Lief Privacy Policy
Last Updated: May 8th, 2024
1. INTRODUCTION
At Lief Therapeutics, (“Lief,” “us,” “we,” or “our”), our mission is to improve mental health from the inside out. We take privacy seriously and want you to understand how we use, collect, and share Personal Data, and the measures we take to protect your Personal Data. This Privacy Policy applies to Personal Data we collect about members and other consumers who interact with Lief or use our services, including by visiting our websites or our social media pages, or using our mobile apps, the Lief smart patch or another Lief device (collectively, the “Services”). This Privacy Policy does not cover the practices of companies that we do not own or control, or people that we do not manage. We are not responsible for the policies and practices of any third parties, and we do not control, operate, or endorse any information, products, or services that may be offered by third parties or accessible on or through the Services. We have provided supplemental notices below for residents of California.
2. HOW WE COLLECT PERSONAL DATA
We collect Personal Data about you from: Yourself, when you provide such information directly to us, such as when completing your profile; Lief patch or another device that you wear; Lief Coach when you interact with and receive responses from the Lief Coach as described in Section 8 below; Third-party integrations when you authorize them, such as Google Calendar integration. Automatic data collection, such as Cookies, local storage objects, web beacons, and other similar technologies in connection with your use of the Services; Customers and partners, such as employers, insurance companies, coaches, teams, or other organizations that engage with our Services; Marketing and advertising partners, such as companies that have entered in joint marketing relationships with us or assist us with marketing or promotional services, which may provide us with data related to how you interact with our Services, advertisements, or communications; Social media, other third-party platforms, and linked accounts, devices, or features, if you interact with our pages on social media sites, post content to their sites using the Services, sign into the Services through a third-party site or service, or otherwise link accounts, devices, or features to your Lief account; and Data providers, such as information services and data licensors, when we supplement your data.
3. PERSONAL DATA WE COLLECT
We may collect the following types of Personal Data: Contact details, such as your first and last name, email and mailing address, and phone number; Profile data, such as username and password that you may establish to create a Lief account, as well as any photographs or information you choose to include in your Lief profile; Communications that we exchange with you, including when you contact us via email, web app, or mobile app with questions, feedback, or reviews; Wellness Data, such as resting heart rate, heart rate variability, acceleration; metadata on biofeedback exercises, posture and sleep; the type of physical activity you engage in and the duration of your activity; data reflecting stress and recovery; your physiological profile, including birthday, gender identity, weight, height, fitness/athlete level; and details you choose to submit about your diet, medications, and other health information. We may use certain of this information to customize your experience with us as part of our Services; Conversations that you participate in with the Lief Coach, as described in Section 8 below; Calendar data, if you choose to integrate your calendar with Lief, including event names, dates, times, and other calendar meta-data. If you choose to integrate Google Calendar with the Lief Services, please note that we access your Google Calendar information to enhance your user experience, such as scheduling biofeedback sessions, tracking your wellness activities, and aligning your mental health goals with your daily routines. This integration allows us to collect and process information like event times and descriptions solely for these purposes. Lief will not access, store, or use any Google Calendar data beyond what is necessary for providing these features, and we will not share your Google Calendar data with third parties, except as necessary to provide the integrated services or as required by law. You can disconnect Lief from your Google Calendar at any time by adjusting the permissions in your Google account settings.For more information on Google’s privacy practices, please refer to their Privacy Policy here: https://policies.google.com/privacy. Payment and transactional data needed to complete your orders on the website or through the Services (including name, email address, payment card information, bank account number, billing information) and your transaction history, although Lief does not have access to payment card numbers. Our payment processors will collect the financial information necessary to process your payments in accordance with the payment processor’s respective services agreement and privacy policy; Marketing data, such as your preferences for receiving our marketing communications, and details about your engagement with them (e.g., the marketing emails that you open and the links within them that you click); Device data, such as your computer or mobile device operating system type and version, manufacturer and model, browser type, screen resolution, RAM and disk size, CPU usage, device type (e.g., phone, tablet), IP Address, unique identifiers (including identifiers used for advertising purposes), language settings, mobile device carrier, radio/network information (e.g., Wi-Fi, LTE, 3G), and general location information such as city, state, or geographic area; Geolocation data, such as GPS, IP Address, and movement on certain exercise types if you give permission for Lief to do so; and Online activity data, such as pages or screens you view, how long you spent on a page or screen, the website you visited before visiting our website, navigation paths between pages or screens, information about your activity on a page or screen, access times, and duration of access.
