Last modified: 7/8/2015
Keas complies with the U.S. – E.U. Safe Harbor Framework and the U.S. Swiss Safe Harbor framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal data from European Union member countries and Switzerland. Keas has certified that it adheres to the Safe Harbor Privacy Principles of notice, choice, onward transfer, security, data integrity, access, and enforcement. To learn more about the Safe Harbor program, and to view Keas’ certification, please visit https://safeharbor.export.gov/companyinfo.aspx?id=26353.
Via the Site and Applications, we provide an online employee wellness program that combines the best of social media and online games to engage you in taking charge of your health (the “Services”). At Keas, we strive to make health and wellness fun, social, and interactive. Throughout the year, employers work with Keas to sponsor incentivized, time-bound challenges (each a “Keas Health Challenge”) that encourage healthy competition among employees for prizes and top honors. Employers can choose to sponsor between 1 and 4 Keas Health Challenges per year, but even when employees are not participating in a Keas Health Challenge, they can continue to use the Site and Applications. Participants of the Services may earn virtual “points” or other rewards for completing small, but important health goals. Depending on the specifics of a Keas health challenge, Participants can participate as part of a team or individually. Each week, Participants can access the Services and choose goals for improving their health. Goals could be as simple as going for a walk three times a week, avoiding fried foods for a week, or doing stress-reduction exercises. Participants earn points by completing goals and reporting their progress via the Services.
Participants may also earn points for other Services-related activities, such as getting people to registerto use the Services, taking quizzes to test Participants’ knowledge, and posting comments via the Services. Participants will be recognized and may be eligible to win prizes in connection with their accrual of points via the Services. Specific terms may apply for a challenge.
Creating an Account and Records—Collection of Your Personal Information
If you choose to sign up to receive our newsletter via the Site and Applications, we will collect your name and email address in order for Keas to process your request. Out of respect for your privacy, you may choose to stop receiving our newsletter by following the unsubscribe instructions included in these emails or you can contact us at email@example.com. If you choose to send email or other communications to us, we may retain those communications in order to process your inquiries, respond to your requests, and improve our Services. Additionally, if you choose to post any comments via the Services, the content of such comments will be shared with all of the Participants within your Keas Health Challenge in connection with your name.
Information Related to Our Service
Keas collects information under the direction of its Clients, and has no direct relationship with the individuals whose personal data it processes.
We collect information for our Clients, if you are an employee of one of our Clients and no longer wish to use our service, please contact your employer directly.
Keas may transfer personal information to companies that help us provide our service. Transfers to subsequent third parties are covered by the provisions in this Policy regarding notice and choice and the service agreements with our Clients
Keas will retain personal data we process on behalf of our Clients for as long as needed to provide services to our Client. Keas will retain and use this personal information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.
Information Collected Using Cookies and Other Technologies
Keas, its marketing partners, affiliates, and analytical services use technologies such as cookies, beacons, tags and scripts on the services. We use these technologies to analyze trends, administer the site, track users’ movements around the site and to gather demographic information about our user base as a whole. We may receive reports based on the use of these technologies by these companies on an individual as well as aggregated basis.
Advertising and Targeted Ads
We partner with a third party ad network to display advertising on our Site. Our ad network partner uses scripts and Web beacons to collect non-personal information about your activities on this and other Web sites to provide you targeted advertising based upon your interests. If you wish to not have this information used for the purpose of serving you targeted ads, you may review the choices you have to opt-out by clicking TRUSTe’s “Your Advertising Choices” located at http://preferences-mgr.truste.com or the Network Advertising Initiative’s Consumer Opt-Out at http://www.networkadvertising.org/managing/opt_out.asp. If you are in the European Union, you may review your opt-out choices at http://www.youronlinechoices.eu/. You can learn more about online behavioral advertising by review TRUSTe’s resources at http://www.truste.com/consumer-privacy/about-oba/. Please note this does not opt you out of being served advertising. You will continue to receive generic ads.
Information Related to Use of Our Services
As is true of most web sites, we gather certain information automatically and store it in log files. This information may include internet protocol (IP) addresses, browser type, internet service provider (ISP), referring/exit pages, operating system, date/time stamp, and/or clickstream data.
