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PRIVACY POLICY

Last Updated Aug 17, 2021

Our policy

Welcome to Fully! Fully Technologies, LLC ("Fully," "we," "us," or "our") provides tools for meditation practice and instruction through our Fully mobile application (the "App") and we provide information about the App through our website (the "Site"). In this Privacy Policy, the Site and the App and our related services are referred to collectively as the "Service."

This Privacy Policy explains what Personal Data (defined below) we collect, how we use and share that data, and your choices concerning our data practices. Before using the Service or submitting any Personal Data to Fully, please review this Privacy Policy carefully and contact us if you have any questions. By using the Service, you agree to the practices described in this Privacy Policy. If you do not agree to this Privacy Policy, please do not access the Site or otherwise use the Service.

Personal Data We Collect

We collect information that alone or in combination with other information in our possession could be used to identify you ("Personal Data") as follows:

Personal Data You Provide: We collect Personal Data when you register for or use the Service, contact us with inquiries or otherwise communicate with us, or while using the App. The Personal Data collected during these interactions may vary based on what you choose to share with us, but it will generally include name, email, password, your meditation experience and other information relevant to helping you practice meditation.

Personal Data We Collect Through Our Social Media Pages: We have pages on social media sites like Facebook and Twitter ("Social Media Pages"). When you interact with our Social Media Pages, we will collect Personal Data that you elect to provide to us, such as your contact details. In addition, the companies that host our Social Media Pages may provide us with aggregate information and analytics regarding the use of our Social Media Pages.

Personal Data We Receive Automatically From Your Use of the Service: When you visit, use and interact with the Service, we may receive certain information about your visit, use or interactions. For example, we may monitor the number of people that visit the Service, peak hours of visits, which page(s) are visited, the domains our visitors come from (e.g., google.com, yahoo.com, etc.), and which browsers people use to access the Service (e.g., Firefox, Microsoft Internet Explorer, etc.), broad geographical information, and navigation patterns. In particular, the following information is created and automatically logged in our systems:

• Log data: Information that your browser automatically sends whenever you visit the Site ("log data"). Log data includes your Internet Protocol address, browser type and settings, the date and time of your request, and how you interacted with the Site.
• Cookies: Please see the "Cookies" section below to learn more about how we use cookies.
• Device information: Includes name of the device, operating system, device/advertising identifiers, and browser you are using. Information collected may depend on the type of device you use and its settings.
• Usage Information: We collect information about how you use our Service, such as the types of content that you view or engage with, the features you use, the actions you take, date and the time, frequency and duration of your activities. Usage information includes referring and exit pages and URLs, platform type, number of clicks, landing pages, pages and content viewed and the order of those pages and errors logs.

We do not collect or use any information from health apps like Google Fit, Apple Health or HealthKit.

Cookies: We use cookies to operate and administer our Site, gather usage data on our Site and improve your experience on it. A "cookie" is a piece of information sent to your browser by a website you visit. Cookies can be stored on your computer for different periods of time. Some cookies expire after a certain amount of time, or upon logging out (session cookies), others survive after your browser is closed until a defined expiration date set in the cookie (as determined by the third party placing it), and help recognize your computer when you open your browser and browse the Internet again (persistent cookies). For more details on cookies please visit All About Cookies.

Analytics: On our site, we use Google Analytics, a web analytics service provided by Google, Inc. ("Google"). Google Analytics uses cookies to help us analyze how users use the Site and enhance your experience when you use the Site. For more information on how Google uses this data, go to www.google.com/policies/privacy/partners/.

In our App, we use Mixpanel, a mobile analytics service provided by Mixpanel, Inc. ("Mixpanel"). Mixpanel allows us to measure how users use the App so that we can enhance the App experience. For more information how Mixpanel users this data, go to https://mixpanel.com/legal/privacy-policy/.

