Last Updated: September 22, 2018

Sibly, Inc., including as applicable its wellness coaches or “heroes”, (“Sibly”) is committed to protecting your privacy. We have prepared this Privacy Policy to describe to you our practices regarding the Personal Data (as defined below) we collect from users of our website, located at www.sibly.co, our mobile applications (“Application(s)”), and online services (collectively, the “Service”).

PLEASE NOTE THAT, AS DESCRIBED FURTHER IN SECTION 7.6 BELOW, IF WE BELIEVE, IN OUR SOLE DISCRETION, THAT YOU MAY BE A THREAT TO YOURSELF OR OTHERS, OR ARE AT RISK OF CAUSING PHYSICAL HARM, WE RESERVE THE RIGHT TO NOTIFY THE POLICE OR OTHER EMERGENCY PERSONNEL.

  1. Questions; Contacting Sibly; Reporting Violations.  If you have any questions, concerns or complaints about our Privacy Policy or our data collection or processing practices, or if you want to report any security violations to us, please contact us at  the following address or phone number:

  2. Sibly, Inc.

Attention: Customer Care

44 Tehama

San Francisco, CA 94105

 

  1. User Consent.  By submitting Personal Data, as defined in Section 5.1, through our Service, you agree to the terms of this Privacy Policy and you expressly consent to the collection, use and disclosure of your Personal Data in accordance with this Privacy Policy.

  2. A Note About Children.  We do not intentionally gather Personal Data from visitors who are under the age of 13.  If a child under 13 submits Personal Data to Sibly and we learn that the Personal Data is the information of a child under 13, we will attempt to delete the information as soon as possible.  If you believe that we might have any Personal Data from a child under 13, please contact us at care@sibly.co.

  3. A Note to Users Outside of the United States.  If you are a non U.S. user of our Service, by visiting our Service and providing us with data, you acknowledge and agree that your Personal Data may be processed for the purposes identified in the Privacy Policy.  In addition, your Personal Data may be processed in the country in which it was collected and in other countries, including the United States, where laws regarding processing of Personal Data may be less stringent than the laws in your country.  By providing your data, you consent to such transfer.

  1. Types of Data We Collect.  Personal Data.  “Personal Data” means data that allows someone to identify or contact you, including, for example, your name, address, telephone number, e-mail address, as well as any other non-public information about you that is associated with or linked to any of the foregoing data.  “Anonymous Data” means data that is not associated with or linked to your Personal Data; Anonymous Data does not, by itself, permit the identification of individual persons.  We collect Personal Data and Anonymous Data, as described below.

  2. Information You Provide to Us.  

  • We may collect Personal Data from you, such as but not limited to, your first and last name, address, phone number, date of birth, and email address when you create an account to log in to our network (“Account”).

  • If you use our Service on your mobile device, including through our Application(s), we may collect your phone number and the unique device ID number.

  • Our Service lets you store preferences like how your content is displayed.  We may associate these choices with your ID, browser or the mobile device, and you can edit these preferences at any time.

  • We use a third party payment processor to process orders for subscriptions to our Service. Therefore, all information necessary to complete such transactions is submitted to our third party payment processor, including your name, credit card information and billing information. We do not store this information directly on our servers, but this information may be shared with third parties who help process your payment.  When you submit credit card numbers, that information is encrypted using industry standard technology.

  • If your subscription to the Service is sponsored or paid for by a Sponsoring Entity, as defined in Section 7.5, such as your employer, you may be required to provide us with an access or discount code, that can be used by us to identify your Sponsoring Entity, when you sign up for a subscription that is discounted or paid for by such Sponsoring Entity.

  • We retain information on your behalf, such as files and messages that you store using your Account.

  • If you provide us feedback or contact us via e-mail, we will collect your name and e-mail address, as well as any other content included in the e-mail, in order to send you a reply.  

  • When you send messages or content (text, images, photographs, comments or any other kind of content that is not your e-mail address) on our Service, the information contained in your message or content will be stored in our servers and may be accessed by Sibly, although we may remove certain identifying information from the content of your messages.

