We at ProHabits Inc., a Delaware C Corporation company are committed to protecting the information about you that you – our registered users and visitors – share with us, and explaining how we collect, process, and share that information online.
WHAT TYPES OF PERSONAL INFORMATION DO WE COLLECT ABOUT OUR USERS?
We collect information about you including Personal Information you voluntarily provide to us. We don't require you to give us Personal Information to access public areas of our Sites. This is true unless you live in a country that defines Personal Information to include network identifiers like your Internet Protocol addresses. Certain secure areas of our Sites, however, enable authentication or require you to provide Personal Information when you use specific features on our Sites. If you can’t or choose not to provide us with the Personal Information we reasonably require, we may be unable to provide you with the information or services you have requested. For example, we may collect Personal Information from you when you:
- Ask to register for an account with us;
- Make in-app purchases;
- Interact with our video and voice communications, and text messaging functionalities;
- Ask us to match the information stored on your device’s address book against our public directory of registered users; and
- Request customer or technical support.
Information we collect about you, for example, may include your:
- Postal address;
- Geolocation (your device’s longitudinal and latitudinal information);
- E-mail address;
- Social media account information (such as username and website);
- Telephone or mobile number;
- Photograph, image, or likeness; and
- Payment card information.
We may also collect certain demographic information (e.g., gender, country of residence, preferences) you provide to us, and may sometimes also combine it with your Personal Information.
In some situations, we may collect, use, and share emotion metrics, analytics, mobile apps used, and other information that no longer identifies you personally, with certain identifiers removed, for trend monitoring, market or product research, and overall technological enhancements.
Depending on the permissions you’ve granted and other factors, we may receive information about your location and mobile device when you download or use apps created by our Sites, including a unique identifier for your device. We may use this information to provide you with location-based services, such as advertising, certain player search results, and other personalized content. We may also share this information with unaffiliated third parties for their own marketing activities. Examples of the device information we collect include:
- Attributes such as the operating system, hardware version, device settings, file and software names and types, battery and signal strength, and device identifiers.
- Device locations, including specific geographic locations, such as through GPS, Bluetooth, or WiFi signals.
- Connection information such as the name of your mobile operator or ISP, browser type, language and timezone, mobile phone number, and IP address.
Most mobile devices allow you to turn off location services, and we encourage you to contact your device manufacturer for detailed instructions on how to do that.
If you purchase a product or service on our Sites, we may collect payment card information from you directly or through a service provider, including your name, expiration date, authentication code, and billing address. We transmit this information consistent with payment card industry rules and practices to the appropriate payment facilitators. We may offer you the option to save information about the method and choice of payment on our Sites. If you save this payment card information on our Sites, you will be able to add, delete, or modify that information at any time using your account settings.
DO WE ADVERTISE ONLINE?
We advertise in a number of ways, including online through managed social media presences, and on other unaffiliated sites and mobile applications. To understand how our advertising campaigns are performing, we may collect certain information via our Sites through our advertising service providers. We or our vendors use several common online tracking tools to collect this information, such as browser and flash cookies, web beacons and other, similar technologies. The information we collect includes IP addresses, the number of page visits, pages viewed via our Sites, search engine referrals, browsing activities over time and across other websites following your visit to one of our Sites or applications, and responses to advertisements and promotions on the websites and applications where we advertise.
Controlling Our Tracking Tools
Your browser may give you the ability to control cookies. How you do so, however, depends on your browser and the type of cookie. Certain browsers can be set to reject all browser cookies. If you configure your computer to block all cookies, you may disrupt certain web page features and limit the functionality we can provide when you visit or use our Sites. If you block or delete cookies, not all of the tracking that we have described in this policy will stop. Some browsers have a “Do Not Track” feature that lets you tell websites that you do not want to have your online activities tracked. These browser features are still not uniform, so we are not currently set up to respond to those signals.
