Privacy and Cookies Policy
Collection and use of personal information
Data storage and Data Protection Compliance
Deletion of your Account
Virgin Pulse, Inc. participates in and has certified its compliance with the EU-U.S. Privacy Shield Framework. Virgin Pulse, Inc. 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, Inc. 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. Inc. 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. Inc. is subject to the regulatory enforcement powers of the U.S. Federal Trade Commission in certain situations, Virgin Pulse. Inc. 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.
Collection and Use of Personal Information
Your Personal Information includes your:
You are under no obligation to provide any such information. 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:
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.
Virgin Pulse may send you e-mails 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 e-mail to email@example.com.
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 recognized by our web server. We use this information to analyze trends, to administer the site, to track users’ movements around the site, to gather demographic information about our user base as a whole and to personalize the website to users’ preferences.
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, analyzing 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 similar services that may be offered to you by your employer or entities with which your employer contracts, for the following general purposes:
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, provided you expressly consent to this, to your employer.
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.
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 Member Service. We will respond to your request to within 30 days.
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 analyzing patterns in the program 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 organizations for purposes of research and program analysis. You are welcome to request the names of such partnering organization from us at any time. We use this Anonymous Information to analyze and understand demographics trends, customer behavior patterns and desires, and information that may enrich the content and quality of our member programs.
If you are a member of the Virgin Pulse Program through your employer’s participation in one of our programs, 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 program overall as well as provide additional benefits, programs, 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 analyze the information to generate general analytical information. You are welcome to request the names of such Analytics Processors from us at any time.
Technologies such as cookies, beacons, tags, scripts and other similar technologies are used by us and our service providers, technology partners or other 3rd party assets. These technologies are used to help administer the site, identify the total number of users, measure traffic patterns for research purposes, personalize or customize content so that a user’s preferences can be “remembered” when they return to the site, and to better manage content.
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 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.
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 browser. 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 detail about specific cookies issued through this website.
|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 behaviors 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.||All pages of our websites and mobile app.|
|Crittercism||Allow us to collect mobile app error information through Crittercism.com||All pages of our mobile app|
|Inspectlet||Allows us to track members’ website journey and create heat maps||All Virgin Pulse platform pages|
|Functionality:||Filepicker.io||Allow us to offer our customers ability to upload photo files to the web site||All pages of our websites|
|Zendesk||Allows us to offer customers to email or chat with one of our Customer Service agents online.||All pages of our websites|
|Walk Me||Tool used to create web page tutorials for members and explain them the usage||All pages of our website|
|Pusher||Tool which allows us to create real time chat and notification system for members||All pages of our website and mobile app|
|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:||Bizographics||Cookies are used by the partner to track performance of marketing campaigns and recognize you on third party websites, to ensure marketing messages are as relevant as possible.||In various places across the Virgin Pulse website.|
|Localytics||Allows us to track actions and send marketing and engagement messages to our members||All pages of our website and mobile apps|
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 3rd party sites
Virgin Pulse follows reasonable physical, electronic, and managerial procedures to safeguard and secure your Personal Information. However, no company, including Virgin Pulse, can fully eliminate security risks associated with Personal Information. Among the security measures taken 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 unauthorized persons.
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 Data Centers located in 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.
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.
The Privacy Officer
Virgin Pulse, Inc.
492 Old Connecticut Path, Suite 601, Framingham, MA 01701, United States
Revision Date: December 2016