Online Tracking and Do Not Track Signals: We and our third party service providers may use cookies or other tracking technologies to collect information about your browsing activities over time and across different websites following your use of the Site and use that information to send targeted advertisements. Our Site currently does not respond to "Do Not Track" ("DNT") signals and operates as described in this Privacy Policy whether or not a DNT signal is received. If we do respond to DNT signals in the future, we will update this Privacy Policy to describe how we do so.

Your Choices. On most web browsers, you will find a "help" section on the toolbar. Please refer to this section for information on how to receive a notification when you are receiving a new cookie and how to turn cookies off. Please see the links below for guidance on how to modify your web browser’s settings on the most popular browsers:

• Internet Explorer
• Mozilla Firefox
• Google Chrome
• Apple Safari

Please note that if you limit the ability of websites to set cookies, you may be unable to access certain parts of the Site and you may not be able to benefit from the full functionality of the Site.

Advertising networks may use cookies to collect Personal Data. Most advertising networks offer you a way to opt out of targeted advertising. If you would like to find out more information, please visit the Network Advertising Initiative’s online resources at www.networkadvertising.org and follow the opt-out instructions there.

If you access the Site on your mobile device, you may not be able to control tracking technologies through the settings.

How We Use Personal Data

We may use Personal Data for the following purposes:

• To provide the Service and help you practice meditation;
• To respond to your inquiries, comments, feedback or questions;
• To send administrative information to you, for example, information regarding the Service, and changes to our terms, conditions, and policies;
• To analyze how you interact with our Service;
• To maintain and improve the content and functionality of the Service;
• To develop new products and services;
• To prevent fraud, criminal activity, or misuses of our Service, and to ensure the security of our IT systems, architecture and networks; and
• To comply with legal obligations and legal process and to protect our rights, privacy, safety or property, and/or that of our affiliates, you or other third parties.

Aggregated Information. We may aggregate Personal Data and use the aggregated information to analyze the effectiveness of our Service, to improve and add features to our Service, and for other similar purposes. In addition, from time to time, we may analyze the general behavior and characteristics of users of our Services and share aggregated information like general user statistics with prospective business partners. We may collect aggregated information through the Service, through cookies, and through other means described in this Privacy Policy.

Marketing. We may use your Personal Data to contact you to solicit feedback or tell you about products or services we believe may be of interest to you. For instance, if you elect to provide your email, we may use that information to ask you if you have any feedback. You may opt out of receiving emails by following the instructions contained in each email we send you. In addition, if at any time you do not wish to receive future marketing communications, you may contact us. If you unsubscribe from our marketing lists, you will no longer receive marketing communications but we will continue to contact you regarding management of your account, other administrative matters, and to respond to your requests. We may also use Personal Data for targeted online advertising campaigns.

Sharing and Disclosure of Personal Data

In certain circumstances we may share your Personal Data with third parties without further notice to you, unless required by the law, as set forth below:

• Vendors and Service Providers: To assist us in meeting business operations needs and to perform certain services and functions, we may share Personal Data with vendors and service providers, including providers of hosting services, cloud services and other information technology services providers, email communication software and email newsletter services, advertising and marketing services, payment processors, customer support services, and analytics services (for more details on the third parties that place cookies through the Site, please see the "Cookies" section above)]. Pursuant to our instructions, these parties will access, process or store Personal Data in the course of performing their duties to us. We take commercially reasonable steps to ensure our service providers adhere to the Security standards we apply to your Personal Data.
• Business Transfers: If we are involved in a merger, acquisition, financing due diligence, reorganization, bankruptcy, receivership, sale of all or a portion of our assets, or transition of service to another provider, your Personal Data and other information may be shared in the diligence process with counterparties and others assisting with the transaction and transferred to a successor or affiliate as part of that transaction along with other assets.
• Legal Requirements: If required to do so by law or in the good faith belief that such action is necessary to (i) comply with a legal obligation, including to meet national security or law enforcement requirements, (ii) protect and defend our rights or property, (iii) prevent fraud, (iv) act in urgent circumstances to protect the personal safety of users of the Services, or the public, or (v) protect against legal liability.
• Affiliates: We may share Personal Data with our affiliates, meaning an entity that controls, is controlled by, or is under common control with Fully. Our affiliates may use the Personal Data we share in a manner consistent with this Privacy Policy.
• Health Apps: Where you choose to do so, we may share your health information with Health Apps, such as Google Fit and Apple Health.

