Last Updated: July 25, 2021
TribalFitt contracts with “Program Sponsors” to provide a health and well-being program (“Services”) to eligible participants. A Program Sponsor may be an employer, spouse’s employer, charitable organization, or other organization.
Personal Information. We collect anonymous and Personal Information about you. Any information that may be used alone or in conjunction with other information to identify a specific individual is called “Personal Information.” Examples include your name, address, phone number, date of birth, email address, social security number, and health information.
We or others on our behalf use mobile analytics software to allow us to review the functionality of our mobile app and how to improve it. Examples of the information that may be recorded by the analytics software are how often you use the mobile app, performance data, crash reports, events that occur within the mobile app, aggregate usage, and where the app was downloaded from. The data obtained from the mobile analytics software is not linked to your Personal Information.
While some internet browsers offer a “do not track” or “DNT” option that lets you tell websites that you do not want to have your online activities tracked, these features are not yet uniform and there is no common standard that has been adopted by industry groups, technology companies or regulators. Therefore, we do not currently commit to responding to browsers’ DNT signals. To find out more about “Do Not Track,” you may wish to visit http://www.allaboutdnt.com.
Why We Collect and How We Use Information About You
We and others acting on our behalf may use your information to determine your eligibility to participate in our Services, provide you with our Services, facilitate the health and well-being program provided by your Program Sponsor, track your progress and rewards, provide information to you about the Services, provide support to you and/or address technical problems, manage or support your account, improve the delivery of our Sites and Services to you, improve your experience with our Sites and Services, administer the Sites and Services, measure traffic on our Sites and Services, troubleshoot technology issues, count users who visit our Sites, enhance the security controls around the Sites and Services, analyze trends, track movement/activity, gather information, detect, prevent, investigate and respond to fraud, violations of our terms, intellectual property infringement, or other misuse of our Services or Sites, and for any other use permitted by applicable law.
We may use information obtained through cookies and tracking technologies for advertising purposes. We may implement third-party content or advertising on the Site or Services that may use clear gifs or other forms of web beacons, which allow the third-party content provider to read and write cookies to your browser in connection with your viewing of the third-party content on the Site or Services.
We and others acting on our behalf may collect and use your Personal Information to create aggregated or anonymous data records by removing any information that would allow you to be identified. We may use this aggregated or anonymous data for business or other purposes not prohibited by applicable law, such as for research and marketing purposes, as well as analyzing the use of our Services and identifying trends or behavioral patterns in order to improve our Services.
Where We Get Information About You
We collect and use information about you from various sources when you use our Services and visit our Sites, including Automatically Collected Information as stated above. Additional sources are identified below.
Information You Give Us. We may collect and use any information you provide to us directly through your use of our Sites or Services. When using the Sites or Services, you may provide us with Personal Information, including but not limited to: name, date of birth, mailing address, telephone numbers, email addresses, biometric data, your photographic image, height and weight, information about your health, fitness, and wellness activities and goals, points/rewards you earn through the Services, comments and achievements you may elect to post, and other information about your participation in and use of the Sites or Services. You may provide us with Personal Information when you:
Visit, register, and/or enter information about yourself in connection with the Sites or Services, including but not limited to setting up an account/profile;
sign up to participate in a sweepstakes, challenge, activity, event, or contest;
complete a survey, questionnaire, or assessment;
subscribe to our Services, email notifications and/or newsletters;
provide feedback, request support, or ask for additional information;
post comments in public areas, such as the newsfeed or group/discussion blogs;
utilize feature such as health log entries, and nutrition and exercise tracking;
link a compatible device or third-party app that shares your information with us;
participate in online courses;
schedule a biometric screening, coaching appointment, or other service; and
interact with others using the messaging features of the Site or Services.
Beyond the information necessary for enrollment/registration, you are under no obligation to provide any Personal Information to us. You can choose to limit the data you share with us by not inputting or not using certain features. If you choose to withhold some Personal Information, We may be unable to provide you with certain Services and/or they may not function properly, such as rewards offered by your Program Sponsor.
Information Provided to Us By Your Program Sponsor. Your employer, your spouse’s employer, or other organization sponsoring your use of the Services may provide us with information about you, such as your name, employee ID number, email address, date of birth, department, work location, hire date, and address to help facilitate the health and well-being Services.
Information Provided to Us by Your Healthcare Provider or Third Party Lab. We may receive your biometric data, health-related measurements, blood test results, and other healthcare-related information from a lab or healthcare provider and any clinics or healthcare organizations with whom they are associated.