4. COOKIES AND SIMILAR TECHNOLOGIES
Lief uses cookies and similar technologies such as pixel tags, web beacons, clear GIFs, and JavaScript (collectively, “Cookies”) to enable our servers to recognize your web browser and tell us how and when you visit and use our Services, as well as to analyze trends, learn about our user base, and operate and improve our Services. Cookies are small pieces of data – usually text files – placed on your computer, tablet, phone, or similar device when you use that device to visit our Services. We may also supplement the information we collect from you with information received from third parties, including third parties that have placed their own Cookies on your device(s). Cookie Usage and Type. Lief uses the following Cookies: Essential Cookies:Essential Cookies are required for providing you with features or Services that you have requested. For example, certain Cookies enable you to log into secure areas of our Services. Disabling these Cookies may make certain features and Services unavailable. Functionality Cookies: Functional Cookies are used to record your choices and settings regarding our Services, maintain your preferences over time, and recognize you when you return to our Services. These Cookies help us to personalize our content for you, greet you by name, and remember your preferences (e.g., your region). Performance/Analytical Cookies: Performance/Analytical Cookies allow us to understand how users use our Services by collecting information on how often a user engages with a particular feature of the Services. We use these aggregated statistics internally to improve the Services. Performance/Analytical Cookies also help us measure the performance of our advertising campaigns in order to help us improve our campaigns and the Services’ content for those who engage with our advertising. For example, Google, Inc. (“Google”) uses Cookies in connection with its Google Analytics services. For more information on how Google uses this information, click here. Marketing Cookies: Marketing Cookies collect data about your online activity and identify your interests so that we and our advertising partners can provide marketing that we believe is relevant to you. For more information, please see the section below titled “Interest-based advertisements.” Online tracking opt-outs. There are a number of ways you can opt out of certain interest-based advertising and other online tracking activities, which we have summarized below. Blocking Cookies in your browser. Most browsers let you remove or reject Cookies, including Cookies used for interest-based advertising. To do this, follow the instructions in your browser settings. Many browsers accept Cookies by default until you change your settings. For more information about Cookies, including how to see what Cookies have been set on your device and how to manage and delete them, visit www.allaboutcookies.org. Blocking advertising ID use in your mobile device settings. Your mobile devices may offer settings that enable you to make choices about the collection, use, or transfer of your advertising ID associated with your mobile device for interest-based advertising purposes. Using privacy plug-ins or browsers. You can block our websites from setting Cookies used for interest-based ads by using a browser with privacy features, like Brave, or installing browser plugins like Privacy Badger, Ghostery, or uBlock Origin, and configuring them to block third party Cookies/trackers. You can also opt out of Google Analytics by downloading and installing the browser plug-in available at: https://tools.google.com/dlpage/gaoptout. Platform opt-out. Google (AdWords): adsettings.google.com; Microsoft (Bing): about.ads.microsoft.com/en-us/resources/policies/personalized-ads; and Facebook: www.facebook.com/about/ads. Some third-party ad networks, including third-party ad servers, ad agencies, ad technology vendors, and research firms, allow you to opt-out directly by using their opt-out tools. Some of these providers, and links to their opt-out tools, are: Advertising industry opt-out tools. Digital Advertising Alliance for Websites: https://optout.aboutads.info; Digital Advertising Alliance for Mobile Apps: https://youradchoices.com/appchoices; and Network Advertising Initiative: https://optout.networkadvertising.org/. You can also use these opt-out options to limit use of your information for interest-based advertising by participating companies: Please note that some opt-out features are Cookie-based, meaning that when you use these opt-out features, an “opt-out” Cookie will be placed on your computer or other device indicating that you do not want to receive interest-based advertising from certain companies. If you delete your Cookies, use a different browser, or use a different device, you will need to renew your opt-out choice. Opting out of interest-based advertising does not mean that you will no longer receive online ads. It only means that such ads will no longer be tailored to your specific viewing habits or interests. You may continue to see ads on and about the Service.
5. HOW WE USE PERSONAL DATA
We process Personal Data to operate, improve, understand, and personalize our Services. We use Personal Data for the following purposes: Service delivery, including to: Provide, operate, improve, develop, understand, and personalize the Services and our business, including testing, research, analysis, and product development; Satisfy the reason you provided the information to us, including responding to and fulfilling requests; Communicate with you about the Services, including Service announcements, updates, or offers; Provide support and assistance for the Services; Create and manage your account or other user profiles; Customize website content and communications based on your preferences; and Process orders, memberships, or other transactions. Research and development. We may create and use Aggregated Data, De-identified Data, or other anonymous data from Personal Data we collect, including Wellness Data, for our business purpose, including to analyze the effectiveness of the Services, to improve and add features to the Services, and to analyze the general behavior and characteristics of users of the Services. We also use anonymous Wellness Data for research purposes to help us and our research partners answer important questions about human performance and create an even-better experience for our members by identifying cutting-edge insights and providing new content and product features. Direct marketing and advertising. We may use data from the Personal Data we collect, including Wellness Data and certain data collected when you browse our website, to send you direct offers marketing messages or advertise the Services or other Lief product offerings. Interest-based advertising. We engage our advertising partners, including third party advertising companies and social media companies, to advertise our Services. We and our advertising partners may use Cookies and similar technologies to collect information about your interaction over time across the web, our communications, and other online services, and may use that information to serve online ads. We comply with the Digital Advertising Alliance Self-Regulatory Principles for Online Behavioral Advertising. To learn more about the industry self-regulatory programs and other information and choices about interest-based ads, please see the section above entitled “Online tracking opt-outs.” Compliance and protection, including to: Protect against or deter fraudulent, illegal, or harmful actions and maintain the safety, security, and integrity of our Services; Comply with or enforce our legal or contractual obligations, resolve disputes, and enforce our Terms of Use; Audit our internal processes for compliance with legal and contractual requirements and internal policies; Protect our, your, or others’ rights, privacy, safety, or property (including by making and defending legal claims); and Respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.
6. HOW WE SHARE PERSONAL DATA
We may share your Personal Data with: Service providers, such as payment processors, vendors who advertise our Services or other Lief products, security and fraud prevention consultants, hosting and other technology and communications providers, analytics providers, and staff augmentation and contract personnel, that provide services to us or on our behalf; our service providers also include our third-party Large Language Model (“LLM”) partner that powers Lief Coach, as described in Section 8 below; Advertising partners that may collect information on our website through Cookies and other automated technologies, including for the interest-based advertising purposes described above. We do not share your Wellness Data with advertising partners; Professional advisors, such as lawyers, auditors, bankers, and insurers, where necessary in the course of the professional services they render to us; Authorities and others, including law enforcement, government authorities, and private parties we believe in good faith to be necessary or appropriate to comply with the law or legal process; and Business transferees, such as acquirers and other relevant participants in business transactions (or negotiations for such transactions) involving a corporate divestiture, merger, consolidation, acquisition, reorganization, sale, or other disposition of all or any portion of the business or assets of, or equity interests in, Lief or our affiliates (including, in connection with a bankruptcy or similar proceedings). Distributors and retailers of our Services or other Lief products; Affiliates of Lief.
7. HOW YOU MAY SHARE PERSONAL DATA THROUGH Lief
Depending on your use of the Services, you may share Personal Data with: Other users of the Services, such as through our Lief Live or other group sharing features, which allow you to share information and content with other users of the Service, and users are by default searchable by other users; Third-party social media platforms, or linked accounts, devices, or features, when you choose to connect your account on those services with Lief or post content to social media, such as through the Lief Live feature; The Public. When you make Personal Data visible to other users of the Services, including through the Lief Live, it may become publicly available and can be collected, viewed, and used by anyone; Managing entities. If your use of the Services is on behalf of or managed by a managing entity, such as a coach, team, organizing body, or other entity with which you are affiliated, your account information and Personal Data may be shared with the managing entity subject to your consent, and you hereby consent to that managing entity allowing that information to be publicly shared, subject to any features of the Services that expressly override that control. The managing entity will determine how the relevant information and content is shared; and Corporate wellness programs. If you use the Services in connection with an employer or organizational corporate wellness program, we may share your information with that organization subject to your consent. Typically, we will share only Aggregated Data with these organizations.
