This Privacy Policy governs our data collection, processing and usage practices. It also describes your choices regarding use, access and correction of your personal information. If you do not agree with the data practices described in this Privacy Policy, you should not use our Services.

Specifically, this Privacy Policy covers:

(a)  Information we collect about you: We may collect Personal Information, Usage and Device Information (collectively, “information,” defined in detail below).

(b) How we use your information: We use the information we collect only in compliance with this Privacy Policy.

(c) How we share your information: We may share your information with our business units, affiliates, subsidiaries, business partners, service providers and/or your representatives, in order to provide or improve our Services to you and certain others as described in detail below.

Your rights regarding your personal information

We provide you with the opportunity to be informed of whether we are processing your information and to access, correct, update, oppose, delete, block, limit or object, upon request and free of charge, to our use of your Personal Information to the extent required by applicable law.

Retention of your information

We keep your account information, like your name, email address, and password, for as long as your account is in existence because we need it to operate your account. In some cases, when you give us information for a feature of the Services, we delete the data after it is no longer needed for the feature. We keep your account data until you use your account settings or tools to delete the data or your account because we use this data to provide you Services. We also keep information about you and your use of the Services for as long as necessary for our legitimate business interests, for legal reasons, and to prevent harm, including as described in the How We Use Your Information and How We Share Your Information sections.

Security of your information

We work hard to keep your data safe. We use a combination of technical, administrative, and physical controls to protect the confidentiality, integrity and availability of your data.  No method of transmitting or storing data is completely secure, however. If you have a security-related concern, please contact Customer Support.

Cookies and similar technologies

We may use “cookies” and similar technologies to help deliver our Services. This technology may involve placing small files/code on your device or browser that serve a number of purposes, such as remembering your preferences and offering you a more personalized user experience.

Marketing analytics and communications

We may collaborate with partners who provide us with marketing analytics and communications services. This includes helping us understand how users interact with our Services, communicating with you about our Services and features, and measuring the performance of those communications. These companies may use cookies and similar technologies to collect information about your interactions with the Services and other websites and applications. To learn more about your privacy choices, please see more details in the How We Use Your Information and How We Share Your Information sections.

Links to other websites

Our Services may contain links to other websites or services that we do not own or control, including links to websites of our sponsors and partners. This Privacy Policy only applies to information collected by our Services. We have no control over these third-party websites, and your use of third party websites and features are subject to privacy policies posted on those websites. We are not responsible or liable for the privacy or business practices of any third-party websites linked to our Services. Your use of third parties’ websites linked to our Services is at your own risk, so we encourage you to read the privacy policies of any linked third-party websites when you leave one of our Services.

Our policies for children

Our Services are directed toward adults. If you are under the age of 16, you must obtain the authorization of a responsible adult (parent or legal custodian) before using or accessing our Services. We will not knowingly collect or use any personal information from any children under the age of 16. If we become aware that we have collected any personal information from children under 16, we will promptly remove such information from our systems.

Situations where this policy does not apply

This Privacy Policy does not apply to the extent that: Our products and services set forth an additional or alternative Privacy Policy; or Applicable law imposes different processing or privacy requirements on your information.

Changes to this privacy policy

We periodically update this Privacy Policy. We will post any privacy policy changes on this page and, if the changes are significant, we will provide a more prominent notice by sending you notification by email or notification alert within our Services. While we will notify you of any material changes to this Privacy Policy, we encourage you to review this Privacy Policy periodically. We will also keep prior versions of this Privacy Policy in an archive for your review.

Information we collect about you

When you use our Services, we collect the following types of information.

Information you provide us (“Personal Information”)

Account information. Some information is required to create an account on Services, such as your

• name
• email address
• password
• company
• phone number
• financial information such as, bank account and routing numbers, credit and debit card information, other financial information
• other information necessary to establish an account or profile
• mailing address
• country information
• date of birth
• additional contact phone numbers such as your mobile telephone number,

If you contact us or participate in a survey, contest, or promotion, we collect the information you submit such as your name, email address, contact information, and message.

Information from third-party services:

If you choose to connect your account on our Services to your account on another service, we may receive information from the other service. You can stop sharing the information from the other services with us by removing our access to each other service.