Controlling Online Interest-Based Ads
We sometimes work with online advertising vendors to provide you with relevant and useful ads (for example, we may use Google technologies among others and you may learn more about how Google technologies work at https://www.google.com/policies/privacy/partners/). This may include ads served on or through our Sites. This may also include ads served on other companies’ websites, online accounts, or mobile applications. These ads may be based on information collected by us or third parties. For example, your postal code may be used to target an ad for people in your area. These ads may also be based on your activities on our Sites or on third party websites, online accounts, or mobile applications.
To learn more about Interest-Based Advertising or to generally opt-out of this type of advertising by those third parties that are members of the self-regulatory programs such as the Network Advertising Initiative, please visit the NAI’s website (www.networkadvertising.org), which will allow you to opt out of Interest-Based Advertising by one, or all, NAI members. For more information about our ad service provider and its cookies, including information about how to opt out of these technologies, you may visit www.aboutads.info/choices . In addition, users may prevent Google’s collection of data generated by your use of the Sites (including your IP address) by downloading and installing a Browser Plugin available at https://tools.google.com/dlpage/gaoptout?hl=en.
Minors and Children Under 13
Our Sites are not intended for those under the age of 13. We do not knowingly collect any Personal Information from children under the age of 13 or knowingly track the use of our Sites by these minor users.
HOW WE USE AND SHARE YOUR PERSONAL INFORMATION?
In accordance with applicable law, we may share what we know about you with affiliated and unaffiliated third parties for their marketing activities, or for any purpose allowed by law (California residents see below). In certain instances, we may also help advertisers better reach our users by providing your device ID and type, geographic and geolocation information, language preferences, demographic, and other information obtained from you and other companies. We may run joint or co-sponsored programs or promotions with unaffiliated companies and, as part of that, collect, use, and may share certain information about you, only for the purpose of those programs or promotions. Finally, we may share collected location and Bluetooth data for Interest-Based Advertising, allowing certain advertisers to infer interests and serve ads to our users based on activity and location over time.
Whatever the purpose may be, we only process and share information about you to the extent reasonably necessary to fulfill your requests and other legitimate business objectives. When we disclose information about you to external entities that perform services on our behalf, they may access that information only for the purposes of performing those services. We may also use what we know about you to offer you other products and services. We may combine your online information with information collected from other sources or information we already have. We may also use and disclose what we know about you to our affiliates and others for any purpose allowed by law.
We process and may use information about you to:
- Respond to your questions about our product or services;
- Help you match your contacts against our directory of registered users;
- Allow you to establish a connection with the Sites, send and receive connection requests, play or send game requests, use various functionalities on our Sites (including audio, video, and text with other users), or other permitted activities through the Sites;
- Identify new visitors to our Sites and recognize returning visitors;
- Send you communications, including ads, electronic newsletters, or other offers tailored to you;
- Enable our advertisers to provide you with more personalized content, advertise on other sites and mobile applications, and track the effectiveness of certain advertising campaigns;
- Determine whether you might be interested in new products or services;
- Better understand our audience, customers, or other visitors to our Sites;
- Comply with applicable law, obey judicial orders, cooperate with law enforcement authorities, or prevent any suspected illegal activities; or
- For any other everyday business purposes, such as product development and administration of the Sites.
Address Book Information
Authorized Service Providers
We use other companies and individuals to perform certain functions on our behalf. Those functions include payment card processors, shipping vendors, call-center support, notification fulfillment vendors (for email and push notifications for example), analyzing or hosting data on cloud-based servers, and other companies that help us improve our products and services. We may disclose your information about you to these companies and other individuals only for the purposes of performing services on our behalf in the United States or other locations where we may conduct business at that time.
For California Residents
Under California’s “Shine the Light” law, California residents may opt-out of a company’s disclosure of Personal Information to third parties for its direct marketing purposes. If you wish to opt-out of our sharing your Personal Information with third parties for marketing purposes, you may do so at any time by sending us an email at email@example.com with subject line “CA Opt Out.” Please make sure to send this request from the email account registered with us and tell us the application you are emailing about; if you have more than one account associated with that email address, please also include your specific User ID for which you are making the request. We will take steps to process your request shortly after we receive your request. Please know that this opt-out request does not, however, prohibit disclosures made for other non-marketing purposes.
