In order to use some of our apps or websites, we may ask you to enter your name, email, areas for improvement, fashion preferences, and ask other onboarding questions depending on the web products you choose from our ecosystem. In some of our apps you are able to skip some of the onboarding questions by tapping on Skip or similar indication.

We also may automatically collect from your device: language settings, IP address, time zone, type and model of a device, device settings, operating system, other technical information. We need this data to provide our services (for example, to render a certain element of the product), analyze how our customers use the app (for example, to know whether our customers use the features we release), to serve ads. Most of the time, you can influence such processing by limiting it via our privacy features available on the websites and/or apps.

Please read our Privacy Policy below to know more about what we do with data (Section 2), what data privacy rights are available to you (Section 4).

This Privacy Policy explains and lists the transparency information regarding what personal data is collected when you use our websites and the services provided through them (together “Services”) and how such personal data will be processed.

By using the Services, you promise us that (i) you have read, understand and agree to this Privacy Policy and the data processing described, and (ii) you are over 18 years of age. If you do not agree, or are unable to make this promise, you must not use the Services. In such a case, you must (a) delete your account and contact us and request deletion of your data; (b) cancel any subscriptions using the functionality or ask us to do it if you purchased it directly from our Services.

Any translation of the English version is provided for your convenience and transparency purposes only. In the event of any difference in meaning or interpretation between the English language version of this Privacy Policy available, and any translation, the English language version will prevail. The original English text shall be the sole legally binding version.

Contents:

Categories of personal data we collect
What are the purposes and legal bases for processing your personal data
With whom we share your personal data
How you can exercise your privacy rights
Age limitation
International data transfers
Changes to this privacy policy
Data retention
Personal data controller
Contact us

1. Categories of personal data we collect

We process data:

(i) you directly provide to us (for example, when you choose your areas for improvement or send us an email),
(ii) we receive about you from third parties,
(iii) automatically when you use our Services.

Data directly provided by you

Identifiers
This may include your full name, phone number, email address. You provide us with this information when you register for the Services, subscribe to our newsletters, or contact us by any other means.

Onboarding and usage data

You provide us with this category of information when you register for the Services and/or go through the onboarding process and/or use the Services. This category, in particular, includes:

General information about you. For example, age, gender, preferences, etc.

Learning Data. When you access content, we collect certain data including which courses, assignments, workspaces, and quizzes you’ve started and completed; answers to questions, and other items submitted to satisfy course and related content requirements.

Commercial information
When you make payments through the Services, you need to provide financial account data, such as your credit card number, to our third-party service providers that serve us as data and payments processors. We do not collect or store, or have access to full credit card number data, though we may receive some limited information, for example, credit card-related data (including a secure token reflecting your payment method), data about services purchased, date, time and amount of the purchase, the type of payment method used and limited digits of your card number.

Comments and attachments you provide with your requests
You may also provide us with some personal information using our “Leave us a message” forms or by sending emails to our email addresses (including by the means of our data processors referenced as Communication services providers in Section 3). This information may include any comments or attachments you log in when you send your inquiry.

BetterMe Store purchases data

When you buy our physical products, such as BetterMe devices (for example, BetterMe Band), apparel, accessories and other wellness goods (“Products”) at BetterMe Store, you provide us with your delivery address, size of the Products and other characteristics of the Products.

1.2. Data we collect automatically:

Online activity
We record how you interact with our Services. For example, we log your interactions with certain areas of the interface, the features, and content, courses you do and your progress, the time and duration of your course interaction, how often you use the Services, how long you stay in the Services, and your subscription orders.

Device and Geolocation data

We collect data from your mobile device. Examples of such data include: language settings, Internet Protocol address, type and model of a device, device settings, operating system, Internet service provider, geolocation data, mobile carrier, hardware ID, and Facebook ID.

Advertising IDs
We collect your Apple Identifier for Advertising (“IDFA”) or Google Advertising ID (“AAID”) (depending on the operating system of your device). You can typically reset these numbers through the settings of your device’s operating system (but we do not control this).

Cookies and similar tracking technologies

Our Services employs technologies (cookies, SDKs, etc.) to process your data to enhance your user experience, optimize ads, and analyze traffic. These technologies are activated when you interact with our Services or enable certain features. Disabling these technologies may affect the functionality of certain features, although our Services will remain usable.

