- Terms of Service
- Information We Collect
- How We Use Personal Information We Collect
- Our Legal Basis for Collecting Personal Information
- Your Failure to Provide Personal Information
- Our Retention of Your Personal Information
- Sharing Personal Information
- Sale of Personal Information
- Your Privacy Choices
- Privacy Rights Specific to California Residents
- Exercising Your Rights
- Our Response to Your Request
- Privacy Rights Specific to European Union Residents
- Our Opt-in/Opt-out Policy
- Third Party Links
- International Transfer
- How We Protect Personal Information
- Children’s Privacy
- Direct Marketing and “Do Not Track” Signals
- How to Contact Us
INFORMATION WE COLLECTWe collect information, including Personal Information, to provide better services to all our Users. We use the term “Personal Information” to refer to any information that identifies or can be used to identify you. Common examples of Personal Information include: full name, email address, digital identity, such as a login name or handle, information about your device, and certain metadata. “Sensitive Personal Information” refers to a smaller subset of Personal Information which is considered more sensitive to the individual, such as race, biometric information, physical health information, or gender. When you use our Services, we collect Personal Information in the following ways:
- Information You Give to Us
- Mobile Application
- Information We Obtain from Your Use of Our Services
- Social Networking
- Cookies and Similar Technologies
HOW WE USE PERSONAL INFORMATION WE COLLECTWe use your Personal Information in ways that are compatible with the purposes for which it was collected or authorized by you, including for the following purposes:
- To present, operate or improve the Application and Services, including analysis of Application activity;
- To inform you about Services and products available from Beep;
- To authorize access to our Applications and Services;
- To validate your identity or verify communications from you;
- To offer and administer programs;
- To customize or tailor your experience of the Services;
- To communicate about, and administer your participation in, special programs, surveys, contests, online campaigns, online programs, sweepstakes, prize draws and other offers or promotions, and to deliver pertinent emails;
- To send you confirmations, updates, security alerts, and support and administrative messages and otherwise facilitate your use of, and our administration and operation of, the Services;
- For marketing purposes, including but not limited to, facilitating interest-based advertising, creating traveler profiles, creating custom audiences to target online and mobile advertising, sending integrated marketing messages across channels and devices, personalizing email marketing that we send to you, sending you other promotional materials, and notifying you about special promotions, offers, events or opportunities that may be of interest to you;
- To improve our customer service, conduct customer satisfaction, market research, and quality assurance reviews;
- To respond to and support users regarding their use of the Applications and Services;
- To process applications for employment that you submit through the Applications;
- To administer general recordkeeping;
- To comply with all applicable legal requirements;
- To perform data analysis and testing;
- To use statistical information that we collect in any way permitted by law, including from third parties in connection with their commercial and marketing efforts;
- To resolve disputes;
- To otherwise fulfill the purpose for which the information was provided.
OUR LEGAL BASIS FOR COLLECTING PERSONAL INFORMATIONWe have set out below, in a table format, a description of all the ways we plan to use your Personal Information, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate. Purpose/Activity Type of data Lawful basis for processing including basis of legitimate interest To register you as a new customer Identity (ie data which identifies you) Contact (ie your contact details) Performance of a contract with you Manage payments, fees and charges Collect and recover money owed to us Identity (ie data which identifies you) Contact (ie your contact details) Financial (ie your payment details) Transaction (ie the services that you are purchasing) Marketing and Communications (ie your direct marketing preferences) Performance of a contract with you; and/or Necessary for our legitimate interests (effectively managing our business operations) To provide you with analytical information about your workout through the use of our apps Identity (ie data which identifies you) Health data (ie data gathered by the sensor for example, your glucose levels) Race data (ie your ethnicity) Performance of a contract with you; and/or To the extent that information we collect is special category of personal data, we rely on your explicit consent to process the data To manage our relationship with you which will include: Notifying you about changes to our terms or privacy notice Asking you to leave a review or take a survey Identity (ie data which identifies you) Contact (ie your contact details) Profile (ie your profile as a user of the service) Marketing and Communications (ie your direct marketing preferences) Performance of a contract with you; and/or Necessary to comply with a legal obligation Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services) or consent in some limited instances. To enable you to partake in an event, prize draw, competition or complete a survey Identity (ie data which identifies you) Contact (ie your contact details) Profile (ie your profile as a user of the service) Usage (ie metrics on your use of the sensor and application) Marketing and Communicatio ns (ie your direct marketing preferences) Performance of a contract with you; and/or ● Necessary for our legitimate interests (to study how customers use our products/services, to develop them and grow