  • We also collect other types of Personal Data that you provide to us voluntarily if you contact us via e-mail regarding support for the Service.

  • We may also collect Personal Data, such as at other points in our Service that state that Personal Data is being collected.

 

  1. Information Collected via Technology.

  • Information Collected by Our Servers.  To make our Service more useful to you, our servers (which may be hosted by a third party service provider) collect information from you, including your browser type, operating system, Internet Protocol (“IP”) address (a number that is automatically assigned to your computer when you use the Internet, which may vary from session to session), domain name, and/or a date/time stamp for your visit.  

  • Log Files.  As is true of most websites, we gather certain information automatically and store it in log files.  This information includes IP addresses, browser type, Internet service provider (“ISP”), referring/exit pages, operating system, date/time stamp, and clickstream data.  We use this information to analyze trends, administer our Service, track users’ movements around our Service, gather demographic information about our user base as a whole, and better tailor our Services to our users’ needs.  For example, some of the information may be collected so that when you visit our Service again, it will recognize you and the information could then be used to serve advertisements and other information appropriate to your interests.  Except as noted in this Privacy Policy, we do not link this automatically-collected data to Personal Data.

  • Cookies.  Like many online services, we use cookies to collect information.  “Cookies” are small pieces of information that a website sends to your computer’s hard drive while you are viewing the website.  We may use both session Cookies (which expire once you close your web browser) and persistent Cookies (which stay on your computer until you delete them) to provide you with a more personal and interactive experience on our Service.  This type of information is collected to make our Service more useful to you and to tailor the experience with us to meet your special interests and needs.

  • Pixel Tags. In addition, Sibly may use “Pixel Tags” (also referred to as clear Gifs, Web beacons, or Web bugs).  Pixel Tags are tiny graphic images with a unique identifier, similar in function to Cookies that are used to track online movements of Web users.  In contrast to Cookies, which are stored on a user’s computer hard drive, Pixel Tags are embedded invisibly in Web pages. Pixel Tags also allow us to send e-mail messages in a format users can read, and they tell us whether e-mails have been opened to ensure that we are sending only messages that are of interest to our users.  We may use this information to reduce or eliminate messages sent to a user. We do not tie the information gathered by Pixel Tags to our users’ Personal Data. We also allow our Analytics Providers to use tracking pixels, agents, or other visitor identification technology that collects, uses, shares and stores data about you and your use of the Service.

  • How We Respond to Do Not Track Signals.  We do not currently respond to “do not track” signals or other mechanisms that might enable consumers to opt out of tracking on our Service.

  • Mobile Services.  We may also collect non-personal information from your mobile device if you have downloaded our Application(s).  This information is generally used to help us deliver the most relevant information to you. Examples of information that may be collected and used include how you use the Application(s) and information about the type of device you use.   In addition, in the event our Application(s) crash on your mobile device, we will receive information about your mobile device model software version and device carrier, which allows us to identify and fix bugs and otherwise improve the performance of our Application(s).  This information is sent to us as aggregated information and is not traceable to any individual and cannot be used to identify an individual.

  • Analytics Services.  In addition to the tracking technologies we place, other companies may set their own cookies or similar tools when you visit our Service.  This includes third party analytics services, including but not limited to Flurry Analytics and Amplitude (“Analytics Services”) that we engage to help analyze how users use our Service.  We may receive reports based on these parties’ use of these tools on an individual or aggregate basis.  We use the information we get from Analytics Services only to improve our Service. The information generated by the Cookies or other technologies about your use of our Service (the “Analytics Information”) is transmitted to the Analytics Services.  The Analytics Services use Analytics Information to compile reports on user activity.  The Analytics Services may also transfer information to third parties where required to do so by law, or where such third parties process Analytics Information on their behalf. Each Analytics Services’ ability to use and share Analytics Information is restricted by such Analytics Services’ Terms of Use and Privacy Policy. For more information on Flurry’s Privacy Policy, please visit https://policies.oath.com/xw/en/oath/privacy/intl/index.html. To learn more about the choices offered in connection with the Analytics Services’ use of data, please visit http://www.networkadvertising.org/managing/opt_out.asp.  By using our Service, you consent to the processing of data about you by Analytics Services in the manner and for the purposes set out above.  For a full list of Analytics Services, please contact us at care@sibly.co.  

