice about behavioral tracking, see below Your Choices about Our Collection, Use and Disclosure of Your Information.

 

Technologies Used to Collect Information

We may serve “cookies” when you use JOOL. A “cookie” is a small computer file stored on your computer that’s used to provide you with tailored information. We use cookies to analyze how frequently you visit and help improve your overall experience with us.

Third-Party Information Collection

Additionally, certain third parties (such analytics companies and your mobile service provider) may use tracking technologies to collect information about you when you use JOOL. 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.

We do not control these third parties’ tracking technologies or how they may be used.

How We Use the Information We Collect From You

We use the information you provide, and that we collect, to enable and enhance JOOL functionality. We may also use your information to:

  • Communicate with you about your account and send you information about JOOL features
     

  • Communicate with you about changes to our policies
     

  • Personalize content and experiences in JOOL for you
     

  • Send you newsletters, surveys, offers and promotions for our products and services, or special events by e-mail or other another medium
     

  • Optimize or improve our products, services and operations
     

  • Detect, investigate, and prevent activities that may violate our policies or be illegal
     

  • Perform statistical, demographic, and site use analyses of users of JOOL and their workflow patterns
     

  • Estimate our audience size and usage patterns. We analyze this information to help make JOOL more useful, and for the following reasons:

    • To determine the number of visitors

    • To count the number of times files are downloaded and web pages are accessed

    • To identify system performance problems

    • To find errors in problem pages and files

    • To review the types of technology visitors are using

    • To maintain a secure website

  • ​Evaluate the impact of JOOL, for example, by combining JOOL data with data from other sources to evaluate outcomes

Please note, these are only examples and there are other potential kinds of data collected and other uses made of such data. Occasionally, we may also use your information to notify you about important changes to JOOL, including new services or new information we think you might find valuable. If you don’t wish to receive mailings or receive information by mistake, please contact us by e-mail and request removal from the mailing list at the following e-mail address: support@joolhealth.com

 

Disclosure and Retention of Your Information

The Anonymous Information we collect is not reported or used in any manner that would reveal personally identifiable information, and will not be released to outside parties unless it’s permitted or required by law.

We may disclose aggregated, anonymous information about our users, and information that does not identify any individual, without restriction. We may also share aggregated, anonymous or individual, anonymous usage information with 3rd party research partners for the purpose of helping us improve our analytic and engagement techniques, for research into mobile engagement, or for research into the role “Purpose” can play in positively impacting lives and/or communities.

In addition, we may disclose Personal Information that we collect or you provide:

  • To our subsidiaries and affiliates
     

  • To contractors, service providers and other third parties we use to support our business. For example, we use certain trusted business partners who assist us in operating JOOL, conducting our business, or servicing you. These business partners may have access to the information that we collect through JOOL, but only if they agree to keep this information confidential and not use it for their independent business purposes.
     

  • To a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution or other sale or transfer of some or all of JOOL Health’s’ assets, whether as a going concern or as part of bankruptcy, liquidation or similar proceeding, in which personal information held by JOOL about our Users is among the assets transferred.
     

  • To fulfill the purpose for which you provide it.
     

  • For any other purpose disclosed by us when you provide the information.
     

  • With your consent.
     

  • To comply with any court order, law or legal process, including responding to any government or regulatory request.
     

  • To enforce our rights arising from any contracts entered into between you and us, including the App EULA and for billing and collection.
     

  • If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of our customers or others. This includes exchanging information with other companies and organizations (including applicable law enforcement) for the purposes of fraud protection and credit risk reduction.

 

We may release personal and account information when we believe it’s appropriate to do so to comply with law, with other agreements, or to protect the rights, property, or safety of JOOL Health or others. We will not sell, share, or rent this information to others in ways different from what is disclosed in this Privacy Notice. We won’t trade, rent or sell your Personal Information. We use personal information you provide and we collect for the purposes of making products and services available to you.

If access to JOOL is being offered to you through an organization that provided you with a group code, invitation or is otherwise sponsoring your account (“Sponsor Organization”), we won’t share your personally identifiable information with that Sponsor Organization without your express permission. We may, however, share aggregated group and anonymized individual information with the Sponsor Organization including via the Dashboard. Aggregate information means your data is combined with that of other users so that it’s impossible to identify individual responses. Anonymized information may include individual details but has all identifiable details (e.g., name, email address) removed. We may also share, with the Sponsor Organization or a 3rd party identified by said Sponsor Organization who is acting on its behalf, individually identified usage information such as whether you created an account, how many times you charted, and what features of the application you used and how often, for the purposes of program evaluation or incentive tracking; information shared will not include any individually identified health information. Your Sponsor Organization can provide information about 3rd party organizations.  We may also send you emails on the Sponsor Organization’s behalf with requests to complete surveys about your experience using JOOL and with other information related to your use of JOOL. If you’re not comfortable with our sharing your anonymized information with the Sponsor Organization, don’t create an account.

