Privacy Policy

Introduction

This Privacy Policy, together, with our Terms of Use, applies to our applications (including the RenewMe and Soulscape Apps), various websites (including www.myrenewme.com), widgets, email notifications, push notifications, and other mediums, or portions of such mediums, including our online and offline services and products (collectively, our “Services”),through which you have accessed this Privacy Policy. This Privacy Policy and our Terms of Use describe the types of personally identifiable information and non-personally identifiable information that you provide to us or that we collect from you in connection with the provision of our Services (“Your Information”).

Please read this Privacy Policy and our Terms of Use carefully. By accessing or using our Services, you consent to the collection, transfer, manipulation, storage, disclosure, processing and other uses of Your Information as described in this Privacy Policy. If you do not want Your Information used or disclosed in the manner described in this Privacy Policy, then you should not use our Services or provide us with Your Information. To the extent that this Privacy Policy conflicts with our Terms of Use, this Privacy Policy will apply and control.

This Privacy Policy does not apply to the following information:

• Information collected by anyone other than us (even if related to our business).
• Information collected by us where a separate privacy policy applies.
• Non-personally identifiable information, which, standing alone, cannot be used to determine your identity. However, if we link such non-personally identifiable information with Your Information in a manner that can be used to determine your identity, then this Privacy Policy will apply.
• Unsolicited information that you provide to us through the Services or through any other means, including information posted to any public areas of our Services, such as bulletin boards, any ideas for new products or modifications to existing products or services, and other unsolicited submissions (collectively, “Unsolicited Information”). All Unsolicited Information is deemed to be non-confidential and we are free, and you hereby grant us the right, to reproduce, use, disclose and distribute such Unsolicited Information to others without limitation or attribution.

Information We Collect and How We Collect It

1- Information You Provide to Us Directly

When you register with or otherwise use our Services, we may require Your Information, such as your name, email, phone number, mailing address, and other information that may help us improve our Services. We may require additional information to provide you with Our Services, including in connection with Transactions, Promotions, purchasing Products, or otherwise for any reason associated with our business. If you choose not to provide us with any requested information, you may not be able to use some or all of the features of our Services.

We may also let you create a profile, separate from your social network profile (for example, your Facebook profile), that RenewMe users and other third parties can see. We collect Your Information and content (such as photos, reviews, ratings, and other information) that you choose to submit in connection with our Services, including in the process of creating or editing your account and user profile.

2- Information that You Generate Using Our Communications Features

Our Services may allow you to communicate or share information with us, as well as other RenewMe users through publicly accessible pages, blogs, private messages, community forums, and other mediums. You expressly acknowledge and agree that we may access in real-time, record, and store archives of these communications (including any call or message data, such as the date, time, and content of such call or message and the applicable phone numbers) on RenewMe’s servers to make use of them in connection with our Services.

We may also let you create a profile, separate from your social network profile (for example, your Facebook profile), that RenewMe users and other third parties can see. We collect Your Information and content (such as photos, reviews, ratings, and other information) that you choose to submit in connection with our Services, including in the process of creating or editing your account and user profile.

3- Third Parties Provide Your Information to Us.

We may collect Your Information from sources other than you, such as from social networks (for example, Facebook, Instagram , Snapchat, and others), blogs, other users, and our business partners. If you use or access our Services on or through a social network, then we will receive certain information about you and your friends from the social network automatically. The information that we will receive depends on the social network and your privacy settings. For instance, we may collect some or all of the following of Your Information from the social network: your name, profile picture, social network identification number, login email, physical location, gender, birthday, age, other publicly available information, and any other information that you or the social network shares with us. If you access our Services from a social network, please read that social network’s terms of use and privacy policy carefully.

4- Information We Collect Automatically

When you use our Services, we and service providers acting on our behalf may use technology to collect information about you, including your location, IP address, browser type, ISP, cookie identifiers, mobile carrier, MAC address, IMEI, Game Center ID, referral and exit pages, clickstream data, pages visited, time of visits and information related to your device, such as hardware models and IDs, device type, operating system version, the request type, the content of your request and basic usage information about your use of our Services, such as date and time. We may also collect and store information locally on your device using mechanisms, such as browser web storage and application data caches.

We and service providers acting on our be half may collect such information through a variety of technical methods, including sending cookies, web beacons, pixel tags and other anonymous identifiers to your device. “Cookies” are pieces of data stored on our computer, mobile phone or other device. A “web beacon” is a type of technology that lets us know if you visited a certain page or whether you opened an email. A “pixel tag” is a type of technology placed within a website or email for the purpose of tracking activity, which is often used in combination with cookies. Other “identifiers” are random strings of characters used for the same purposes as cookies, such as with mobile devices where cookie technology is not available. These technologies help us provide you with features based on your preferences, understand when you are interacting with our Services, and compile other information regarding your use of our Services.