our business); and/or Consent (in some limited instances) To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data) Identity (ie data which identifies you) Contact (ie your contact details) Technical (ie data related to your use of the sensor or application) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganization or group restructuring exercise); and/or Necessary to comply with a legal obligation To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you Identity (ie data which identifies you) Contact (ie your contact details) Profile (ie your profile as a user of the service) Usage (ie metrics on your use of the sensor and application) Marketing and Communicatio ns (ie your direct marketing preferences) Technical (ie data related to your use of the sensor or application) Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy); and/or Consent To use data analytics to improve our website, products/services, marketing, customer relationships and experiences Technical (ie data related to your use of the sensor or application) Usage (ie metrics on your use of the sensor and application) Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy); and/or Consent To make suggestions and recommendations to you about goods or services that may be of interest to you Identity (ie data which identifies you) Contact (ie your contact details) Technical (ie data related to your use of the sensor or application) Usage (ie metrics on your use of the sensor and application) Profile (ie your profile as a user of the service) Necessary for our legitimate interests (to develop our products/services and grow our business); and/or Consent To evaluate potential employee candidates and conduct hiring decisions Employment history (ie previous places you have worked) Educational background (ie details about your educational qualifications) Professional memberships (ie details about your professional memberships) Trade union membership Employee reference checks Necessary to comply with a legal obligation; and/or To the extent that information we collect is special category of personal data, we rely on your explicit consent to process the data Provided that, in each circumstance, we will weigh the necessity of our processing for the purpose against your privacy and confidentiality interests, including taking into account your reasonable expectations, the impact of processing, and any safeguards which are or could be put in place. In all circumstances, we will limit such processing for our legitimate business interest to what is necessary for its purposes.
YOUR FAILURE TO PROVIDE PERSONAL INFORMATIONYour provision of Personal Information is required in order to use certain Services and programs. In some instances, if you fail to provide such Personal Information, you may not be able to access and use our Services, or parts of our Services.
OUR RETENTION OF YOUR PERSONAL INFORMATIONWe use and retain your Personal Information for as long as necessary to fulfill the purpose for which it is being processed, to carry out legitimate business interests, as well as on the basis of applicable legal requirements (such as applicable statutes of limitation). After expiry of the applicable retention periods, your Personal Information will be deleted. If there is any data that we are unable, for technical reasons, to delete entirely from our systems, we will put in place appropriate measures to prevent any further use of such data.
SHARING PERSONAL INFORMATIONBeep may disclose your Personal Information to commercial providers for a business purpose. When we disclose Personal Information for these reasons, we enter into a contract that describes the purpose and requires the recipient to both keep that Personal Information confidential and not use it for any purpose except for the purposes set forth in the contract. We may also share fully anonymised statistical data with our partner Abbott. In the preceding twelve (12) months, we have disclosed the following categories of Personal Information for one or more business purposes:
- California Customer Records Personal Information categories;
- Protected classification characteristics under California or federal law;
- Commercial information;
- Internet or other network activity information;
- Biometric Information;
- Geolocation Data;
- Sensory Data;
- Inferences drawn from other personal information.
- Our affiliates;
- Service providers and other third parties we use to support our business, including without limitation those performing core services (such as billing, credit card processing, customer support services, customer relationship management, accounting, auditing, administering sweepstakes, surveys, advertising and marketing, analytics, email and mailing services, data storage, and security) related to the operation of our business and/or the Services, and making certain functionalities to our Users;
- Commercial sensor providers;
- Enterprise accounts;
- Third parties to whom you or your agents authorize us to disclose your Personal Information in connection with the services we provide to you.
- We may disclose your Personal Information for legal reasons. Specifically, we will share Personal Information with companies, organizations or individuals outside of Beep if we have a good-faith belief that access, use, preservation or disclosure of the information is reasonably necessary to:
- Fulfill any purpose for which you provide it;
- Meet any applicable law, regulation, legal process or enforceable governmental request;
- Enforce applicable Terms of Service, including investigation of potential violations;
- Detect, prevent, or otherwise address fraud, security or technical issues;
- Protect against harm to the rights, property, assets or safety of Beep, our Users or the public, content found on the Services, or to protect the Services from unauthorized use or misuse, as required or permitted by law;
- For any other purpose disclosed when you provide the information; and,
- When we obtain your consent to do so.