We use, in particular, the following categories of tracking technologies:

Strictly necessary

Our Services and its features require certain technologies to function properly. These technologies are typically activated when you request our services, for example, when you visit our Services. By utilizing them, we can (i) remember your preferences as you navigate our Services, (ii) ensure swift loading of the content you request, (iii) enhance the security of our Services and (iv) enable other functionalities of our Services. Moreover, some of these technologies are activated when you enable certain features.

Functional

We use functional technologies to personalize and enhance your experience. By utilizing them, we can remember your choices (for example, custom design settings or storing your language preference for an extended period). Additionally, they provide you with a more consistent user experience by remembering your settings, keeping you logged in for extended periods, or saving your selections.

If you disable these technologies, some features may not function properly, although you will still be able to use our Services.

Performance

We use performance technologies to process information about how you and others interact with our Services. This helps us understand user engagement with our Services and its features, and identify preferences or dislikes. Some examples include:

Counting visits and identifying traffic sources.
Understanding which sections or features are most favored.
Analyzing user preferences to help us decide what new features to build.

When you disable performance technologies, we will not receive certain information that we process for analytical purposes.

Targeting
We, and our partners, use targeting technologies to tailor ads and display them to you at relevant times. For instance, if these technologies are enabled and you interact with our Services, you might see ads for our products in your social media feeds. Additionally, they help us measure the effectiveness of advertising campaigns and make advertising more relevant to you.

If you decline these targeting technologies, you may see less relevant ads and miss our timely offers. It would also be more challenging for us to measure ad effectiveness.

If you are located in certain countries, you can adjust your tracking technology preferences in the special banner.

2. What are the purposes and legal bases for processing your personal data

To enter into a contract with you for providing you with the functionality of our Services, we need to collect some personal data. Without it, it is impossible to provide you with our services.

We also collect and utilize your data to enhance the Services’s quality and to continuously improve it. Furthermore, we aim to attract new customers to our Services. Below, you'll find a more comprehensive breakdown of how we use your information, illustrated with clear examples.