Please note that, in most cases, you can stop making your location available to us or remove or block cookies (such as by using the settings in your browser), but doing so may affect your ability to use our Services.

Further, our Services do not have the capability to respond to “Do Not Track” signals received from our web browsers. Do Not Track (“DNT”) is a privacy preference that users can set in certain web browsers. DNT is a way for users to inform services and websites that they do not want certain information about their webpage visits collected and across online services or websites.

5- Network Advertising

From time to time, we may participate in or use advertising networks, such as third-party advertising servers, advertising agencies, technology vendors, and research firms. We may use these third-party advertising networks for marketing, advertising, and promotional purposes, as well as to serve advertisements to you. Advertising networks often gather data about consumers who view advertisements to make inferences about a consumer’s interests and preferences, which enables such networks to deliver advertisements directly targeted to the consumer’s specific interests. This practice is often referred to as “online behavioral advertising.” For example, a third-party advertising network might collect the type of Internet browser you use, the type of computer operating system you use, the domain name of a website you visit, whether or not you visit specific pages of a website, the location of your Internet service provider’s presence, the date and time of a visit to a website and other interactions between you and a website. Please see the Online Behavioral Advertising subsection of the Choices About How We Use and Collect Your Information section below to read about how you can prevent certain third-party advertising networks from collecting information about you.

6- Third-Party Content

Some content or applications, including advertisements, on our Services may be served by third parties, including advertisers, ad networks and servers, content providers and application providers. These third parties may collect information about you when you use our Services. We do not control these third parties’ tracking technologies or how they may be used. If you have any questions about any targeted content, you should contact the responsible provider directly.

How and Why We Use Your Information

We may use Your Information for various lawful business purposes. Among others, below are some specific examples of these purposes:

• Provide our Services to you. We strive to ensure our services meet the high standards that you would expect of RenewMe. For example, we might verify the information that you provide to us and provide you with administrative notices.
• Contact you and provide you with information. For example, we might contact you through telephone, email, postal, notifications, text messages, or other communications, where permitted by applicable law, to provide you with Service updates, promotional materials, surveys, offers, quotes, personalized information, and other information from us or our business partners.
• Analyze, improve and manage our Services and operations. For example, we might obtain feedback regarding our Services to understand and anticipate your needs and preferences, better understand your use of our Services, customize and tailor Service content, improve our marketing and promotional efforts, engage in statistical analysis, and provide feedback or information to our business partners, vendors, advertisers, and other third parties.
• Resolve problems and disputes, and engage in other legal and security matters. For example, we may use Your Information to comply with, monitor compliance with, and enforce this Privacy Policy, our Terms of Use, and any other applicable agreements and policies, as well as meet other legal and regulatory requirements and protect the security and integrity of our Services.
• Sharing content with friends or colleagues. For example, RenewMe may allow you to provide information about your friends through our “Tell a Friend” referral services. This service may allow you to forward or share certain content with a friend or colleague, such as an email inviting your friend to use our Services. Email addresses that you may provide for a friend or colleague may be used to send your friend or colleague the link or content you request, but will not be collected or otherwise used by us or any other third parties for any other purpose.
• Other purposes. We may also use Your Information in other ways. To the extent required by applicable law, we will provide notice at the time of collection and obtain your consent. For instance, if you apply for a job, we may collect Your Information in order to process your job application.

How We Disclose Your Information

We may disclose Your Information:

• To any person who, in our reasonable judgment, is authorized to receive Your Information as your agent, including as a result of your business dealings with that person (for example, your attorney);
• To our third-party vendors so that they may provide support for our internal and business operations (“Our Vendors”), including for payment or data processing, IT or related services, data verification, data storage, surveys, research, customer service activities, internal marketing, delivery of promotional and marketing materials and our Services’ maintenance and security;
• To fulfill the purpose for which you provide it;
• For any other purpose disclosed by us when you provide Your Information to us;
• With your consent;
• To third parties that are interested in contacting you or providing offers to you that may be related to our services that you may find of interest;
• To third parties whose websites or applications we may link to through our Services if you choose to click on the third-party links;
• As required by law or ordered by a court, regulatory or administrative agency;
• As we deem necessary, in our sole discretion, if we believe that you are violating any applicable law, rule, or regulation, or are otherwise interfering with another’s rights or property, including our rights or property;
• If requested by authorities in the event of any act or instance of local, regional, national, or international emergency;
• To enforce our Terms of Use, this Privacy Policy, and any other applicable agreements and policies;
• To enforce or protect our rights;
• In connection with a business transfer (as described in the section titled Business Transfers below); and
• To our affiliated companies (for example, companies under common control or management with us).

