Sureify Lifetime Privacy Policy
Effective Date: January 2, 2019

OVERVIEW

This privacy policy describes the privacy practices for the Sureify Lifetime Application (the App). When we refer to “Sureify” “we,” or “our” in this policy, we are referring to the Sureify app. The App itself is accessed as a website application using a computer’s web browser, and as a mobile application downloaded to one’s mobile device.

Please review this App privacy policy carefully. It is intended to help you understand the information we collect, how we use it, who we share it with, and what choices you have.

When you submit information to or through the App, you consent to the collection, use, and processing of your information as described in this privacy policy. And, if you have not done so already, please also review the App’s Terms and Conditions and, for mobile devices, the App’s End User License Agreement. If you do not agree with any part of this privacy policy, the App’s Terms and Conditions, or the App’s End User License Agreement, please do not download or use the App.

THE APP IS NOT INTENDED FOR CHILDREN

The App is not directed toward or intended for use by children. Users under the age of 18, or the equivalent minimum age in the relevant jurisdiction, are not permitted to create accounts and use the App. Parents who believe that their child has submitted personal information to us and would like to have it deleted may contact us at support@sureify.com.

INFORMATION WE COLLECT

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

INFORMATION YOU PROVIDE US

ACCOUNT INFORMATION. Certain information is required to create an App account, such as your name, email address, password, date of birth, state of residence, your mobile telephone number, and the like.

ADDITIONAL INFORMATION YOU PROVIDE. To use or participate in certain App features, you may choose to provide us with additional information. For example, if you contact us or participate in a survey, poll, contest, promotion, or other similar activity we collect the information you submit such as your name, contact information, response, and message.
If you choose to connect your account on our App to your account on another service, we may receive information from the other service. For example, if you connect through our App to social media sites such as Facebook or Twitter, we may receive information like your name, profile picture, age range, language, email address, posts, pictures, information about your contacts, and other personal information you have separately provided to the social media sites. Your social media site may allow you to control what information you choose to share with the App. In addition, you can stop sharing with us the information from social media sites by removing our access to those sites.

INFORMATION WE RECEIVE FROM YOUR USE OF OUR APP

INFORMATION FROM CONNECTED DEVICES. If you choose to connect a device (wearable fitness device for instance) to the App, we will receive the information collected by that device. For example, your device may collect data like the number of steps you take, calories burned, weight, heart rate, sleep stages, and location. The data we receive varies depending on which device you use and what you choose to share with us through the App. When your device syncs with our App, data recorded on your device is transferred from your device to our App. You can stop sharing with us the information from such services and devices by removing our access to those services or disconnecting the device.

LOCATION INFORMATION. The App includes features which utilize precise location data, including GPS signals, device sensors, Wi-Fi access points, and cell tower IDs. We collect this type of data if you grant us access to your location. You can always remove our access using your mobile device settings. We may also derive your approximate location from your IP address. [If you choose to permit the App to access location information from your device, this information can be used to allow us to know your precise location and calculate motion (for example, how fast you are driving) and time (for example, when you are at a specific location).]

HOW YOU INTERACT WITH THE APP. When you use our App, we receive certain data showing your interaction within the App. This includes information about when you view or search content in the App, create or log into your account, pair your device to your account, or open or interact with an application such as a social media account via the App. We use this information for a variety of reasons as explained at the How We Use Information section below.

USAGE INFORMATION. We also collect data about the devices and computers you use to access the App, including IP addresses, browser type, language, operating system, 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.

INFORMATION COLLECTED BY USE OF COOKIES AND SPOTLIGHT TAGS

We allow third-party companies, such as Google Analytics and others, to use cookies and spotlight tags to collect certain usage information (Usage Information) when you visit the App website at www.sureify.com. Usage Information helps us analyze visitor activity on our websites and measure the performance of our online advertising campaigns. Usage Information may include browser type, device type, operating system, application version, the page accessed, the time, the preceding page views, and your use of website features.

