Effective Date: August 1st, 2018
Citizen Health Project, Inc., a Delaware Public Benefit Corporation located at 6641 Hwy 98 Suite 200, Hattiesburg, Mississippi 39402 USA.
The Services provide software tools for users to access and manage various features and functions related to health and wellness ( “Personal Health Journey”, “Health Score”, collectively “Health”), a marketplace and digital assets including tokens, cryptocurrencies, virtual currencies ( “Medit”, “Medex” , collectively “Digital Assets”), including interfacing with third party sources for certain information.
INFORMATION WE COLLECT AND HOW WE COLLECT IT
We collect the information that you give, information generated as you use our services and information from third parties.
Information you give us
You chose to give us certain information when using our services, including:
- When you create an account, we may collect your name, email address, mobile telephone number, account preferences, credit card and/or other payment information (if applicable), certain health information, photographs, biographical details or any other information that you choose to provide to us.
- When you link your wearable and other data sources, we collect the information that you provide to track your Personal Health Journey and Health Score.
- When you create a wallet, we collect the information that you provide to track the value of your Digital Assets through your wallet.
- If you contact us, we may collect the information you provide us during the interaction. We may use that information for training purposes for customer care and quality assurances.
- When you participate in our surveys and other feedback methods, we collect your insights into the Services and responses to our questions. You may choose whether to participate in a survey or to give us feedback. We may use your responses for our own company marketing purposes.
- FB Clause: As part of the Services, we may provide functionality allowing you to search for friends by using your Facebook credentials and, when you elect to do this, you will be asked to allow the App to access certain information associated with your Facebook account such as your name, profile picture, gender and list of friends. Provided you consent to this, such information will be processed by us in order to identify your Facebook friends who are users of App and to allow you to invite those Facebook friends to install the App.
Information collected when you use the the Services
When you use the Services, we collect information about which features you used, how you use them and the devices you use to access the Services.
- We collect information about your activity on the Services. We automatically collect and store in server logs your date and time you logged in, search queries, the date and time of your request and referral URL.
- We collect information from and about the devices you use to access the Services, including Internet Protocol (IP) address (including country), device ID and type, device-specific and other hardware settings, operating system and other software settings, browser type, browser language, time zones, and certain cookies or other technologies that identify your browser, device or App account. Citizen Health may associate your Device information with your Humantiv account.
- We collect information from and about information on your wireless and mobile network connection, like your service provider and signal strength.
- With your consent, we will collect information about your location and physical movements in order for the Humantiv App to verify your movement to issue Medit. You can turn location monitoring on and off in the settings of your mobile device operating system, but disabling this functionality will result in the App not being able to collect information relating to your activity and GPS/Cell-ID location which will prevent tracking and/or conversion of your activity into Medit.
- We collect other information with your consent.
Information collected through Third Parties
Third parties that assist us with our business operations also collect information through the Services.
We engage service providers to collect information to help us secure the Services and detect and prevent fraud. We may receive information about you from our advertising partners, such as when advertising campaigns are published through the Services. Some of this information is collected through the technology described in the next section.
We work with third parties from time to time (including, for example, business partners, sub-contractors in technical, payment and delivery services, advertising networks, analytics providers, search information providers and credit reference agencies) who may provide to us information about you. This may include your purchase history from business partners who supply you with rewards made available via the App.
COOKIES AND OTHER DATA COLLECTION TECHNOLOGY
Cookies are small text files that are sent to or accessed from your web browser or your computer’s hard drive. A cookie typically contains the name of the domain (internet location) from which the cookie originated, the “lifetime” of the cookie (i.e., when it expires) and a randomly generated unique number or similar identifier. A cookie also may contain information about your computer, such as user settings, browsing history and activities conducted while using the Services. A web beacon (also called a pixel tag or clear GIF) is a piece of computer code that enables us to monitor user activity and website traffic. To learn more about cookies and web beacons, visit www.allaboutcookies.org.
Data collection technology helps us improve your experience of the Services by, for example, storing your password so you do not have to re-enter it each time you use the Services, helping us analyze technical and navigational information about the Services to better understand how our products and services are being used, personalizing and tailoring ads or rewards to your interests and to detect and prevent fraud. We may link information from cookies with other personal information we hold about you.
