PAI HEALTH PRIVACY POLICY
Updated: March 20, 2020
Effective Date: April 20, 2020
SERVICES
PAI Health Inc. ("PAI Health", "we", "us" or "our") provides an integrated suite of health-related products and services, including:
- PAI Health-branded fitness and health websites, including paihealth.com;
- PAI Health-branded fitness and health mobile applications; and
- other associated health and fitness related websites, applications, applets, widgets, software development kids, application programming interface, tools, calculations, content, social networking components, products, services, or select promotional offers made available by PAI Health
(collectively, the "Services").
We have posted this Privacy Policy to let you know what kind of information we collect when you interact with the Services, the purposes for which we collect and use your information, how it is handled, with whom it will be shared, and what choices you have regarding our use of your information. This Privacy Policy applies to all personal information we collect or acquire about you through the Services and through any other media channels and platforms, whether online, offline, print, telephonic, mobile, wireless, or otherwise, whether collected or acquired by PAI Health, or any other PAI Health subsidiary or affiliate.
ACCEPTANCE
By using the Services or submitting personal information to PAI Health, you agree that PAI Health may collect, use, disclose, and transfer your personal information in accordance with this Privacy Policy and applicable law.
You may refuse or withdraw your consent to certain practices identified in this Privacy Policy by contacting us or following the instructions below. If you withdraw your consent, we may no longer be able to provide you with the Services.
Please note that certain Services may require that you consent to additional privacy-related practices. In that event, we will disclose those practices to you in a separate Privacy Policy, and that Privacy Policy will be considered to be a part of this Privacy Policy. In the case of any conflict between this Privacy Policy and a more specific Privacy Policy, the more specific Privacy Policy shall prevail with regard to the particular Service it is associated with.
UPDATES
PAI Health reserves the right to make changes to this Privacy Policy from time to time. If we make a material change to this Privacy Policy, we will provide you with reasonable notice prior to the changes either by posting a notice on our website or within our application(s). It is your responsibility to review the most current version of the Privacy Policy by visiting our website. Revisions to this Privacy Policy will become effective on the date set forth in our notice, and if you continue to use the Services after that date, your use will constitute accept of such revised Privacy Policy. If any change to this Privacy Policy is not acceptable to you, you may refuse or withdraw your consent if permitted by this Privacy Policy or applicable law, or cease your use of the Services.
WHAT TYPES OF PERSONAL INFORMATION DO WE GATHER?
We collect information about you when you register to use our Services, connect your social media account, use our Services, or communicate with us. You can choose not to provide certain information or opt out of some automated collection of your information, but then you may not be able to take advantage of certain features or Services. By using our Services, you grant us permission to process your personal information in accordance with the provisions of this Privacy Policy.
Personal Information. When you sign up for a particular Service that requires registration or an account (collectively, any type of account that you create through PAI Health is referred to in this Privacy Policy as “Account”), we ask you to submit certain personal information. Personal information is any information that identifies you personally, either alone or in combination with other information available to us. Personal information includes, but is not limited to:
Your name, username, email address, phone number, and/or age;
Information about the device used to connect to the Services, including your IP address, the type of device, and your carrier;
Certain information concerning your health and physical characteristics; and
Any other personally information you provide with PAI Health through the Services.
Social Media Connection. We may from time to time enable you to log in to the Services via various social media or social networking services such as Facebook or Twitter (“Social Networking Services”) in order to offer you a richer and more personalized experience with our Services. If you do choose to connect your social media account to our Services, we may collect certain personal information that you have provided to that Social Networking Service. For example, when you log in with your Facebook credentials, with your permission, we may collect personal information from your Facebook profile, such as your email address, profile picture, and friend list.
Payment Method Information.For certain Services, we may collect certain financial information, including but not limited to, credit card or other payment account information. All financial transactions with PAI Health are performed on secure servers that meet industry standards. We will only store your credit card information with your express consent, typically when you are paying for a recurring subscription to our Services.
Location Information.Some Services use location-based components. To provide these features, we or our partners and licensees will collect, use, and share precise location information, including the real-time geographic location of your mobile device. For some third-party partners, such as Google, this location information will be shared automatically. For others, such as Facebook, location information will only be shared with your explicit permission or if you choose to share it via the device. Location information will be collected from your wireless carrier, certain third-party service providers, or directly from the mobile device with which you use or access our Services. The collection and tracking of your location information will occur even when our Services, including any mobile application, are not actively open and running. Your location information, however, is only displayed and shared in accordance with your established privacy settings.