 

  1. Use of Your Personal Data

    1. General Use.  In general, Personal Data you submit to us is used either to respond to requests that you make, or to aid us in serving you better.  We use your Personal Data in the following ways:

  • facilitate the creation of and secure your Account on our network;

  • identify you as a user in our system;

  • respond to your messages on our Service;

  • provide improved administration of our Service;

  • provide our Service you request;

  • improve the quality of experience when you interact with our Service;

  • send you a welcome e-mail to verify ownership of the e-mail address provided when your Account was created;

  • send you administrative e-mail notifications, such as security, or support and maintenance advisories;

  • respond to your inquiries related to employment opportunities or other requests;

  • make telephone calls to you, from time to time, as a part of secondary fraud protection or to solicit your feedback; and

  • send newsletters, surveys, offers, and other promotional materials related to our Service and for other marketing purposes of Sibly.

 

    1. Creation of Anonymous Data.  We may create Anonymous Data records from Personal Data by excluding information (such as your name) that makes the data personally identifiable to you.  We use this Anonymous Data to analyze request and usage patterns so that we may enhance the content of our Service and improve Service navigation. We also share Anonymous Data with our service providers to help provide features of the Service.  For example, when you send an in-App message to one of our coaches through the Service, we take steps to de-identify your message and then share its content with our service provider, SendBird, which provides in-Service messaging functionality. We reserve the right to use Anonymous Data and aggregated and other de-identified information for any purpose and disclose Anonymous Data to third parties in our sole discretion.

  1. Disclosure of Your Personal Data.  We disclose your Personal Data as described below and as described elsewhere in this Privacy Policy.

    1. Coaches.  Please do not include any Personal Data in messages your send to coaches through our Service.  Although we try to remove identifying information from messages sent to our coaches, we cannot guarantee that all Personal Data you include in a message will be removed.  If you do provide Personal Data in the messages you send to our coaches, you acknowledge that (a) such Personal Data may be shared with our coaches for the purpose of enabling our coaches to respond to messages and provide our Service, and (b) Sibly coaches may communicate such Personal Data and related information with each other in connection with responding to your messages and providing our Service. Except as otherwise stated in this Privacy Policy or as required by law, we require our coaches to keep your Personal Data confidential.

    2. Third Party Service Providers.  We may share your Personal Data with third party service providers to:  provide you with our Service; to conduct quality assurance testing; to facilitate creation of accounts; to provide technical support; and/or to provide other services to the Sibly.  For example, we share our users’ email addresses with our payment processor, Stripe, for billing purposes. These third party service providers are required not to use your Personal Data other than to provide the services requested by Sibly.

    3. Affiliates.  We may share some or all of your Personal Data with our parent company, subsidiaries, joint ventures, or other companies under a common control (“Affiliates”), in which case we will require our Affiliates to honor this Privacy Policy.  

    4. Corporate Restructuring.  We may share some or all of your Personal Data in connection with or during negotiation of any merger, financing, acquisition or dissolution, transaction or proceeding involving sale, transfer, divestiture, or disclosure of all or a portion of our business or assets.  In the event of an insolvency, bankruptcy, or receivership, Personal Data may also be transferred as a business asset. If another company acquires our company, business, or assets, that company will possess the Personal Data collected by us and will assume the rights and obligations regarding your Personal Data as described in this Privacy Policy.

    5. Sponsoring Entity. If your subscription to our Service is partially or fully sponsored or paid for through your employer or another sponsoring entity (the “Sponsoring Entity”), we may send the Sponsoring Entity Anonymous Data, including usage patterns associated with the Sponsoring Entity’s users. All information provided to the Sponsoring Entity will be de-identified.