If you correspond with us through email we may retain the content of your messages, together with your email address(es) and our responses. Email communications from joolhealth.com and related websites may not be encrypted and this information may not be secured. Like many transmissions over the Internet, it’s possible for these communications to be intercepted or accessed without your authorization. Consequently, we suggest not sharing highly sensitive information with us via email. We also receive and store information you enter into JOOL.

From time to time we may share aggregated group information that doesn’t personally identify you with agents, contractors or affiliates of ours for the purpose of providing services to us. We may also share this information with our partners.

 

Your Choices about Our Collection, Use and Disclosure of Your Information

We strive to provide you with choices regarding the Personal Information you provide to us. This section describes mechanisms we provide for you to control certain uses and disclosures of your information.

  • Tracking Technologies. You can set your browser to refuse all or some browser cookies, or to alert you when cookies are being sent. You can choose whether or not to allow JOOL to collect information through other tracking technologies by updating your privacy settings in JOOL or by adjusting your browser’s privacy settings, as applicable. If you disable or refuse cookies or block the use of other tracking technologies, some parts of JOOL may then be inaccessible or not function properly.
     

  • Location Information. You can choose whether or not to allow JOOL to collect and use real-time information about your device’s location through the device’s settings. If you block the use of location information, some parts of JOOL may then not function properly. Additionally, in order to use JOOL, you are required to enter a valid zip code. If you wish not to enter your own zip code, but rather, a random zip code, JOOL’s functionality might be based on geographic data that is not relevant to you.

 

Accessing and Correcting Your Personal Information

You can review and change your Personal Information by logging into JOOL and visiting your account profile page, or you may also send us an e-mail at support@joolhealth.com to request access to, correct or delete any Personal Information that you have provided to us. In many cases, we cannot delete your Personal Information except by also deleting your user account. We may not accommodate a request to change information if we believe the change would violate any law or legal requirement or cause the information to be incorrect.

 

Data Security

JOOL Health has taken steps to protect the data in its possession and prevent unauthorized access. These measures are designed to prevent corruption of data, block unknown or unauthorized access or alteration to, and use or disclosure of, our systems and information, and provide reasonable protection of private information in our possession. Unauthorized attempts to upload information or change information available through JOOL are illegal and are strictly prohibited.

The safety and security of your information also depends on you. Where you have chosen a password for access to certain parts of JOOL, you are responsible for keeping this password confidential. We ask you not to share your password with anyone.

No data transmission over the Internet can be guaranteed to be 100% secure. While we try to protect your information from unauthorized access, use or disclosure, JOOL Health cannot guarantee the security of any information you transmit to us through the Internet.

Again, by using JOOL, you agree to this Privacy Notice. If you don’t agree to this Privacy Notice, please do not use JOOL.

 

Changes to Our Privacy Notice

We reserve the right to modify this Privacy Notice from time to time. If we make material changes to how we treat our users’ personal information, we will post the new Privacy Notice with a notice that the Privacy Notice has been updated. Your continued use of JOOL following the posting of changes to this Privacy Notice will mean you accept those changes. The date the Privacy Notice was last revised is identified at the top of the page. You are responsible for ensuring we have an up-to-date active and deliverable e-mail address for you and for periodically visiting this Privacy Notice to check for any changes.

 

ADDITIONAL INFORMATION REGARDING THE CHILDREN’S ONLINE PRIVACY PROTECTION ACT

JOOL is intended for use by adults, and not intended for children under 13 years of age. It’s not our intention to collect personally identifiable information about children, and we do not knowingly collect personal information from children under 13 years of age. If you’re under 13 years of age you shouldn’t use JOOL. If you’re a parent/guardian who believes we have collected personally identifiable information about your child under age 13, please contact us immediately at support@joolhealth.com with the child’s name and email address, and we will be happy to delete any personally identifiable information about your child from our records and provide information in accordance with the Children’s Online Privacy Protection Act. Additionally, if we learn we have collected or received personal information from a child under 13 years of age without verification of parental consent, we will delete that information.

 

Your California Privacy Rights

California Civil Code Section 1798.83 permits users of JOOL that are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please send an e-mail to support@joolhealth.com. Additionally, CalOPPA requires us to disclose how we respond to “do-not-track” requests from our users. At this time, we do not currently respond to “do-not-track” requests from our users.

 

Questions?

Have questions or feel we are not abiding by this Privacy Notice? Please contact us by e-mail at the following e-mail address: support@joolhealth.com.

 

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Last modified: January 13, 2017