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Privacy NoticeGlobal Challenge

Member Privacy Notice

TRUSTe
TRUSTe

Last Updated: August 1st, 2019

The Virgin Pulse Global Challenge program (the “Program“) is a voluntary employee engagement and wellness program that encourages healthy lifestyle changes. The Global Challenge is paid for by your employer, your spouse’s employer or other sponsoring organisation (the “Program Sponsor“) and operated by Virgin Pulse, Inc., a corporation organised under the laws of the State of Delaware, headquartered at 75 Fountain Street, Providence, Rhode Island, 02902 (“Virgin Pulse“, “Us“, “We” or “Our“).

We are committed to protecting your rights and your privacy. This Privacy Notice (the “Notice“) explains what data We collect about you and how We store, analyse and share the data We collect about you through the platform and the Virgin Pulse mobile application. This Notice applies to all Personal Information whether collected online or offline. The Notice also explains your rights with regards to your data, and how to contact Us to request access, corrections, transfer, restriction or deletion of the data We have collected about you.

We have designed our Privacy Notice in a question and answer format to make it easy to read and understand. Please read through it carefully. If you do not agree with our policies and practices contained in this Notice, please do not enroll in the Virgin Pulse Program.

What laws, regulations and frameworks does Virgin Pulse comply with?

Virgin Pulse participates in, and has certified its compliance with, the EU-U.S. Privacy Shield and Swiss-U.S. Privacy Shield Frameworks, as set forth by the U.S. Department of Commerce, regarding the collection, use and retention of Personal Information from the European Economic Area, the United Kingdom, and Switzerland to the United States. Virgin Pulse is committed to subjecting all personal data received from European Economic Area (EEA) member countries, the United Kingdom and Switzerland to applicable Privacy Shield Framework Principles. If there is any conflict between the terms of this Statement and the Privacy Shield Principles, the Privacy Shield Principles shall govern. To learn more about the Privacy Shield Framework, visit the U.S. Department of Commerce’s Privacy Shield website at https://www.privacyshield.gov/list .To view and learn more about our certification please visit https://www.privacyshield.gov/participant?id=a2zt0000000TOtTAAW&status=Active.

Accountability for Onward Transfer. Virgin Pulse is responsible for the processing of personal data it receives and subsequently transfers to a third party acting as an agent on its behalf, under the Privacy Shield Framework. Virgin Pulse complies with the Privacy Shield Principles for all onward transfers of personal data from the EEA, the United Kingdom and Switzerland, including the onward transfer liability provisions.

With respect to personal data received or transferred pursuant to the Privacy Shield Framework, Virgin Pulse is subject to the regulatory enforcement powers of the U.S. Federal Trade Commission. The Federal Trade Commission may be contacted at the following address:

Federal Trade Commission
Attn: Consumer Response Center
600 Pennsylvania Avenue NW
Washington, DC 20580
Email: Consumerline@ftc.gov
www.ftc.gov

In certain situations, Virgin Pulse may be required to disclose personal data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.

Recourse and Enforcement. In compliance with the Privacy Shield Principles, Virgin Pulse commits to resolve complaints about its collection or use of Member personal information. Any Member within the European Economic Area, United Kingdom or Switzerland with questions or concerns regarding the use or disclosure of personal information or who wishes to file a complaint are directed to contact us via the mechanism indicated herein.  We will respond to any reasonable and valid complaint within 45 days of receipt of such complaint. We will investigate and attempt to resolve complaints and disputes regarding use and disclosure of personal information in accordance with the principles contained in this Statement.

If you have an unresolved privacy or data use concern that we have not addressed satisfactorily, please contact our U.S.-based third party dispute resolution provider (free of charge) at https://feedback-form.truste.com/watchdog/request.

Under certain conditions, more fully described on the Privacy Shield website [https://www.privacyshield.gov/article?id=How-to-Submit-a-Complaint], you may be entitled to invoke binding arbitration when other dispute resolution procedures have been exhausted.

Choice. A Member’s knowledge of and consent to our collection, use and disclosure of Personal Data is important. We rely on the following actions by the Member as indications of consent to our existing and future Personal Data handling:

  • A Member’s voluntary provision of Personal Data to us directly;
  • A Member’s express consent or acknowledgement contained within a written, verbal or electronic application process; and
  • A Member’s verbal consent solicited by us (or our agent) for a specified purpose.

Where We rely on consent for the fair and lawful processing of Personal Data, the opportunity to consent will be provided when the Personal Data in question is collected. A Member’s consent may be given through an authorized representative such as a legal guardian, agent or holder of a power of attorney.