The Services use the following cookies:
- Strictly necessary cookies, which are required for the operation of the Services. Without them, for example, you would not be able to register or log in for the Services that we may offer.
- Analytical/performance cookies, which allow us to recognize and count the number of visitors, to learn how visitors navigate the Services and to help us to improve the way Services function.
- Functionality cookies, which are used to recognize you when you return to the Services.
- We use Google Analytics which is a Google service that collects information about use of the Services. Google Analytics does not identify individual users.
- To provide the Services (using our own systems and those of appropriate third party service providers);
- In order to verify your physical movement and location and issue Medit on the basis of this verified data;
- To analyse the usage of, and improve, the Services;
- In order to perform market and customer research;
- To market our services to you;
- To correct errors and problems with the Services;
- To investigate and/or prevent suspected fraud or other criminal activities;
- To create daily leaderboards of users, comprising all users or users meeting particular criteria as ranked by the number of steps completed or using other criteria;
- To operate the Marketplace; and/or
- To investigate disputes between users.
Additionally, we and/or our trusted partners may contact you from time to time with offers that may interest you and/or to inform you of other products and services or rewards. Certain aspects of your personal data may be shared with other users of the App as part of the normal operation of the Services (for example your uploaded profile picture and biographical information will be accessible to all users, and we may publish your total verified steps, or other activity, during a particular period to other users from time to time). Further, we may, from time to time, expand or reduce our business which may involve the transfer of certain divisions or assets of our company to other parties, and the data we store and use, where relevant, may be transferred to such third parties. From time to time we may transfer the data we store and use to locations outside the European Economic Area, some of which may have different data protection laws to the UK or the EU, or no data protection laws. In all such cases, we transmit such information only to entities that comply with this policy and applicable law.
Your personal data will be kept only for as long as is necessary. We take reasonable industry-standard care in keeping all our data secure and in preventing any unauthorised access or unlawful use of it. All personal data we store and process is handled strictly in accordance with applicable data protection legislation.
Your Control of Cookies:
Some web browsers (including some mobile web browsers) provide settings that allow you to control or reject cookies or to alert you when a cookie is placed on your computer, tablet or mobile device. You also may be able to reject mobile device identifiers by activating the appropriate setting on your mobile device. Although you are not required to accept cookies or mobile device identifiers, if you block or reject them, you may not have access to all features available through the Services.
Our Policy On Do Not Track Signals:
Some web browsers (including Safari, Internet Explorer, Firefox and Chrome) incorporate a “Do Not Track” (“DNT”) or similar feature that signals to websites that a user does not want to have his or her online activity and behavior tracked. If a website that responds to a particular DNT signal receives the DNT signal, the browser can block that website from collecting certain personal information about the browser’s user. Not all browsers offer a DNT option and DNT signals are not yet uniform. For this reason, many website operators, including Citizen Health, do not respond to DNT signals.
HOW WE PROCESS PERSONAL INFORMATION
Citizen Health processes personal information:
To administer your account and provide the Services to you
- To set up and maintain your account and wallets;
- To communicate with you;
- To respond to your questions and to try to resolve problems with one of our products;
- To complete transactions requested by you
To improve the Services and develop new ones
- Administer surveys
- Conduct research and analysis of users’ behavior to improve the Services and their content. For example, we may decide to change the look and feel or even substantially modify a given feature based on users’ behavior.
- Develop new features and services. For example, we may decide to build a new interests-based feature further to requests received from users.
To prevent, detect and fight fraud or other illegal or unauthorized activities
- Address ongoing or alleged misconduct
- Data analysis to better understand and design countermeasures against these activities
- Retention of data related to fraudulent activities to prevent against recurrences
To ensure legal compliance
- Comply with legal requirements
- Enforce or exercise our rights
To process your information as described above, we rely on the following legal bases:
- Provide the Services to you: We process your information to perform the contract (Terms of Service) that you have with us.
- Legitimate interests: We use your information for legitimate business interests when permitted by law. For example, we analyze users’ behavior on the Services to improve them, for direct marketing and for administrative, fraud detection and legal purposes.
HOW WE SHARE INFORMATION
Citizen Health may share information collected through the Services as follows:
- Service Providers: We share information with our third-party service providers that help us operate the Services, such as by providing customer service or product support or testing and hardening our security measures.