Purpose of processing*	Description and examples	Categories of personal data	Lawful basis
To provide our Services and administer your account	This includes verifying your identity, email verification, enabling you to access and use our Services in a seamless manner and preventing or addressing Services errors or technical issues, customizing your experience. Responding to your requests for technical or customer support, Services information or to any other communication you initiate. This includes accessing your account to address technical support requests, providing a comprehensive answer to your inquiries, making sure that you are satisfied with our Services, as well as processing any disputes in regard to our Services, accessing your account to address technical support requests. For this purpose, we may send you, for example, notifications or emails about the performance of our Services, security, payment transactions, notices regarding our Terms and Conditions of Use or this Privacy Policy.	All categories	Performing our contract with you
To communicate with you regarding your use of our Services	We communicate with you, for example, by email. These may include reminders and motivational messages encouraging you to follow your educational plan, or other information about the Services, password resets or account updates. We may also communicate with you regarding important updates or changes to our Services, to gather feedback on our Services or to respond to any inquiries or complaints you may have.	All categories	Performing our contract with you or legitimate interest*, when it is not necessary for provision of our Services
To communicate with you regarding possible cooperation	This includes being able to contact you to discuss possible forms of cooperation, such as partnership opportunities or Services enhancements that may be of interest to you.	Identifiers	Legitimate interest*
To process and fulfill your orders and transactions	This includes managing and fulfilling your orders and requests, providing customer support in regards to your orders, processing your payments, providing receipts and order confirmations/updates, processing disputes related to an order. We use third-party services for payment processing. As a result of this processing, you will be able to make a payment for our Services and we will be notified that the payment has been made and will provide you with the purchase. We will not store or collect your payment card details ourselves.	Identifiers Commercial information Device and Geolocation data	Performing our contract with you
To research and analyze your use of the Services	This helps us to better understand our business, analyze our operations, maintain, improve, innovate, plan, design, and develop the Services and our new products. We also use data for statistical analysis purposes, to test and improve our offers. This enables us to better understand what features of the Services our users like more, what categories of users use our Services. As a consequence, we often decide how to improve the Services based on the results obtained from this processing.	All categories	Legitimate interest (unless it requires consent, e.g. the method of processing is covered under certain privacy regulations)
To send our marketing communications	We may add your email address to our marketing list, provided we receive consent or otherwise establish a legal basis for sending you marketing communications. As a result, you will receive information about our products, such as, for example, special offers. If you do not want to receive marketing emails from us, you can unsubscribe following instructions in the footer of the marketing emails.	Identifiers	Consent or Legitimate interest* (in jurisdictions that allow exception to consent requirements)
To personalize our ads	We and our partners use your personal data to tailor ads and show them to you at the relevant time. For example, you might see ads of our products in your Instagram’s feed.	Onboarding and usage data Online activity Commercial information Device and Geolocation data Advertising IDs (for example, we may use it for preventing or fixing technical issues); Cookies and similar tracking technologies.	Consent or Legitimate interest* (unless it requires consent, for example, when covered under certain privacy regulations)
To audit ad performances	That means to conduct auditing related to counting ad impressions to unique visitors, verifying positioning and quality of ad impressions, and auditing compliance with this specification and other standards.	Identifiers Onboarding and usage data Online activity Commercial information Device and Geolocation data Advertising IDs; Cookies and similar tracking technologies.	Consent or Legitimate interest* (unless it requires consent, for example, when covered under certain privacy regulations)
To enforce our Terms and Conditions of Use and to defend our legal rights and interests	We collect and store personal data to the extent necessary to defend our legal rights and interests in the event of legal disputes or claims and to enforce our agreements and contractual commitments, in particular, our Terms and Conditions of Use. This may include using the data to support our legal claims, respond to legal requests, or establish, exercise, or defend our legal position.	All categories	Legitimate interest*
To comply with legal obligations	We may use this data to comply with legal obligations, such as tax regulations, accounting standards, or other applicable laws and regulations. Specifically, we may use your Commercial information to calculate and report taxes owed, issue invoices or receipts, respond to tax-related inquiries from government authorities, maintain accurate financial records, comply with data protection laws, such as CCPA and GDPR, respond to lawful requests from law enforcement or regulatory agencies, etc.	All categories	Complying with legal obligations
To prevent and combat fraud	We use personal data to detect, prevent, and combat fraud. This may involve verifying user identities, monitoring transactions for suspicious activities, and taking appropriate action to protect our users and our Services from fraudulent activities.	All categories	Legitimate interest*

We do not use automated decision-making, including profiling, which produces legal effects concerning you or similarly significantly affects you.

*We rely, in particular, on the following legitimate interests:

To communicate with you regarding your use of our Services.

This includes, for example, sending you emails reminding you about your tasks within the course you bought.The legitimate interest we rely on for this purpose is our interest to encourage you to use our Services more often. We also take into account the potential benefits to you of using the Services to complete educational courses.

To communicate with you regarding possible cooperation.

The legitimate interest we rely on for this processing is our interest to establish and maintain business relationships with potential partners, clients or collaborators allowing you to benefit from our programs and offers.

To research and analyze your use of the Services.

Our legitimate interest for this purpose is our interest in improving our Services so that we understand users’ preferences and are able to provide you with a better experience (for example, to make the use of the Services easier and more enjoyable, or to introduce and test new features).

To send you marketing communications (unless you provide consent to that).
The legitimate interest for this processing is our interest to promote our Services in a measured and appropriate way. We may rely on it, for example, when we have an established business relationship with you, which may cover purchasing some products within the Services.

To personalize our ads.
We rely on our interest to promote our Services in a reasonably targeted way.

To audit ad performances.
The legitimate interest for this processing is our interest in ensuring the accuracy and quality of our advertising services and complying with industry standards.

To defend our legal rights and interests.
The legitimate interest refers to our need to protect ourselves from legal disputes, claims, or other actions that could threaten our operations, reputation, or financial stability. This interest is considered legitimate because it enables us to effectively manage risks and maintain compliance with applicable laws and regulations. This could involve using the data to support the organization's position in a dispute, respond to legal requests, or provide evidence in litigation.

To enforce our Terms and Conditions of Use, to defend our legal rights and interests and to prevent and combat fraud.

Our legitimate interests for this purpose are enforcing our legal rights, preventing and addressing fraud and unauthorized use of the Services, non-compliance with our Terms and Conditions of Use.

