Privacy Policy

1. Demographic and Contact Information: Demographic and contact information that you provide to us. For example, we may collect information such as your name, mailing address, e-mail address, and telephone.

2. Online or Other Account Information: Username or email address and corresponding passwords, security questions, and other information needed to permit access to certain components of our Services which require registration and/or credentials.

3. Creating an Account and Onboarding: When you create a user account, we collect information that enables you to register and onboard to use our products and Services, such as your name, company, date of birth, contact information (phone number, email address), location, preferred password, and primary language.

4. Webforms and Requests: Information you submit to us through online or interactive forms available within our Services. For example, you may “contact us,” submit feedback, request additional information about a product or Service, sign up for a mailing or other type of newsletter, or reach out to us regarding a question or concern.

5. Websites: Information such as your username and password to enter certain sections of our websites or Services, unique identifiers, preference information (such as marketing preferences), browser type, Internet service provider (ISP), referring/exit pages, the files viewed on our site, operating system, date/time stamp, and clickstream data and other pieces of information. This is further described in tracking technologies subsection below.

6. Mobile Applications: Some of our Services are available either as mobile applications or mobile sites that you can use on your mobile device. If you use a mobile device to access and use our Services, we may additionally collect mobile-specific information including your device ID, device type, hardware type, media access control (“MAC”) address, the version of your mobile operating system, the platform used to access or download the Services, location information and usage information about your device and your use of the Services. Please note that not all of our mobile Services link to this Privacy Notice, so be sure to read the applicable privacy notice before using mobile Services.

7. Device Information: We may collect device information such as Internet Protocol (“IP”) addresses, log information, error messages, device type, hardware model, operating system, unique device identifiers, and mobile network information. For example, we collect IP addresses from you when you log into the Service as part of our log-in andsecurity features. If you use a mobile device to access and use our Services, we may additionally collect mobile-specific information. We may also associate the information we collect from your different devices, which helps us provide consistent Services across your devices.

8. Log Information: Usage details of our Services, including the address (or URL) where you came from before visiting us, which pages or features you visit or utilize, which browser you use, search terms you enter, and items you click on. We may also create usage statistics and monitor the traffic from your use or interaction with our Services.

9. Internet Protocol (IP) Addresses: Internet protocol (IP) addresses are unique identifiers automatically assigned to each computer when logging onto the Internet. We generally collect IP address information from visitors using or interacting with the Services and we log them for system administration purposes. In some cases, as described below in the Tracking Technologies subsection, we may also use IP addresses to serve you ads on third party websites regarding our Services that may be of interest to you based upon your use or interaction with the Services if you have opted-in to certain types ofcookies. You can always adjust your Cookie Settings or your individual browser’s settings.

10. Location Information: Your location information may be collected in a variety of ways depending on how you use or interact with our Services. For example, location information can be derived from your IP address, location information associated with your use of a device, your country or location selection, or other location-based components and content of our Services.

11. Progress Information: We also may collect information about your progress in using the Service, but only if you choose to provide this information to us. Progress information may be used to customize your Services. This information may include responses to wellness quizzes, surveys or other tasks.

12. Business Interactions: Information derived from your business-related requests, communications, and dealings we have with you, or the company/organization you work(ed) for or are associated with. This may include your job title, business contact information (phone, email, fax, and address), information about products or Services you expressed an interest in or purchased from us, or that we have purchased from you oryour company/organization, and other information needed to verify your ability to conduct business with us.

13. Social Media: Our Services may link to our pages or accounts on third party social media networks (“social media”) but our Services may use social media plug-ins. If you choose to interact with us on social media, we may collect the information you publish or submit. Note that this information is also governed by the privacy policies of the respective companies offering the social media service.

14. Forums and Blog: Some Services may link to blogs or forums (“forums”) that may or may not be owned or operated by MentalFit. If you choose to participate in forums, we may collect the information you submit to the forums. Note that such information may also be governed by the privacy policies of the respective companies offering the forums.

15. Video Recording and Photographs: If you choose to use certain portions of our Services which involve video and/or photography, we will collect this Personal Information from you in order to provide you with the Services you have requested.

16. Customer Support, Product Research, and Feedback: When you reach out to us such as to obtain support, give us feedback about the Service and our Providers, or participate in optional satisfaction surveys, product research (including user testing), we may also collect information that you choose to share.

1. Users of Online Services: How you use and interact with our online Services, such as the date of your last login, the type of content that you viewed or accessed, pages you viewed, features you use, your browser and device type, error reports, and any links you click on to leave or interact with the Service.

2. Members: To enable us to personalize your experience, provide care options, and design new products and Services, we also collect your answers to our well-being assessment as well as information about your preferred areas of focus.

4. Prospective Applicants or Employees: Information related to your prospective employment with us including but not limited to work history, education, the contents of your resume, references. If you later become an employee of MentalFit, you will receive a separate privacy notice which describes how your employment information will be handled.

1. Cookies: A cookie is a small file placed on your hard drive by some of our web pages. HTML5 local stored objects may store larger amounts of information on your browser. When you access the Service, either through our mobile applications or website, certain information (including computer and connection information, mobile application use, browser type and version, operating system and platform details, and the time of accessing the Service) is automatically collected. We, or third parties we do business with, may use cookies to help us analyze our web page flow, customize the Service, content and advertising, measure promotional effectiveness, and promote trust and safety. This information will be collected every time you access the Services and it will be used for the purposes outlined in this Privacy Notice.

2. Tags: Pieces of code, or tags, which gather information about users. For example, tags are used on our websites to better understand online usage patterns and trends. We may also use tags in our emails or newsletters to count how many of those messages are read.