COOKIES AND HOW WE USE THEM. Cookies store information on your computer by causing your web browser to ‘remember’ specific bits of information about your previous visits to our website. Cookies also allow you to access secured information, conduct secured transactions, and take advantage of promotional opportunities. Cookies allow us to use the cookies’ stored information to improve the App’s content and functionality.

Cookies also allow us to identify your device, which in combination with other information we collect, may allow us to identify you personally. Such personally identifiable information is stored in our protected systems and not in the cookie or on the Internet.

TYPE OF COOKIES WE USE. There are different types of cookies. We use what are referred to as session cookies. These are temporary and expire when you leave our website or are inactive for a specified length of time. Session cookies allow the website to recognize you as you navigate between pages during a single browser session.

ABOUT SPOTLIGHT TAGS. Spotlight tags analyze behavior of website visitors who have previously clicked or viewed one of our online advertisements. Spotlight tags collect anonymous, non-personally identifiable information.

HOW YOU CAN CONTROL DATA COLLECTED THROUGH COOKIES. The information collected through cookies depends on your web browser settings. Most web browsers automatically accept cookies, but permit your changing the settings prevent this. Doing so, however, may limit your access to certain sections and features of our App.

HOW WE USE INFORMATION

We may use the information we collect from your use of the App for any of the following purposes:

TO FACILITATE FUTURE CONVERSATIONS OR MAKE PRODUCT RECOMMENDATIONS
If your interactions within the App (e.g., clicking on educational or informative content) indicate you might be interested in, or have a need for, a certain product or service, this information may be used by us, or provided to one of our [advisors / agents / representatives] and used, to facilitate future conversations or to make product recommendations.
Similarly, if the information we receive from your social media sites (those sites that you have connected the App to) or your location data or other information collected through the App indicates that you have had a life event (e.g., a marriage, new job, or new child), we may use this information, or provide it to one of our [advisors / agents / representatives] to use, to facilitate future conversations or to make product recommendations.

TO DEVELOP, IMPROVE AND PERSONALIZE OUR PRODUCTS AND SERVICES
We use the information collected through your use of our App to provide you with the products and services you request; understand how you and other users interact with our services and App; track exercise, activity, and other trends; provide customer support; troubleshoot and protect against errors; perform data analysis and testing; conduct research and surveys; assess the effectiveness of, improve, and personalize advertising and other marketing and promotional activities; provide specific education and informative content that may be relevant to a given user; and, develop new features and services.

When you allow us to collect precise location information, we use that information to provide and improve features of the App such as showing you certain insights about your day-to-day activities.

For Customer Service, Security, to Detect Fraud or Illegal Activities, and for Archival Purposes in Connection with the Provision of the App

We use the information we collect to promote the safety and security of the App, our users, and other parties. For example, we may use the information to authenticate users, protect against fraud and abuse, respond to a legal request or claim, conduct audits, and enforce our terms and policies.

TO COMMUNICATE WITH USERS EITHER VIA EMAIL, TELEPHONE, TEXT (SMS) MESSAGES, MAIL, OR AS OTHERWISE AUTHORIZED BY YOU

We use information collected from your use of the App to send you service and product notifications and inform you of new features or products we think may be interest. 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. We also use your information to respond to you when you contact us.

TO BETTER RESPOND TO USER PREFERENCES, INCLUDING LANGUAGE AND LOCATION CUSTOMIZATION, PERSONALIZED HELP, OR OTHER RESPONSES TO USERS’ USAGE OF THE APP

We use the information we collect to personalize the App, make inferences, and show you more relevant content. For example, if you have connected a wearable fitness device, information like your height, weight, gender, and age allows us to personalize your daily exercise and activity statistics like the number of calories you burned and the distance you traveled. If your device relays your sleep data, we may make inferences about your sleeping patterns and provide you with customized insights to possibly help improve your sleep. Similarly, we may personalize exercise and activity goals for you based on the goals you previously set and your historical exercise or activity data.

