Effective April 29, 2019
We know that the privacy of your personal information is important to you, and that you are trusting us with some of that information. We want to be transparent about how we use it and protect it, how you can control it, and how to get in touch with our team if you have questions or concerns. In short, your privacy is very important to us.
Specifically, we’re going to cover these topics:
HealthyWage creates and implements weight loss challenges, step tracker challenges, and diet bets that employ gamification, financial incentives and prizes, positive peer pressure and other techniques to help make your weight loss or fitness plan more successful. Our programs let you get paid to lose weight or get paid to get healthy. Our programs require only minimal information from participants, as described below, and we safeguard that information very carefully.
When you use the Services, we collect and develop the following types of information.
In order to create an account on our Services, you must provide an email address and password. This is the only information you have to provide to create an account with us, but more information is required if you choose to join a challenge or get specific prize offers for the HealthyWager -- see below.
WHEN YOU JOIN A CHALLENGE
When you join a challenge, you will have to provide some additional information, including your name, date of birth, country, gender, weight and height; you may also have to provide proof, as required by the rules of the particular challenge(s) and the referees, related to the relevant goals in the challenge(s) -- e.g., for typical weight loss challenges, you will have to provide proof of your starting and ending weight. To help improve your experience or enable certain features of the Services, you may choose to provide us with additional information, like your logs for food, weight, sleep, water, etc.
WHEN YOU PLAY WITH THE HEALTHYWAGER PRIZE CALCULATOR
If you want to see specific prize offers for the HealthyWager (even before you sign up for a HealthyWager), you must provide gender, height, weight, waist size and information about your weight loss goal(s).
WHEN YOU WIN A CHALLENGE
If you win a challenge, you will have to provide an electronic signature that certifies that you did not cheat, and we may, depending on the type of challenge you won and the prize amount, ask you to show photo identification and proof of height, and, in rare cases, you may be asked to provide additional proof.
WHEN YOU WANT TO CASH OUT
If you've won at least one challenge and want to cash out, you will need to provide information so we can pay you -- e.g., you will need to provide your PayPal email address or the physical address where you want to receive a check.
Since HealthyWage is a social experience, you may wish to expand your account and provide additional information, such as a profile photo, challenge-specific goals and other such information. You may also connect with friends who have already joined HealthyWage or invite friends by providing their email addresses, accessing social networking accounts, or using the contact list on your mobile device. We do not store your contact list and delete it after it is used for adding contacts as friends.
If you contact us or participate in a survey, contest, or promotion, we collect the information you submit such as your name, contact information, and message.
INFORMATION FROM THIRD-PARTY SERVICES
If you choose to connect your HealthyWage account to your account on another service, such as a step tracking device, we may receive information from the other service. For example, if you connect to Facebook, we may receive information like your name, profile picture, age range, language, email address, and friend list. As another example, if you connect your account to Fitbit, we may receive information like the number of steps you take each day. You can stop sharing the information from the other service with us by removing our access to that other service.
PAYMENT AND CARD INFORMATION
When you make a payment on HealthyWage, you may provide payment information such as your payment card or other payment details. We use Payment Card Industry compliant third-party payment services and we do not store your credit card information.
INFORMATION WE DEVELOP
When you use our Services, we may develop and store certain information about you for your benefit or to improve our Services. For example, we may use your weight and height to calculate your BMI.
When you access or use our Services, we receive various kinds of usage data. This includes information about your interaction with our website, mobile apps and other aspects of the Services. For example, when you view or search content, install applications, create or log into your account, sync your device with your account, or open or interact with a HealthyWage application, we receive and track that information.
We also collect data about the platforms, browsers, devices and computers you use to access our Services, including browser type, city, region, country, language, operating system, IP addresses, fitness device or mobile device information (including device and application identifiers), referring web page, pages visited on our Services and sometimes on third party services and cookie information.