We may combine the personal information and/or the location information that you provide via your Account with information from other Services or third parties in order to enhance your experience and/or to improve the overall quality of the Services. For certain Services, we will give you an opportunity to opt out from providing or sharing your personal information.
Other Information You Provide. When you use our Services, we receive non-personally identifiable information about your use of the Services. Such information, which will be collected passively using various technologies or via submission of data by devices you may have configured to work with the Services, cannot be used to specifically identify you. We will store such information ourselves, including within databases owned and maintained by our respective affiliates, agents, and/or service providers. We will use such information and pool it with other information to track, for example, the total number of visitors to the Services, the number of visitors to each page of the Services, and the domain names of our visitors’ Internet service providers. No personal information is available or used in this process.
Aggregated Information. To better serve you and improve the Services, we will conduct research or obtain certain information on your demographics, interests, and behavior based on personal information and other information you provided via the Services or to third-parties. This information will be compiled and analyzed on an aggregate basis, and we will share this aggregated information with our affiliates, agents, and business partners. This aggregate information does not identify you personally. We will also disclose aggregated information in order to describe our services to current and prospective business partners and to other third parties for other lawful purposes.
Cookies, Automatic Data Collection, and Related Technologies.When you access or use the Services, we and third parties that provide certain functionality on our Services, such as Facebook, Twitter, and ad networks, will engage, receive, collect, and store certain types of information through automatic data collection tools including cookies, pixel tags, web beacons, embedded web links, and other commonly used information gathering tools (“Automatic Data Collection Tools”). These Automatic Data Collection Tools collect certain information including, but not limited to, information such as your web requests, Internet Protocol address, browser type, browser language, the date and time of your request, referring/exit pages and URLs, platform type, number of clicks, domain names, landing pages, pages viewed and the order of those pages, cookies that will uniquely identify your browser, and elements employed in the Mobile Applications.
Cookies. A “cookie” is a small data file stored by your web browser on your computer’s hard drive. It allows us to recognize your computer (but not specifically who is using it) when you visit one of the Services by associating the identification numbers in the cookie with other user information you have provided us. That user information is stored on our secured database. Some cookies will remain on the hard drive of your computer or mobile device for the duration of your browsing session, while others will remain for longer periods of time or will remain unless and until deleted by you. You will be able to configure your browser to accept or reject all or some cookies (other than Flash cookies) or notify you when a cookie is set. Each browser is different, so please check the “Help” or “Settings” menu of your browser to learn how to change your cookie preferences. Please note that some of our Services or features may not function properly or at all if cookies are disabled or blocked.
Some third-party service providers may use “Flash cookies,” also known as Local Shared Objects or LSOs. Flash cookies are saved on your computer in the same way as other cookies, but they cannot be rejected, disabled, turned off, opted out of, or deleted in the same way as regular cookies. For information on how to manage and remove Flash cookies, please visit: http://helpx.adobe.com/flash-player/kb/disable-local-shared-objects-flash.html or http://epic.org/privacy/cookies/flash.html.
Pixel Tags.“Pixel tags” (also known as “tracking pixels” or “web beacons”) are small graphic files that allow us to monitor the use of our Services. The use of pixel tags is industry standard technology used by most major web sites. A pixel tag can collect information such as the Internet Protocol (“IP”) address of the computer that downloaded the page on which the tag appears; the Uniform Resource Locator (“URL”) of the page on which the pixel tag appears; the time the page containing the pixel tag was viewed; the type of browser that fetched the pixel tag; and the identification number of any cookie on the computer previously placed by that server. One of the ways in which we use pixel tags is through a third-party service provider to serve ads on our behalf across the Internet. They will collect anonymous (other than your IP address) information about your visits to and interaction with our Services. They will also use this information about your visits to the Services and other websites and applications to target advertisements for goods and services. If you would like more information about online marketing practices and to know your choices about not having this information used by our third party service providers, please click www.networkadvertising.org/choices.
HOW DO WE USE YOUR PERSONAL INFORMATION?
When you sign up for a particular Service that requires an Account, we will ask you to provide certain personal information or location information. If we intend to use this personal information in a manner different than the purpose for which it was collected, we will ask you for your specific consent prior to such use. If we propose to use personal information in ways that are less restrictive than those described in this Privacy Policy and/or in the specific service notices, we will offer you an effective way to opt out of such use of your personal information for such identified other purposes. In addition, you may decline to submit personal information or location information to any of the Services; this will mean, however, that we are unable to provide certain Services to you.