8. LIEF COACH & THIRD-PARTY AI TECHNOLOGY
Lief Coach is a generative AI feature that is intended to help you understand and make progress to your goals, decipher Lief concepts, and provide educational guidance, and integrate with the rest of the Lief experience. Lief Coach creates a health coaching experience by combining your unique, anonymized Lief metrics with the science of biofeedback to help you optimize your health, fitness, and performance. If you decide to use Lief Coach, please note that Lief Coach leverages third-party AI technology provided by our LLM partner. This technology is trained on real-world data to generate intelligent and personalized responses in conversations with users. Responses from Lief Coach are based on your requests and relevant information collected through your Lief metrics. For example, if you ask Lief Coach a sleep-related question, then Lief Coach may provide personalized tips for improving your sleep based on your anonymized sleep data collected through the Services. We require our LLM partner to use your anonymized Lief metrics only for the purpose of allowing Lief Coach to generate responses to your chats. We have ensured that our LLM partner has a “Zero-Retention/Zero Training Policy” with respect to your Lief metrics, meaning that our LLM partner will not store or retain any of the anonymized Lief metrics they receive through your use of Lief Coach, and our LLM partner will not use any of the anonymized Lief metrics they receive for training any algorithms or LLM technology. We will only share your anonymized Lief metrics with our LLM partner. We ask that you refrain from providing any identifying information, such as your name, in conversations with Lief Coach. Lief may retain the history of your conversations with Lief Coach to ensure you continue to have access to previous conversations while using the feature. When you revisit any topics from previous chats, Lief may share the context of your previous conversations with Lief Coach to create a better experience for you. You may delete your Lief Coach chat data at any time by requesting a deletion through support@getlief.com. If you agree to use Lief Coach, please note that Lief employees will only access member Personal Data when required to provide services and support, which may include collecting information about your experience with Lief Coach to assess the performance of and improve Lief Coach and other product offerings.
9. YOUR CHOICES
Access, update, or delete. When you log in to your account, you may access, and, in some cases, edit or delete certain information you’ve provided to us, such as first and last name, username and password, email and mailing address, and other information in your profile. When you update information, however, we may maintain a copy of the unrevised information in our records. You may request access to or a full deletion of your account and corresponding data by contacting support@getlief.com. You will be asked to complete a verification form in connection with such access or deletion request in order to ensure that you have the authority to access or delete your account. We may need to retain certain Personal Data in our records, as well as Aggregated Data or De-identified Data derived from or incorporating your Personal Data that does not identify you after you update or delete it. Push notifications and device permissions. Access, update, or delete. When you log in to your account, you may access, and, in some cases, edit or delete certain information you’ve provided to us, such as first and last name, username and password, email and mailing address, and other information in your profile. When you update information, however, we may maintain a copy of the unrevised information in our records. You may request access to or a full deletion of your account and corresponding data by contacting support@getlief.com. You will be asked to complete a verification form in connection with such access or deletion request in order to ensure that you have the authority to access or delete your account. We may need to retain certain Personal Data in our records, as well as Aggregated Data or De-identified Data derived from or incorporating your Personal Data that does not identify you after you update or delete it. Geolocation data. You may allow or disallow Lief to collect geolocation data by enabling or disabling location services on your mobile device. If you decline to grant Lief access to this data, we will not be able to provide certain Services, capabilities, or features to you. Wellness Data. You can disable collection of additional Wellness Data by un-pairing your Lief device from your mobile device. Lief Coach. You can choose whether or not to enable and interact with Lief Coach. We will only share your anonymized Lief metrics with our LLM partner that powers Lief Coach if you engage with the feature. If you no longer wish to use Lief Coach, you can simply not interact with the feature. Marketing communications. We give you the ability to opt-out of marketing-related emails and other communications by emailing support@getlief.com, or by following the opt-out or unsubscribe instructions contained in the marketing-related message. You cannot opt-out of receiving certain non-marketing emails regarding the Service. Online tracking opt-outs. There are a number of ways you can opt-out of certain interest-based advertising and other online tracking activities, which we summarize in the “Online tracking opt-outs” section above. Do Not Track. Some Internet browsers may be configured to send “Do Not Track” signals to online services. The Services do not currently support “Do Not Track” requests or similar signals. To find out more about “Do Not Track,” please visit http://www.allaboutdnt.com.
10. OTHER SITES AND SERVICES
The Services may contain links to websites and other online services operated by Third Parties. In addition, our content may be integrated into web pages or other online services that are not associated with us. These links and integrations are not an endorsement of, or representation that we are affiliated with, any Third Party. We do not control mobile applications, websites or online services offered or operated by Third Parties, and we are not responsible for their actions. You can learn about and control how these Third Parties use and share Personal Data about you, including with Lief, by reviewing their privacy notices and exercising the privacy choices the Third Party may offer.
11. DATA SECURITY AND RETENTION OF PERSONAL DATA
We employ a number of physical, technical, organizational, and administrative security measures designed to protect the Personal Data we collect. While we endeavor to protect the privacy of your account and other Personal Data we hold in our records, no security measures are failsafe, and we cannot guarantee the security of your Personal Data. We retain Personal Data for as long as reasonably necessary for the purposes described in this Privacy Policy, while we have a business need to do so, or as required by law (e.g., for tax, legal, accounting, or other purposes), whichever is longer.
12. PERSONAL DATA OF CHILDREN
If you are under the age to consent to data sharing, as applicable based on your jurisdiction, please do not attempt to register for the Services or send any Personal Data about yourself to us. If we learn that we have collected Personal Data from a child under the age to consent to data sharing, as applicable based on jurisdiction, we will delete that information as quickly as possible. If you believe that a child under the age to consent to data sharing, as applicable based on your jurisdiction,, may have provided us Personal Data, please contact us at support@getlief.com.
13. CHANGES TO THIS PRIVACY POLICY
We are constantly trying to improve our Services, so we may need to change this Privacy Policy from time to time. We will alert you to changes by placing a notice on the Lief website, by sending you an email, and/or by some other means. If you use the Services after any changes to the Privacy Policy have been posted, that means you agree to all of the changes.