COOKIES AND SIMILAR TECHNOLOGIES
One of the primary purposes of cookies is to provide a convenience feature to save you time. For example, if you personalize a web page, or navigate within a site, a cookie helps the site to recall your specific information on subsequent visits. Using cookies simplifies the process of delivering relevant content and eases site navigation. When you return to the web site, you can retrieve the information you previously provided, so you can easily use the site's features that you customized.
You have the ability to accept or decline cookies. Most web browsers automatically accept cookies, but you can usually modify your browser setting to decline some or all cookies if you prefer. HealthyWage is committed to providing you choices to manage your privacy and sharing. However, HealthyWage does not recognize or respond to browser-initiated Do Not Track signals. To learn more about Do Not Track signals, you can visit https://allaboutdnt.com. Not accepting cookies may make certain features of the Services unavailable to you. HealthyWage may also use your IP address to identify you, to administer the Services and to assist in diagnosing problems with HealthyWage's servers.
SPECIAL CATEGORIES OF PERSONAL DATA
To the extent that information we collect is health data or another special category of personal data subject to the European Union’s General Data Protection Regulation (“GDPR”), we ask for your explicit consent to process the data. We obtain this consent separately when you take actions leading to our obtaining the data, for example, when you pair your device to your account, grant us access to your exercise or activity data from another service. You can use your account settings and tools to withdraw your consent at any time, including by stopping use of a feature, removing our access to a third-party service, unpairing your device, or deleting your data or your account. If you need any help changing, removing or obtaining your data, please just ask (we are happy help): firstname.lastname@example.org.
We use the information we collect for the following purposes:
Your information, including your profile, name, photos, friendships, members you follow and who follow you, clubs you belong to, your activities, and likes and comments you give and receive will be shared on HealthyWage. Your comparative information (like your place in the leaderboards) and the fact of your victory and information about it may also be shown to others. We will not publish a success story about you without your permission. We also keep your weight and age private (though we may place you in a group of people with similar weights and/or ages, but only those fellow group members will know about your presence in such a group).
We may also use your information to credit or accept payments, provide support related to the Services, protect and enforce our Terms of Service and Services Agreement, promote safety, and communicate with you. Additionally, your information may be shared with third parties, as set forth below. We do not sell your information to third parties.
HealthyWage is a social experience, and other people will, of course, see the things you choose to post or share (that’s usually the whole point of posting and sharing). In addition, people in your challenges will be able to see your name and photo and certain non-sensitive stats, like, for example, your rank (if applicable) and your percentage weight loss (if applicable), but not your actual weight (unless you choose to make it known). People in your challenge will find out whether you won, but we will not publicly share your success story without your permission.
We also use your information to analyze, develop and improve the Services. To do this, HealthyWage may use third party analytics providers to gain insights into how our Services are used and to help us improve the Services. We may also use your information to market the Services.
HealthyWage may de-identify or aggregate the content you make available in connection with the Services, in ways that do not personally identify you. Examples of such aggregated information or statistical data include information about equipment, usage, demographics and performance. HealthyWage may use, sell, license, and share this information with third parties for research, business, civic or other purposes.
We use your information to communicate with you about the Services, send you marketing communications (where you have agreed to receive such messages), or let you know about new features or updates to our Terms of Service and Subscription Agreement. We also use your information to respond to you when you contact us. HealthyWage will use your information to communicate with you, for example by sending you notifications.
We use the information we collect to promote the safety and security of the Services and HealthyWage, our users and participants, and other parties. For example, we may use the information to authenticate users, facilitate secure payments, and protect against fraud and abuse.
We may use the information to respond to a legal request or claim, conduct audits, and enforce our terms, Services Agreement and policies, including collecting an obligation owed to us.
For personal data subject to the GDPR, we rely on several legal bases to process the data. These include when you have given your consent, which you may withdraw at any time using your account settings or by contacting us; when the processing is necessary to perform or enforce a contract with you, like the Terms of Service or Services Agreement; and our legitimate business interests, such as in improving, personalizing, and developing the Services, marketing new features or products that may be of interest, and promoting safety and security as described above.
