RENDLE® PRIVACY POLICY Last modified: January 2024
The privacy of your personal information is very important to RENDLE, Inc. (“RENDLE,” “Company,” “our”, “us” or “we”). This privacy policy describes how we protect and handle the personal information that you provide to us and that we obtain through our web-based service and platform made available via our website www.rendle.com and secured links (collectively, the “Site”). The use of information collected through the RENDLE Service (“Services”) is limited to the purposes described in this privacy policy.
INTRODUCTION
RENDLE provides comprehensive, dynamic online questionnaires and delivers detailed personalized feedback in resulting reports to help drive lifestyle improvement, specifically in the areas of sleep, stress management, happiness, mindfulness, exercise, nutrition and healthy weight management.
CREATING AN ACCOUNT AND RECORD: COLLECTION OF YOUR PERSONAL INFORMATION
In order to complete the RENDLE Questionnaires and receive Feedback you will be sent an email through a secured link or you will be given an account with an initial password. In this privacy policy, “Personal Information” means information that can be used to contact or identify any individual, as well as other information you provide such as your gender, height, year of birth and weight. The Personal Information that you provide to RENDLE via the Services or authorize your employer, healthcare provider, or any third-party to provide to RENDLE, will be used as described in this privacy policy. We will use our website to provide the Services to you. If you choose to send an email or other communications to us, we may retain those communications in order to process your inquiries, respond to your requests, and improve our Services.
INFORMATION RELATED TO OUR SERVICES
We collect information for employers and other organizations, (“Clients”) and you, their employees and members. RENDLE may share Personal Information with companies that help us provide our Services (for example, our website hosting company). RENDLE may retain Personal Information we process on behalf of our Clients for as long as needed to provide Services to our Client. RENDLE may retain and use this Personal Information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.
INFORMATION COLLECTED AUTOMATICALLY
Our servers can automatically record certain information about how a person uses our Services (we refer to this information as “Log Data”), including both account holders and non-account holders (either, a “User” or “user”). Log Data may include information such as a User's Internet Protocol (IP) address, browser type, operating system, the web page that a User was visiting before accessing our Services, the pages or features of our Services which a User browsed and the time spent on those pages or features, search terms, the links on our Services that a User clicked on and other statistics. We may use this information to administer the Services and we analyze (and may engage third parties to analyze) this information to improve and enhance the Services, by expanding their features and functionality, and tailoring them to our Users' needs and preferences.
INFORMATION COLLECTED THROUGH GOOGLE ANALYTICS
If you’re a visitor to our website www.rendle.com, we may use Google Analytics, a web analytics service provided by Google, Inc. (“Google”) to collect certain information relating to your use of the Site. Google Analytics uses “cookies”, which are text files placed on your computer, to help the website analyze how users use the site. The information generated by the cookie about your use of the website (including your IP address) will be transmitted to and stored by Google on servers in the United States. Google will use this information for the purpose of evaluating your use of the website, compiling reports on website activity for website operators and providing other services relating to website activity and internet usage. Google may also transfer this information to third parties where required to do so by law, or where such third parties process the information on Google’s behalf. Google will not associate your IP address with any other data held by Google. You may refuse the use of cookies by selecting the appropriate settings on your browser, however please note that if you do this you may not be able to use the full functionality of this website. By using this website, you consent to the processing of data about you by Google in the manner and for the purposes set out above. For more information regarding Google Analytics please visit Google's website, and pages that describe Google Analytics, such as www.google.com/analytics/learn/privacy.html.
HOW WE USE YOUR PERSONAL INFORMATION
We use Personal Information to provide the Services as described in this privacy policy. We do not use or disclose your Personal Information except as described in this privacy policy. We may use personal information to:
· email you access to your personalized lifestyle assessments through a secured link and questionnaire;
· provide you with personalized results and lifestyle-related recommendations;
· track your participation and see if you are eligible for a reward or incentive;
· respond to your questions and requests.
HOW WE CREATE AND USE AGGREGATED DATA
We create “Aggregate Data” using anonymized individual data sources. Anonymization is a data processing technique that removes or modifies all personally identifiable information; it results in anonymized data that cannot be associated with any one individual. Aggregate Data records are a compilation of anonymous data sources of an entire population or segment of a population. Aggregate data refers to information that is compiled into data summaries or summary reports, for the purposes of statistical analysis or benchmarking and measuring the progress of a population as a whole.
HOW WE USE LOG DATA
We may use Log Data gathered from Users of the Services and related statistics to improve the Services, and for research and analysis purposes. We may also provide this information to our partners for such purposes. This data does not include Personal Information.
· We use Log Data to analyze trends, to administer the Services, to track users' movements around the services and to gather demographic information about our user base as a whole.
· We may link Log Data to personal information in order to provide personalized features to users of the services.
We may use third-party tracking services that use cookies to track non-personally identifiable information about users in aggregate. We may also share aggregated information and non-identifying information with third parties for industry analysis, demographic profiling and other similar purposes.
SHARING YOUR PERSONAL INFORMATION WITH EMPLOYERS
We will never share Personal Information with your employer. Your employer will only have access to Aggregate Data which has been anonymized at the individual level.
COMPLIANCE WITH LAW AND OUR OBLIGATIONS
We may access and/or disclose your Personal Information if we believe such action is necessary to: (a) comply with the law or legal process served on us; (b) protect and defend our rights or property (including the enforcement of our agreements); or (c) act in urgent circumstances to protect the personal safety and welfare of Users or members of the public.