Subject to certain legal or contractual restrictions and reasonable notice, consent may be withdrawn at any time. We will inform the Member of the consequences of withdrawing consent. In some cases, refusing to provide certain Personal Data or withdrawing consent for Us to collect, use or disclose your Personal Data could mean that We cannot provide the requested services or information for you.

If you wish to withdraw consent, please refer to the Contact information section below. However, there are a number of instances where We do not require your consent to engage in the processing or disclosure of Personal Data. We may not solicit your consent for the processing or transfer of Personal information for those purposes, which have a statutory basis, such as:

  • The transfer or processing is necessary for the performance of a contract between you and Virgin Pulse (or one of Our affiliates);
  • The transfer or processing is necessary for the performance of a contract, concluded in your interest, between Us (or one of our affiliates) and a third party;
  • The transfer or processing is necessary, or legally required, on important public interest grounds, for the establishment, exercise, or defense of legal claims, or to protect your vital interests; or
  • The transfer or processing is required by applicable law.

Data Integrity and Purpose Limitation. In addition to employing reasonable Data Security safeguards, We take reasonable steps to ensure that Personal Data is reliable for its intended use; as well as being current, accurate, and complete. We only collect, use, and disclose Personal Data for the purposes specified in this Statement. As part of maintaining current, accurate, and complete Personal Data, We need your help. Should you know that the Personal Data you’ve provided to Us is inaccurate or incomplete, please contact Us via the point of contact as specified herein.

We will normally retain Personal Data for as long as necessary for the fulfillment of the Identified Purposes. However, some Personal Data may be retained for longer purposes as required by law, contract, or auditing requirements.

Contact Information. You may contact Us via email at privacyofficer@virginpulse.com or via the “Contact Us” section of the Virgin Pulse web-based platform and mobile application.

Alternatively, you can contact Us by writing to:

The Virgin Pulse Data Protection Officer
Virgin Pulse, Inc.
75 Fountain Street,
Providence, Rhode Island 02902
United States.

Virgin Pulse’s privacy practices, described in this Privacy Notice, comply with the APEC Cross Border Privacy Rules System. The APEC CBPR system provides a framework for organisations to ensure protection of personal information transferred among participating APEC economies. For more information about the APEC framework please visit http://www.apec.org/Groups/Committee-on-Trade-and-Investment/~/media/Files/Groups/ECSG/CBPR/CBPR-PoliciesRulesGuidelines.ashx

Does Virgin Pulse collect information about me?

Yes. We collect anonymous and Personal Information about you to provide you with the Virgin Pulse services. “Personal Information” means any information, including personal and material circumstances, that allows a person to become identifiable. You are under no obligation to provide any Personal Information to Us at any time. However, if you choose to withhold some Personal Information, We may be unable to provide you with certain services.

The definition of “Personal Information” includes, but is not limited to:

  • Your contact information, including your name and last name, address, personal and business email addresses, and your phone number;
  • The email address you use to sign-in;
  • Your gender, date of birth and age;
  • Information about your health, fitness and related wellness activities offered within the Program;
  • Information about your participation and performance in challenges;
  • The comments and contributions you may make on the web-based platform or mobile application; and
  • Additional information you may provide as you submit queries and requests to Us.

Please keep in mind that the extent of the Personal Information you may be able to share with Us will depend on the features made available to you, as well as your level of participation in the Program. You are under no obligation to provide any Personal Information to Us at any time. However, if you choose to withhold some Personal Information, We may be unable to provide you with certain services.

How does Virgin Pulse use my Personal Information?

We will use the Personal Information collected only to provide you with access to our services, including:

  • To administer and manage your Virgin Pulse account and membership;
  • To identify you when you sign-in;
  • To allow you to participate in Challenges and initiatives;
  • To track your progress in the Program;
  • To provide you with information about the Program and Program features;
  • To inform you of contests you may enter and notify you of the outcome;
  • To display content based on your interests;
  • To improve our communications with you, if you chose to receive any; and
  • To respond to your questions and requests.

Additionally, We may use your Personal Information to create “Anonymous Data” records by removing any information (including any Contact Information) that would allow the remaining data to be linked back to you. We may use the Anonymous Data for internal purposes, such as analysing patterns and program usage to improve our services. Additionally, we may use Anonymous Data to analyse and understand demographic trends, customer behaviour patterns and preferences, and information that can help Us enrich the content and quality of the Virgin Pulse Global Challenge Program. We reserve the right, subject to applicable laws and regulations, to disclose Anonymous Data at our discretion.