Information provided by other individuals

While using our Services, individuals may provide information about another individual, or an authorized user (such as an account administrator) creating an account on your behalf may provide information about You. When one individual provides us with information (including personal information) about another individual, we assume that the individual has permission and authority to do so and to consent on behalf of that individual to the collection and use of personal information as described in this Privacy Policy. Please contact us immediately if you become aware of an individual providing us with personal information about another individual without being authorized to do so, and we will act consistently with this Privacy Policy.

Information we receive from your use of our services

Usage and device information: When you use our Services, we receive certain usage data (“Usage and Device Information”). This includes information about your interaction with the Services, for example, when you view or search content, install or open applications or software, create or log into your account, import data into your account, or integrate a third-party service to your account. We may also collect data about the devices and computers you use to access our Services, including IP addresses, browser type, language, operating system, or mobile device information (including device and application identifiers), the referring web page, pages visited, location (depending on the permissions you have granted us), and cookie information.

However, if we are acting as a service provider (a “Data Processor”) processing your personal information on behalf of a third party that has collected such data from you, and such third party is the party that has the right to determine the purposes for which it will process your personal information and the means it will use to process your personal information (the “Data Controller”), then such Data Controller has the legal obligation to ask for your explicit consent to process your sensitive personal data and we are not responsible for obtaining such consent from you. In such a scenario, the Data Controller may have their own, separate policies regarding the use and disclosure of your personal information, including any sensitive personal data you provide to such Data Controller. In such a scenario, this Privacy Policy does not apply to, we cannot control the activities of, and we are not responsible for the activities of the applicable Data Controller generally; this Privacy Policy only applies to our processing of your personal information that we, as a Data Processor, have been asked to process on behalf of the Data applicable Data Controller. We encourage you to review such Data Controller’s privacy policy and/or contact the applicable Data Controller for more information about the policies that apply to their use and disclosure of your personal information, including any sensitive personal data.

How we use your information

We use the information we collect for the following purposes.

Provide and maintain the services

We use the information we collect to deliver the Services to you and honor our Terms of Service for each Service or business contract with you. For example,

• to administer, operate, maintain and secure our Services
• to monitor and analyze trends, usage and activities in connection with our Services
• for accounting, record keeping, backup and administrative purposes
• to customize and improve the content of our communications, websites and social media accounts
• to provide customer service and support
• to communicate with you, including responding to your comments, questions and requests regarding our Services
• to process and complete transactions, and send you related information, including alerts and notifications about your service, purchase confirmations and invoices; and
• to educate and train our workforce in data protection and customer support.

Improve, personalize, and develop the services

We use the information we collect to improve and personalize the Services and to develop new ones. For example, we use the information to troubleshoot and protect against errors; perform data analysis and testing; conduct research and surveys and develop new features and Services.

Communicate with you

We use your information when needed to send you Service notifications and respond to you when you contact us. We also use your information to promote new features or products that we think you would be interested in. You can control marketing communications and most Service notifications by using your notification preferences in account settings or via the “Unsubscribe” link in an email.

Promote safety and security

We use the information we collect to promote the safety and security of the Services, our users and other parties. For example, we may use the information

• to authenticate users
• to facilitate secure payments
• to respond to a legal request or claim, conduct audits, and enforce our terms and policies
• to investigate and protect against fraud, malicious or unauthorized access, and other illegal activities; and
• to demonstrate and verify compliance with our internal policies and procedures, and applicable privacy and data security laws and regulations, such as HIPAA and GDPR.

Use and disclosure of de-identified information

“De-identified” means that we have removed, or rendered unreadable through complex computational algorithms, your personally-identifiable information, such as your name, address, or birthdate. We may use de-identified information that we have obtained from our Services for various purposes, including for example:

• In accordance with regulatory requirements, we may de-identify, store and use your information for internal quality control, validation and research and development. We may use de-identified information as permitted by law.
• We may use or disclose de-identified information for general research and communications purposes.

We use cookies and similar technologies for the purposes described above. For personal data subject to the GDPR, we rely on several legal bases to process the data. These include when you have given your consent, which you may withdraw at any time using your account settings and/or other tools; when the processing is necessary to perform a contract with you, like the Terms of Service; and our legitimate business interests, such as in improving, personalizing, and developing the Services, marketing new features or products that may be of interest, and promoting safety and security as described above.

