Privacy Policy

Your Privacy Rights

Your privacy and the security of your personal information are important to us. We want you to be as comfortable as possible visiting our Website and using our Application and Online Products.  This Privacy Policy governs our website www.lifestartseminars.com (our “Website”), Application, and Online Products, and explains how we collect your personal information, how we protect such information, and the choices you have concerning the use of such information. Please read this Privacy Policy carefully. Except as LifeStart Seminars specifically discloses in this Privacy Policy, we will not sell, share, license, trade, or rent your personal information to others.

We may amend this Privacy Policy from time to time. We will post any changes to this Privacy Policy here so that you will always know what information we gather, how we might use that information, and whether we will disclose that information to anyone. Please refer back to this Privacy Policy on a regular basis. By using our Website or any of our products, offerings, features, tools or resources that we provide on our Website or Application (collectively, our “Online Products”), including our products or offerings for personal digital assistants or other handheld or mobile devices (collectively, our “Handheld Products”), you agree to the terms of this Privacy Policy.

Please remember that this Privacy Policy applies only to information collected by our Website, Application, or through our Online Products. We are not responsible for the privacy of any information, including information about your health or medical conditions, you reveal or post in any public forum (e.g., message board, blog, personal page, etc.) or through the “Public Profile” feature available on our Website, or for the privacy practices of websites that are operated or owned by third parties.  We reserve the right to republish your postings on any public forum, blog, or meal library in any format.

BY USING OUR WEBSITE, YOU SIGNIFY YOUR ACCEPTANCE OF THIS PRIVACY POLICY. IF YOU DO NOT AGREE TO THIS PRIVACY POLICY, YOU SHOULD NOT USE OUR WEBSITE OR APPLICATION. YOUR CONTINUED USE OF OUR WEBSITE OR APPLICATION FOLLOWING THE POSTING OF CHANGES TO THIS PRIVACY POLICY WILL MEAN THAT YOU ACCEPT THOSE CHANGES.

WHAT INFORMATION ABOUT YOU IS COLLECTED ON OUR WEBSITE, APPLICATION, OR THROUGH OUR ONLINE PRODUCTS?

We collect two types of information: personally identifiable information and non-personally identifiable information.

Personally Identifiable Information.

Personally identifiable information is information that identifies you or can be used to identify or contact you (“Personally Identifiable Information”). Such Personally Identifiable Information may include your name, address, email address, telephone number, birth date (primarily for eligibility purposes) and information required for billing, payment, and shipping purposes. We may request Personally Identifiable Information from you when you register on our Website, write to us via our contact form on the Website, subscribe to our Online Products, or in connection with other Online Products we may make available on our Website or Application from time to time. In all of these cases, we will collect Personally Identifiable Information from you only if you voluntarily submit such information to us. Unless you give us permission to do so, we will not sell, share, license, trade or rent your Personally Identifiable Information other than as specified in this Privacy Policy.

You do not have to provide us with any Personally Identifiable Information to visit our Website. However, if you choose to withhold requested information, you may not be able to visit all sections of our Website or use all of our Application or Online Products, such as subscribing to our community or using the tools available to members.

Non-Personally Identifiable Information.

When you become a registered user of our Website, and become a member of the LifeStart Seminars community, we also may collect information that by itself cannot be used to identify or contact you, such as demographic information (like age, profession or gender), your relationship to the LifeStart Seminars programs, and health information (“Non-Personally Identifiable Information”). Non-Personally Identifiable Information may also include user IP addresses, browser types, domain names, and other anonymous statistical data involving the use of our Website, Application, and Online Products. Non-Personally Identifiable Information is used to help us understand who uses our Website and to improve and market our Website, Application, and Online Products.

Information from Other Sources.

We may also supplement the information we collect with information from other sources to assist us in evaluating and improving our Website, Application, and Online Products, to determine your preferences so that we can tailor our Website, Application, and Online Products to your needs.

WHERE AND WHEN IS INFORMATION COLLECTED ON OUR WEBSITE, APPLICATION, OR THROUGH OUR ONLINE PRODUCTS (INCLUDING THROUGH THE USE OF COOKIES AND ACTION TAGS)?

We may collect information (including information that is Personally Identifiable Information) from you in different manners and at different places and times on our Website or Application, such as when you become a member of the LifeStart Seminars community. We also may collect information from you in connection with, or through, our Website, Application, and Online Products. The following is a description of the areas and/or manners in which we primarily collect information about you.