How does Virgin Pulse communicate with me?

If you have opted to receive push notifications on your mobile device, We may, from time to time, send you push notifications to provide you with reminders and notifications. If you no longer wish to receive such communications, you may turn them off at the device level.

From time to time, We may send you e-mails or newsletters with information about your Program and the Virgin Pulse platform and services. Depending on your country of residence, you may be given the opportunity to opt-in to receive these communications as you enroll in the platform. Regardless of your initial selection, you may opt-out of these communications, free of charge, at any time during your Membership, by updating your preferences in your account profile information, or by contacting Us directly.

How does Virgin Pulse collect my Personal Information?

We collect Personal Information you voluntarily provide as you submit it through the web-based platform and the mobile application, by reviewing your use of the web-based platform and mobile application (for example through the completion of a health assessment), your use of a synched tracking device such as a Pulse or MAX BUZZ. Virgin Pulse may also collect information about you and your participation in the Program through engagement surveys. Depending on your Program design, your Program Sponsor may have the opportunity to create surveys (the “Virgin Pulse Surveys”) for its Members to complete.

We may also automatically collect additional information when you visit Our web-based platform or mobile application, including the type of browser used, the internet service provider (ISP), referring and exit pages, the files viewed on Our site (e.g., HTML pages, graphics, etc.), date and time stamps of activity on the platform, the accessing IP address (the unique address that identifies your device on the internet) and the operating system your device uses. We use this additional information to derive a broad, non-specific understanding of the locations from which Our Members access Our services, and to enhance the security controls around platform access. We also use it to analyse trends, administer the web-based platform, track Members’ movements on the platform and around the website, and to gather demographic information about Our Member base as a whole.

What information do Virgin Pulse Surveys collect from me?

Your Program Sponsor may choose to create engagement surveys for its Members to complete. If you decide to take part in an engagement survey, the results will be shared with your Program Sponsor in aggregated reports. Your Program Sponsor will not be able to identify you from these reports. However, if the survey offered gives you the ability to respond to a question by writing in a response, the response will be shared with the Program Sponsor. If you include identifiable Personal Information in these open-ended responses, your Program Sponsor may be able to identify you.

What information does Virgin Pulse collect through GC Me?

GC Me is a health assessment questionnaire. GC Me includes the Heart Age survey, which assesses your heart health, and the Lifestyle Score, which assesses your lifestyle across multiple areas of wellbeing. You do not have to complete a GC Me if you do not want to share this type of information with Us.

What are the activity tracking devices and how do they track my activity?

As a Program Member you will be able to connect activity trackers to your account. If you choose to synchronize an activity tracker with the Program, We will receive limited information about your activity to populate your account. Activity tracking devices can track a wide number of different aspects of your daily activities, including, among others, your daily steps and fitness activity, your heartbeat and sleep pattern. Depending on the brand and model of activity tracker you use, the data collected may vary. In general, companies selling activity tracking devices have specific privacy policies available, which outline what data the specific activity tracking device collects. We strongly suggest you review the right privacy notice to know what specific data points your activity tracking device collects about you. While we allow integration with these third-party activity trackers, Virgin Pulse does not make are representation or warranty as to their functionality and compatibility with Our platform, as well as their accuracy, reliability or otherwise. If you have any questions about these devices you should contact the manufacturer.

The Virgin Pulse activity tracking devices are the “Pulse” and the MAX BUZZ. These devices track your step activity per minute. From this information, Virgin Pulse is able to determine your total active fitness minutes and calories consumed. Additionally, if you wear the MAX BUZZ to sleep, it can recognize the length of your sleep from how long you lie still.

Does Virgin Pulse collect information about other individuals?

As a Member, you may have the ability to invite other individuals to participate in the Virgin Pulse Global Challenge. To allow another person to join the Program, We will ask you to provide us with the person’s name and email address. We will use this information exclusively for the purpose of allowing the person to join the Program, and will remove their information if they ask Us not to contact them again.

What Tools does Virgin Pulse use to Collect my Personal Information?

Virgin Pulse and its vendors use tools such as Cookies, tags, scripts and other similar technologies to enhance and support your experience on the platform. These technologies help us administer the web-based platform and mobile application, measure traffic patterns and the total number of users, as well as to personalize and customise the platform’s content, so that your settings are “remembered” when you login.