3. With whom we share your personal data

General classification

We engage partners to carry out specific services or business functions on our behalf using their technologies and resources, based on our instructions.This cooperation may involve, in particular, processing your data using their software development kits (SDKs), APIs, cookies, and other technologies. Consequently, your information is transferred and processed on their servers (usually without a partner's direct access to the specific pieces of information) on our behalf for our purposes.

Such type of processing of personal data may be regarded as sharing of information with third parties. We strive to conclude specific data processing agreements with all such parties to establish the rules for processing of your data specifically on our behalf and limited to it. Our partners help us operate, provide, improve, integrate, customize, support, and market our Services.

The types of third parties we share information with include, in particular:

Third-party services providers

We share personal data with third parties that we hire to provide services or perform business functions on our behalf, based on our instructions. We process your personal information using the following types of service providers (and in certain cases, their subprocessors):

Cloud storage providers

To host personal data and enable our Services to operate and be distributed we use Amazon Web Services, which is a hosting and backend service provided by Amazon. You may read more on Amazon’s security practices on its website.

Product monitoring service providers

We use Sentry, which is a monitoring service provided by Functional Software Inc. that helps us identify and resolve errors and crashes in our Services across different platforms such as JavaScript, Python, Ruby, Java and React. Sentry automatically captures all unhandled exceptions and relevant diagnostic data such as device information, user feedback and breadcrumbs. We can also manually report errors to Sentry with custom tags and context data. Sentry also provides us with features such as performance monitoring, alerting and dashboards to help us prioritize and fix issues faster. You may read about Sentry’s Security & Compliance on its website.

Email verification service providers

We use ZeroBounce, which is an email verification service provider that helps us validate, check and verify emails instantly. ZeroBounce allows us to improve our email deliverability and open rates by removing invalid, spammy and inactive addresses from our lists. ZeroBounce stores email validation results up to 30 days, and then deletes them automatically. You may read about ZeroBounce’s Cybersecurity and Data Privacy on its website.

Data analytics providers

General analytics tools

We use Amplitude that is an analytics service that we use to understand how customers use our Services. Amplitude collects various technical information, in particular, time zone, type of device, unique identifiers (such as IDFA). Amplitude also allows us to track various interactions that occur in our Services. As a result, Amplitude helps us to decide what features we should focus on. Amplitude complies with the EU-U.S. Data Privacy Framework (“EU-U.S. DPF”). Amplitude provides more information on how they process data in its Privacy Policy.

To analyze how visitors use the Services and to measure the effectiveness of some ads we use Google Analytics, a web analysis program of Google. On Google Analytics we get, in particular, information on the data you enter on our website and users’ interactions within the website. Google allows you to influence the collection and processing of the information generated by Google, in particular, by installing a browser plug-in, available here. We also use Google Tag Manager to configure and deploy tags on our Services. You can read more about how Google uses the information here.

Gateway service providers and payment processing partners

We use various payment processing and payment gateway providers that help us connect with different banks and payment systems around the world. These providers allow us to offer our customers a wide range of payment options and ensure fast and smooth transactions. Each payment processing provider has its own terms and conditions and privacy policy that may apply to the transactions they process.As a customer, you will need to provide your payment information directly to our payment partners.

Communication services providers

Zendesk provides us with customer service software, which enables us to handle your inquiries and requests via email, chat, phone and other channels. Thus, when you contact us via any of these channels, some of your information is automatically transferred to Zendesk. The transfer is required to provide you with timely and effective support. Read more about Zendesk’s approach to privacy on their website.

We use eSputnik, which is an omnichannel customer data platform for B2C marketing, to send you email advertising and transactional emails. eSputnik allows us to segment our customers based on their behavior and preferences and to send them personalized recommendations via email. When you subscribe to our email newsletter or make a purchase on our Services, some of your information is automatically transferred to eSputnik in order to allow us to communicate with you via emails.

Marketing service providers

Meta. We use Meta Ads Manager together with Meta Custom Audience, which allows us to choose audiences that will see our ads on Facebook or other Facebook’s products (for example, Instagram). Through Meta Custom Audience we may create a list of users with certain sets of data, such as an IDFA, choose users that have completed certain actions in the Services. As a result, we may ask Meta to show some ads to a particular list of users. As a result, more of our ads may show up while you are using Facebook or other Meta’s products (for example, Instagram). You may learn how to opt out of advertising provided to you through Meta Custom Audience here.