SALE OF PERSONAL INFORMATIONIn the preceding twelve (12) months, we have not sold any Personal Information.
YOUR PRIVACY CHOICESYou may have certain rights relating to your Personal Information, subject to local data protection law. Whenever you use our services, we aim to provide you with choices about how we use your Personal Information. Subject to applicable law, you may obtain a copy of Personal Information we maintain about you. In addition, if you believe that Personal Information we maintain about you is inaccurate, subject to applicable law, you may have the right to request that we correct or amend the information by contacting us as indicated in the “How to Contact Us” section below. To help protect your privacy and maintain security, we will take steps to verify your identity before granting you access to the information. Our Response to Your Request Upon receiving your request, we will confirm receipt of your request by sending you an email confirmation of receipt. To help protect your privacy and maintain security, we may take steps to verify your identity before granting you access to the information. In some instances, such as a request to delete personal information, we may first separately confirm that you would like for us to in fact delete your personal information before acting on your request. We will respond to your request within forty-five (45) days. If we require more time, we will inform you of the reason and extension period in writing. If you have an account with us, we will deliver our written response to that account. If you do not have an account with us, we will deliver our written response by mail or electronically, at your option. In some cases our ability to uphold these rights for you may depend upon our obligations to process Personal Data for security, safety, fraud prevention reasons, compliance with regulatory or legal requirements, listed below, or because processing is necessary to deliver the services you have requested. Where this is the case, we will inform you of specific details in response to your request. We may deny your deletion request if retaining the information is necessary for us or our service providers to:
- Complete the transaction for which we collected the Personal Information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you;
- Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities;
- Debug products to identify and repair errors that impair existing intended functionality;
- Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law;
- Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 seq. );
- Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information’s deletion may likely render impossible or seriously impair the research’s achievement, if you previously provided informed consent;
- Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us;
- Comply with a legal obligation; or
- Make other internal and lawful uses of that information that are compatible with the context in which you provided it.
PRIVACY RIGHTS SPECIFIC TO EUROPEAN UNION RESIDENTSThe European Union’s General Data Protection Regulation (“GDPR”), and corresponding legislation in the United Kingdom and Switzerland, provide European, Switzerland and United Kingdom residents with certain rights in connection with Personal Information you have shared with us. If you are resident in the European Economic Area, you may have the following rights:
- The right of access. You have the right to request a copy of your Personal Information which we hold about you.
- The right of correction. You have the right to request correction or changes of your Personal Information if it is found to be inaccurate or out of date.
- The right to withdraw consent. You have the right to withdraw a previously given consent for processing your Personal Information for a specific purpose.
- The right to be forgotten. You have the right to request us, at any time, to delete your Personal Information from our servers and to erase your Personal Information when it is no longer necessary for us to retain such data. Note, however, that deletion of your Personal Information will likely impact your ability to use our services.
- The right to object (opt-out). You have the right to opt-out of certain uses of your Personal Information, such as direct marketing, at any time.
- Right to restriction of processing: You may require that we restrict the processing of your personal data in certain cases, for example where we no longer need your personal data but you need it to determine, enforce, or defend legal claims or you have objected to processing based on our legitimate interest in order to enable us to check if our interest overrides your interest.
- The right to data portability. You have the right to a “portable” copy of your Personal Information that you have submitted to us. Generally, this means your right to request that we move, copy or transmit your Personal Information stored on our servers or information technology environment to another service provider’s servers or information technology environment.
- The right to refuse to be subjected to automated decision making, including profiling. You have the right not to be subject to a decision and insist on human intervention if the decision is based on automated processing and produces a legal effect or a similarly significant effect on you.
- The right to lodge a complaint with a supervisory authority. You have the right to lodge complaints about our data processing activities by filing a complaint with us or with the Irish Data Protection Commission. They can be contacted via email@example.com. You may also contact your local Supervisory Authority. A list of Supervisory Authorities is available here: http://ec.europa.eu/justice/data- protection/bodies/authorities/index_en.htm.
- At any time, you can follow a link provided in offers, newsletters or other email messages (except for e-commerce confirmation or service notice emails) received from us to unsubscribe from the service.