Sale of the Businesses
WHAT CHOICES DO YOU HAVE ABOUT THE COLLECTION, USE, AND SHARING OF YOUR PERSONAL INFORMATION?
If you wish for us to stop receiving marketing communications or newsletters you signed up to receive from us, you can opt-out any time by clicking the “Unsubscribe” link at the bottom of those communications.
If you wish for us to stop sharing your Personal Information with unaffiliated third parties for marketing activities, please contact us at firstname.lastname@example.org with subject line “Opt Out.” Please make sure to send this request from the email account registered with us and tell us the application you are emailing about; if you have more than one account associated with that email address, please also include your specific User ID for which you are making the request. We will honor your request shortly after we receive it, and your request will only apply as of that date onward.
If you wish to deactivate your account at any time, please contact us at email@example.com with subject line “Deactivate Account.” Please make sure to send this request from the email account registered with us and tell us the application you are emailing about; if you have more than one account associated with that email address, please also include your specific User ID you wish to deactivate. We will deactivate your account shortly after we receive your request.
WHAT KINDS OF SECURITY MEASURES DO WE TAKE TO SAFEGUARD YOUR PERSONAL INFORMATION?
The security and confidentiality of your Personal Information matters to us. That’s why we have technical, administrative, and physical controls in place to protect your Personal Information from unauthorized access, use, and disclosure. We also review our security procedures periodically to consider appropriate technology and methods. Even so, despite our reasonable efforts, no security measure is ever perfect or impenetrable.
When you use some features and functionalities on our Sites (for example video communications, voice communications, text messages), or post on a forum, chat room, or social networking service, the information and content you share may be visible to other users, and can be read, collected, or used by them. You are responsible for the information you choose to share or submit in these instances. Please carefully consider what you share in your online profiles, photographs, videos, chat, and text conversations, and we urge you to not share private, confidential, and any Personal Information in general with anyone online.
HOW CAN YOU ACCESS, UPDATE, OR BLOCK YOUR PERSONAL INFORMATION?
You can log-in to your account to view your information and submit any updates or corrections to your information directly in your account profile. We cannot change information stored in systems belonging to third parties.
If you wish to deactivate your account at any time, please contact us directly at firstname.lastname@example.org with subject line “Deactivate Account.” Please make sure to send this request from the email account registered with us and tell us the application you are emailing about; if you have more than one account associated with that email address, please also include your specific User ID you wish to deactivate. We will deactivate your account shortly after we receive your request. While your account will be deactivated on a going forward basis, information about you may still be retained to comply with applicable record retention laws, legal holds, or other business requirements.
For UK Consumers
The Data Protection Act gives you the right to access information we hold about you. Your right of access can be exercised in accordance with the Act. Any access request may be subject to a fee of up to £10 to meet our costs in providing you with details of the information we hold about you. If you wish to access information in this way, please contact us at email@example.com with subject line “UK Consumer Request.” Please make sure to send this request from the email account registered with us and tell us the application you are emailing about; if you have more than one account associated with that email address, please also include your specific User ID for which you are making the request.
Our postal address is:
Attn.: Privacy Office
220 North Aberdeen Street, Suite 200
Chicago, Illinois 60607
For Australian Consumers
If we fail to respond to your complaint within a reasonable period of receiving it in writing, or if you are dissatisfied with the response that you receive from us, you may lodge a complaint with the Office of the Australian Information Commissioner ("OAIC"). Details of how to contact the OAIC are located at www.oaic.gov.au.
ProHabits Data Policy
1. Personal Information We May Collect
Where applicable, we indicate whether and why you must provide us with your Personal Information, as well as the consequences of failing to do so. If you do not provide Personal Information when requested, you may not be able to benefit from our Service if that information is necessary to provide you with the service or if we are legally required to collect it.