14. CONTACT US
If you have any questions or concerns regarding our privacy policies, please send us a detailed message to support@getlief.com or at the mailing address below. Lief Therapeutics, 2443 Fillmore St. #380-6060, San Francisco, CA 94115 15. PRIVACY NOTICE FOR CALIFORNIA RESIDENTS We are providing this supplemental privacy notice to consumers in California, pursuant to the California Consumer Privacy Act of 2018 (the “CCPA”). We do not sell Personal Data. As we explain in this Privacy Policy, we use Cookies and other tracking technologies to analyze website and application traffic and use, and to facilitate advertising. To limit use of Cookies and other tracking technologies, please review the instructions provided in the “Online tracking opt-outs” section. You may also direct us to share your data, as described in the “How You Share Personal Data Through Lief” section of the Privacy Policy. California Privacy Rights. If you are a California resident, you have the following rights: Information: The Privacy Policy describes the types of Personal Data we collect in the “Personal Data We Collect” section above and the sources through which we collect Personal Data in the “How We Collect Personal Data” section above. We describe the purposes for which we use and share this data in the “How We Use Personal Data section above and the “How We Share Personal Data section above. Access: You can request a copy of the personal information that we maintain about you. Deletion: You can ask to delete the personal information that we have collected from you. Opt-out of sale of your Personal Data: We do not sell Personal Data. We offer instructions on how to limit online tracking in the “Online tracking opt-outs” section of the Privacy Policy. Please note that the CCPA limits these rights by, for example, prohibiting businesses from providing certain sensitive information in response to an access request and limiting the circumstances in which they must comply with a deletion request. You are entitled to exercise the rights described above free from discrimination. Exercising Your Rights. To exercise these rights, you can submit requests as follows: To request access to or deletion of Personal Data collected via your use of the Services, please email us at support@getlief.com. To learn how to opt-out of interest-based ads and other online tracking, see the “Online tracking opt-outs” section of the Privacy Policy. To verify your identity prior to responding to your requests, we may ask you to confirm information that we have on file about you or your interactions with us. Where we ask for additional Personal Data to verify your identity, we will only use it to verify your identity or your authority to make the request on behalf of another consumer. Authorized agents: California residents can empower an “authorized agent” to submit requests on the resident’s behalf. Your authorized agent may submit requests in the same manner, although we may require the agent to present signed written permission to act on your behalf, and you may also be required to independently verify your identity with us and confirm that you have provided the agent permission to submit the request.
15. DEFINITIONS
We use some specifically defined terms in our Privacy Policy and when we communicate about our Privacy Policy. We want to be clear on how the terms we use are defined to help you better understand our policies. Aggregated Data: Aggregated Data is data that has undergone a process whereby raw data is gathered and expressed in a summary form for statistical analysis. Raw data can be aggregated over a given time period, across individuals, or both, to provide statistics such as average, minimum, maximum, sum, and count. After the data is aggregated analysis can be performed to gain insights about particular data sets. When data is aggregated across a number of individuals, the resulting aggregation is considered anonymized such that it is no longer Personal Data. See our Privacy Policy for more information on how we use Aggregated Data. CCPA: The California Consumer Privacy Act, or CCPA, is a state law that provides California consumers with robust data privacy rights. These rights include the right to know, the right to delete, and the right to opt-out of “sale” of personal information that businesses collect, as well as additional protections for minors. A “sale” under the CCPA is defined as “selling, renting, releasing, disclosing, disseminating, making available, transferring, or otherwise communicating orally, in writing, or by electronic or other means, a consumer’s personal information by the business to another business or to a third party for monetary or other valuable consideration.” See our Privacy Policy for more details on the information we may share with others. Cookies: Cookies are small files which are stored on a user’s computer. They are designed to hold a modest amount of data specific to a particular user and website and can be accessed either by the web server or the user computer. This allows the server to deliver a page tailored to a particular user, or the page itself can contain some script which is aware of the data in the cookie and is therefore able to carry information from one visit to the website (or related site) to the next. See our Privacy Policy to learn about cookies and how they are used on our websites. De-Identified Data: De-Identified Data is data where all the personally identifiable information has been removed, rendering the data anonymous by stripping out information that would allow an individual’s identity to be determined from the remaining data. Data is “de-identified” to protect the privacy and identity of individuals associated with the data. De-identified Data is no longer Personal Data. See our Privacy Policy for more information on how we use De-identified Data. IP Address: An IP Address is a unique address that identifies a device on the internet or a local network. It allows a system to be recognized by other systems connected via the internet protocol. An IP Address may be considered Personal Data and is at times used by advertisers to serve interest-based ads. See our Privacy Policy for details on how we share Personal Data. IP Address: An IP Address is a unique address that identifies a device on the internet or a local network. It allows a system to be recognized by other systems connected via the internet protocol. An IP Address may be considered Personal Data and is at times used by advertisers to serve interest-based ads. See our Privacy Policy for details on how we share Personal Data. Personal Data: Personal Data is any data that identifies or relates to you as a particular individual, including information referred to as “personally identifiable information” or “personal information” under applicable data privacy laws, rules, or regulations. See our Privacy Policy for an outline of the ways in which we use, collect, and share Personal Data. Services: Services means, collectively, our websites and mobile apps, any software embedded within the Lief patch, and any features, content, or applications offered, from time to time, by Lief in connection therewith. Third Parties: Third Parties in the context of the relationship between Lief, Lief Members (our end users), and third parties are entities or businesses involved in an arrangement, contract, deal, or transaction but are not one of the principals (i.e., Lief or Lief Members). We use Third Parties to enable us to do business with our members, such as charging for transactions or storing data. Third Parties also include advertisers that serve interest-based ads to visitors to our website. See our Privacy Policy for more information on the Third Parties that do business with Lief. Lief Coach: The Lief Coach is an advanced generative AI feature that helps members understand and make progress to their goals, deciphers Lief concepts, and provides educational guidance, and integrates with the rest of the Lief experience. Lief Patch: Your Lief Patch is a wearable sensor that, when used in connection with the Services, collects certain types of Personal Data. Lief, we, us, our: The terms “Lief,” “we,” “us,” or “our” mean Lief Therapeutics, and each of its wholly owned subsidiaries. Wellness Data: Wellness Data is (a) data collected by your Lief patch and sent to the Lief platform, including your heart rate, heart rate variability, sleep duration, respiratory rate, and data such as the type of activity you engage in and the duration of your physical activity; and (b) any additional information you chose to enter during the use of our Services, such as information about your health and wellness, including information collected from accounts, devices, or features that you link with your Lief account. See our Privacy Policy for additional details on Wellness Data.