- Corporate Transaction: We may share and transfer information if we are involved in a merger, sale, acquisition, divestiture, restructuring, reorganization, dissolution, bankruptcy or other change of ownership or control by Citizen Health or any affiliated company (in each case, whether in whole or in part).
- When Required by Law: Applicable law may require Citizen Health to disclose your personal information if: (i) reasonably necessary to comply with legal process (such as a court order, subpoena or search warrant), government investigation or other legal requirements or (ii) necessary for the prevention or detection of crime (subject in each case to applicable law).
- Other Lawful Disclosures: We also share information if (i) disclosure would mitigate Citizen Health’s liability in an actual or threatened lawsuit; (ii) as necessary to protect legal rights of Citizen Health, users, customers, business partners or other interested parties; (iii) to pursue available remedies or limit the damages; (iv) to enforce our agreements; and (v) to respond to an emergency.
Citizen Health may aggregate information collected through the Services and remove identifiers so that the information no longer identifies or can be used to identify an individual (“Aggregated Information”). Citizen Health shares Aggregated Information with third parties and does not limit third parties’ use of the Aggregated Information.
CROSS-BORDER DATA TRANSFERS
Sharing information sometimes involves cross-border data transfers. For example, if the Services are available to users in the European Economic Area (“EEA”), these users’ personal information is transferred to countries outside of the EEA to the US or other jurisdictions. We use safeguards approved by the European Commission to legitimize data transfers from the EEA to other countries.
OPTING OUT OR CORRECTING INFORMATION
If you do not wish to receive marketing-related emails from us, please click the unsubscribe link in one of our marketing emails or contact us at [email protected]
To review, correct, update, suppress, restrict or delete personal information that you have previously provided to us or if you would like to receive an electronic copy of your personal information for purposes of transmitting it to another company (if this right to data portability is provided to you by law), you can:
- Access, correct and delete certain information using Account settings.
- Change your settings on your device to either consent or withdraw consent to the collection of certain information. Of course, if you do that, certain Services may lose full functionality.
- Delete your Account.
- Contact us at [email protected] and provide the email address associated with your Account.
In your request, please make clear what personal information you would like to have changed, whether you would like to have your personal information suppressed from our database, or other limitations you would like to put on our use of your personal information. For your protection, we only fulfill requests for the personal information associated with the email address associated with your Account. We may need to verify your identity before fulfilling your request. We will try to comply with your request as soon as reasonably practicable.
Please note that we often need to retain certain data for recordkeeping purposes and/or to complete any transaction that you began prior to requesting a change or deletion. Our databases also may have residual data which we do not remove. In addition, we also may not allow you to review certain data for legal, security or other reasons.
If you are an EEA resident, you have the right to lodge a complaint with a data protection authority about how we process your personal information.
Notice to California Residents: California Civil Code Section 1798.83 permits individual 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 contact us at [email protected].
LINKS TO OTHER WEBSITES AND SERVICES
PROTECTION OF INFORMATION
We take precautions intended to help protect information that we collect and store. Unfortunately, however, no system or online transmission of data is completely secure. We cannot guarantee the security of information transmitted to or through the Services. Any transmission is at your own risk and we expect that you will use appropriate security measures to protect your information.
You are responsible for maintaining the security of your account, including the device on which your store your wallet. Access to the Services through your account is treated as authorized by you. Unauthorized access to password-protected or secure areas is prohibited and may lead to criminal prosecution. We may suspend your use of all or part of the Services without notice if we suspect or detect any breach of security.
If you believe that information you provided to us is no longer secure, please notify us immediately using the contact information provided below.
We keep your personal information in identifiable form only as long as we need it for the lawful purpose for which we collected it or, if longer or shorter, to comply with law, to resolve disputes and to enforce agreements with you.
The Services are not directed to or intended for use by minors. Consistent with the requirements of the Children’s Online Privacy Protection Act, if we learn that we have received any information directly from a child under age 13 without his or her parent’s verified consent, we will use that information only to respond directly to that child (or his or her parent or legal guardian) to inform the child that he or she cannot use the Services.
HOW TO CONTACT US
Please contact us at [email protected] , or;
Citizen Health Project, Inc.
6641 Hwy 98 Suite 200
Hattiesburg, MS 39402