2. Personal Information Provided By You
If you desire to have access to certain restricted sections of the Site or request to receive marketing materials, you may be required to become a registered user, and to submit the following types of Personal Information to ProHabits: your name, email address, phone number, and time zone. No other information is collected or asked at any point in the user journey.
3. Personal Information Automatically Obtained from Your Interactions with the Service
When you use our Service, our servers automatically record information that your browser sends whenever you visit a website ("Log Data"). This Log Data may include information such as your IP address, browser type or the domain from which you are visiting, the web-pages you visit, the search terms you use, and any advertisements on which you click.
Cookies and Similar Technologies
Like many websites, we also use "cookie" technology to collect additional website usage data and to improve the Site and our Service. A cookie is a small data file that we transfer to your computer's hard disk. A session cookie enables certain features of the Site and our service and is deleted from your computer when you disconnect from or leave the Site. A persistent cookie remains after you close your browser and may be used by your browser on subsequent visits to the Site. Persistent cookies can be removed by following your web browser help file directions. Most Internet browsers automatically accept cookies. ProHabits may use both session cookies and persistent cookies to better understand how you interact with the Site and our Service, to monitor aggregate usage by our users and web traffic routing on the Site, and to improve the Site and our Service.
We may also automatically record certain information from your device by using various types of technology, including "clear gifs" or "web beacons." This automatically collected information may include your IP address or other device address or ID, web browser and/or device type, the web pages or sites that you visit just before or just after you use the Service, the pages or other content you view or otherwise interact with on the Service, and the dates and times that you visit, access, or use the Service. We also may use these technologies to collect information regarding your interaction with email messages, such as whether you opened, clicked on, or forwarded a message, to the extent permitted under applicable law.
You can instruct your browser, by editing its options, to stop accepting cookies or to prompt you before accepting a cookie from the websites you visit. Please note that if you delete, or choose not to accept, cookies from the Service, you may not be able to utilize the features of the Service to their fullest potential.
Do Not Track
ProHabits does not process or respond to web browsers' "do not track" signals or other similar transmissions that indicate a request to disable online tracking of users who use our Service.
Third Party Web Beacons and Third Party Buttons
Links to Other Websites
Our Site contains links to other websites. The fact that we link to a website is not an endorsement, authorization or representation of our affiliation with that third party. We do not exercise control over third party websites. These other websites may place their own cookies or other files on your computer, collect data or solicit Personal Information from you. Other sites follow different rules regarding the use or disclosure of the Personal Information you submit to them. We are not responsible for the content, privacy and security practices, and policies of third-party sites or services to which links or access are provided through the Service. We encourage you to read the privacy policies or statements of the other websites you visit.
4. How We Protect Personal Information
ProHabits is very concerned about safeguarding the confidentiality of your Personal Information. We employ administrative and electronic measures designed to appropriately protect your Personal Information against accidental or unlawful destruction, accidental loss, unauthorized alteration, unauthorized disclosure or access, misuse, and any other unlawful form of processing of the Personal Information in our possession. Please be aware that no security measures are perfect or impenetrable. We cannot guarantee that information about you will not be accessed, viewed, disclosed, altered, or destroyed by breach of any of our administrative, physical, and electronic safeguards, subject to requirements under applicable law to ensure or warrant information security.
We will make any legally-required disclosures of any breach of the security, confidentiality, or integrity of your unencrypted electronically stored Personal Information to you via email or conspicuous posting on our Site in the most expedient time possible and without unreasonable delay, consistent with (i) the legitimate needs of law enforcement or (ii) any measures necessary to determine the scope of the breach and restore the reasonable integrity of the data system , and any other disclosures that may be required under applicable law.
We also take measures to delete your Personal Information or keep it in a form that does not permit identifying you when this information is no longer necessary for the purposes for which we process it, unless we are required by law to keep this information for a longer period. When determining the retention period, we take into account various criteria, such as the type of products and services requested by or provided to you, the nature and length of our relationship with you, possible re-enrollment with our products or services, the impact on the services we provide to you if we delete some information from or about you, mandatory retention periods provided by law and the statute of limitations.