BUSINESS TRANSACTIONS
Information that we collect from our users, including personal information, is considered to be a business asset. As a result, if we go out of business or enter bankruptcy or if we are acquired as a result of a transaction such as a merger, acquisition or asset sale, your personal information may be disclosed or transferred to the third-party acquirer in connection with the transaction. If RENDLE is involved in a merger, acquisition, or sale of all or a portion of its assets, you will be notified via email and/or prominent notice on our Web site of any change in ownership or uses of your Personal Information, as well as any choices you may have regarding your personal information.
SHARING WITH SERVICE PROVIDERS
We may provide your Personal Information to companies that provide services to help us with our business activities and provision of the Services, which include such items as offering customer support. These companies are authorized to use your personal information only as necessary to provide these services to RENDLE and will be bound by the same privacy restrictions RENDLE has in place.
INFORMATION WE DISCLOSE WITH YOUR CONSENT OR AT YOUR REQUEST
We will share your Personal Information with third parties or third-party websites or platforms if you have expressly requested in writing that we do so.
ACCESS TO YOUR INFORMATION AND CHOICES
If you have questions about personal information we have about you or need to update your information, you can email us at privacy@rendle.com. You can opt-out of receiving marketing and promotional e-mails from us by using the opt-out or unsubscribe features contained in the e-mails.
LINKS TO OTHER WEBSITES
Our Site and Applications may from time to time include links to other websites whose privacy practices may differ from those of RENDLE. If you submit Personal Information to any third party websites, your information is governed by the policies of such websites. We encourage you to carefully read the privacy policy of any website you visit.
SECURITY OF YOUR PERSONAL INFORMATION
We are committed to protecting the security of your Personal Information. We use a variety of security technologies and procedures to help protect your personal information from unauthorized access, use, and disclosure. For example, we store the personal information you provide encrypted on computer servers with limited access that are located in controlled facilities. We restrict access to Personal Information to those RENDLE employees, contractors, and agents who need to know that information in order to operate, develop, or improve our Services. These individuals are bound by confidentiality obligations and may be subject to discipline, termination and criminal prosecution, if they fail to meet these obligations. We follow generally accepted standards to protect the Personal Information submitted to us, both during transmission and once we receive it. No method of safeguarding information is perfect, however, and we cannot and do not guarantee that your information will be 100% secure.
INTERNATIONAL TRANSFER
Your Personal Information may be transferred to, and maintained on, computers located outside of your state, province, country or other governmental jurisdiction where the privacy laws may not be as protective as those in your jurisdiction. If you're located outside the United States and choose to provide your personal information to us, we may transfer your personal information to the United States and process it there. By using and accessing our Site, residents and citizens of countries and jurisdictions outside of the United States agree and consent to the transfer to and processing of, personal information on servers located in the United States. They also agree that the protection of such information may be different than required under the laws of your residence or location.
NO INFORMATION FROM CHILDREN UNDER AGE 18
If you are under the age of 18, please do not attempt to participate in an assessment and/or register with us at this Site or provide any personal information about yourself to us. If we learn that we have collected personal information from a child under the age of 18, we will promptly delete that information. If you believe we have collected personal information from a child under the age of 18, please contact us at privacy@rendle.com.
CHANGES TO THIS POLICY
We may occasionally update this privacy policy. When we do, we will also revise the "last modified" date at the top of the privacy policy. For material changes to this privacy policy, we will notify you by placing a prominent notice on the home page of the Site and via Applications, or by sending you a notification directly via email. If you have specific questions regarding this privacy policy you can email us at privacy@rendle.com or alternatively you can periodically review this privacy policy in order to stay informed about how we collect, use and share your Personal Information and how we try to protect the Personal Information we collect.
GDPR
The General Data Protection Regulation (GDPR) is a regulation in EU law on data protection and privacy for all individuals within the European Union and the European Economic Area (EEA). Our data protection standards and procedures fulfill the requirements of GDPR.
HOW YOU CAN CONTACT US IF YOU WOULD LIKE TO DELETE YOUR DATA:
Under EU General Data Protection Regulation (GDPR) you are entitled to request us to erase any personal data we hold about you. You can email us at privacy@rendle.com if you would like to delete your data. We will respond to your request as quickly as possible. If you are contacting us on someone else’s behalf, we will need additional verification and consent from the data subject before we can process your request.
HIPAA
The Health Insurance Portability and Accountability Act of 1996 (HIPAA) is United States legislation that provides data privacy and security provisions for safeguarding medical information. HIPAA, like GDPR, relates to privacy and data security of personal information collected and requires data security processes and procedures to ensure privacy. HIPAA also includes the concept of portability whereby a user may transfer their information to another entity. Unlike GDPR, HIPAA pertains only to health-related personally identifiable information. Our data protection standards meet the requirements of HIPAA. Any questions or concerns can be addressed by contacting our privacy and compliance officer at privacy@rendle.com.
RENDLE® CALIFORNIA PRIVACY RIGHTS
Residents of the State of California have the right to request a list of all third parties to which a company conducting business in California has disclosed personally identifiable information during the preceding year for direct marketing purposes. We do not share your personally identifiable information with any third party for direct marketing purposes.
CCPA
The California Consumer Privacy Act (CCPA), enacted in 2018, creates new consumer rights relating to the access to, deletion of, and sharing of personal information that is collected by businesses. If you’re a California resident and you would like to access or delete your data or you would like more information, feel free to contact us at privacy@rendle.com. Keep in mind, we don’t sell any data. We never share any personal information, unless it’s with the user’s consent, in which case it’s a designated health coach or health professional that is helping that person to create healthier habits.
CONTACT INFORMATION
We welcome your comments regarding this privacy policy. If you have questions about this statement, please contact us by email: privacy@rendle.com