We may combine this automatically collected log information with other information we collect about you. We do this to improve services we offer you or site functionality.
Local Storage Objects
We use Local Storage Objects (LSOs) such as HTML5 to store your preferences such as volume control or high game score, or display content based upon what you view on our site to personalize your visit. Third parties with whom we partner to provide certain features on our site or to display advertising based upon your Web browsing activity use LSOs such as HTML5 and Flash to collect and store information. Various browsers may offer their own management tools for removing HTML5 LSOs. To manage Flash LSOs please click here: http://www.macromedia.com/support/documentation/en/flashplayer/help/settings_manager07.html
How We Use Your Personal Information
- allow you to participate in the Keas Health Challenge;
- suggest health goals to you;
- provide you with important information about the Services, including critical updates and notifications;
- send you email relating to the Services, your account, and your participation in the Keas Health Challenge;
- modify the Keas Health Challenge to better address your health needs and progress; and
- determine appropriate services that may be relevant to you, your lifestyle, and your geographic location.
How We Use Log Data and Aggregated Information and Statistics
- We may use Log Data or aggregated information gathered from Users of the Services and related statistics to improve the Services, and for research and analysis purposes.
- We may also provide this information to our partners for such purposes. This does not include Personal Information, but may include aggregated information related to Participant gender, height, weight, and related information.
- Aggregated information is information from multiple users that is not associated with any individual Participant.
- We use Log Data to analyze trends, to administer the Services, to track users’ movements around the Services and to gather demographic information about our user base as a whole.
- We do link Log Data to Personal Information in order to provide personalized features to users of the Services.
Sharing Your Personal Information
We may share information about your participation in the Keas Health Challenge with other Participants and the employer-sponsors of your Keas Health Challenge. Some of this shared participation information is associated with you, such as your Keas Health Challenge point totals, the health goals you choose via the Services and comments you post via the Services. Some of this participation information, such as certain goals you choose, may allow other Participants and sponsors to discern certain things about your health. For example, a goal such about avoiding salt could lead other Participants and sponsors to believe you have or are at risk for high blood pressure.
Compliance with Law and Our Obligations
We may access and/or disclose your Personal Information if we believe such action is necessary to: (a) comply with the law or legal process served on us; (b) protect and defend our rights or property (including the enforcement of our agreements); or (c) act in urgent circumstances to protect the personal safety and welfare of Users or members of the public.
Information Shared with Third Parties
- We may share aggregated information and non-identifying information with third parties for industry analysis, demographic profiling and other similar purposes.
- We may disclose your information-including the contents of your communications with other parties-to other parties, such as when we have a good faith belief that:
- It is necessary to respond to lawful governmental requests or legal process (for example, a court order, search warrant, or subpoena);
- The information is relevant to a crime that has been or is being committed;
- An emergency exists that poses a threat to your safety or the safety of another person; or
- It is necessary to protect our rights or property.
Information that we collect from our users, including Personal Information, is considered to be a business asset. As a result, if we go out of business or enter bankruptcy or if we are acquired as a result of a transaction such as a merger, acquisition or asset sale, your Personal Information may be disclosed or transferred to the third-party acquirer in connection with the transaction. If Keas is involved in a merger, acquisition, or sale of all or a portion of its assets, you will be notified via email and/or prominent notice on our Site or any change in ownership or uses of your personal information, as well as any choices you may have regarding your personal information.
Sharing with Service Providers
We may provide your Personal Information to companies that provide services to help us with our business activities and providing the Services, such as offering customer support. These companies are authorized to use your Personal Information only as necessary to provide these services to Keas , and such service providers are not authorized to use such information for other purposes.
Your Transmissions and Blogs
The Keas Health Challenge and some of the other Services may allow users to post or transmit messages, comments, and other materials. We do not monitor such transmissions, and therefore we cannot be responsible for any Personal Information or other information that may be contained in such transmissions. Please keep in mind that if you directly disclose Personal Information or personally sensitive data through the news feed or other community-based programs or forums, this information may be viewed, collected and used by other Users.