Cookies are small pieces of text sent to your browser by a website you visit. Cookies help our web-based platform to remember information about your visit, like your preferred settings. Cookies play an important role, they can make your next visit easier and the web-based platform more useful to you. You can learn more about Cookies by visiting www.allaboutcookies.org, where you will also find information about how to block Cookies on different types of browsers. Depending on your location, additional information about Cookies may be presented to you when you visit the web-based platform, and you are given the opportunity object to the use of Cookies. However, please be aware that by blocking or deleting Cookies you may not be able to take full advantage of the web-based platform or mobile application.

Virgin Pulse’s web-based platform uses Cookies to collect information about Member usage of the Program. Additionally, some Cookies on our web-based platform are set by third parties who are delivering services on our behalf. Within the mobile application, webpages are sometimes displayed. Cookies allow you to avoid having to reenter your login credentials when accessing webpages.

We use Cookies:

  • To remember that you have used the website before, allowing us to identify you, as well as the number of unique visitors we receive and manage capacity;
  • To allow you to navigate the website more quickly and easily;
  • To remember your log-in session as you move from one page to the next within the platform;
  • To store your settings and preferences;
  • To customise some aspects of the platform to reflect your interests and preferences; and
  • To collect statistical information about how you use the website, allowing us to improve our services over time.

Does Virgin Pulse use behavioural advertising?

Yes. We partner with a third party ad network provider to either display advertising on Our Website or to manage Our advertising on other websites. Our ad network partner uses Cookies to collect pseudonymised information about your activities on this and other websites 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 alter your overall settings by clicking here (or here if you are an European Union resident). Please note altering your advertising settings does not eliminate all online advertising, and you will continue to receive generic, non-targeted, ads.

Does Virgin Pulse use mobile analytics?

Yes. We use mobile analytics software to allow us to review the functionality of Our mobile software on your phone, and how to improve its quality and Our services. The mobile analytics software may record information such as how often you use the mobile application, the events that occur within the mobile application, crash reports and performance data, where the application was downloaded from and other metrics, such as aggregated usage. The information collected by the mobile analytics software is managed separately from other Personal Information you submit within the mobile application.

Are there links to third party websites and mobile applications on the Virgin Pulse platform and mobile application?

Yes. Our web-based platform and mobile applications may contain links to other websites that are not owned or controlled by Virgin Pulse. These may include promotions, functions, events and competitions or other activities sponsored by third parties. We provide these links and connections for your convenience. Virgin Pulse has no control over these third parties, their privacy policies, and the content they display on their websites or mobile applications. If you choose to participate in these actives and submit Personal Information while visiting these websites or using these mobile applications, please be aware your rights will be governed by the third parties’ privacy policies. Participation in these additional services is at your own risk. We strongly encourage you to carefully read the privacy notice of any website or mobile application you visit or use.

Who at Virgin Pulse has access to my Personal Information?

As a global company, Virgin Pulse has a number of offices and subsidiaries around the world. Virgin Pulse has office locations in the United States, the United Kingdom, Bosnia, Canada, Switzerland, Singapore, Brazil and Australia. Our employees at these locations may be required to access your Personal Information to allow Us to provide you with quality services, including Member support services through the Virgin Pulse Call Center. Our employees are obligated to respect the confidentiality of your Personal Information and are only authorized to access your Personal Information as necessary to provide you with services or support.

Can other Members or my Program Sponsor view my Virgin Pulse profile?

Yes. You can set up special Leagues and Leaderboards and invite other Program Members to compete in these Leagues or Leaderboards if you know their email address. If a Member accepts your invitation, everyone participating on the League or Leaderboard you created will be able to see the standings and each Member’s performance. The profile you create on Our site containing personal information, such as your full name, can be made visible to other registered members at your discretion. You may change the privacy settings of your profile at any time through your event profile page.

To the extent that you participate in any wellness challenges or competitions as part of the Virgin Pulse Program, please be aware that your name and performance information will be available to other Members participating in the challenge or competition, and to your Program Sponsor. Additionally, the Virgin Pulse Program may make message boards and messaging forums available to you. Please be aware that any information disclosed in these settings may become public information. You should exercise caution if disclosing Personal Information while using these features.

What is Team Feed and what information about me is available through it?

Team Feed is a chat-style communication portal, where you can communicate with your teammates. Any information you post will be available for your teammates to view.