We process and use personal information and location information for the purposes described in this Privacy Policy and/or any specific privacy notices set forth for select Services. In addition to the above, such purposes will include:
Operating, maintaining, and providing you all of the features of the Services, including the display of customized content and advertising;
Providing the basic functionality of mobile applications, such as displaying your live location and movement;
Employing “reverse geo-coding” and your IP address or saved location information to provide you with specialized route and event content;
Contacting you to deliver special offers, promotions, or other information;
Auditing, research, and analysis in order to maintain, protect, and enhance the Services;
Ensuring the functionality and usability of the Services;
Installing and monitoring elements for security and/or credit or fraud prevention purposes;
Creating user profiles that permit us to better understand what information a given user of our Services might like to receive from us;
Providing you with information and notices related to the Services;
Inviting you to participate in surveys conducted by us and/or our affiliates;
Developing new products and services;
Improving our marketing and promotional efforts; and
Providing you with updates, notifications, and release information pertaining to the Services.
Direct Marketing.Each user that has registered or created an Account (through our product registration form(s), website(s), application(s), or otherwise), has the choice of receiving announcements about our products, services, and special events or promotions from us via email. You will receive email communications only if you have opted in and agreed to receive them from PAI Health by (i) checking the box next to the invitation to receive announcements, news, and promotions when registering or creating your Account via website or the mobile in-app registration process, or (ii) clicking on an email signup link on the Services and entering your email address. If you opt in to our email communications, we will receive a confirmation when you open email messages from the Services. If you no longer want to receive email communication from us, please see the section titled “How Can You Opt-Out of Receiving Communications From Us?”
YOUR CHOICES
Account Privacy Settings and Online Disclosures. Certain Services come equipped with privacy settings for your profile and activities. These privacy settings control who can view your online disclosures, including but not limited to, certain personal information, location information, and activity data.
We recommend that you actively manage your privacy settings on an ongoing basis, so that you can effectively guard against the unauthorized use or misuse of your personal information or location information by others. Managing your privacy settings will also allow you to refuse or withdraw your consent to the collection of certain information.
HOW DO WE USE AUTOMATIC DATA COLLECTION TOOLS?
We use Automatic Data Collection Tools to:
customize our Services;
improve our site design, product assortments, customer service, and special promotions;
analyze use and performance of our Services by measuring and recording the number of visitors to the Services, the paths to the Services, and activity on the Services;
identify the pages you click on during your visit to our Services and the name of the website you visited immediately before navigating to our Services;
enable you to interact with our Services;
measure the success of our marketing activities; and
manage our advertising programs, such as by delivering advertisements on or through our Services and on third party websites that may be particularly relevant to individual consumers and that will improve the consumer experience and be tailored to user preferences.
For more information on how to turn off certain Automatic Data Collection Tools, please see the section on “Cookies” and “Pixel Tags” above.
Third Party Data Collection on Our Services. Please note that certain third parties whom we do not control use Automatic Data Collection Tools on our Services. When you “opt-out” of receiving interest-based ads through one of the links below, these Automatic Data Collection Tools will still collect information about your use of the Services for other purposes, such as analytics and fraud prevention.
ONLINE ADVERTISING
On Our Services. We use personal information and data collected through Automatic Data Collection Tools to deliver personalized PAI Health or third-party interest-based advertising to you on our Services. For example, there may be separate products and services offered by third parties advertised on or through our Services that will be complementary to your use of our Services. If you choose to use these separate products or services, disclose information to the third-party providers, or grant them permission to collect information about you, then their use of your information is governed by their own privacy policies. PAI Health is not responsible for these third-party privacy practices. If you click on a link to a third-party site or are considering using a third-party providers’ products or services, we encourage you to check and evaluate the privacy policy on that third party’s website.
Please see "How You Can Opt-Out of Online Tracking and Receiving Interest-Based Advertisements" for more information about your choices.
On Third Party Websites.We work with third-party companies that use tracking technologies, such as Automatic Data Collection Tools, to serve advertisements on our behalf across the Internet. These companies will collect information about your use of the Services and your interaction with our advertising and other communications. If you would like more information about this practice or want to learn more about your choices of opting out of services used by these companies, please see "How You Can Opt-Out of Online Tracking and Receiving Interest-Based Advertisements" below and/or visit www.networkadvertising.org/managing/opt_out.asp.