Facebook also allows its users to influence the types of ads they see on Facebook. To find how to control the ads you see on Facebook, please go here or adjust your ads settings on Facebook.

Google Ads is an ad delivery service provided by Google that can deliver ads to users. In particular, Google allows us to tailor the ads in a way that they will appear, for example, only to users that have conducted certain actions with our Services (for example, show our ads to users who have purchased a subscription). Google allows its users to opt out of Google’s personalized ads and to prevent their data from being used by Google Analytics.

We also use Snapchat Advertising Platform together with Snapchat Audience Based Match, which is an ad delivery service provided by Snapchat that can link the activity of some users of our Services with the Snapchat advertising network and show some of our ads to them. As a result, you may see more ads on Snapchat in case you use our Services. Snapchat allows you to Opt Out of their audience based ads. Read more about Snapchat’s approach to privacy in its Privacy Policy.

Pinterest is a social media service that allows us to share our content and reach more users. In particular, Pinterest allows us to use its conversion tracking feature to measure the effectiveness of our ads and to tailor our ads based on your interests and activities on our Services. Pinterest allows you to opt out of personalized ads in your account settings.You can access and review the Privacy Policy of Pinterest here.

Ad networks, ad agencies and direct publishers are third-party services that provide us with advertising solutions for displaying our ads on various websites and apps. In particular, these services allow us to target our ads based on your interests and activities on our Services. These services may also collect some information about you such as your device ID or IP address for delivering relevant ads. You can opt out of interest-based advertising by visiting the Digital Advertising Alliance’s consumer choice page or the Network Advertising Initiative’s consumer opt-out page.

B. Law enforcement agencies and other public authorities

We may use and disclose personal data to enforce our Terms and Conditions of Use, to protect our rights, privacy, safety, or property, and/or that of our affiliates, you or others, and to respond to requests from courts, law enforcement agencies, regulatory agencies, and other public and government authorities, or in other cases provided for by law.

C. Third parties as part of a merger or acquisition

As we develop our business, we may buy or sell assets or business offerings. Our Clients’ information is generally one of the transferred business assets in these types of transactions. We may also share such information with any affiliated entity (e.g. parent company or subsidiary) and may transfer such information in the course of a corporate transaction, such as the sale of our business, a divestiture, merger, consolidation, or asset sale, or in the unlikely event of bankruptcy.

D. Affiliates

We may share your personal information with our partner organizations that are part of our corporate group – these are companies that are owned by, own, or are jointly-owned with us. These partner organizations will use the information in ways that align with this Privacy Policy, ensuring that your privacy is respected and protected across all our affiliated services within our group.

II. CCPA classification of service providers and third parties

In order to provide our services, we may share your personal information with other entities that perform functions on our behalf or assist us in fulfilling our purposes. Depending on their role and relationship with us, these entities may be classified as service providers (or contractors) and third parties under the California Consumer Privacy Act (CCPA), as amended by the California Privacy Rights Act (CPRA).

The CCPA specifies the following categories of personal information:

Category A - Identifiers;
Category B - Personal information categories listed in the California Civil Code §1798.80(e);
Category D - Commercial Information;
Category F - Internet or other similar network activity;
Category G - Geolocation data;
Category I - Professional or employment-related information;
Category L - Sensitive personal information.

Depending on the actual circumstances, we may collect some of these categories that correspond to the categories mentioned in Section 1.

To help you understand what personal data we collect and for what particular purposes we do that, we have provided the table below that outlines the categories of service providers and third parties that we work with. Not all the items listed in the table below are relevant to you. The scope of use of the personal data depends on the services you use.