At Lief Therapeutics, (“Lief,” “us,” “we,” or “our”), our mission is to improve mental health from the inside out. We take privacy seriously and want you to understand how we use, collect, and share Personal Data, and the measures we take to protect your Personal Data. This Privacy Policy applies to Personal Data we collect about members and other consumers who interact with Lief or use our services, including by visiting our websites or our social media pages, or using our mobile apps, the Lief smart patch or another Lief device (collectively, the “Services”). This Privacy Policy does not cover the practices of companies that we do not own or control, or people that we do not manage. We are not responsible for the policies and practices of any third parties, and we do not control, operate, or endorse any information, products, or services that may be offered by third parties or accessible on or through the Services. We have provided supplemental notices below for residents of California.
2. HOW WE COLLECT PERSONAL DATA
We collect Personal Data about you from: Yourself, when you provide such information directly to us, such as when completing your profile; Lief patch or another device that you wear; Lief Coach when you interact with and receive responses from the Lief Coach as described in Section 8 below; Third-party integrations when you authorize them, such as Google Calendar integration. Automatic data collection, such as Cookies, local storage objects, web beacons, and other similar technologies in connection with your use of the Services; Customers and partners, such as employers, insurance companies, coaches, teams, or other organizations that engage with our Services; Marketing and advertising partners, such as companies that have entered in joint marketing relationships with us or assist us with marketing or promotional services, which may provide us with data related to how you interact with our Services, advertisements, or communications; Social media, other third-party platforms, and linked accounts, devices, or features, if you interact with our pages on social media sites, post content to their sites using the Services, sign into the Services through a third-party site or service, or otherwise link accounts, devices, or features to your Lief account; and Data providers, such as information services and data licensors, when we supplement your data.
3. PERSONAL DATA WE COLLECT
We may collect the following types of Personal Data: Contact details, such as your first and last name, email and mailing address, and phone number; Profile data, such as username and password that you may establish to create a Lief account, as well as any photographs or information you choose to include in your Lief profile; Communications that we exchange with you, including when you contact us via email, web app, or mobile app with questions, feedback, or reviews; Wellness Data, such as resting heart rate, heart rate variability, acceleration; metadata on biofeedback exercises, posture and sleep; the type of physical activity you engage in and the duration of your activity; data reflecting stress and recovery; your physiological profile, including birthday, gender identity, weight, height, fitness/athlete level; and details you choose to submit about your diet, medications, and other health information. We may use certain of this information to customize your experience with us as part of our Services; Conversations that you participate in with the Lief Coach, as described in Section 8 below; Calendar data, if you choose to integrate your calendar with Lief, including event names, dates, times, and other calendar meta-data. If you choose to integrate Google Calendar with the Lief Services, please note that we access your Google Calendar information to enhance your user experience, such as scheduling biofeedback sessions, tracking your wellness activities, and aligning your mental health goals with your daily routines. This integration allows us to collect and process information like event times and descriptions solely for these purposes. Lief will not access, store, or use any Google Calendar data beyond what is necessary for providing these features, and we will not share your Google Calendar data with third parties, except as necessary to provide the integrated services or as required by law. You can disconnect Lief from your Google Calendar at any time by adjusting the permissions in your Google account settings.For more information on Google’s privacy practices, please refer to their Privacy Policy here: https://policies.google.com/privacy. Payment and transactional data needed to complete your orders on the website or through the Services (including name, email address, payment card information, bank account number, billing information) and your transaction history, although Lief does not have access to payment card numbers. Our payment processors will collect the financial information necessary to process your payments in accordance with the payment processor’s respective services agreement and privacy policy; Marketing data, such as your preferences for receiving our marketing communications, and details about your engagement with them (e.g., the marketing emails that you open and the links within them that you click); Device data, such as your computer or mobile device operating system type and version, manufacturer and model, browser type, screen resolution, RAM and disk size, CPU usage, device type (e.g., phone, tablet), IP Address, unique identifiers (including identifiers used for advertising purposes), language settings, mobile device carrier, radio/network information (e.g., Wi-Fi, LTE, 3G), and general location information such as city, state, or geographic area; Geolocation data, such as GPS, IP Address, and movement on certain exercise types if you give permission for Lief to do so; and Online activity data, such as pages or screens you view, how long you spent on a page or screen, the website you visited before visiting our website, navigation paths between pages or screens, information about your activity on a page or screen, access times, and duration of access.
4. COOKIES AND SIMILAR TECHNOLOGIES
Lief uses cookies and similar technologies such as pixel tags, web beacons, clear GIFs, and JavaScript (collectively, “Cookies”) to enable our servers to recognize your web browser and tell us how and when you visit and use our Services, as well as to analyze trends, learn about our user base, and operate and improve our Services. Cookies are small pieces of data – usually text files – placed on your computer, tablet, phone, or similar device when you use that device to visit our Services. We may also supplement the information we collect from you with information received from third parties, including third parties that have placed their own Cookies on your device(s). Cookie Usage and Type. Lief uses the following Cookies: Essential Cookies:Essential Cookies are required for providing you with features or Services that you have requested. For example, certain Cookies enable you to log into secure areas of our Services. Disabling these Cookies may make certain features and Services unavailable. Functionality Cookies: Functional Cookies are used to record your choices and settings regarding our Services, maintain your preferences over time, and recognize you when you return to our Services. These Cookies help us to personalize our content for you, greet you by name, and remember your preferences (e.g., your region). Performance/Analytical Cookies: Performance/Analytical Cookies allow us to understand how users use our Services by collecting information on how often a user engages with a particular feature of the Services. We use these aggregated statistics internally to improve the Services. Performance/Analytical Cookies also help us measure the performance of our advertising campaigns in order to help us improve our campaigns and the Services’ content for those who engage with our advertising. For example, Google, Inc. (“Google”) uses Cookies in connection with its Google Analytics services. For more information on how Google uses this information, click here. Marketing Cookies: Marketing Cookies collect data about your online activity and identify your interests so that we and our advertising partners can provide marketing that we believe is relevant to you. For more information, please see the section below titled “Interest-based advertisements.” Online tracking opt-outs. There are a number of ways you can opt out of certain interest-based advertising and other online tracking activities, which we have summarized below. Blocking Cookies in your browser. Most browsers let you remove or reject