These third-party service providers will have access to user personal information needed to perform their functions, but will not use such information for any purpose other than the function which we have directed them to perform on our behalf. We require such third-party service providers to implement and maintain reasonable security measures to safeguard the confidentiality, security, and integrity of your personal information.
HOW CAN YOU OPT-OUT OF RECEIVING COMMUNICATIONS FROM US?
Email Opt-Out. When you register or create an Account via website or the mobile in-app registration process, you have the choice of receiving announcements and promotions from us via email.
If you no longer wish to receive email updates from us, you can withdraw your consent and unsubscribe by clicking on the link “Unsubscribe” at the bottom of any email message from us. Please note that some email communications are prepared well in advance. We appreciate your patience in giving us time to carry out your request. If you unsubscribe from our email updates, you will still receive Service-related emails, including confirmations of purchases, important product updates and notifications regarding changes to our Terms of Use, Privacy Policy, and/or other legal matters as permitted by applicable law.
HOW YOU CAN OPT-OUT OF ONLINE TRACKING AND RECEIVING INTEREST-BASED ADVERTISEMENTS
If you want to withdraw your consent or “opt out” of tracking for purposes of serving you online interest-based advertisements, please follow the instructions at www.aboutads.info/choices or http://www.networkadvertising.org/choices/. When you “opt out” using any one or all of these options, an “opt-out” Cookie will be placed on your device indicating that you do not want to receive interest-based advertisements. If you delete cookies on your device generally, please keep in mind that you will need to opt-out again.
Please Note: When you “opt-out” of receiving interest-based advertisements, this does not mean you will no longer see advertisements from us or on the Services. It means that the online ads that you do see will not be targeted to you based on your particular interests. We will still collect information about you and your use of the Services for any purpose permitted under the Privacy Policy, including for analytics and fraud prevention.
HOW WILL WE SHARE YOUR PERSONAL INFORMATION?
Information about our users is an important part of our business, and we do not sell it to others. We share user information as described below.
With Your Consent. We will share your personal information and/or location information where you have consented to the disclosure (including through this Privacy Policy). Other than as described in this Privacy Policy, you will receive notice when information about you might go to third parties, and you will have an opportunity to choose not to share the information.
With Third Party Service Providers.We will share any information we receive with vendors and service providers retained in connection with the provision of our Services.
For Protection of PAI Health. We disclose personal information when we believe it is necessary to comply with the law; enforce or apply our Terms of Service, Privacy Policy and other agreements; or protect the rights, property or safety of our company, our users, or others. This includes exchanging information with other companies and organizations for fraud protection and credit risk reduction.
Merger, Acquisition, Sale, or Transfer of Assets or Business. If PAI Health is acquired by or merged with or into another entity, or if our assets or business is sold or transferred to another entity, your personal information will be transferred to such entity as part of the transaction.
INTERNATIONAL USERS
If you are visiting and/or using our Services from the European Union or other regions with laws governing data collection and use, please note that you are agreeing to the transfer of your personal information to the United States, Canada, and/or processing globally. By visiting and/or using our Services, you consent to any transfer and processing of any personal information you provide in accordance with this Privacy Policy including processing by PAI Health subsidiaries and affiliates.
WHAT ARE YOUR DATA PROTECTION RIGHTS?
Right to access. You have the right to view all personal information that PAI Health has collected about you, as well as the disclosure of this data. PAI Health will retain your personal information as long as your account remains active. In order to access your personal information, please contact the PAI Health Data Privacy Officer. The first copy of this information is provided free of charge.
Right to accuracy. You have the right to ensure that the personal information PAI Health has stored is accurate. If there is incorrect data within our system that you are not able to change, please contact the PAI Health Data Privacy Officer.
Right to be forgotten. You have the right to request deletion of your personal information. To request that your personal information be deleted, please contact the PAI Health Data Privacy Officer. In some cases, there may be a legal requirement to retain your personal information. PAI Health will notify you directly if this is the case.
Right to withdraw consent. You have the right to withdraw your consent to use of your personal information at any time by contacting the PAI Health Data Privacy Officer. Please note that without consent to process your personal information, we will be unable to deliver the Services.
Right to notification of unauthorized disclosure. PAI Health will notify you as required by law if there has been a breach of the security of your personal information.