When you first access the Team Feed, you will have the opportunity to opt-in to automatic sharing of your individual achievements (often called “Trophies”) on the Team Feed. If you opt-in to this function, we may from time to time post on the Team Feed information about your performance and achievements. You will have the opportunity to modify your preferences at any time through the Team Feed settings. If, after opting-in to these posts on the Team Feed, you later choose to opt-out, the achievements posted up until the time you change your settings will remain visible in the Team Feed. These achievements will remain visible even in the event that you are removed from the Team for any reason or choose to cancel your account.

Where and how is my Personal Information and other data stored?

All your data, including any Personal Information We collect about you, is processed and stored by Virgin Pulse at Microsoft Azure data centers located in the Netherlands. Because your data is stored on Dutch soil, it may be subject to Dutch laws as well as the jurisdiction of the Dutch government, tribunals, law enforcement and regulatory agencies, which may require Virgin Pulse to grant them access to your data.

How does Virgin Pulse Secure my Personal Information?

Virgin Pulse is committed to protecting your data and your privacy. To ensure data security, We follow reasonable physical, electronic and managerial procedures designed to safeguard and secure your data and Personal Information. However, no company can fully eliminate security risks associated with the provision of online services.

Among the security features We use to protect your Personal Information and other data, We require that you create and use a username and unique password to access the web-based platform and mobile application. We use multiple layers of security to protect your Personal Information and data, including firewalls, intrusion detection tools and antivirus software.

Does Virgin Pulse disclose my Personal Information to third parties?

We may, from time to time, share your Personal Information with third parties to allow Us to provide you with our services. If We need to share your Personal Information with third parties, We will limit the information disclosed to the minimum amount necessary to ensure the provision and quality of the services We offer you. We do not make your Personal Information available to any third parties without your permission. Other than through the limited use of cookies, as described above, We never use, disclose, or share your Personal Information for marketing purposes, and We never sell, rent or lease your Personal Information. Subject to any limitations imposed by applicable laws, we reserve the right to disclose Anonymous Data at our discretion.

In the event that We (a) undergo reorganisation or liquidation under bankruptcy, or (b) are sold to a third party, any Personal Information We hold about you may be transferred to the reorganised entity or third party, in accordance with applicable laws. In any such event, the new entity will continue to use your Personal Information in accordance with and within the limits of this Notice to ensure continuation of service.

Who does Virgin Pulse disclose my Personal Information to?

Agents and contractors

In some instances, We may disclose your Personal Information to agents or contractors that work on Our behalf and assist Us in providing and supporting the services We offer. This may include processing transactions in the online store, fulfilling your requests, analysing your data, or helping Us to communicate important information about the Program.

Your Program Sponsor

We may share anonymised and aggregated data with your Program Sponsor. In specific circumstances and for limited purposes, such as to ensure you are rewarded for your participation in the Program or to support tax compliance, we may share reports containing identifiable information with your Program Sponsor.  Your Program Sponsor will not be able to use such anonymised information or aggregated reports to directly identify you. Your Program Sponsor may use the anonymised information in its discretion, including to evaluate the overall program, as well as to provide additional benefits, programs and services.

If your activity information indicates there may be an abnormality or Program abuse, We may share your activity information with your Program Sponsor and make adjustments, suspend or terminate your account, in accordance with your Program Sponsor’s instructions.

Depending on the Program design and features offered, We may share additional information about you and your participation in the Program, to ensure you are provided access to any additional engagement opportunities, rewards and benefits that may be offered through your Program Sponsor.

Government entities

Virgin Pulse may be required to disclose your Personal Information if:

  1. Legally required to do so by governments, tribunals, law enforcement and regulatory agencies (for example as part of an ongoing investigation, subpoena, similar legal process or proceeding);
  2. As otherwise required under any applicable law, regulation, or rule; and
  3. If We believe, in good faith, that such disclosure is necessary to protect or defend our rights or the rights of others, to assist in an investigation or to prevent illegal activity.

Why does Virgin Pulse disclose my Personal Information?

We will only disclose your Personal Information for the following limited purposes:

  1. To coordinate enrollment in additional services made available to you;
  2. To enhance your Program experience;
  3. To provide you with information about the services available to you through the Program and platform, or provided to you by a Program Partner or a Third Party Provider;
  4. To ensure that you receive appropriate rewards for participation in our services and other similar services provided by your Program Sponsor or Third Party Providers;
  5. To evaluate the overall quality and effectiveness of the program(s) you may participate in;
  6. To assess your eligibility for other programs that your Program Sponsor or Third Party Providers may offer.

Is any information I may share with Virgin Pulse become publicly available?