TO COMBINE WITH INFORMATION RECEIVED FROM OTHER SOURCES INCLUDING OTHERS’ USE OF THE APP
Information collected through the App may be used in an aggregated or individualized manner in combination with information from other sources. In an individualized manner, we may combine information from your use of the App with other information we have or receive from third parties, including one or more of our [advisors / agents / representatives], in order to facilitate future conversations or make product recommendations.

On an aggregated basis, information collected from your use of the App may be anonymized and deidentified of all of your personally identifiable information (removing your name, address, phone number, email address, date of birth, and the like) and combined in one or more databases with similarly deidentified information from other App users as well as other sources. Such databases may be used for data analysis and research for a variety of different business purposes.

HOW INFORMATION IS SHARED AND DISCLOSED

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

WHEN YOU AGREE OR DIRECT US TO SHARE. You may direct us to disclose your information to others, such as when you use the Apps forums and other social tools. For certain information, we provide you with privacy preferences in account settings and other tools to control how your information may be accessed by other users on the App. [If you choose to participate in a challenge, information like your profile photo, points earned, total steps in the challenge, personal statistics, and achievements, is not governed by your privacy preferences and will be visible to all other challenge participants.]
You may authorize us to share your information with others, for example, with a third-party application when you give it access to your account. Use of your information by an authorized third-party application will be governed by third-party application’s privacy policies and terms of use. You can revoke your consent to share with third-party applications, including wellness programs, using your account settings.

FOR PROCESSING WITHIN SUREIFY. We may share information we collect about you with other member companies within Sureify for a variety of purposes. For example, we share information to assist us in providing service and account maintenance of the App and other products and services you may have with Sureifty to help us design and improve products, to offer products and services that may be of interest to you, and to provide educational or informative content that may be relevant to you.

FOR PROCESSING EXTERNALLY BY OUR THIRD-PARTY SERVICE PROVIDERS. We may share information we collect from you with external third-party service providers, and other partners who process information for us, based on our instructions, and in compliance with this privacy policy and any other appropriate confidentiality and security measures. These partners provide us with a variety of services, including customer support, App hosting, information technology, data analysis, research, and surveys.

FOR USE BY YOUR SUREIFY ADVISOR / AGENT / REPRESENTATIVE]. We may share information we collect from you with your Sureify [advisor / agent / representative]. This information is provided to your [advisor / agent / representative] to facilitate conversations you have with your [advisor / agent / representative]. and to help your [advisor / agent / representative] identify products or services that might be of interest to you.

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 App or the physical safety of any person.

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 before transferring any personal information to a new entity.

HOW TO ACCESS OR DELETE YOUR PERSONAL INFORMATION

We provide you with account settings and tools to access and manage the personal information associated with your account. We store your personal information associated with your account until your account is deleted. You can delete your account at any time by contacting support@sureify.com. Please note that it may take up to [thirty (30) days] to delete your account information, and we may preserve an archived copy for legal reasons or to prevent harm, including as described in the How Information Is Shared and Disclosed. For clarity, derived anonymized deidentified information aggregated in one or more database with similarly deidentified information is not deleted when your account deletes.

INFORMATION SECURITY

We work hard to keep your data safe. We use a combination of technical, administrative, and physical controls to maintain the security of your data. We have comprehensive security practices and procedures in place to protect data entrusted to us. No method of transmitting or storing data is completely secure, however. If you have a security-related concern, please contact support@sureify.com.

EFFECTIVE DATE AND CHANGES TO THIS POLICY

The Effective Date of this privacy policy is set forth at the top of this page. Whenever possible, we will notify you before we make material changes to this policy and give you an opportunity to review the revised policy before deciding if you would like to continue to use the App. Your continued use of the App after the Effective Date constitutes your acceptance of the amended privacy policy. The amended privacy policy supersedes all previous versions. Archived versions of this privacy policy are available online.

HOW TO CONTACT US

If you have questions about this policy, or about our use of your information, please contact us at support@sureify.com
1100 Lincoln Ave, STE 240, San Jose, CA 95125