Information Provided to Us by Linking Compatible Devices and Apps. You have the option of linking one or more compatible third-party devices (activity tracker/smart watch, blood pressure monitor, wireless weight scale, and blood glucose monitor) and third-party compatible apps (such as Google Fit, SHealth, Apple HealthKit, and MyFitnessPal) to the portal. Should you choose to do so, we will receive information about you to auto-populate your account. Depending on the device or app you sync, the information may include but not be limited to your steps, distance, calories, heartrate, active minutes, sleep data, nutrition and food/water consumption, exercise, weight, BMI, body fat percentage, blood glucose levels and type (fasting or non-fasting), blood pressure, and time/date stamps. Note that these third-party devices and apps have their own privacy policies that we encourage you to review.
Information Provided to Us by Program Partners. Depending on the program features offered by your Program Sponsor, you may have access to third-party “Program Providers” that offer biometric or lab testing services, coaching services, online courses, and other types of services. If you choose to use these features, the Program Partners may share activity, participation, outcomes, and biometric/health data with us. Note that these Program Partners have their own privacy policies that we encourage you to review.
Information Provided to Us through Public Databases. We may receive information about you from other sources including publicly available databases or third parties from whom we have purchased data, and combine this data with information we already have about you. Examples of Personal Information we may obtain through public databases include address verification through the US Postal Service and “do not call” status through the US Federal Do Not Call registry.
Communicating With You
We may contact you through e-mail, text messages, push notifications on your mobile device or tablet, telephone, or postal mail, as permitted by law to send you information and updates related to the Sites or Services, notices requested by you or generated as a result of your use of the Sites or Services, company news or Services information, and marketing communications relating to our business which we think may be of interest to you. You can turn off certain types of email notifications automatically generated by the Services under the Notifications Settings within your profile.
Disclosure of Your Information
We may use third parties to perform certain services on our behalf. We may share your Personal Information with these third parties solely to enable them to perform the services for us. We require that those third-party vendors maintain at least the same level of confidentiality that we maintain for such information. We do not provide your Personal Information to parties unconnected with the Services we provide, and we do not sell your Personal Information.
Agents, Contractors, Business Partners, and Other Service Providers: In order to provide you with the Sites and Services, we may disclose your information to our agents, contractors, business partners, or other service providers who assist us in providing you with our Sites and Services or perform services on our behalf, such as incentive fulfillment, web hosting, e-mail providers, data storage, providing integrated services via our platform, sending postal mail and e-mail, removing repetitive information from participant lists, analyzing data and providing marketing assistance.
Other Participants. Your information can be shared with other participants depending on the privacy settings you set up in your profile, which you can change at any time. Your information may also be shared based on your participation in challenges or contests between you and other participants. If you participate in these challenges, limited information such as your name and progress/performance, will be visible to other participants and your Program Sponsor. In addition, any information you choose to post in the newsfeed and group/discussion pages will be visible to other participants and your Program Sponsor.
Coaches. You may choose to share your Personal Information, such as your name, age, picture, activity logs, nutrition logs, and health logs (including Health Risk Assessment and biometric screening results), with coaches based on the Coach Privacy Settings within your User Settings, which you can change at any time. You may also share documents with your coach(es) through the Services by uploading them.
Your Program Sponsor. We may share anonymous and aggregated data with your Program Sponsor, and they will not be able to use such data to directly identify you. In addition, we may share limited Personal Information with your Program Sponsor solely for the purpose of administering the purchased Services, health and well-being program, and benefits offered by your Program Sponsor or as otherwise permitted by law. For example, we may share the number of points you have earned by participating in a program or challenge, or that you have completed a Health Risk Assessment (no details of the HRA results specific to you will be disclosed). Please note that if you set your privacy settings to “Public” (meaning public to all participants under the Program Sponsor), then your Program Sponsor may have access to the information you have set to Public. If your Site activity indicates there is any abnormal usage or potential abuse, we may share your activity with your Program Sponsor, and your access may be limited, suspended, or terminated.
Corporate Affiliates. We may share information with our corporate affiliates for their everyday business purposes to provide services. We may also participate in joint ventures with others and we may share information as permitted by this Policy as part of that joint venture.
Business Transfer. We may share and/or transfer Personal Information about you in connection with the acquisition, sale, merger, divestiture, restructuring, reorganization, dissolution, bankruptcy, consolidation, liquidation, transfer of assets, or other change of ownership or control of our business.
Protection of Ourselves and Others. We may use and share the information we gather to enforce our rights and protect our property and those of our affiliates, customers, Program Partners, members of the public, and other interested parties; to comply with applicable law, regulation, legal process, legal advice, or other legal requirement; and for preventing fraud, theft, or other crime or injury to you, us or others.