Becoming a Subscriber

In order to access certain sections of our Website, you must first complete certain steps to become a subscriber. During these steps, you may be required to provide us with information (including Personally Identifiable Information) such as name, date of birth, zip code and email address, and payment and billing information. This information is used to help us understand who uses our Website, to improve our Website and our Online Products, to contact users about requested Applications and/or for subscription billing purposes.

Cookies and Action Tags.

We also collect Non-Personally Identifiable Information passively using “cookies, ”“action tags,” and similar methods.

“Cookies” are small text files that are placed on your computer or mobile device in order to identify (i) your Web browser, (ii) the activities of your computer on our Website and (iii) your activity in connection with our advertisements and other marketing and promotional efforts. Cookies may be used to:

• assist you in using our Website, Application, and Online Products (e.g., to save you time by not having to reenter your name upon each visit to our Website), and
• allow us to statistically monitor how you are using our Website, Application, and Online Products for purposes of improving our online offerings.

We also may use cookies to conduct marketing and promotional efforts, or to determine the popularity of certain content.

You do not have to accept cookies to use our Website, however, you may not be able to use certain products, offerings, features, or resources of our Website (such as “remember me”) if you do not accept cookies. Although most browsers are initially set to accept cookies, you may reset your browser to notify you when you receive a cookie or to reject cookies generally. Most browsers offer instructions on how to do so in the “Help” section of the toolbar.

Online Products.

We collect information, some of which may be Personally Identifiable Information, that you voluntarily provide to us when you choose to use some of our Online Products (some of which are available on a subscription basis) such as the tracking tools, calendar and reminders, love and support feed, public and private forums, blogs, meal libraries and the “Private Profile” feature. Some of these Online Products may ask you for health-related information; we collect this information in order to help you track your progress against your health-related goals.

Handheld Products.

Information is also collected when you use our Handheld Products, including the software application needed to utilize the Handheld Products on your handheld device (the “Application”). During the installation of the Application and subsequent synchronizations, we collect Non-Personally Identifiable Information concerning your device (such as the specific type of operating system and hardware you have, and the amount of free and total memory) and the Application’s files on your device.

Our Handheld Products also collect information about your usage of the Application (such as the dates you last synced with the Internet or the dates you last used certain features). When you sync your device with the Website, we store some of this information.

Log Files.

We also collect Non-Personally Identifiable Information through our Internet log files, which record data such as user IP addresses, browser types, domain names, and other anonymous statistical data involving the use of our Website. This information may be used to analyze trends, to administer the Website, to monitor our Website’s use, and to gather general demographic information. We may link this information to Personally Identifiable Information for these and other purposes such as personalizing your experience on our Website and evaluating our Online Products in general.

User-Generated Content: Public Forums, Blogs, Meal Libraries, and Other Postings

In order to make a posting on our Website, you will be asked to sign in with your member login information. We do not use this information in any way other than to recognize you for postings nor do we disclose this information to any third parties.

With regard to public and private forums, blogs, and meal libraries, your email address is not visible on the boards; however, other users are able to send you email via your user name without your email address being displayed. We do not share this information with any third parties unless required by authorized law enforcement agencies when required.

Do remember that whatever you post on the public forums, blogs, or meal libraries, or other public pages is considered public knowledge and that you should always use caution when posting. Avoid posting your home address or phone number on any public board, blog, chat, or other public page on our Website. Although one must be a registered user to post messages the public and private forums, blogs, and meal libraries, the public forums, blogs, and meal libraries are public and may be read by non-registered users.

Email or Refer a Friend.

Through our referral tools for informing a friend about our Website, or our Application, we will automatically send your friend a one-time email containing the information you request to be sent. If you elect to use these referral tools, we will collect from you certain Personally Identifiable Information about your friend which you have provided, such as your friend’s name and email address. We do not store your friend’s information or use it for any other purpose.

DO WE COLLECT INFORMATION FROM CHILDREN UNDER 13 YEARS OF AGE?

We are committed to protecting the privacy of children. Our Website and Online Products are not designed for or directed to children under the age of 13. We do not collect Personally Identifiable Information from any person we actually know is under the age of 13. We urge all parents or guardians to participate in their children’s exploration of the Internet, and to teach their children about protecting their personal information while online.

WHAT DO WE DO WITH THE INFORMATION WE COLLECT?

In general, we use the information collected on our Website and through our Application to help us understand who uses our Website, Application, and Online Products and how they are used, to assist you in using our Website, Application and Online Products, to improve our Website, Application, and Online Products, and for subscription billing and shipping purposes, if applicable. With respect to our Handheld Products, for example, we may use such information, among other things, to ensure that your handheld device is supported and that it has enough room for the Application, and to confirm which versions of the Application’s files are installed on your device.

