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Privacy Policy

Virgin Pulse Privacy Policy | Global Challenge Privacy Policy

 


 

Privacy and Cookies Policy

Virgin Pulse, Inc. (“Virgin Pulse,” “we,” “us,” “our”) is committed to protecting your privacy. This Privacy and Cookies Policy (the “Privacy Policy”) explains our data practices regarding the Personal Information we collect about you in connection with our resources and services available through the website and mobile applications (the “Services”), all of which are entirely voluntary, and what steps you can take to protect that information.

Here are the topics we will cover in this Privacy Policy:
Collection and use of Personal Information
Push Notifications
Information Emails
Additional information
Information sharing Access
Anonymous information
Cookies
Security
Data Storage and Data Protection Compliance
Deletion of your Account
External links
Your rights
Changes to this Privacy Policy
Contacting us

Privacy Shield

Virgin Pulse participates in and has certified its compliance with the EU-U.S. Privacy Shield Framework. Virgin Pulse is committed to subjecting all personal data received from European Union (EU) member countries, in reliance on the Privacy Shield Framework, to the Framework’s applicable Principles. To learn more about the Privacy Shield Framework, visit the U.S. Department of Commerce’s Privacy Shield List at https://www.privacyshield.gov/list.

Virgin Pulse is responsible for the processing of personal data it receives under the Privacy Shield Framework and subsequently transfers to a third party acting as an agent on its behalf. Virgin Pulse complies with the Privacy Shield Principles for all onward transfers of personal data from the EU, 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. 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.
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://www.jamsadr.com/file-an-eu-us-privacy-shield-or-safe-harbor-claim.

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

Collection and Use of Personal Information

To enable us to provide quality services to you, we need to collect anonymous and Personal Information about you. “Personal Information” means any information concerning the personal or material circumstances of an identified or identifiable individual. We collect Personal Information through your use of the Software and related services such as the Virgin Pulse Activity Tracking Devices (hardware devices distributed by Virgin Pulse that can be connected with our services), the Biometric Tracking Kiosks (tracking stations located e.g. at your place of employment), and information you provide related to your use of the website and mobile applications (e.g. through the use of cookies).

Your Personal Information includes, but is not limited to, your:

  • contact Information, such as your name, address, email address, phone number provided by your employer, or which you provide when you enrol as a user of the website, upload or submit activity information or any material via the website or request any information;
  • email address in connection with your account sign-in facility;
  • gender and age when you enrol and in connection with your account profile;
  • information collected through the use of our software and related services about your health, fitness and related activities including technical information from your fitness device;
  • record of your participation in activities and challenges and your rewards;
  • information you post in the form of comments or contributions to discussions, and communications you send us to submit queries or comments regarding the website or its content.

You are under no obligation to provide any Personal Information to us at any time. However, if you should choose to withhold specific information, we may be unable to provide you with certain services.

We will use your Personal Information only for the purpose of providing our services to you, including to:

  • Administer your account with us;
  • Identify you when you sign in;
  • Track your programme progress and determine your eligibility for rewards, as well as provide you with information that you may find helpful;
  • Analyse on an anonymous, aggregated data basis the use of the website and the people visiting in order to improve our content and services, including research into our users’ demographics; and send you information that you have requested from us.

Push Notifications

We send you push notifications on your device from time to time in order to provide you with in- product reminders and notifications. If you no longer wish to receive these types of communications, you may turn them off at the device level.

Informational Emails

Virgin Pulse may send you emails or newsletters with information and offers about the Virgin Pulse platform and services. You can opt out of such communications free of charge at any time by updating the ‘my profile’ section of the website or by sending an email to privacy@virginpulse.com.

Additional Information

When you visit the website we may automatically collect additional information such as the type of Internet browser or mobile device you use, your IP address (the unique address that identifies your device on the internet) and the operating system of your device, which is automatically recognised by our web server. We use this information to derive a broad, non-specific understanding of the locations from which you are accessing our services, to analyse trends, administer the site, track users’ movements around the site and to gather demographic information about our user base as a whole and to personalise the website to users’ preferences.

Information Sharing

In general, we will use and disclose your Personal Information to administer our services to you including, at times, disclosing your Personal Information to agents or contractors that work on our behalf and assist us in providing and supporting the services we offer through the website including processing transactions, fulfilling requests, analysing data or helping us to communicate with our members. We may also disclose your Personal Information if you have expressly consented to this.