How we share your information

We do not share your personal information except in the limited circumstances described below..

When you agree or direct us to share

You may also authorize us to share your information with others, for example, with a third-party application when you give it access to your account, or with your employer company or other organizations and provide consent to each organization. Remember that their use of your information will be governed by their privacy policies and terms. You can revoke your consent to share with third-party applications or employee wellness programs using your account settings.

For external processing

We transfer information to our corporate affiliates, service providers and other partners who process it for us, based on our instructions and in compliance with this policy and any other appropriate confidentiality and security measures. These partners provide us with services globally, including for customer support, information technology, payments, sales, marketing, data analysis, research and surveys.

For legal reasons or to prevent harm

We may preserve or disclose information about you to comply with a law, regulation, legal process or governmental request; to assert legal rights or defend against legal claims; or to prevent, detect or investigate illegal activity, fraud, abuse, violations of our terms or threats to the security of the Services or the physical safety of any person. Please note: Our policy is to notify you of legal process seeking access to your information, such as search warrants, court orders or subpoenas, unless we are prohibited by law from doing so. In cases where a court order specifies a non-disclosure period, we provide delayed notice after the expiration of the non-disclosure period. Exceptions to our notice policy include exigent or counterproductive circumstances, for example, when there is an emergency involving a danger of death or serious physical injury to a person. We may share non-personal information that is aggregated or de-identified so that it cannot reasonably be used to identify an individual. We may disclose such information publicly and to third parties, for example, in public reports about exercise and activity, to partners under agreement with us or as part of the community benchmarking information we provide to users of our subscription services. If we are involved in a merger, acquisition, or sale of assets, we will continue to take measures to protect the confidentiality of personal information and give affected users notice for the transferring of any personal information to a new entity.

California Residents: Your rights regarding your personal information

State consumer privacy laws may provide their residents with additional rights regarding our use of their personal information. California's "Shine the Light" law (Civil Code Section § 1798.83) permits that are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes.

California Do Not Track Disclosure. We do not track website visitors over time and across third party websites to provide targeted advertising. We respond to ‘Do Not Track’ (DNT) signals for our website’s Google Analytics. We do not currently respond to DNT signals for other tracking technologies, and use your information as described in this Privacy Policy.

As a California resident, you may be able to exercise the following rights in relation to the personal information about you that we have collected (subject to certain limitations at law):

The Right to Know: The right to confirm whether we are processing personal information about you and, under California law only, to obtain certain personalized details about the personal information we have collected about you in the last 12 months, including:

The categories of personal information collected;

The categories of sources of the personal information;

The purposes for which the personal information were collected;

The categories of personal information disclosed to third parties (if any), and the categories of recipients to whom the personal information were disclosed;

The categories of personal information shared for cross-context behavioral advertising purposes (if any), and the categories of recipients to whom the personal information were disclosed for those purposes; and

The categories of personal information sold (if any), and the categories of third parties to whom the personal information were sold.

The Right to Access and Portability: The right to obtain access to the personal information we have collected about you and, where required by law, the right to obtain a copy of the personal data in a portable and, to the extent technically feasible, readily usable format that allows you to transmit the data to another entity without hindrance.

The Right to Request Deletion: You have the right to request the deletion of personal information that we have collected from you, subject to certain exceptions.

The Right to Correction: You have the right to request that any inaccuracies in your personal information be corrected, taking into account the nature of the personal information and the purposes of the processing of your personal information.

How to Exercise Your Privacy Rights

To submit a request to exercise one of the privacy rights identified above, please submit a request by: Email support@cotribute.com with the subject line “Data Subjects Rights Request,” or calling 800.790.8421.

We will need to verify your identity before processing your request. In order to verify your identity, we will generally require the matching of sufficient information you provide us to the information we maintain about you in our systems. Although we try to limit the personal information collected in connection with a request to exercise the right to access, right to know and/or the right to deletion to that personal information, certain requests may require us to obtain additional personal information from you. In certain circumstances, we may decline a request to exercise the right to know and/or right to deletion, particularly where we are unable to verify your identity. If we are unable to comply with all or a portion of your request, we will explain the reasons for declining to comply with the request.