If you become a member of our Website, we may use your information to send you a welcoming email that may confirm your username. If you “opt-in” (for example, if you check a box, or if the box is pre-checked, you do not opt out by unchecking the box) we may send you electronic newsletters, contact you about products, services, information and news that may be of interest to you, and provide you with targeted feedback. If you no longer desire to receive these communications, we will provide you with an option to change your preferences. In addition, if you identify yourself to us by sending us an email with questions or comments, we may use your information (including Personally Identifiable Information) to respond to your questions or comments, and we may file your questions or comments for future reference. We may also use the information collected to contact you about important service announcements and updates regarding our Website or Application or, if you are a subscriber, about your billing account status. You will not be able to opt-out of these service announcements and updates as they contain important information relevant to your use of our Website and/or our Application and are not promotional in nature. (If you do not wish to receive these service announcements, you may cancel your account with us and delete the Personally Identifiable Information maintained about you on our systems by contacting our Privacy Coordinator at the address set out below.)

We may also use the information gathered on our Website and through our Application to perform statistical analysis of user behavior, to analyze and evaluate issues relating to health and lifestyle, or to evaluate and improve our Website, Application, and Online Products.

WHEN DO WE DISCLOSE INFORMATION TO THIRD PARTIES?

Except as set forth in this Privacy Policy or as specifically agreed to by you, we will not disclose any information we gather from you on our Website.

Research Affiliates

We may disclose information (including Personally Identifiable Information) about you to our Research Affiliate, CompassHealth Consulting, Inc. (“CHC”). CHC is a non-profit organization that reviews the data collected on our Website, Application, and Online Products to help us improve our Website, Application, and Online Products and to determine the effectiveness of LifeStart Seminars in supporting sustainable lifestyle changes.

Laws and Legal Rights.

We may also disclose your information (including Personally Identifiable Information) if we believe in good faith that we are required to do so in order to comply with an applicable statute, regulation, rule or law, a subpoena, a search warrant, a court or regulatory order, or other valid legal process. We may disclose Personally Identifiable Information in special circumstances when we have reason to believe that disclosing this information is necessary to identify, contact or bring legal action against someone who may be violating our Terms of Use or our Subscription Agreement, or to protect the safety and/or security of our users, our Website or Application, or the general public.

Outside Contractors.

We may employ independent contractors, vendors and suppliers (collectively, “Outside Contractors”) to provide specific services and products related to our Website or Applications, such as providing payment processing and fraud screening, developing applications for our Website and e-mail services, and shipping goods ordered from the Website. These Outside Contractors may sometimes have limited access to information collected on our Website, including your Personally Identifiable Information, in the course of providing products or services to us. Access to your Personally Identifiable Information by these contractors is limited to the information reasonably necessary in order for the Outside Contractors to perform their limited function for us. We also require that these Outside Contractors (i) protect the privacy of your Personally Identifiable Information consistent with this Privacy Policy and reasonable security procedures, and (ii) not use or disclose your Personally Identifiable Information for any purpose other than providing us with products or services for which we contracted.

[Note: If and when LifeStart Seminars has 20 or more employees, there are certain additional disclosures we should make if you provide any personal identifying information to third parties for direct marketing purposes.]

Web Analytics Services & Tracking

The Website uses the third-party tracking and analytics service Google Analytics and may use other similar services in the future (collectively, “Analytics Service Providers”).  The information collected about your use of the Website (including your IP address) will be transmitted to and stored by the Analytics Service Providers  on servers in the United States.  The Analytics Service Providers  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.  The Analytics Service Providers may also transfer this information to third parties when they are required to do so by law, or where such third parties process the information on the Analytics Service Providers’ behalf.  You may refuse the use of cookies as and subject to the limitations discussed above.  By using the Website, you consent to the processing of data about you by our Analytics Service Providers in the manner and for the purposes set forth in this paragraph.

Sale of Business.

We reserve the right to transfer information to a third party in the event of a sale, merger or other transfer of all or substantially all of the assets of LifeStart Seminars provided that the third party agrees to adhere to the terms of this Privacy Policy. We will notify users of any such transfer through notice on our site and through email.

DOES THIS PRIVACY POLICY APPLY WHEN YOU LINK TO OTHER WEBSITES?

Our Website does not currently contain links to third-party websites, except for a link www.compasshealth.net, the website of our Research Affiliate.  This Privacy Policy applies to www.compasshealth.net.  [Please let us know if you do not want this policy to apply to compasshealth.net ]

IS THE INFORMATION WE COLLECT SECURE?