Our Site offers publicly accessible blogs. You should be aware that any information you provide in these areas may be read, collected, and used by others who access them. To request removal of your Personal Information from our blog or community forum, contact us at firstname.lastname@example.org. In some cases, we may not be able to remove your Personal Information, in which case we will let you know if we are unable to do so and why.
Some of our pages utilize framing techniques (IFrames) to send personal information to our partners in order to serve content from them while preserving the look and feel of our Site.
With your prior consent, we may post any testimonials you provide to us via the Services along with your name. If you wish to update or delete your testimonial, you can contact us at email@example.com.
Social Media Features and Widgets
Information We Disclose With Your Consent or at Your Request
We will share your Personal Information with third parties or third-party websites or platforms if you have expressly requested that we do so.
To keep you informed of the latest improvements and alerts relating to the Keas Health Challenge and activities, we may send you emails. You have the ability to manage and opt out of receiving emails on your account settings page, by following the unsubscribe directions in the email you receive or by contacting us at firstname.lastname@example.org.
If you choose to use our referral service to tell a friend or work colleague (a “Referred Friend”) about our Services, we will ask you for your Referred Friend’s name and email address. We will automatically send your Referred Friend a one-time email inviting the Referred Friend to use the Services. Keas stores this information for the sole purpose of sending this one-time email and tracking the success of our referral program. Your friend may contact us at email@example.com to request that we remove this information from our database.
Reviewing, Modifying and Deleting Your Information
You can review and update the Personal Information you provide, modify, add, or delete any optional information, or update your email, contact and privacy preferences by signing into your account and editing your account profile at any time via the Services or by contacting us at firstname.lastname@example.org. We will respond to your request within 30 days.
Please be aware that even after your request for a change is processed, we may, for a time, retain residual information about you in our backup and/or archival copies of our database. We will retain and use your information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.
Closing Your Account
You can close and delete your account at any time by signing into your account and editing your account profile or by contacting us. If you request that your account be deleted from our records, there may be a brief delay in our processing that request while we verify that the request is valid and originates from you as opposed to an unauthorized third party. If you request that your account be deleted, we reserve the right to terminate and/or limit your access to the Services.
If you choose to close your account, we will remove your name and other Personal Information from our database. We may retain certain data contributed by you if we believe it may be necessary to prevent fraud or future abuse, or for legitimate business purposes, such as analysis of aggregated, non-personal information, account recovery, or if required by law.
To request that we close your account and remove your information, please send your request to email@example.com. Please send your request using an email account that you have registered with the Services under your name. We will respond to your request within 30 days.
Links to Other Websites
Our Policy Toward Children
Our Services are intended for a general audience and are not directed to minors. We do not knowingly collect Personal Information from children under 13. If we learn that we have collected Personal Information of a child under 13 we will take steps to delete such information from our files as soon as possible.
Security of Your Personal Information
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, we store the Personal Information you provide encrypted on computer servers with limited access that are located in controlled facilities. We restrict access to Personal Information to our employees, contractors, and agents who need to know that information in order to operate, develop, or improve our Services. These individuals are bound by confidentiality obligations and may be subject to discipline, termination and criminal prosecution, if they fail to meet these obligations.
When you enter sensitive information (such as your account log-in credentials or use our Services), we encrypt the transmission of that information using secure socket layer technology (SSL). We follow generally accepted standards to protect the Personal Information submitted to us, both during transmission and once we receive it. No method of safeguarding information is perfect, however, and we cannot and do not guarantee that your information will be 100% secure. If you have any questions about security on our Site, you can contact us at firstname.lastname@example.org.
Your Personal Information may be transferred to, and maintained on, computers located outside of your state, province, country or other governmental jurisdiction where the privacy laws may not be as protective as those in your jurisdiction. If you’re located outside the United States and choose to provide your Personal Information to us, we may transfer your Personal Information to the United States and process it there.
Our address is:
625 Market St., 9th Floor
San Francisco, CA 94105
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CALIFORNIA PRIVACY RIGHTS