Category of service providers	Purpose of sharing data	Categories of personal data shared
Cloud storage service providers	To store your personal data and enable provision of our Services.	All сategories of personal data mentioned in Section 1
Product monitoring service providers	To prevent and/or address errors or technical issues	All сategories of personal data mentioned in Section 1
Communication service providers	To provide our Services To maintain and service your account and provide you with customer service To communicate with you regarding your use of our Services.	Identifiers Onboarding and usage data Online activity Commercial information Device and Geolocation data
Marketing service providers	To send you marketing communications To deliver our ads	Identifiers Advertising IDs Onboarding and usage data Online activity Commercial information
Email verification service providers	To verify your information you before you creating account	Identifiers
Gateway service provider and payment processors	To process and fulfill your transactions	Identifiers Onboarding and usage data Commercial information Device and Geolocation data
Data analytics providers	To research and analyze your use of the Services. To audit ad performances	All categories of personal data mentioned in Section 1

The categories of third parties to whom personal information was disclosed that may be considered a “sale” under California law are: Marketing service providers, Data analytics providers.

4. How you can exercise your privacy rights

To be in control of your personal data, you have the following rights:

Accessing / reviewing / updating / correcting your personal data. You have the right to review, edit, or change the personal data that you had previously provided to us. If you would like to receive a copy of data we process, please send us a data access request at privacy@betterme.world.

Deleting your personal data. You can request erasure of your personal data, as permitted by law. When you request deletion of your personal data, we will use reasonable efforts to honor your request. In some cases we may be legally required to keep some of the data for a certain time (for example, information about your payments and your requests to us); in such event, we will fulfill your request in relation to portion of the data within the timeframes required for exercising data deletion requests and to another portion of the data after we have complied with our retention obligations (for example, after the end of data retention period obligation for payment data).

Getting to know the details of the processing. You have the right to be informed about the collection and use of your personal data. This means that you have the right to understand what personal data is being processed, why it's being processed, who it's being shared with, how long it's being stored. We strive to follow the transparency requirements and provide most of the information in this Privacy Policy. However, if you have any questions about our data processing practices or if you would like more details about how we use your personal data, please send us an email at privacy@betterme.world or by contacting us in any other convenient way.

Objecting to or restricting the use of your personal data. You can ask us to stop using your personal data or limit our use. For example:

Email marketing: we provide you with the ability to unsubscribe from email marketing communication by following the unsubscribe link in every email or by contacting our support team.

Additional means to influence personalized advertising

iOS: On your iPhone or iPad, go to “Settings,” then “Privacy” and tap “Advertising” to select “Limit Ad Track”. In addition, you can reset your advertising identifier (this also may help you to see less of personalized ads) in the same section.

Android: To opt-out of ads on an Android device, simply open the Google Settings app on your mobile phone, tap “Ads” and enable “Opt out of interest-based ads”. In addition, you can reset your advertising identifier in the same section (this also may help you to see less personalized ads).

To learn even more about how to affect advertising choices on various devices, please look at the information available here.

In addition, you may get useful information and opt out of some interest-based advertising, by visiting the following links:

Network Advertising Initiative – http://optout.networkadvertising.org/
Digital Advertising Alliance – http://optout.aboutads.info/
Digital Advertising Alliance (Canada) – http://youradchoices.ca/choices
Digital Advertising Alliance (EU) – http://www.youronlinechoices.com/
DAA AppChoices page – http://www.aboutads.info/appchoices

We value your right to influence the ads that you see, thus we are letting you know what service providers we use for this purpose and how some of them allow you to control your ad preferences.

The right to lodge a complaint with supervisory authority. We would love you to contact us directly, so we could address your concerns as customer satisfaction is our top priority, thus we strive to appoint sufficient resources and efforts to provide you with top of the market customer support and most likely will be able to satisfy your request directly. Nevertheless, you have the right to lodge a complaint with a competent data protection supervisory authority.

You can find the full list of EU supervisory authorities through the link.

The right to data portability. If you wish to receive your personal data in a machine-readable format, you can do so by requesting a copy of your personal data as described above. The data will be made available to you in the .json file or another file format.

California residents’ privacy rights

What additional rights do you have under the CCPA?

This section provides details about additional rights that are available to California consumers under the California Consumer Privacy Act (CCPA), as amended by the California Privacy Rights Act (CPRA) and California’s Shine the Light law. Therefore, this section applies only to residents of California, United States.

For more details about the personal information we have collected, including the categories of sources, please see Section 1 above. We collect this information for purposes described in Section 2 of this Privacy Policy. We may also share your information with certain categories of third parties as indicated in Section 4.