We may share your information with third parties who provide services to HealthyWage such as supporting and improving the Services, promoting the Services, processing payments, or fulfilling orders. These service providers will only have access to the information necessary to perform these limited functions on our behalf and are required to protect and secure your information. We may also engage service providers to collect information about your use of the Services over time on our behalf so that we or they may promote HealthyWage or display information that may be relevant to your interests on the Services or other websites or services.
Subject to your decisions and privacy settings, your information and content may be publicly accessible. For example, HealthyWage may allow you to share your information publicly. If you choose to do so, then that information will be public.
When you choose to use third party apps, plugins, or websites that integrate with the Services, they may receive your information and content, including your personal information, photos, and your activity data. Information collected by these third parties is subject to their terms and policies. HealthyWage is not responsible for the terms or policies of third parties.
We may preserve and share your information with third parties, including law enforcement, public or governmental agencies, or private litigants, within or outside your country of residence, if we determine that such disclosure is reasonably necessary to comply with the law, including to respond to court orders, warrants, subpoenas, or other legal or regulatory process. We may also retain, preserve or disclose your information if we determine that disclosure is reasonably necessary or appropriate to prevent any person from death or serious bodily injury, to address issues of national security or other issues of public importance, to prevent or detect violations of our Terms of Service or Services Agreement or fraud or abuse of HealthyWage or its members, or to protect our operations or our property or other legal rights, including by disclosure to our legal counsel and other consultants and third parties in connection with investigations about fraud, collections or actual or potential litigation
We may share your information with third parties when we forward Digital Millennium Copyright Act (DMCA) notifications, which will be forwarded as submitted to us without any deletions.
If you are participating through an employer, then HealthyWage may, at the request of such employer, to the extent permitted by relevant laws and regulations, share participant information with the company.
Our team will promptly assist you with accessing and controlling your personal data, as described below, regardless of where you live. If you live in the European Economic Area, United Kingdom, and Switzerland (the “Designated Countries”), you have a number of legal rights with respect to your information, which our team will promptly help you use and enforce, as outlined below.
By logging into your account, you can access your personal information, including your dashboard with your weight and/or step data. If you have any trouble finding what you need, please reach out to us and we will be glad to promptly assist.
You can change and delete many pieces of your personal information in the dashboard and account settings. For instance, you can edit or delete the profile data you provide and delete weight entries and social posts you've made. If you have any trouble finding or editing what you need, or if you wish to delete your account, please reach out to us and we will be glad to promptly assist. If you choose to delete your account, please note that while most of your information will be deleted within 30 days, it may take up to 90 days to delete all of your information, like data stored in our backup systems. This is due to the size and complexity of the systems we use to store data. We may also preserve data for legal reasons or to prevent harm or to collect debts and enforce legal rights and obligations, including as described in the How We Use Information section and the Circumstances When We Share Information section. Please also note that it may be impossible to delete your account if there is a balance owing from you to us or from us to you, and the balance may need to be resolved before we can delete your account.
We give you account settings and tools to control our data use. For example, using your notification settings, you can limit the notifications you receive from us; and under your application settings, you can revoke the access of third-party applications that you previously connected to your HealthyWage account. If you live in a Designated Country, in certain circumstances, you can object to our processing of your information based on our legitimate interests, including as described in the How We Use Information section. You have a general right to object to the use of your information for direct marketing purposes. Please see your notification settings to control our marketing communications to you about our Services. If you have any trouble finding what you need, please reach out to us and we will be glad to promptly assist.
In addition to the various controls that we offer, if you reside in a Designated Country, you can seek to restrict our processing of your data in certain circumstances. Please note that you can always delete your account at any time (subject to the notes in the Editing and Deleting Data section above). If you need further assistance regarding your rights, please contact our Data Protection Officer at email@example.com, and we will consider your request in accordance with applicable laws. If you reside in a Designated Country, you also have a right to lodge a complaint with your local data protection authority.