Cookies, including Cookies used for interest-based advertising. To do this, follow the instructions in your browser settings. Many browsers accept Cookies by default until you change your settings. For more information about Cookies, including how to see what Cookies have been set on your device and how to manage and delete them, visit www.allaboutcookies.org. Blocking advertising ID use in your mobile device settings. Your mobile devices may offer settings that enable you to make choices about the collection, use, or transfer of your advertising ID associated with your mobile device for interest-based advertising purposes. Using privacy plug-ins or browsers. You can block our websites from setting Cookies used for interest-based ads by using a browser with privacy features, like Brave, or installing browser plugins like Privacy Badger, Ghostery, or uBlock Origin, and configuring them to block third party Cookies/trackers. You can also opt out of Google Analytics by downloading and installing the browser plug-in available at: https://tools.google.com/dlpage/gaoptout. Platform opt-out. Google (AdWords): adsettings.google.com; Microsoft (Bing): about.ads.microsoft.com/en-us/resources/policies/personalized-ads; and Facebook: www.facebook.com/about/ads. Some third-party ad networks, including third-party ad servers, ad agencies, ad technology vendors, and research firms, allow you to opt-out directly by using their opt-out tools. Some of these providers, and links to their opt-out tools, are: Advertising industry opt-out tools. Digital Advertising Alliance for Websites: https://optout.aboutads.info; Digital Advertising Alliance for Mobile Apps: https://youradchoices.com/appchoices; and Network Advertising Initiative: https://optout.networkadvertising.org/. You can also use these opt-out options to limit use of your information for interest-based advertising by participating companies: Please note that some opt-out features are Cookie-based, meaning that when you use these opt-out features, an “opt-out” Cookie will be placed on your computer or other device indicating that you do not want to receive interest-based advertising from certain companies. If you delete your Cookies, use a different browser, or use a different device, you will need to renew your opt-out choice. Opting out of interest-based advertising does not mean that you will no longer receive online ads. It only means that such ads will no longer be tailored to your specific viewing habits or interests. You may continue to see ads on and about the Service.
5. HOW WE USE PERSONAL DATA
We process Personal Data to operate, improve, understand, and personalize our Services. We use Personal Data for the following purposes: Service delivery, including to: Provide, operate, improve, develop, understand, and personalize the Services and our business, including testing, research, analysis, and product development; Satisfy the reason you provided the information to us, including responding to and fulfilling requests; Communicate with you about the Services, including Service announcements, updates, or offers; Provide support and assistance for the Services; Create and manage your account or other user profiles; Customize website content and communications based on your preferences; and Process orders, memberships, or other transactions. Research and development. We may create and use Aggregated Data, De-identified Data, or other anonymous data from Personal Data we collect, including Wellness Data, for our business purpose, including to analyze the effectiveness of the Services, to improve and add features to the Services, and to analyze the general behavior and characteristics of users of the Services. We also use anonymous Wellness Data for research purposes to help us and our research partners answer important questions about human performance and create an even-better experience for our members by identifying cutting-edge insights and providing new content and product features. Direct marketing and advertising. We may use data from the Personal Data we collect, including Wellness Data and certain data collected when you browse our website, to send you direct offers marketing messages or advertise the Services or other Lief product offerings. Interest-based advertising. We engage our advertising partners, including third party advertising companies and social media companies, to advertise our Services. We and our advertising partners may use Cookies and similar technologies to collect information about your interaction over time across the web, our communications, and other online services, and may use that information to serve online ads. We comply with the Digital Advertising Alliance Self-Regulatory Principles for Online Behavioral Advertising. To learn more about the industry self-regulatory programs and other information and choices about interest-based ads, please see the section above entitled “Online tracking opt-outs.” Compliance and protection, including to: Protect against or deter fraudulent, illegal, or harmful actions and maintain the safety, security, and integrity of our Services; Comply with or enforce our legal or contractual obligations, resolve disputes, and enforce our Terms of Use; Audit our internal processes for compliance with legal and contractual requirements and internal policies; Protect our, your, or others’ rights, privacy, safety, or property (including by making and defending legal claims); and Respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.
6. HOW WE SHARE PERSONAL DATA
We may share your Personal Data with: Service providers, such as payment processors, vendors who advertise our Services or other Lief products, security and fraud prevention consultants, hosting and other technology and communications providers, analytics providers, and staff augmentation and contract personnel, that provide services to us or on our behalf; our service providers also include our third-party Large Language Model (“LLM”) partner that powers Lief Coach, as described in Section 8 below; Advertising partners that may collect information on our website through Cookies and other automated technologies, including for the interest-based advertising purposes described above. We do not share your Wellness Data with advertising partners; Professional advisors, such as lawyers, auditors, bankers, and insurers, where necessary in the course of the professional services they render to us; Authorities and others, including law enforcement, government authorities, and private parties we believe in good faith to be necessary or appropriate to comply with the law or legal process; and Business transferees, such as acquirers and other relevant participants in business transactions (or negotiations for such transactions) involving a corporate divestiture, merger, consolidation, acquisition, reorganization, sale, or other disposition of all or any portion of the business or assets of, or equity interests in, Lief or our affiliates (including, in connection with a bankruptcy or similar proceedings). Distributors and retailers of our Services or other Lief products; Affiliates of Lief.
7. HOW YOU MAY SHARE PERSONAL DATA THROUGH Lief
Depending on your use of the Services, you may share Personal Data with: Other users of the Services, such as through our Lief Live or other group sharing features, which allow you to share information and content with other users of the Service, and users are by default searchable by other users; Third-party social media platforms, or linked accounts, devices, or features, when you choose to connect your account on those services with Lief or post content to social media, such as through the Lief Live feature; The Public. When you make Personal Data visible to other users of the Services, including through the Lief Live, it may become publicly available and can be collected, viewed, and used by anyone; Managing entities. If your use of the Services is on behalf of or managed by a managing entity, such as a coach, team, organizing body, or other entity with which you are affiliated, your account information and Personal Data may be shared with the managing entity subject to your consent, and you hereby consent to that managing entity allowing that information to be publicly shared, subject to any features of the Services that expressly override that control. The managing entity will determine how the relevant information and content is shared; and Corporate wellness programs. If you use the Services in connection with an employer or organizational corporate wellness program, we may share your information with that organization subject to your consent. Typically, we will share only Aggregated Data with these organizations.