In addition, we may use your Personal Information, in connection with your participation in our services and your possible participation in other third-party-provided wellness services (“Third- Party Providers”) that may be offered to you by us, your employer or entities with which your employer contracts, for the following general purposes:

  • to coordinate (x) enrolment in, (y) enhancement of your experience and (z) education about the services available to you through our platform such as a Health Risk assessment or any related wellness services provided by a Third-Party Provider,
  • to ensure that you receive appropriate rewards for participation in our services and other similar services provided by your employer or entities that contract with your employer,
  • to evaluate the overall quality and effectiveness of the programme(s) in which you may participate; and
  • to assess your eligibility for other programmes that your employer or contractors on behalf of your employer, may offer.

To the extent you participate in any wellness challenges or competitions that we sponsor, please be aware that your name and performance information will be available to other wellness challenge or competition participants and to your employer.

Except as described in this Privacy Policy, we will not sell, rent or make available your Personal Information to third parties without your permission.
Unless in using the website or mobile applications you expressly or impliedly agree to make certain information available, all Personal Information that we collect is kept confidential to the best of our ability, subject to the other terms and conditions of this Privacy Policy. In addition, our employees and contractors who provide services related to our website or mobile applications are obliged to respect the confidentiality of any Personal Information held by us. Our employed staff and contractors are authorised to use your Personal Information only as necessary to provide these services to us.

In the event that we undergo re-organisation or are sold to a third party, any Personal Information we hold about you may be transferred to that re-organised entity or third party in accordance with applicable law. You acknowledge that such acquisitions may occur, and that any acquirer of Virgin Pulse or its assets may continue to use your Personal Information as set forth in this Privacy Policy.

We may disclose your Personal Information to our subsidiaries, including overseas recipients located in the United Kingdom, Australia, Canada, Singapore or Switzerland.

Virgin Pulse may disclose your Personal Information (a) if legally entitled or required to do so (for example if required by law or by a court order or other judicial or administrative proceeding, (b) as otherwise required under any applicable law, rule or regulation and (c) if we believe, in good faith, that such disclosure is necessary to protect or defend our rights or those of others or to assist in the investigation or prevention of illegal activity.

The website makes message boards and messaging forums available to its members. Any information that is disclosed in these areas may become public information and you should exercise caution when using these and disclosing your Personal Information.

Access

Upon request we will provide you with information about whether we hold any of your Personal Information. If your Personal Information changes or is incorrect or outdated, you may correct, update or amend it by making the change through the “my account” section of the website. If you no longer desire our service, please contact our Member Services department. We will respond to your request within 30 days.

For California Users: California Civil Code Section 1798.83 permits Site visitors who are California residents and who have provided us with “personal information” (as that term is defined in Section 1798.83) to request certain information about the disclosure of that information to third parties for their direct marketing purposes. If you are a California resident, you may contact us by writing to: Virgin Pulse, Inc., 492 Old Connecticut Path, Suite 601, Framingham, MA 01701.

For Canadian Users: Canadian citizens, except under circumstances defined by law, are entitled to access their own personal data collected by Virgin Pulse by writing to: Virgin Pulse, Inc., 492 Old Connecticut Path, Suite 601, Framingham, MA 01701. If you believe that the personal data about you that we have collected is incomplete or inaccurate, please contact us and we will correct the information upon verification of the omission or error and of the identity of the person requesting the change.

Anonymous Information

We may create “Anonymous Information” records from the Personal Information records by excluding your Contact Information or excluding any other information that could link the Anonymous Information back to you. We may use this Anonymous Information for internal purposes, such as analysing patterns in the programme usage, so that we may enhance the services. We reserve the right, subject to applicable law, to use and disclose any Anonymous Information at our discretion. For example, upon request by your employer, we may share Anonymous Information with other partnering organisations for purposes of research and programme analysis. You are welcome to request the names of such partnering organisations from us at any time. We use this Anonymous Information to analyse and understand demographics trends, customer behaviour patterns and desires, and information that may enrich the content and quality of our member programmes.

If you are a member of the Virgin Pulse programme we may (a) share Anonymous Information with your employer in an anonymous aggregated or group format and (b) provide your Personal Information in an anonymous aggregated or group format to third parties (“Analytics Processors”) that process that Personal Information to generate Anonymous Information and analytical information related to that Anonymous Information to be shared with your employer. Your employer will not be able to use such Anonymous Information to directly identify you. Your employer may use this Anonymous Information in its discretion, including to evaluate the programme overall as well as to provide additional benefits, programmes and services. The Analytics Processors do not have any independent right to use your Personal Information except to provide services to generate the Anonymous Information and analyse the information to generate general analytical information. You are welcome to request the names of such Analytics Processors from us at any time.