Please note that the list above is not exhaustive and that we may, in our sole discretion, to the extent permitted by applicable law, share, loan, rent, sell or otherwise disclose information we collect from you to third parties at any time, for any lawful purpose, without notice or compensation to you.

If we disclose Your Information to third parties, Your Information will become permanently subject to the information use and sharing practices of the third party. We have taken steps to ensure that such third parties respect Your Information, but please be aware that we make no guarantee whatsoever in connection with how such third parties use, disclose and treat Your Information and such third parties may further disclose, share and use Your Information. By submitting Your Information to us, you expressly consent to such disclosure and use of Your Information. If you do not want Your Information shared as described above, then you should not provide us with Your Information.

Aggregation and De-Personalization

We may take Your Information and de-identify it either by combining it with information about other individuals (aggregating Your Information with information about other individuals) or by removing characteristics (such as your name) that make Your Information personally identifiable to you (de-identifying Your Information). We reserve the right to share, loan, rent, sell or otherwise disclose such information to third parties at any time, for any lawful purpose, without notice or compensation to you.

Sharing with Friends

If you use any functionality of our Services that allow you to send, share or communicate content, information, or material to a friend, then please be aware that (i) we may display your email address or another mode of communication to your friend; and (ii) we may use any information that you provide about your friend to facilitate the communication and as otherwise set forth in this Privacy Policy.

Promotions

Please refer to the official rules and privacy policy for each individual Promotion (if any), as well as this Privacy Policy and our Terms of Use, for our specific policies regarding information sharing and disclosure pursuant to that Promotion.

Circumvention of Security Measures

We use a variety of technical, administrative, and organizational security measures to keep Your Information safe. However, despite our efforts, please be aware that methods of transmission and electronic storage are not completely secure. We cannot guarantee the privacy or security of Your Information or any voice or data transmissions, as third parties may unlawfully intercept or access transmissions or electronic storage . Further, to the extent permitted by applicable law, we are not responsible for circumvention of any privacy settings or security measures of our Services. Therefore, you use our Services at your own risk, you should not expect, that Your Information or voice or data transmissions will always remain private, and we do not guarantee the performance or adequacy of our privacy settings or security measures. In the event that an unauthorized third party compromises our security measures, to the extent permitted by applicable law, we will not be responsible for any damages, directly or indirectly, caused by an unauthorized third party’s ability to view, use or disseminate Your Information.

User Contributions

You may provide information (including messages and other content) to be published, posted, submitted, transmitted or displayed (collectively, “posted”) on or through our Services to RenewMe users or other third parties (collectively, “User Contributions”). Your User Contributions are posted on our Services at your own risk. We cannot control the actions of other users of our Services with whom you may choose to share your User Contributions. Therefore, we cannot and do not guarantee that your User Contributions will not be viewed by unauthorized persons. Please exercise caution before posting any User Contributions on our Services

Business Transfers

We specifically and expressly reserve the right to disclose, lease, sell, assign or transfer Your Information to a buyer or other successor in the event of a sale, acquisition, merger, consolidation, reorganization, bankruptcy, dissolution, or other corporate change involving our business, even if such event is only being contemplated and regardless of whether such event relates to a part of the whole of our business. Nothing in this Privacy Policy is intended to interfere with our ability to transfer all or part of our business, equity, or assets to an affiliate or independent third party at any time, for any lawful purpose, without notice or compensation to you.

How Long Do We Retain Your Information

We will retain Your Information for the period necessary to fulfill the purposes for which Your Information has been collected as outlined in this Privacy Policy unless a longer retention period is required by applicable law.

Choices About How We Use and Disclose Your Information

We strive to provide you with choices regarding Your Information that you provide to us. Below are some mechanisms that provide you with control over certain information:

• Cookies. If you do not wish us to collect cookies, you may set your browser to refuse cookies or to alert you when cookies are being sent. If you do so, please note that some or all parts of our Services may then be inaccessible or may not function properly.
• Communications. If you do not wish to receive notifications, text messages, alerts, posts, notices, emails, or other communications from us, you can opt out of receiving such communications from us (other than service-related communications, such as those communications related to the completion of your registration, correction of user data, change of password and other similar communications essential to your transactions on or through our Services) through your account settings or by, to the extent applicable, by using the unsubscribe process at the bottom of such communication, by emailing us at info@MyRenewMe.com or by calling us at 1-800-515-6460. Please be aware that it can take up to 10 business days to remove you from our marketing lists. If you opt out from receiving our marketing communications, you may continue to receive service-related communications, such as communications that are essential to your transactions on or through our Services.
• Managing Your Information. If a portion of our Services allows you to create an account with us, then you can review and update some of Your Information by logging into that portion of our Services, visiting your account profile page, and making changes. To the extent required by applicable law, you may have the right to request (i) access to Your Information; (ii) an electronic copy of Your Information (portability); (iii) correction of Your Information if it is inaccurate or incomplete; or (iv) deletion or restriction of Your Information in certain circumstances provided by applicable law; provided, however, that deletion or restriction may not include all locations(for instance, Your Information may be retained in back-ups, be required to be retained for a longer period of time under applicable law, or be shared with third parties prior to removal). We may decline to process requests that jeopardize the privacy of others, are extremely impractical, or would cause us to take any action that is not permissible under applicable laws. We will make all required updates and changes within the time specified by applicable law, and where permitted under applicable law, may charge an appropriate fee to cover the costs of responding to such request. Further, where we have obtained your consent for processing Your Information, you have the right to withdraw your consent at any time. If you have a request regarding Your Information, please contact us using any of the methods described below under the section titled Questions, Comments, or Concerns. About this Privacy Policy? below. Please remember, if you make such a request, we may not be able to provide you with the same quality and variety of Services to which you are accustomed.
• Online Behavioral Advertising. Certain third-party advertising networks that deliver behavioral advertising are members of the Network Advertising Initiative (“NAI”). You can prevent NAI member companies from collecting preference data about you by visiting http://www.networkadvertising.org/choices/ and following the NAI’s directions. Note that if you opt out through the NAI, you will still receive advertising. In addition, if you opt out through the NAI and later delete your cookies, use a different browser or buy a new computer, you will need to renew your opt-out choice.

Your Information that You Disclose to Third Parties

This Privacy Policy applies only to our Services and not to websites, online services, or applications owned by third parties. Our Services may contain links to other websites, online services, or applications. We are not responsible for the privacy policies and other practices of such third parties or the accuracy or quality of the services of such third parties. Any information you disclose to third parties will be subject to such third parties' privacy policies and practices. You should review such third parties' privacy policies and practices before disclosing information to them. If you have any questions about how these third parties use your information, you should review their policies and contact them directly.

Operations of Our Services in the United States

Our Services are operated in the United States. Your Information may be processed by us in the country where it was collected as well as in other countries (including, without limitation, the United States) where laws regarding the processing of Your Information may be less stringent than the laws in your country.

Children’s Information.

If you are below the age of 18, you may only download, install, access, or use our Services under the supervision of a parent or legal guardian who agrees to be bound by this Privacy Policy and our Terms of Use. Our Services are not directed towards children under 13 and we do not knowingly collect personally identifiable information from children under 13. If we learn that we have inadvertently gathered personal information from a child under 13, we will take reasonable measures to promptly remove that information from our records.

Changes to this Privacy Policy

We may update, amend or change this Privacy Policy at any time, in our sole discretion and without notice. Amendments will take effect immediately upon us posting such updates on our Services. If we materially change the way in which we process Your Information, we will provide you with prior notice, or where legally required, request your consent prior to implementing such material changes. We encourage you to periodically check this Privacy Policy for changes, as your continued access and use of our Services following the posting of any changes will automatically be deemed your acceptance of all changes. If you do not agree to any change to this Privacy Policy, you must discontinue using the Services. This Privacy Policy replaces all previous notices or statements with respect to this subject, and cannot be modified orally or in writing by any of our associates, representatives or any other third parties.

Your California Rights Policy

Individuals who are residents of California and have provided Your Information to us may request certain information regarding our disclosure of Your Information to third parties for direct marketing purposes. Such requests must be submitted to us at pr@myrenewme.com or

RenewMe
Attention: Legal
299 Camino Gardens Blvd, Suite 100
Boca Raton, Florida 33432

California privacy rights requests must include the reference “Request for California Privacy Information” on the subject line and in the body of the message and must include the email address or mailing address, as applicable, for us to send our response. This request may be made no more than once per calendar year. We reserve the right not to respond to requests submitted other than to the address specified above.

Questions, Comments, or Concerns About this Privacy Policy?

Our team is always happy to hear from you. We welcome any questions, comments and concerns about this Privacy Policy. If you have questions, comments or concerns regarding this Privacy Policy, or wish to exercise your rights related to Your Information, please contact us at pr@myrenewme.com:

RenewMe
Attention: Legal
299 Camino Gardens Blvd, Suite 100
Boca Raton, Florida 33432

If we do not address your questions, comments or concerns about this Privacy Policy to your satisfaction, you may have a right to lodge a complaint with the applicable supervisory authority.