8. LIEF COACH & THIRD-PARTY AI TECHNOLOGY
Lief Coach is a generative AI feature that is intended to help you understand and make progress to your goals, decipher Lief concepts, and provide educational guidance, and integrate with the rest of the Lief experience. Lief Coach creates a health coaching experience by combining your unique, anonymized Lief metrics with the science of biofeedback to help you optimize your health, fitness, and performance. If you decide to use Lief Coach, please note that Lief Coach leverages third-party AI technology provided by our LLM partner. This technology is trained on real-world data to generate intelligent and personalized responses in conversations with users. Responses from Lief Coach are based on your requests and relevant information collected through your Lief metrics. For example, if you ask Lief Coach a sleep-related question, then Lief Coach may provide personalized tips for improving your sleep based on your anonymized sleep data collected through the Services. We require our LLM partner to use your anonymized Lief metrics only for the purpose of allowing Lief Coach to generate responses to your chats. We have ensured that our LLM partner has a “Zero-Retention/Zero Training Policy” with respect to your Lief metrics, meaning that our LLM partner will not store or retain any of the anonymized Lief metrics they receive through your use of Lief Coach, and our LLM partner will not use any of the anonymized Lief metrics they receive for training any algorithms or LLM technology. We will only share your anonymized Lief metrics with our LLM partner. We ask that you refrain from providing any identifying information, such as your name, in conversations with Lief Coach. Lief may retain the history of your conversations with Lief Coach to ensure you continue to have access to previous conversations while using the feature. When you revisit any topics from previous chats, Lief may share the context of your previous conversations with Lief Coach to create a better experience for you. You may delete your Lief Coach chat data at any time by requesting a deletion through support@getlief.com. If you agree to use Lief Coach, please note that Lief employees will only access member Personal Data when required to provide services and support, which may include collecting information about your experience with Lief Coach to assess the performance of and improve Lief Coach and other product offerings.
9. YOUR CHOICES
Access, update, or delete. When you log in to your account, you may access, and, in some cases, edit or delete certain information you’ve provided to us, such as first and last name, username and password, email and mailing address, and other information in your profile. When you update information, however, we may maintain a copy of the unrevised information in our records. You may request access to or a full deletion of your account and corresponding data by contacting support@getlief.com. You will be asked to complete a verification form in connection with such access or deletion request in order to ensure that you have the authority to access or delete your account. We may need to retain certain Personal Data in our records, as well as Aggregated Data or De-identified Data derived from or incorporating your Personal Data that does not identify you after you update or delete it. Push notifications and device permissions. Access, update, or delete. When you log in to your account, you may access, and, in some cases, edit or delete certain information you’ve provided to us, such as first and last name, username and password, email and mailing address, and other information in your profile. When you update information, however, we may maintain a copy of the unrevised information in our records. You may request access to or a full deletion of your account and corresponding data by contacting support@getlief.com. You will be asked to complete a verification form in connection with such access or deletion request in order to ensure that you have the authority to access or delete your account. We may need to retain certain Personal Data in our records, as well as Aggregated Data or De-identified Data derived from or incorporating your Personal Data that does not identify you after you update or delete it. Geolocation data. You may allow or disallow Lief to collect geolocation data by enabling or disabling location services on your mobile device. If you decline to grant Lief access to this data, we will not be able to provide certain Services, capabilities, or features to you. Wellness Data. You can disable collection of additional Wellness Data by un-pairing your Lief device from your mobile device. Lief Coach. You can choose whether or not to enable and interact with Lief Coach. We will only share your anonymized Lief metrics with our LLM partner that powers Lief Coach if you engage with the feature. If you no longer wish to use Lief Coach, you can simply not interact with the feature. Marketing communications. We give you the ability to opt-out of marketing-related emails and other communications by emailing support@getlief.com, or by following the opt-out or unsubscribe instructions contained in the marketing-related message. You cannot opt-out of receiving certain non-marketing emails regarding the Service. Online tracking opt-outs. There are a number of ways you can opt-out of certain interest-based advertising and other online tracking activities, which we summarize in the “Online tracking opt-outs” section above. Do Not Track. Some Internet browsers may be configured to send “Do Not Track” signals to online services. The Services do not currently support “Do Not Track” requests or similar signals. To find out more about “Do Not Track,” please visit http://www.allaboutdnt.com.
10. OTHER SITES AND SERVICES
The Services may contain links to websites and other online services operated by Third Parties. In addition, our content may be integrated into web pages or other online services that are not associated with us. These links and integrations are not an endorsement of, or representation that we are affiliated with, any Third Party. We do not control mobile applications, websites or online services offered or operated by Third Parties, and we are not responsible for their actions. You can learn about and control how these Third Parties use and share Personal Data about you, including with Lief, by reviewing their privacy notices and exercising the privacy choices the Third Party may offer.
11. DATA SECURITY AND RETENTION OF PERSONAL DATA
We employ a number of physical, technical, organizational, and administrative security measures designed to protect the Personal Data we collect. While we endeavor to protect the privacy of your account and other Personal Data we hold in our records, no security measures are failsafe, and we cannot guarantee the security of your Personal Data. We retain Personal Data for as long as reasonably necessary for the purposes described in this Privacy Policy, while we have a business need to do so, or as required by law (e.g., for tax, legal, accounting, or other purposes), whichever is longer.
12. PERSONAL DATA OF CHILDREN
If you are under the age to consent to data sharing, as applicable based on your jurisdiction, please do not attempt to register for the Services or send any Personal Data about yourself to us. If we learn that we have collected Personal Data from a child under the age to consent to data sharing, as applicable based on jurisdiction, we will delete that information as quickly as possible. If you believe that a child under the age to consent to data sharing, as applicable based on your jurisdiction,, may have provided us Personal Data, please contact us at support@getlief.com.
13. CHANGES TO THIS PRIVACY POLICY
We are constantly trying to improve our Services, so we may need to change this Privacy Policy from time to time. We will alert you to changes by placing a notice on the Lief website, by sending you an email, and/or by some other means. If you use the Services after any changes to the Privacy Policy have been posted, that means you agree to all of the changes.