    6. Emergencies.  If we believe, in our sole discretion, that (a) you may be a threat to yourself or others, including without limitation any vulnerable individuals, such as children or the elderly, or (b) you are at risk of causing any type of physical harm, we may provide information about you, including Personal Data, to the police or other emergency personnel.  Sibly will not directly notify your employer or other Sponsoring Entity upon the occurrence of one of the events described in this Section 6.6; however, please note that the police or other emergency personnel may notify your employer or other Sponsoring Entity in their discretion.

    7. Other Disclosures.  Regardless of any choices you make regarding your Personal Data, Sibly may disclose Personal Data if it believes in good faith that such disclosure is necessary (a) in connection with any legal investigation; (b) to comply with relevant laws or to respond to subpoenas or warrants served on Sibly; (c) to protect or defend the rights or property of Sibly or users of our Service; and/or (d) to investigate or assist in preventing any violation or potential violation of the law, this Privacy Policy, or our Terms of Use.

  2. Third Party Websites.  Our Service may contain links to third party websites.  When you click on a link to any other website or location, you will leave our Site and go to another site and another entity may collect Personal Data or Anonymous Data from you.  We have no control over, do not review, and cannot be responsible for, these outside websites or their content. Please be aware that the terms of this Privacy Policy do not apply to these outside websites or content, or to any collection of your Personal Data after you click on links to such outside websites.  We encourage you to read the privacy policies of every website you visit. The links to third party websites or locations are for your convenience and do not signify our endorsement of such third parties or their products, content or websites.

  3. Your Choices Regarding Your Information.  You have several choices regarding use of information on our Services:

    1. Email Communications.  We may periodically send you free newsletters and e-mails that directly promote the use of our Service.  When you receive newsletters or promotional communications from us, you may indicate a preference to stop receiving further communications from us and you will have the opportunity to “opt-out” by following the unsubscribe instructions provided in the e-mail you receive or by contacting us directly (please see contact information above). Despite your indicated e-mail preferences, we may send you service related communications, including notices of any updates to our Terms of Use or Privacy Policy.

    2. Cookies.  If you decide at any time that you no longer wish to accept cookies from our Service for any of the purposes described above, then you can instruct your browser, by changing its settings, to stop accepting cookies or to prompt you before accepting a cookie from the websites you visit. Consult your browser’s technical information. If you do not accept cookies, however, you may not be able to use all portions of the Service or all functionality of our Service. If you have any questions about how to disable or modify cookies, please let us know at the contact information provided above.

    3. Changing or Deleting Your Personal Data.  Some of our users’ data is store in their downloaded copy of our mobile Application, such as the users’ name, email address and user id.  If you wish to delete the information that is stored in your downloaded copy of our mobile Application, you should delete the Application.  Except as described above, we currently do not provide a mechanism to electronically request we delete or modify Personal Data. If you would like to submit a request that we delete your Personal Data, please contact us at [insert email] and we may honor your request in our sole discretion.

    4. Applications.  You can stop the collection of additional information by the Application(s) by uninstalling the Application(s).  You may use the standard uninstall processes as may be available as part of your mobile device or via the mobile application marketplace or network.  

    5. Security of Credit Card Information.  For online payments, we use the payment services of Stripe (https://stripe.com/).  We do not process, record or maintain your credit card information.  For more information on how payments are handled, or to understand the data security and privacy afforded such information, please refer to https://stripe.com/.

  4. Changes to This Privacy Policy.  Please revisit this page periodically to stay aware of any changes to this Privacy Policy, which we may update from time to time. If we modify this Privacy Policy, we will make it available through our Service, and indicate the date of the latest revision. In the event that the modifications materially alter your rights or obligations hereunder, we will make reasonable efforts to notify you of the change. For example, we may send a message to your email address, if we have one on file, or generate a pop-up or similar notification when you access our Service for the first time after such material changes are made. Your continued use of our Service after the revised Privacy Policy has become effective indicates that you have read, understood and agreed to the current version of this Privacy Policy.

Sibly Privacy Policy

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