3. Widgets: Small components embedded within our Services which enable you to use certain functionalities.

4. Google Analytics: Google Analytics uses cookies to collect data such as time of visit, website pages visited, time spent on each MentalFit website page, IP address, URL, and type of operating system. To learn more about how Google Analytics collects and processes Personal Information, please visit www.google.com/policies/privacy/partners.To opt out of having your activity available to Google Analytics, you can download the Google Analytics opt-out browser add-on

5. Web Beacons: Web beacons are electronic images placed in the code of a webpage, application or email that allow us to monitor things such as user activity and site traffic. Web beacons may be used to track the traffic patterns of users from one page to another in order to maximize web traffic flow.

6. Advertising: We do not target any advertisements toward individual consumers or members of our platform. Nothing you do on the MentalFit app or web platform will be used by us to target any advertisements towards you as an individual consumer anywhere else on the internet. We may engage third party service providers who utilize tracking technologies on our corporate website (www.mentalfitlife.com) to serve advertisements that may be of interest to potential employer-buyers of our Services. Some of these advertisements may be personalized, meaning that the advertisements are intended to be relevant to potential Organizational-buyers based on what we, or the third party service providers, know about them, such as employment at or agency for a company that might be interested in offering MentalFit as a benefit to its employees.

20. Other uses required to do so by law, for example in order to maintain accounting records, compliance with applicable retention obligations, for purposes of reporting obligations, to respond to lawful requests by public authorities, to investigate potential breaches and to protect our rights, property, safety and those of our users.

21. When permitted by law, we may also enhance or combine information about you, including your Personal Information, with information about you that we obtain from third parties for the same purposes described in this Privacy Notice.

1. MentalFit Affiliates: To our related MentalFit professional entity affiliates, in order to provide you with the Services.

2. Service Providers: To third party companies and individuals that we hire to perform services on our behalf, including to help us administer and provide the Services to you.These third parties are required to treat your Personal Information in accordance with appropriate contractual and legal privacy and security requirements.

3. Links to/From Third-Party Website: As a resource to our users, we may provide links to/from other unaffiliated websites or services within our Services. If you choose to visit such third-party websites or services, please note that any information you submit to them is subject to the privacy notice of the third-party website or service and not subject to this Privacy Notice.

4. Customers: Customers include, but are not limited to employers, educational institutions, and non-profits. We do not share any Personal Information with Customers unless necessary to prevent imminent harm (e.g., crisis management) or as required by law. We only share anonymized and aggregated information with Customers. MentalFit provides several administrator controls to allow Customers to manage the platform. For example, to create encouragement groups, upload and control rewards, and manage users.

If you are accessing the service through a Customer (such as single sign-on), the Customer may collect information about your login activity, including whether and when you access MentalFit Services. MentalFit does not control the information collection practices of Customers or other benefit providers, and you should consult their internal policies and procedures for more information about their information collection practices.

1. Performance of a Contract: For example, to carry out our contractual obligations with you pursuant to a contract to supply goods or services.

2. Legal Obligations: For example, some countries have transparency requirements regarding interactions with healthcare professionals, or requirements to provide information to authorities in case of adverse events or medical incidents related to the use of our Services.

3. Vital Interests: For example, when processing your Personal Information is in your vital interest or required to protect your life.

4. Consent: For example, if you opt-in to receive marketing communications from us or expressly provide your consent for us to process your Personal Information. In the event you provide your consent, you may also withdraw your consent when permitted by applicable law, if you contact us.

5. Legitimate Interests: This may include, for example, managing, operating, maintaining, and securing our websites, network systems, and other assets; and providing you with features and functionalities in the Services.

1. Withdraw consent: If we use or share your Personal Information based on your consent, you may withdraw your consent at any time.

2. Access: You may request access to or copies of your Personal Information. You may also request what types of Personal Information we have, the purposes for which we process it, and who has received access to your Personal Information.

3. Correction and Deletion: You may request that we correct your Personal Information if you think it is inaccurate or incomplete. You can also request that we erase or delete your Personal Information. Please note, if you are a MentalFit member, you can immediately request deletion of your Personal Information/account within the MentalFit mobile app by clicking on “Delete Account” in the account settings and following the instructions to complete your request. Once your Personal Information/account is deleted, you will no longer be able to access your account.

4. Restrict Processing: You may request that we restrict the processing of certain Personal Information.

5. Data Portability: You may request that we provide you with your Personal Information that we obtained from you, and you can ask us to provide it to another entity.

6. Object: You may have the right to object to our processing of your Personal Information for certain purposes.

7. Lodge a Complaint: If you believe we are using, disclosing, or otherwise processing your Personal Information in a way that is not in accordance with applicable law, you can lodge a complaint with the relevant data protection authority in your country.

1. Identifiers

A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, Social Security number, driver's license number, passport number, or other similar identifiers.

2. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).

A name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver's license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information. Some personal information included in this category may overlap with other categories.

3. Protected classification characteristics under California or federal law.

Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information).

4. Commercial information.

Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.

5. Biometric information.

Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as, fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data.

6. Internet or other similar network activity.

Browsing history, search history, information on a consumer's interaction with a website, application, or advertisement.

7. Geolocation data.

Physical location or movements.

8. Sensory data.

Audio, electronic, visual, thermal, olfactory, or similar information.

9. Professional or employment-related information.

Current or past job history or performance evaluations.

10. Inferences drawn from other personal information.

Profile reflecting a person's preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.
We obtain the above listed categories of Personal Information from the following sources (in addition to directly from users), as identified in this Privacy Notice:

• Types of users

• Personal Information obtained from third parties.

We disclose the above listed categories of Personal Information to the following categories of third parties, as described in the How we Use your information section
We collect and disclose the above listed categories of Personal Information for the business purposes, as described in the How we use your personal information section.