We offer publicly accessible blogs or community forums, where you will have the opportunity to share your thoughts and ideas. You should be aware that any information you provide in these areas may be read and used by others who access them.

To request removal of information you may have posted on Our blog or community forum, contact Us at customer.service@virginpulse.com. However, please keep in mind that We may not always be able to remove the information you posted. If We are unable to remove this information, We will explain why.

Can I access or change the Personal Information Virgin Pulse has collected about me?

Yes, you can review and change your Personal Information by logging into the platform or mobile application. All our Members, regardless of residency, except in specific circumstances identified by local laws, have a legal right to access and correct or update the information Virgin Pulse has collected about you. You can also request a copy of all the Personal Information and data We hold about you. We will provide you with a copy of all the data We have collected about you in a standard format (such as Excel) through a secure channel. You can contact Us to request a copy of all your Personal Information or to request a change in your Personal Information through the “Data Requests” option in the platform or mobile application. We will respond to your request within a reasonable timeframe.

Please keep in mind that We may not be able to accommodate your request if We reasonably believe the change would violate any laws or cause the information to be inaccurate or incorrect. Additionally, We may not be able to fulfill a request where it would impose a burden on Us that is disproportionate to the risk to your privacy, or where your request may affect another individual’s rights to privacy. If We are unable to fulfill a request We will provide you with the reasons why we are unable to comply.

What Privacy Rights do I have under California law?

In accordance with the California Civil Code Section 1798.83 you may contact Us at the address above to request certain information about the disclosure of Personal Information (as defined in Section 1798.83) to third parties for their direct marketing purposes. However, please keep in mind we do not share your Personal Information with third parties for their direct marketing purposes.

Can my Personal Information and other data be transferred to a different company?

Yes, you can request that all your Personal Information and other data be transferred to a different wellness services provider. To complete the transfer, We will require additional information about the new vendor to ensure a secure channel is used, so that your Personal Information and other data remain protected. Depending on the circumstances, we may be unable to support a transfer. However, We will be able to provide you with your Personal Information which you will be able to disclose to anyone you choose. To request this transfer, you may contact Us through the “Data Requests” option in the platform or mobile application. We will respond to your request within a reasonable timeframe.

Can my Personal Information and data be deleted from Virgin Pulse databases?

Yes, you can request that the data collected about you be deleted from our system by terminating your Membership. You may terminate your Membership at any time by submitting a deletion request to our Member Services team, or through the “Data Requests” option in the platform or mobile application. Your Membership will be terminated thirty (30) days after We receive your request. During this thirty (30) day period your Personal Information will be permanently and irreversibly deidentified. If you attempt to access the Program after this process is complete you will be unable to retrieve any information you had previously input and will have to register a new account.

Can I request that Virgin Pulse restrict processing for some of my data?

No. Due to the type of services we offer, we are unable to accommodate requests to restrict the processing of certain sets of data. If you wish for Us to stop processing parts of your data, you can always request that all data be deleted through the deletion process outlined above.

How does Virgin Pulse make changes to this Privacy Notice?

We may update this Notice from time to time to reflect changes in Our information practice and services offered. If We make any material changes to this Notice, you will be notified via an update notification, and you will be given the opportunity to review and accept the new Notice prior to being able to access the platform or continue to use the Program. The date indicating the last update can be found at the top of the Notice. If there are typographical mistakes, like grammar or spelling errors, in the Notice we may correct them without notifying you.

What should I do if I have a concern or complaint against Virgin Pulse and its data privacy practices?

If you have an unresolved privacy or data use concern that we have not addressed satisfactorily, please contact our U.S.-based third party dispute resolution provider (free of charge) at https://feedback-form.truste.com/watchdog/request.

Which Translation of the Virgin Pulse Privacy Notice is the Official Version?

Please note that any translation of this Notice is intended solely to facilitate your access to this information. The English version is the only official version of this Notice and any translation inaccuracies or discrepancies are not binding and have no legal effect for compliance or enforcement purposes.

How can I contact Virgin Pulse or its Data Protection Officer (DPO)?

If you have any questions, comments or concerns, about this Notice, or your rights and obligations under this Notice, you may contact Us via email at privacyofficer@virginpulse.com or via the “Contact Us” section of the Virgin Pulse web-based platform and mobile application.

Alternatively, you can contact Us by writing to:

The Virgin Pulse Data Protection Officer
Virgin Pulse, Inc.
75 Fountain Street,
Providence, Rhode Island 02902
United States.