Keas® Privacy Policy

Last modified: 9/18/2013
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The privacy of your personal information is very important to Keas, Inc. (“Keas”, “our”, “us” or “we”). This privacy policy describes how we protect and handle the personal information that you provide to us and that we obtain through our web-based service and platform made available via our website, accessible at http://www.keas.com (collectively, the “Site”) and our mobile device applications (the “Applications”).

Keas has been awarded TRUSTe's Privacy Seal signifying that this privacy policy and practices have been reviewed by TRUSTe for compliance with TRUSTe's Program Requirements and the TRUSTed Cloud Program Requirements including transparency, accountability and choice regarding the collection and use of your personal information. If you have questions or complaints regarding our privacy policy or practices, please contact us at support@keas.com. If you are not satisfied with our response you can contact TRUSTe here.

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 http://www.export.gov/safeharbor/

The TRUSTe certification covers the collection, use and disclosure of information we collect through the Site and the Keas Service. The use of information collected through the Service is limited to the purposes described in this privacy policy. The TRUSTe certification does not cover the Applications.

Introduction

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 Challengers per year, but even when employees are not participating in a Keas Health Challenge, they can continue to use the Services.

Participants in the Keas Health Challenge (“Participants”) earn virtual “points” for completing small, but important health goals. Depending on the specifics of the 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 register to use the Services, taking quizzes to test Participants' knowledge, doing “Healthy Breaks”, and posting comments via the Services. Participants will be recognized and may be eligible win prizes in connection with their accrual of points via the Services. The Keas Health Challenge Official Rules provide additional information related to participation in the Keas Health Challenge.

Creating an Account and Records—Collection of Your Personal Information

In order to participate in the Keas Health Challenge and to use other tools made available via the Services, you must create an account. In order to create an account, we will ask you to provide certain Personal Information such as your name and email address, and you will establish a password. We may also ask you to provide location information, such as your city and state. As used in this privacy policy, “Personal Information” means information that can be used to contact or identify an individual. In some cases, your employer may supply this information to us on your behalf. Keas may also request additional information that is not considered Personal Information because it cannot be used to contact or identify you, such as your time zone, gender, height, age group, body mass index and weight. Any information, including Personal Information that you provide to Keas via the Services or authorize your employer, healthcare provider, or any third-party to provide to Keas will be used as described in this privacy policy. We will use your email address to provide the Services to you and to communicate with you in connection with your participation in the Services.

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. 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. You can adjust the privacy settings in your account profile to limit sharing of your comments.

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

We collect certain information through the use of “cookies,” which are small text files that are saved by your browser when you access our Services. We may use both session cookies and persistent cookies to identify that you've logged in to the Services and to tell us how and when you interact with our Services. We may also use cookies to monitor aggregate usage and web traffic routing on our Services and to customize and improve our Services. Unlike persistent cookies, session cookies are deleted when you log off from the Services and close your browser. Although most browsers automatically accept cookies, you can change your browser options to stop automatically accepting cookies or to prompt you before accepting cookies. Please note, however, that if you don't accept cookies, you may not be able to access all portions or features of the Services. Some third-party services providers that we engage (including third-party advertisers) may also place their own cookies on your browser. Note that this privacy policy covers only our use of cookies and does not include use of cookies by such third parties.

Our third party partners employ clear gifs (a.k.a. Web Beacons/Web Bugs), images, and scripts that help them better manage content on the Site and Applications. We may tie the information gathered via these technologies to your Personal Information.

We use local shared objects, also knows as Flash cookies, 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 Flash cookies to collect and store information.

Flash cookies are different from browser cookies because of the amount of, type of, and how data is stored. Cookie management tools provided by your browser will not remove Flash cookies. To learn how to manage privacy and storage settings for Flash cookies click here.

Advertising

We partner with a third party ad network to display advertising on our Keas.com Web 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 opt-out by clicking here. 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

Our servers automatically record certain information about how a person uses our Services (we refer to this information as “Log Data”), including both account holders and non-account holders (either, a “User”). Log Data may include information such as a User's Internet Protocol (IP) address, browser type, operating system, the web page that a User was visiting before accessing our Services, the pages or features of our Services to which a User browsed and the time spent on those pages or features, search terms, the links on our Services that a User clicked on and other statistics. We use this information to administer the Services and we analyze (and may engage third parties to analyze) this information to improve and enhance the Services by expanding their features and functionality and tailoring them to our Users' needs and preferences.

How We Use Your Personal Information

We use Personal Information and non-identifying information you provide through the Services, to provide the Services and as described in this privacy policy. We do not use or disclose your Personal Information except as described in this privacy policy. We may use Personal Information to:

  • 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.
  • We use the third-party tracking service Google Analytics which uses cookies to track non-personal information about Users in the aggregate.

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. If you would like to adjust how your information is shared, you may adjust your privacy settings within your account.

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.

Business Transactions

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 Web 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.

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 support@keas.com. 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.

Your Testimonials

With your prior consent, we may post any testimonials you provide to us via the Services along with your name.

Social Media Features and Widgets

Our Site and Applications include social media features, such as the Facebook “Like” button and widgets, such as the “Share” button. These features may collect your IP address, which page you are visiting on our Site or within our Applications, and may set a cookie to enable the feature to function properly. These features are either hosted by a third party or hosted directly on our Site or Applications. Your interactions with these features are governed by the privacy policy of the company providing the applicable feature.

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.

Emails

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 support@keas.com.

Tell-A-Friend

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 support@keas.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 support@keas.com. 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 support@keas.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 Site and Applications include links to other websites whose privacy practices may differ from those of Keas. If you submit Personal Information to any third party websites, your information is governed by the policies of such websites. We encourage you to carefully read the privacy policy of any website you visit.

Our Policy Toward Children

Our Services are not directed to individuals under 18 and 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.

International Transfer

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.

Changes to this Privacy Policy

We may occasionally update this privacy policy. When we do, we will also revise the "last modified" date at the top of the privacy policy. For material changes to this privacy policy, we will notify you by placing a prominent notice on the home page of the Site and via the Applications or by sending you a notification directly via email prior to the change becoming effective. We encourage you to review this privacy policy periodically to stay informed about how we collect, use and share your Personal Information and how we try to protect the Personal Information we collect.

Contact Information

We welcome your comments regarding this privacy policy. If you have questions about this statement, please contact us by email by following this link: support@keas.com.

Our address is:

Keas Inc.
625 Market St., 9th Floor
San Francisco, CA 94105

Keas® and “the power of play”™ are our trademarks.

CALIFORNIA PRIVACY RIGHTS

Residents of the State of California have the right to request a list of all third parties to which a company conducting business in California has disclosed personally identifiable information during the preceding year for direct marketing purposes. Alternatively, the law provides that if the company has a privacy policy that gives either an opt-out or opt-in choice for use of your personally identifiable information by third parties for marketing purposes, the company may instead provide you with information on how to exercise this choice.

We qualify for this alternative option: it has a comprehensive privacy policy and provides you with details on how you may either opt-out or opt-in to the use of your personally identifiable information by third parties for direct marketing purposes (see Opt-Out Procedures above). Therefore, we are not required to maintain or disclose a list of the third parties that received your personally identifiable information for marketing purposes during the preceding year.

 

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