Concerns or complaints. If you believe that any of your rights with respect to your personal information have been violated by us, our employees or agents, please communicate with the PAI Health Data Privacy Officer.
If you make a request, we have one month to respond to you.
If we are subject to the Health Insurance Portability and Accountability Act (“HIPAA”), you may also contact the Secretary of the U.S. Department of Health and Human Services. Under no circumstances will PAI Health take any retaliation against you for filing a complaint.
HOW CAN YOU CONTACT US ABOUT YOUR INFORMATION?
PAI Health Data Privacy Officer
510 Seymour St
Suite 700
Vancouver, BC V6B 3J5
Canada
If you have any questions, comments, or concerns about our handling of personal information relating to you, please email us at [email protected].
LINKS TO THIRD PARTY WEBSITES:
The Services will contain links to certain third-party websites. We do not own, control, or operate such linked sites, and we are not responsible for the privacy policies or practices of such linked sites. Privacy policies and practices for such linked sites can differ from this Privacy Policy and our practices. Your access and use of such linked sites is entirely and solely at your own risk. We urge you to read the privacy policies of such linked sites before disclosing your personal information on such sites.
THIRD PARTY APPLICATIONS:
You will be able to access certain third party applications or content (collectively, "Third Party Applications") via your Account. If you choose to access these Third Party Applications, you will be requested to log-in and sync your Account with such applications. You are in no way obligated to use any Third Party Applications, and your access and use of such applications is entirely and solely at your own risk. If you opt to use Third Party Applications via your Account, they will gain access to certain information that you have provided to us, including personal information, and they will use, store, and disclose such information in accordance with their individual privacy policies. The manner in which Third Party Applications use, store, and disclose your information is governed solely by their individual privacy policies and terms and conditions. We have no liability or responsibility for the privacy and information security practices or other actions of any Third Party Applications that you choose to access through your Account.
WHAT ARE OUR SECURITY POLICIES?
We use Secure Sockets Layer (“SSL”), the industry-standard encryption technology for internet transmission of your personal information. When the letters “http” in the URL change to “https,” the “s” indicates you are in a secure area employing SSL; also, your browser will give a pop-up message stating that you are about to enter or leave a secure area. Using a browser that is SSL capable will ensure that your information is encoded/encrypted when it is sent over the Internet.
Ultimately, if you register an Account, your Account and personal information is protected by the password you provided when you created your Account or updated your password while logged into your Account. Always keep this password and login information private and never share it with anyone. Also, remember to sign off your Account and close your browser window when you have finished your visit. This is to ensure that others cannot access your Account, especially if you are sharing a computer with someone else or are using a computer in a public place.
Unfortunately, no data transmission over the Internet and no data storage can be 100% secure. Consequently, while we endeavor to safeguard your personal information against unauthorized access and disclosure, we do not warrant or guarantee the security of any personal information you transmit to, from or through our Services. We will notify you in the event we become aware of a security breach involving your personal information stored by or for us. By disclosing your email address to us for any reason, you expressly consent to receive electronic notice from us in the event of such a security breach.
SPECIAL NOTE TO PARENTS:
We take the privacy of children seriously. The Services are expressly not directed at children and our Terms of Service prohibit children under the Permitted Age from registering for or using the Services. Accordingly, we do not knowingly collect personal information from children under the age of 13 through our Services, and we request that children under the age of 13 not submit any personal information through our Services.
PREVAILING LANGUAGE
English shall be the language of communication. In case of any discrepancy between the English version of this Agreement and any translations, the English version shall prevail.
GOVERNING LAW
Except as required by applicable law, this Privacy Policy shall be governed by the law of the Province of British Columbia, and the federal laws of Canada applicable therein, without regard to conflicts of law provisions. To the extent permitted by applicable law, the courts located in the City of Vancouver, British Columbia shall have exclusive jurisdiction over any dispute arising in connection with this Privacy Policy. The parties irrevocably consent to the jurisdiction and venue of any such court in any such action or proceeding.
This Privacy Policy and the Terms of Service constitute the entire agreement between you and us regarding the use of the Services, superseding any prior agreements between you and us relating to your use of the Services. Our failure to exercise or enforce any right or provision of this Privacy Policy shall not constitute a waiver of such right or provision in that or any other instance. If any provision of this Privacy Policy is held invalid, unlawful, void or unenforceable for any reason, that provision shall be deemed severable and the remainder of the Privacy Policy shall continue in full force and effect.