14. CONTACT US
If you have any questions or concerns regarding our privacy policies, please send us a detailed message to support@getlief.com or at the mailing address below. Lief Therapeutics, 2443 Fillmore St. #380-6060, San Francisco, CA 94115 15. PRIVACY NOTICE FOR CALIFORNIA RESIDENTS We are providing this supplemental privacy notice to consumers in California, pursuant to the California Consumer Privacy Act of 2018 (the “CCPA”). We do not sell Personal Data. As we explain in this Privacy Policy, we use Cookies and other tracking technologies to analyze website and application traffic and use, and to facilitate advertising. To limit use of Cookies and other tracking technologies, please review the instructions provided in the “Online tracking opt-outs” section. You may also direct us to share your data, as described in the “How You Share Personal Data Through Lief” section of the Privacy Policy. California Privacy Rights. If you are a California resident, you have the following rights: Information: The Privacy Policy describes the types of Personal Data we collect in the “Personal Data We Collect” section above and the sources through which we collect Personal Data in the “How We Collect Personal Data” section above. We describe the purposes for which we use and share this data in the “How We Use Personal Data section above and the “How We Share Personal Data section above. Access: You can request a copy of the personal information that we maintain about you. Deletion: You can ask to delete the personal information that we have collected from you. Opt-out of sale of your Personal Data: We do not sell Personal Data. We offer instructions on how to limit online tracking in the “Online tracking opt-outs” section of the Privacy Policy. Please note that the CCPA limits these rights by, for example, prohibiting businesses from providing certain sensitive information in response to an access request and limiting the circumstances in which they must comply with a deletion request. You are entitled to exercise the rights described above free from discrimination. Exercising Your Rights. To exercise these rights, you can submit requests as follows: To request access to or deletion of Personal Data collected via your use of the Services, please email us at support@getlief.com. To learn how to opt-out of interest-based ads and other online tracking, see the “Online tracking opt-outs” section of the Privacy Policy. To verify your identity prior to responding to your requests, we may ask you to confirm information that we have on file about you or your interactions with us. Where we ask for additional Personal Data to verify your identity, we will only use it to verify your identity or your authority to make the request on behalf of another consumer. Authorized agents: California residents can empower an “authorized agent” to submit requests on the resident’s behalf. Your authorized agent may submit requests in the same manner, although we may require the agent to present signed written permission to act on your behalf, and you may also be required to independently verify your identity with us and confirm that you have provided the agent permission to submit the request.
15. DEFINITIONS
We use some specifically defined terms in our Privacy Policy and when we communicate about our Privacy Policy. We want to be clear on how the terms we use are defined to help you better understand our policies. Aggregated Data: Aggregated Data is data that has undergone a process whereby raw data is gathered and expressed in a summary form for statistical analysis. Raw data can be aggregated over a given time period, across individuals, or both, to provide statistics such as average, minimum, maximum, sum, and count. After the data is aggregated analysis can be performed to gain insights about particular data sets. When data is aggregated across a number of individuals, the resulting aggregation is considered anonymized such that it is no longer Personal Data. See our Privacy Policy for more information on how we use Aggregated Data. CCPA: The California Consumer Privacy Act, or CCPA, is a state law that provides California consumers with robust data privacy rights. These rights include the right to know, the right to delete, and the right to opt-out of “sale” of personal information that businesses collect, as well as additional protections for minors. A “sale” under the CCPA is defined as “selling, renting, releasing, disclosing, disseminating, making available, transferring, or otherwise communicating orally, in writing, or by electronic or other means, a consumer’s personal information by the business to another business or to a third party for monetary or other valuable consideration.” See our Privacy Policy for more details on the information we may share with others. Cookies: Cookies are small files which are stored on a user’s computer. They are designed to hold a modest amount of data specific to a particular user and website and can be accessed either by the web server or the user computer. This allows the server to deliver a page tailored to a particular user, or the page itself can contain some script which is aware of the data in the cookie and is therefore able to carry information from one visit to the website (or related site) to the next. See our Privacy Policy to learn about cookies and how they are used on our websites. De-Identified Data: De-Identified Data is data where all the personally identifiable information has been removed, rendering the data anonymous by stripping out information that would allow an individual’s identity to be determined from the remaining data. Data is “de-identified” to protect the privacy and identity of individuals associated with the data. De-identified Data is no longer Personal Data. See our Privacy Policy for more information on how we use De-identified Data. IP Address: An IP Address is a unique address that identifies a device on the internet or a local network. It allows a system to be recognized by other systems connected via the internet protocol. An IP Address may be considered Personal Data and is at times used by advertisers to serve interest-based ads. See our Privacy Policy for details on how we share Personal Data. IP Address: An IP Address is a unique address that identifies a device on the internet or a local network. It allows a system to be recognized by other systems connected via the internet protocol. An IP Address may be considered Personal Data and is at times used by advertisers to serve interest-based ads. See our Privacy Policy for details on how we share Personal Data. Personal Data: Personal Data is any data that identifies or relates to you as a particular individual, including information referred to as “personally identifiable information” or “personal information” under applicable data privacy laws, rules, or regulations. See our Privacy Policy for an outline of the ways in which we use, collect, and share Personal Data. Services: Services means, collectively, our websites and mobile apps, any software embedded within the Lief patch, and any features, content, or applications offered, from time to time, by Lief in connection therewith. Third Parties: Third Parties in the context of the relationship between Lief, Lief Members (our end users), and third parties are entities or businesses involved in an arrangement, contract, deal, or transaction but are not one of the principals (i.e., Lief or Lief Members). We use Third Parties to enable us to do business with our members, such as charging for transactions or storing data. Third Parties also include advertisers that serve interest-based ads to visitors to our website. See our Privacy Policy for more information on the Third Parties that do business with Lief. Lief Coach: The Lief Coach is an advanced generative AI feature that helps members understand and make progress to their goals, deciphers Lief concepts, and provides educational guidance, and integrates with the rest of the Lief experience. Lief Patch: Your Lief Patch is a wearable sensor that, when used in connection with the Services, collects certain types of Personal Data. Lief, we, us, our: The terms “Lief,” “we,” “us,” or “our” mean Lief Therapeutics, and each of its wholly owned subsidiaries. Wellness Data: Wellness Data is (a) data collected by your Lief patch and sent to the Lief platform, including your heart rate, heart rate variability, sleep duration, respiratory rate, and data such as the type of activity you engage in and the duration of your physical activity; and (b) any additional information you chose to enter during the use of our Services, such as information about your health and wellness, including information collected from accounts, devices, or features that you link with your Lief account. See our Privacy Policy for additional details on Wellness Data.
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