In addition to the rights listed above, CCPA provides you with the following rights:

Right to know what personal information is sold or shared and to whom. Under that title, you have the right to request that we disclose to you:

The categories of personal information that we collected about you.
The categories of personal information that we sold or shared about you and the categories of third parties to whom the personal information was sold or shared.
The categories of personal information that we disclosed about you for a business purpose and the categories of persons to whom it was disclosed for a business purpose.

The Right to Opt Out of Sale or Sharing and Limit Use of Personal Information. We may share certain information about you with our partners for purposes of targeted advertising or data analytics, which could in certain circumstances be characterized as “selling,” “sharing,” or “targeted advertising” under California laws. You have the right to opt-out of such sale/sharing of your personal information.

We will strive to provide a prominent link named “Your Privacy Choices” that would allow you to exercise this right. Most of the time it will be available to you in the footer, menu, profile, or similar place (depending on the device you use). To know more on how to exercise this right, please visit Your Privacy Choices.

We will also strive to recognize and process your opt-out preference signal as soon as possible after receiving it.

The right not to be discriminated against. Under this title, you have a right not to be discriminated against for exercising any of your rights under the CCPA.

(b) Access rights under California’s Shine the Light

California also provides its residents with additional access rights. Under the California Civil Code Section 1798.83 also known as California's "Shine the Light" law, the residents may ask companies once a year what personal information they share with third parties for those third parties' direct marketing purposes. Learn more about what is considered to be personal information under the Code.

To obtain this information from us, please send an email message to privacy@betterme.world, which includes “Request for California Shine the Light Privacy Information” on the subject line and your state of residence and email address in the body of your message. Please be aware that not all information sharing is covered by the “Shine the Light” requirements and only information on covered sharing will be included in our response.

Exercising your rights

To exercise any of the available privacy rights, please send a request to privacy@betterme.world.

Verification. To ensure that we properly handle the requests you make regarding your rights, we are required to verify those requests. Depending on the type of request, this may include your name, age, email, date of subscription purchase, date of last activity, date of account creation or some other Services use data that will reasonably identify you as an owner of the account, etc. We may also ask you for additional proof of identity, if necessary, but we strive to require as little as possible (for example, for some requests we will send you a verification code or link).

An authorized agent. You may also designate an authorized agent to exercise your rights on your behalf. If you have provided an authorized agent with a power of attorney, we will work directly with your authorized agent to complete your request. Where you have not provided an authorized agent with a proper power of attorney or similar authorization, we will reach out to you directly to confirm the authorized agent’s authority and collect the verification Information. The authorized agent shall verify the identity of both himself and the consumer.

5. Age limitation

We do not knowingly process personal data from persons under 18 years of age. If you learn that anyone younger than 18 has provided us with personal data, please contact us at privacy@betterme.world.

6. International data transfers

We may transfer personal data to countries other than the country in which the data was originally collected in order to provide the Services set forth in the Terms and Conditions of Use and for purposes indicated in this Privacy Policy. If these countries do not have the same data protection laws as the country in which you initially provided the information, we deploy appropriate safeguards, such as standard contractual clauses adopted by the European Commission.

7. Changes to this privacy policy

We may modify this Privacy Policy from time to time. If we decide to make material changes to this Privacy Policy, you will be notified through our Services or by other available means and will have an opportunity to review the revised Privacy Policy. By continuing to access or use the Services after those changes become effective, you agree to be bound by the revised Privacy Policy.

8. Data retention

We will store your personal data for as long as it is reasonably necessary for achieving the purposes set forth in this Privacy Policy and our the Terms and Conditions of Use (including providing the Services to you), which includes (but is not limited to) the period during which you have an account with the Services.

We will also retain and use your personal data as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements. For example, under certain accounting and tax laws we are required to store Commercial Information for long periods of time to comply with laws we are subject to. Therefore, even if you submit a data deletion request, a small portion of the data that relates to our compliance obligations will be stored even after the request is satisfied.

9. Personal data controller

BetterMe will be the controller of your personal data.

10. Contact us

You may contact us at any time for details regarding this Privacy Policy, its previous versions, or our information practices. For any questions concerning your account or your personal data please contact us at privacy@betterme.world.

Last update: March 25, 2025.