Cookies

Technologies such as cookies, beacons, tags, scripts and other similar technologies are used by us and our service providers, technology partners or other third-party assets. These technologies are used to help administer the site, identify the total number of users, measure traffic patterns for research purposes, personalise or customise content so that a user’s preferences can be “remembered” when they return to the site and to better manage content.

The website also uses cookies or similar technology to collect information about members’ access to the website.

Cookies are pieces of information that include a unique reference code that a website transfers to your device to store and sometimes track information about you. A number of cookies that the website uses last only for the duration of your session on the website and expire when you close your browser. Other cookies are used to remember you when you return to the website and will last for longer.

We use cookies to:

  • Remember that you have used the website before; this means we can identify the number of unique visitors we receive and manage capacity;
  • Allow you to navigate the website more quickly and easily;
  • Remember your login session as you move from one page to another within the website;
  • Store your settings and preferences;
  • Customise parts of the content of the website to reflect your targets and awards; and
  • Collect statistical information about how you use the website so that we can improve the website and our content.

Some of the cookies used on the website are set by us and some are set by third parties who are delivering services on our behalf.

Most computer and some mobile device browsers automatically accept cookies but, if you prefer, you can change your browser to prevent that or to notify you each time a cookie is set. You can also learn more about cookies by visiting www.allaboutcookies.org, which includes useful additional information on cookies and how to block cookies using different types of browsers. Please note that by blocking or deleting cookies you may not be able to take full advantage of the website.

The table below provides more details about specific cookies issued through this website.

Mobile Analytics

We use mobile analytics software to allow us to better understand the functionality of our mobile software on your phone. This software may record information such as how often you use the application, the events that occur within the application, aggregated usage, metrics, performance data, crash reports and where the application was downloaded from. We do not link the information we store within the analytics software to any personally identifiable information you submit within the mobile application.

Links to third-party sites

The Virgin Pulse website and mobile applications may contain links to other websites that are not owned or controlled by Virgin Pulse. The provision of such links is for your convenience and does not signify our endorsement of such websites or their contents. We have no control over and are not responsible for the privacy policies governing such other websites or the content displayed on such other websites. If you submit Personal Information to any of those sites, your information is governed by their privacy policies. We encourage you to carefully read the privacy policy of any website you visit.

Security

Virgin Pulse follows reasonable physical, electronic and managerial procedures designed to safeguard and secure your Personal Information. However, no company, including Virgin Pulse, can fully eliminate security risks associated with Personal Information. Amongst the security measures we take is a login process requiring a password and username that you select and a firewall protecting our hosting server. Virgin Pulse will retain your username as part of your Personal Information, but will not share this information with anyone. Please be advised that you are responsible for keeping your password and username confidential and secure from unauthorised persons, and that you are responsible for any and all activities that occur under your member account.

It is advisable to close your browser when you have finished your session to help ensure others do not access your Personal Information if you use a shared computer or a computer in a public place.

Data Storage and Data Protection Compliance

Your data will be processed and held by Virgin Pulse at Amazon Web Services data centres located in the United States of America, and as such, it may be subject to U.S. laws and it may be accessible to the U.S. government, tribunals, law enforcement and regulatory agencies. The level of data protection established in the United States of America is lower than the one established within the European Union. We will take measures to ensure that your Personal Information is
stored safely with us; in particular, we maintain compliance with US Data Protection Acts and the applicable Data Protection Acts within the EU.

Deletion of your Account

If your membership is terminated for any reason, we will delete your contact information so that we retain only Anonymous Information in our databases, unless we are obliged to store your Personal Information for legal or billing reasons.

Your rights

You have a legal right under data protection law to a copy of all the information held about you by us. On request we will provide you with a copy of this information. You also have a right to correct any errors in that information. As mentioned above, you have a right to prevent the use of your Personal Information for direct marketing purposes.

Changes to this Privacy Policy

This Privacy Policy is subject to change from time to time. We will post any revised version of the Privacy Policy on the Virgin Pulse website. If we make material changes to it, we will also send you an email to the last email address you provided to us. Any amended Privacy Policy will be effective seven (7) calendar days after posting for existing members.

Any changes to this Privacy Policy may affect our use or disclosure of Personal Information collected prior to the changes. If you do not agree to any of the changes, you must notify us prior to the effective date of the changes that you wish to terminate your membership with us. Continued use of our Services following notice of such changes will indicate your acknowledgement and acceptance of such changes.