Aggregated Information. We may provide to others, including but not limited to your Program Sponsor, or other third parties, information about you and other users from which we have removed all identifiers and that can no longer be used to identify you (“Aggregate Information”). We reserve the right to use, transfer, sell, and share aggregated, anonymous data, which does not include any Personal Information, about our Site and Services users as a group for any legal business purpose, such as analyzing usage trends and seeking compatible advertisers, sponsors, clients and customers.
TribalFitt is committed to protecting your data and your privacy. We have implemented and follow commercially reasonable measures to protect against unauthorized access to and unlawful interception or processing of Personal Information. Unfortunately, data transmission over the Internet is never 100% secure so we cannot guarantee the security of any information you transmit to us or from our Sites and Services; therefore you use our Sites and Services at your own risk.
In the event we become aware of a data security breach, we will provide you with notice as required by applicable federal and state laws. To the extent permitted by applicable law, we will provide any such notice to you at the email address associated with your user profile or registration invitation, as updated from time to time. By using the Site or Services, you agree to accept such notice electronically.
If you register on our Sites or Services, you are responsible for protecting the security of your username and password. We recommend you use a strong password, never share it with others, and do not use the same password on other sites. You are responsible for any transaction made using your username and password.
Communication sent via email or text messages is not a secure method of communication and is not encrypted, and you agree to assume said security risks, including the risk that the information contained within emails or text messages could be read by others.
Personal Information you submit via our Sites and Services is transmitted via Secure Socket Layer (SSL) or Transport Layer Security (TLS) encryption or other cryptographically secure encryption protocols and is stored in physically secured environments.
Changing Privacy Settings
You can review and modify access you have given to one or more coaches, if live coaching is offered by your Program Sponsor, by clicking on the Coach Settings tab within the User Settings menu of our online platform and mobile application.
Please note that no security measures are 100% secure, so while we allow you to change your privacy settings, we are not responsible for circumvention of privacy settings or security measures on the Sites or Services.
Accessing and Changing/Updating Your Information
You may request that we provide you with information we hold about you or update your information by emailing us at email@example.com. We may not be able to modify or delete your information in all circumstances. Since we collect information about you from a variety of sources, we may ask you to contact the source of the information to correct that information. For example, you may need to contact your healthcare provider to correct a laboratory test result that you feel is inaccurate.
If you have registered for an account with our online portal and mobile applications, you may access, update and change certain information we have collected about you by logging into your account and updating your information. When you edit your information or change your preferences, information that you change or remove may remain in our databases or backup media because it is not always possible to completely remove or delete information from those locations, and we may retain the changed or deleted information for archiving, prevention of fraud and abuse, satisfaction of legal obligations, analytics, or where we have a legitimate business reason to do so.
Posting In Public Areas
You may voluntarily submit information, for example your address, interests or photo, in order to enhance your profile on the Site or Services. You may also choose to participate in groups, challenges, blogs, and other public areas (together “Public Spaces”) for social networking, wherein you have the option of posting comments, videos, graphics, and other content. Submission of this information is strictly voluntary. Do not post information in public areas if you do not want the information to be shared with others.
Personal Information of Children Under 13
This Site is not directed to children, and we do not knowingly collect any Personal Information from children under 13 years of age through our Sites or Services. If you think we have collected Personal Information from a child under 13 years of age for whom you are the parent or guardian, please contact us at the address provided below.
Notice to California Residents – Your California Privacy Rights
California Civil Code Section 1798.83 permits California residents to request and obtain from us a list of what Personal Information (if any) we disclosed to third parties for that third party’s direct marketing purposes in the preceding calendar year and the names and addresses of those third parties. Requests may be made only once a year and are free of charge. Under Section 1798.83, we currently do not share any Personal Information with third parties for their direct marketing purposes. If we do decide to share your Personal Information with third parties for their marketing purposes, you may opt-out of this disclosure at any time by submitting a request to our Privacy Officer by emailing firstname.lastname@example.org or writing to us at our mailing address as described below.
It is important to note that this opt-out does not prohibit disclosures made for non-marketing purposes or for purposes of assisting us with our own marketing.
If you are a registered user under the age of 18 and a resident of California, you may request removal of content you have posted to the Services. Requests can be made by contacting our Privacy Officer by emailing email@example.com or writing to us at our mailing address as described below. Please note that making such requests does not ensure complete or comprehensive removal of the content. For example, we may retain the information for our own internal records, and it is also possible that a third party we do not own or control may copy the posting and repost it elsewhere.
Attn: Privacy Officer
PO Box 43
Bellevue, IA 52031