We keep your account information, like your name, email address, and password, for as long as your account is in existence because we need it to operate your account. In some cases, when you give us information for a feature of the Services, we delete the data after it is no longer needed for the feature. For instance, when you provide your contact list for finding friends on the Services, we delete the list after it is used for adding contacts as friends. We keep other information, like your exercise or activity data, until you use your account settings or tools to delete the data or your account because we use this data to provide you with your personal statistics and other aspects of the Services. We also keep information about you and your use of the Services for as long as necessary for our legitimate business interests, for legal reasons, and to prevent harm, including as described in the How We Use Information and How Information Is Shared sections.
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, all participant data is collected and transmitted over secured connections using 256-bit encryption. All pages on the HealthyWage website are served over TLS. Our databases are isolated from the Internet and are accessed over a virtual private network. All payment data is handled following rigorous Payment Card Industry (PCI) standards set by VISA, MasterCard, and American Express. We perform a periodic security review with assistance from a third-party security firm to ensure we operate securely and follow industry best practices. We operate our website and application using servers owned and protected by Amazon Web Services (AWS). AWS is the global leader in cloud infrastructure services, and our data within AWS is stored across multiple fault-tolerant Availability Zones, consisting of one or more discrete data centers, each with redundant power, networking, and connectivity, housed in separate facilities protected by state-of-the-art security. Although we strive to employ reasonable protections for your information that are appropriate to its sensitivity, we do not guarantee or warrant the security of the information you share with us and we are not responsible for the theft, destruction, loss or inadvertent disclosure of your information or content. No system is 100% secure.
Any employee or contractor who behaves in contravention of this Policy is subject to serious sanctions, including up to termination.
While HealthyWage continues to work hard to protect your personal information, no data transmission over the Internet can be guaranteed to be absolutely secure, and HealthyWage cannot ensure or warrant the security of any information you transmit to HealthyWage. Transmitting personal information is done at your own risk.
We operate internationally and transfer information to the United States for the purposes described in this policy.
We rely on multiple legal bases to lawfully transfer personal data around the world. These include your consent, the EU-US and Swiss-US Privacy Shield and EU Commission-approved model contractual clauses, which require certain privacy and security protections. You may obtain copies of the model contractual clauses by contacting us. HealthyWage LLC complies with the Privacy Shield principles regarding the collection, use, sharing, and retention of personal information as described in our Privacy Shield certifications. Learn more about Privacy Shield here.
HealthyWage LLC is subject to the oversight of the US Federal Trade Commission and remains responsible for personal information that we transfer to others who process it on our behalf as described in the Circumstances When We Share Information section. If you have a complaint about our Privacy Shield compliance, please contact us. You can also refer a complaint to our chosen independent dispute resolution body, JAMS, and in certain circumstances, invoke the Privacy Shield arbitration process.
Please note that the countries where we operate may have privacy and data protection laws that differ from, and are potentially less protective than, the laws of your country. You agree to this risk when you create a HealthyWage account and agree to the data transfers, irrespective of which country you live in. If you later wish to withdraw your consent, you can delete your HealthyWage account as described in the Your Rights To Access and Control Your Personal Data section.
Data privacy for children is important to us. Persons under the age of 18, or any higher minimum age in the jurisdiction where that person resides, are not permitted to create accounts or use HealthyWage. If we learn that we have collected the personal information of a child under the relevant minimum age, we will take steps to delete the information as soon as possible. Parents who believe that their child has submitted personal information to us and would like to have it deleted may contact us at firstname.lastname@example.org.
HealthyWage is headquartered in Coral Gables, Florida and our Services are provided to you by HealthyWage LLC.
If you are a resident of the Designated Countries, HealthyWage LLC is the controller of your personal data for the purposes of EU data protection law.
Our address is:
1234 S. Dixie Highway #1071
Coral Gables, FL 33146