Contacting us

Please submit any questions, concerns or comments you have about this Privacy Policy or any requests concerning your personal data by email to privacy@virginpulse.com or via the “contact us” section of this website. Alternatively, you may contact us at:

The Privacy Officer
Virgin Pulse, Inc.
492 Old Connecticut Path
Suite 601
Framingham
MA 01701
United States

Revision Date: April 2017

 

 

PROTECTING YOUR DATA & PRIVACY

You’re important to us — and so is your data. After all, health and wellness information is personal and should be kept private. No ifs, ands, or buts about it. That’s why we’ve taken big steps to make sure your information is safe and sound. Always.

PRIVACY POLICY

We really don’t like jargon and vague explanations – especially about protecting your privacy online. So, here’s the crystal clear summary. If you need more details, you can always check out the full Privacy Policy below.

  • We keep your data in the EU (European Union), at a best-in-class data storage solution.
  • You don’t have to share your Personal Information (it’s up to you). But if you don’t, the Virgin Pulse program might not be able to offer you as many benefits.
  • On our platform, we have a few links to 3rd party websites and services. If you share data with them, their Terms and Conditions and Privacy Policy will apply to you.
  • You can always manage, correct, or delete your data through your settings on the platform or mobile app.
  • We use Cookies, which collect information about you, to enhance your experience.

Virgin Pulse is committed to protecting your rights and your privacy. This Privacy Policy (the “Policy”) explains what data we collect about you and how we store, analyse and share the data we collect about you through the platform (https://globalchallenge.virginpulse.com) and the Virgin Pulse Global Challenge mobile application. The Agreement 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.

Please carefully read through this Policy. To join the Program and enjoy the Virgin Pulse services and Program benefits, you are required to accept all the terms in this Policy. If you choose to accept these terms and enroll in the Virgin Pulse Global Challenge Program, you will become a Member of the Program.

We may update the terms of this Policy from time to time to reflect changes in Our information practices. If We make any material changes to these terms, you will be notified via an update notice, and you will be given the opportunity to review and accept these terms prior to being able to access the platform or continue to use the Program. You may withdraw your consent to this Policy or its updated terms at any time by contacting Us and notifying Us that you wish to terminate your Membership.

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

What laws and regulations does Virgin Pulse comply with?

Virgin Pulse will be compliant with the European General Data Protection Regulation (GDPR) on or before the established enforcement date, May 25, 2018.

Virgin Pulse participates in and has certified its compliance with the EU-U.S. Privacy Shield and Swiss-U.S. Privacy Shield Framework, as set forth by the U.S. Department of Commerce regarding the collection, use and retention of Personal Information from the European Union and Switzerland to the United States. Virgin Pulse is committed to subjecting all personal data received from European Union (EU) member countries and Switzerland, in reliance on the Privacy Shield Framework, to the Framework’s applicable Principles. To learn more about the Privacy Shield Framework, visit the U.S. Department of Commerce’s Privacy Shield website at https://www.privacyshield.gov.

To view and learn more about Our certification please visit https://www.privacyshield.gov/participant?id=a2zt0000000TOtTAAW&status=Active.

Virgin Pulse is responsible for the processing of personal data it receives, under the Privacy Shield Framework, and subsequently transfers to a third party acting as an agent on its behalf. Virgin Pulse complies with the Privacy Shield Principles for all onward transfers of personal data from the EU 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. 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.

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://www.jamsadr.com/file-an-eu-us-privacy-shield-or-safe-harbor-claim.

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

What information does Virgin Pulse collect about me?

To provide the Virgin Pulse services, We collect anonymous and Personal Information about you. “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.

How does Virgin Pulse collect my Personal Information?

We collect your Personal Information as you submit it through the web-based platform and the mobile application, and by reviewing your use of the web-based platform and mobile application (for example through the use of cookies). We may collect Personal Information through your use of additional services such as the Virgin Pulse Activity Tracking Devices (additional information on these is provided below). Virgin Pulse may also collect information about you and your participation in the Program through experience surveys. Additionally, in some cases, your Program Sponsor will have the opportunity to create surveys for its Members to complete.

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. 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 recognise the length of your sleep from how long you lay still.

Other 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 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 policy 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 items you should contact the manufacturer.

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 an assessment that 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 information with Us.

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.

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.

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.

Is my Personal Information and other data secure?

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 security 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 use an email address 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. We retain your email as part of your Personal Information, to allow Us to recognise you when you login, but We do not share your log in information with anyone.

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 authorised to access your Personal Information as necessary to provide you with services or support.