California Users

Where provided for by law and subject to any applicable exceptions, California residents may have the right:

• To know the categories of Personal Data that Fully has collected about you, the business purpose for collecting your Personal Data, and the categories of sources from which the Personal Data was collected;
• To access the specific pieces of Personal Data that Fully has collected about you;
• To know whether Fully has disclosed your Personal Data for business purposes, the categories of Personal Data so disclosed, and the categories of third parties to whom we have disclosed your Personal Data;
• To have Fully, under certain circumstances, delete your Personal Data;
• To instruct businesses that sell Personal Data to stop doing so – Fully, however, does not sell Personal Data; and
• To be free from discrimination related to the exercise of these rights.

If you would like to exercise any or all of these rights, you may do so by contacting us as instructed below. After we receive your request, we may request additional information from you to verify your identity. 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.

EU Users

Scope. This section applies to individuals in the EU (for these purposes, reference to the EU also includes the European Economic Area countries of Iceland, Liechtenstein and Norway, the United Kingdom, and, to the extent applicable, Switzerland).

Data Controller. Data protection laws in the EU differentiate between the "data controller" and "data processor" of Personal Data. Fully is the data controller for the processing of your Personal Data relating to data collected directly from end users who visit our website or other data we collect independently from our business customers. You can find our contact information, and the contact information of our EU-based representative, in the "Contact Us" section below.

Data Processor. Fully is the data processor for the processing of your Personal Data relating to when we are providing our service on behalf of our business customers. To exercise the rights described below in relation to when Fully is the processor, please contact our customer that processed your Personal Data (the data controller) in order to exercise your rights.

Legal Bases for Processing. This Privacy Policy (the paragraph "How We Use Personal Data") describes the legal bases we rely on for the processing of your Personal Data. Please contact us if you have any questions about the specific legal basis we are relying on to process your Personal Data.

As used in this Privacy Policy, "legitimate interests" means our interests in conducting our business and developing a business relationship with you. This Privacy Policy describes when we process your Personal Data for our legitimate interests, what these interests are and your rights. We will not use your Personal Data for activities where the impact on you overrides our interests, unless we have your consent or those activities are otherwise required or permitted by law.

Your Rights. Pursuant to the GDPR, you have the following rights in relation to your Personal Data, under certain circumstances and subject to any applicable exceptions:

• Right of access: If you ask us, we will confirm whether we are processing your Personal Data and, if so, provide you with a copy of that Personal Data along with certain other details. If you require additional copies, we may need to charge a reasonable fee.
• Right to rectification: If your Personal Data is inaccurate or incomplete, you are entitled to ask that we correct or complete it. If we shared your Personal Data with others, we will tell them about the correction where possible. If you ask us, and where possible and lawful to do so, we will also tell you with whom we shared your Personal Data so you can contact them directly.
• Right to erasure: You may ask us to delete or remove your Personal Data, such as where you withdraw your consent. If we shared your data with others, we will tell them about the erasure where possible. If you ask us, and where possible and lawful to do so, we will also tell you with whom we shared your Personal Data with so you can contact them directly.
• Right to restrict processing: You may ask us to restrict or ‘block’ the processing of your Personal Data in certain circumstances, such as where you contest the accuracy of the data or object to us processing it (please read below for information on your right to object). We will tell you before we lift any restriction on processing. If we shared your Personal Data with others, we will tell them about the restriction where possible. If you ask us, and where possible and lawful to do so, we will also tell you with whom we shared your Personal Data so you can contact them directly.
• Right to data portability: You have the right to obtain your Personal Data from us that you consented to give us or that was provided to us as necessary in connection with our contract with you, and that is processed by automated means. We will give you your Personal Data in a structured, commonly used and machine-readable format. You may reuse it elsewhere.
• Rights in relation to automated decision-making: You have the right to be free from decisions based solely on automated processing of your Personal Data (including profiling) which produce a significant legal effect on you, unless this is necessary in relation to a contract between you and us or you provide your explicit consent to this use.
• Right to object: You may ask us at any time to stop processing your Personal Data, and we will do so:
  • If we are relying on a legitimate interest to process your Personal Data -- unless we demonstrate compelling legitimate grounds for the processing or we need to process your data in order to establish, exercise, or defend legal claims;
  • If we are processing your Personal Data for direct marketing. We may keep minimum information about you in a suppression list in order to ensure your choices are respected in the future and to comply with data protection laws (such processing is necessary for our and your legitimate interest in pursuing the purposes described above);
• Right to withdraw consent: If we rely on your consent to process your Personal Data, you have the right to withdraw that consent at any time. Withdrawal of consent will not affect any processing of your data before we received notice that you wished to withdraw consent.
• Right to lodge a complaint with the data protection authority: If you have a concern about our privacy practices, including the way we handled your Personal Data, you can report it to the data protection authority that is authorized to hear those concerns (in the UK, the Information Commissioner’s Office (ICO), who can be contacted at https://ico.org.uk/concerns, and in other EU countries the data protection authority of the country in which you are located).

Please see the "Contact Us" section below for information on how to exercise your rights.

Data Transfers. Fully is based in the U.S. The U.S. may have data protection laws less stringent than or otherwise different from the laws in effect in the EU and UK. Transfers of your Personal Data to Fully in the U.S. are necessary to perform the agreement we have entered into, or are about to enter into, with you.

Data Retention

We keep 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.

Children’s Privacy

Our Service is not directed to children who are under the age of 13. Fully does not knowingly collect Personal Data from children under the age of 13. If you have reason to believe that a child under the age of 13 has provided Personal Data to Fully through the Service please contact us and we will endeavor to delete all such Personal Data from our databases.

Links to Other Websites

The Service may contain links to other websites not operated or controlled by Fully, including social media services ("Third Party Sites"). The information that you share with Third Party Sites will be governed by the specific privacy policies and terms of service of the Third Party Sites and not by this Privacy Policy. By providing these links we do not imply that we endorse or have reviewed these sites. Please contact the Third Party Sites directly for information on their privacy practices and policies.

Security

You use the Service at your own risk. We implement commercially reasonable technical, administrative, and organizational measures to protect Personal Data both online and offline from loss, misuse, and unauthorized access, disclosure, alteration or destruction. Any data that is transferred over the internet is done so via secure HTTPS, and we encrypt all user account passwords in our databases.

However, no Internet or e-mail transmission is ever fully secure or error free. In particular, e-mail sent to or from us may not be secure. Therefore, you should take special care in deciding what information you send to us via the Service or e-mail. Please keep this in mind when disclosing any Personal Data to Fully via the Internet. In addition, we are not responsible for circumvention of any privacy settings or security measures contained on the Service, or third party websites.

Your Choices

In certain circumstances providing Personal Data is optional. However, if you choose not to provide Personal Data that is needed to use some features of our Services, you may be unable to use those features. You can also contact us to ask us to update or correct your Personal Data.

Changes to the Privacy Policy

The Service, and our business may change from time to time. As a result we may change this Privacy Policy at any time. When we do we will post an updated version on this page, unless another type of notice is required by the applicable law. By continuing to use our Service or providing us with Personal Data after we have posted an updated Privacy Policy, or notified you by other means if applicable, you consent to the revised Privacy Policy and practices described in it.

Contact Us

If you have any questions about our Privacy Policy or information practices, please feel free to contact us at support@fullyapp.com.