We want your information (including Personally Identifiable Information) to remain as secure as possible. We strive to provide secure transmission of your information from your computer to our servers through industry-standard techniques. To help ensure the integrity and privacy of the Personally Identifiable Information you provide to us via the Internet at the time you elect to become a registered user or subscribe to our Online Products, we use Secured Socket Layer (SSL) encryption technology in transmitting such Personally Identifiable Information over the Internet to our servers. We secure the Personally Identifiable Information you provide on servers located in controlled, secure environments, protected from unauthorized access, use, or alteration. Only employees who need access to your information to perform a specific task or function are granted access to such information. In addition, all employees must abide by this Privacy Policy and are kept up-to-date on security practices. Any employee who violates this Privacy Policy is subject to disciplinary action, up to and including termination.

Notwithstanding the above commitments to protect your information (including Personally Identifiable Information) from loss, misuse or alteration by third parties, you should be aware that there is always some risk involved in transmitting information over the Internet. There is also some risk that others could find a way to thwart our security systems. As a result, while we strive to protect your information, we cannot ensure or warrant the security and privacy of any information you transmit to us, and you do so at your own risk.

WHAT CHOICES DO YOU HAVE REGARDING THE COLLECTION, DISCLOSURE AND DISTRIBUTION OF PERSONALLY IDENTIFIABLE INFORMATION?

Except as otherwise described in this Privacy Policy, we will only use Personally Identifiable Information for the purposes described above or as otherwise disclosed at the time we request such information from you. You must “opt-in” and give us permission to use your Personally Identifiable Information for any other purpose. You may change your preference and “opt-out” of receiving other communications by changing that option in the My Profile feature of our Website, following the directions provided in association with the communication.

Users of our Website are notified when Personally Identifiable Information is being collected by third parties on our Website. We do this so you can make an informed choice as to whether you should disclose information to a third party.

CAN YOU UPDATE OR CORRECT YOUR PERSONALLY IDENTIFIABLE INFORMATION?

You can always contact us at [email protected] in order to (1) review the Personally Identifiable Information that we have collected, (2) update or correct your Personally Identifiable Information, (3) change your preferences with respect to communications and other information you receive from us, or (4) delete the Personally Identifiable Information maintained about you on our systems, all by accessing the My Profile feature of the Website. Such updates, corrections, changes and deletions will not have an effect on other information that we maintain, or information that we have provided to third parties in accordance with this Privacy Policy prior to such update, correction, change or deletion.

You should be aware that it is not technologically possible to remove each and every record of the information you have provided to us from our systems. The need to back-up our systems to protect information from inadvertent loss means that a copy of your Personally Identifiable Information may exist in a non-erasable form that will be difficult or impossible for us to locate. We promise that promptly after receiving your request, all Personally Identifiable Information stored in databases we actively use and other readily searchable media will be updated, corrected, changed or deleted, as appropriate, as soon as reasonably practicable.

HOW WILL YOU KNOW IF THERE ARE ANY CHANGES TO THIS PRIVACY POLICY?

If we decide to change this Privacy Policy, we will post those changes on our Website so you are always aware of what information we collect, how we use it, and under what circumstances, if any, we disclose it. If at any point we decide to use Personally Identifiable Information in a manner significantly different from that stated in this Privacy Policy, or otherwise disclosed to you, at the time it was collected, we will notify you by email or otherwise, and you will have a choice as to whether or not we use your Personally Identifiable Information in the new manner. We may also make non-significant changes to our Privacy Policy that generally will not affect our use of your Personally Identifiable Information. If you do not agree to the terms of this Privacy Policy, you should not use our Website, Application, or Online Products.

WHOM DO YOU CONTACT IF YOU HAVE ANY PRIVACY QUESTIONS?

If you have any questions about our Privacy Policy or feel that we are not abiding by the terms of our posted Privacy Policy, please contact our Privacy Coordinator in any of the following ways:

Email our Privacy Coordinator at:

[email protected]

If you do not receive acknowledgment of your inquiry or your inquiry has not been satisfactorily addressed, you should then contact  TRUSTe at http://www.truste.org/consumers/watchdog_complaint.php, by postal mail at Watchdog Complaints, TRUSTe, 55 Second Street, 2d Floor, San Francisco, CA 94105, or by fax at (415) 520-3420. TRUSTe will then serve as a liaison with us to resolve your concerns.

 

Effective date: January 1, 2015