In the event that We (a) undergo reorganisation, or (b) that Virgin Pulse is sold to a third party, any Personal Information We hold about you may be transferred to the re-organised entity or third party, in accordance with applicable laws. In the event that such acquisition occurs, the new entity will continue to use your Personal Information within the limits of this Policy, to ensure continuation of service.

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

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.

Does Virgin Pulse share my Personal Information with 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. We never use, disclose, or share your Personal Information for marketing purposes, and We never sell your Personal Information.

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 store, fulfilling your requests, analysing your data, or helping Us to communicate important information about the Program.

Government entities

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

  1. Legally required to do so by the local government, 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.

Does Virgin Pulse share my Personal Information with my Program Sponsor?

We may provide information in an anonymous and aggregated format or provide your Personal Information in a group format to third parties (“Analytics Processors”) that process that Personal Information to generate Anonymous Information and derive analytical information to be shared with your Program Sponsor. The Analytics Processors do not have any independent right to use your Personal Information, except to provide the aggregation and analysis services. Your Program Sponsor will not be able to use such Anonymous Information or aggregated reports to directly identify you. Your Program Sponsor may use the Anonymous Information in its discretion, to evaluate the overall program, as well as to provide additional benefits, programs and services. Additionally, your Program Sponsor may have access to additional information about you, for the limited purposes above in the section “Does Virgin Pulse share my Personal Information with third parties?”.

We may share Anonymous Data with your Program Sponsor, in an aggregated or group format. Your Program Sponsor may request that We share Anonymous Data with Third Party Providers and partnering organisations, for research and analysis purposes. You can request the names of such Third Party Providers and partnering organisations from Us, or your Program Sponsor, at any time.

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, be aware that We may not always be able to remove your personal information, if that is the case, We will explain why.

Does Virgin Pulse collect other information about me?

When you visit Our web-based platform or mobile application We may automatically collect additional information, including the type of browsers Our Members use, what mobile device you use (the operating system version), your IP address (the unique address that identifies your device on the internet), your 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, 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.

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 with 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.

Does Virgin Pulse use Cookies and other tools to collect data about me?

Virgin Pulse and its Program Partners and 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 personalise 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

What Cookies does Virgin Pulse use?

This chart outlines the Cookies Virgin Pulse uses on its platform and mobile application, what data they collect and how We use the data collected.

Category: Vendor: Purpose: Where Online:
Performance: CloudFlare To serve static content securely from Cloudflare’s global CDN network. All pages of Our websites
New Relic Allow Us to measure site performance. All pages of Our websites
Google Analytics Provides visitor behaviours and actions which allows Us to understand how these visitors are interacting with the site, which allows Us to communicate appropriately with them, both online and offline, to present relevant content. All pages of Our websites and mobile app.
Functionality: Virgin Pulse Uses a number of cookies to help maintain user experience, such as language preference. All pages of Our websites and mobile app.
Targeting: Hubspot Used for marketing/campaign performance (understand how users/visitors interact with content/landing pages) also allows to serve relevant content depending on location/language. All marketing site and landing pages.
LinkedIn Used for retargeting, tracks users from globalchallenge.virginpulse.com site and targets this audience via LinkedIn advertising. All marketing site and landing pages.
GoogleAds Provides visitor behaviours and actions which allows Us to understand how these visitors are interacting with the site, which allows Us to communicate appropriately with them, both online and offline. Used as outlined below for behavioural advertising. All pages of Our websites and mobile app.

Does Virgin Pulse use behavioural advertising?

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 non-identifiable 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?

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.

What are links to third party websites and mobile applications?

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 policy of any website or mobile application you visit or use.

Can I find out what Personal Information and other data Virgin Pulse has collected about me?

Yes, all Our Members, regardless of residency, except in specific circumstances identified by local laws, have a legal right to access the information Virgin Pulse has collected about you. You can 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 data through the “Data Requests” option in the platform or mobile application. We will respond to your request within a reasonable timeframe.

For California Users: 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.

Can I correct or update my Personal Information and other data?

Yes, if your Personal Information changes over time, or you realized your Personal Information is outdated or incorrect, you have a right to be able update it or correct it. You may update or correct the information by modifying it directly within the web-based platform or mobile application. If you are unable to directly update or correct the information within your account, you can contact Us to request that We update or correct the information for you or use 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 other data be transferred to a different company?

At any time during the course of your membership with Virgin Pulse you may 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. To request such 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. You may terminate your Program 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 and this Agreement will terminate 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?

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 request that all data be deleted through the process explained above.

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

If you have any questions, comments or concerns, about this Policy, or your rights and obligations under this Policy, 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.

This policy was last updated on 9 May 2018