Launch Health, a division of Schwabe Industries Inc. ("the Company", "we", or "us") is dedicated to safeguarding your privacy and protecting your personal information. This Privacy Policy ("the Policy") outlines how we manage the personal information collected from visitors to our website, service subscribers, podcast listeners, course purchasers, business associates, and others we engage with during our operations. This Policy applies to data you provide via our website ("the Site"), upon subscribing to our services, in communications with us, and through other interactions with us. Herein, we describe the kinds of personal information we collect, our practices for using and disclosing this information, and the rights and choices you possess concerning your information. Your use of our Site is also governed by our Terms of Use, available for reference [insert link to Terms of Use].
Policy Updates and User Responsibility
Our commitment to transparency in processing your personal information is paramount, yet we acknowledge the need for occasional updates or amendments to this Policy, or the creation of supplementary policies, to reflect evolving circumstances or new legal mandates. Therefore, we emphasize the importance of your thorough understanding of how we utilize your personal information as detailed in this Policy.
We encourage you to periodically review this Policy for any changes. Additionally, in our ongoing relationship, should there be any changes to your personal data, we request that you inform us so we can update our records. Your use of our website, engagement with our services, social media interaction, or provision of personal information signifies your explicit consent to the practices outlined in this Policy. If you disagree with any aspect of this Policy, please refrain from using our website and services, engaging with our social media, completing any purchases, listening to our podcasts, or providing us with your information.
Clarification on Professional Relationship and Information Provided
Accessing our Site, using our services, tuning into our podcast, or following our social media channels does not create a doctor-patient relationship. The information available on our Site, through our services, on our social media platforms, or in our podcast is not intended as personalized medical advice for any individual user or customer. It should not be perceived as universally acknowledged medical advice or as a medically recommended practice or guideline. Our content is designed solely for general informational purposes and is not a substitute for professional consultation with a healthcare provider. We strongly advise consulting a qualified healthcare professional for advice tailored to your specific health needs.
Collection of Personal Data
Part 1
Under this Policy, "personal information" refers to data that can identify or is associated with a specific individual. We collect various types of personal information, including but not limited to:
- Individual Contact Details: Names, email addresses, billing and mailing addresses, and phone numbers.- Business Contact Details: Names, business email addresses, physical business addresses, billing addresses, and business phone numbers.- Member Account Data: Usernames, passwords, contact details (as in individual contact information), accessed content, and other relevant membership details.- Transactional Details: Information about transactions with us, such as payment methods, received payments, payment details, and transaction history.- Payment Data: Information about the payment card or financial account used for transactions.- Marketing Preferences: Information on requested or received promotional materials, service interests, promotional communication receipts, and marketing preferences.- Communication Records: Records of communications with us, including emails, calls, social media interactions, and communications via chatbots or other site features.- Device and Usage Data: Information on how and when you use our Site and services, including device details, IP addresses, usage frequency, viewed pages, referral sources, and interaction details.
This information is collected through various means, such as when you visit our Site, subscribe to services, complete forms, engage with our social media, enter transactions, or communicate with us.
We may anonymize or aggregate the mentioned data, making it non-identifiable, at which point it ceases to be "personal information." We might also source information about you from third parties or publicly available data.
Part 2:
Collection of Usage and Device Data
Our Site, like many others, employs various technologies to automatically gather information about its visitors. These technologies include:
- Cookies: These small text files are stored on your device by our website for record-keeping. We use cookies to customize your experience, deliver relevant content, monitor visitor trends, conduct marketing activities, and analyze site traffic. For more information on cookies and how to disable them, visit www.allaboutcookies.org. Note that disabling cookies may affect your ability to fully experience our Site.
- Log Files and Device Identifiers: We utilize log files to track activities on our Site and gather data such as IP addresses, browser types, Internet service providers, referring/exit pages, timestamps, and device identifiers.
- Web Beacons and Other Technologies: Our Site may use additional tracking tools like web beacons, which are tiny electronic images in content and emails. These are used to track page and content views and email engagement.
- Analytics Services: We may use third-party analytics, such as Google Analytics, to understand how our Site is used. For details on Google Analytics' data collection and processing, visit their site. Google's privacy policy is also available for review.
The data collected through these methods may be linked with personal information or combined with other data on Site visits. We may share this usage data with our advertising and analytics partners, who might integrate it with information you've previously supplied to them.
Part 3
Social Media Interactions
When you engage with us on social media platforms, the following applies:
1. Privacy Settings and Information Sharing: The personal information you share on social media
Social Media Interactions
When you engage with us on social media platforms, the following applies:
1. Privacy Settings and Information Sharing: The personal information you share on social media platforms may be accessible to us, depending on your privacy settings on those platforms. If your settings allow it, we may read, collect, or use your information in line with this Policy.
2. Visibility of Interactions: If we interact with you on social media, be aware that your account name or handle may become visible to all followers or users of our social media accounts.
Please note that social media platforms are independent entities from Launch Health, and we are not responsible for the personal information you choose to submit or make public on these platforms. We recommend reviewing the privacy policies and settings on any social media platforms you use to fully understand their privacy practices.
Part 4 Collection of Information from External Sources
Launch Health may gather both personal and non-personal data about you from various external sources such as affiliated businesses, contractors, suppliers, and other third parties. This information is combined with data we've already collected from you.
Both we and our engaged third parties may merge the information collected directly from you, over time and across different sections of the Site, with data obtained from these external sources. This integration aims to enhance the accuracy and completeness of the information we hold and to refine our interactions and communications with you.
Usage of Personal Information
At Launch Health, we or our designated service providers may utilize the personal information we've collected for various purposes, including:
1. Business Relationships: To negotiate, establish, and manage our relationship with you or your company, including service delivery and payment processing.
2. Membership Services: To register you as a member and provide access to membership content and benefits.
3. Newsletter Subscription: To subscribe you to and deliver our newsletter.
4. Site Experience: To enhance and optimize your experience on our Site, ensuring effective content presentation.
5. Communication: To interact with you, address your inquiries, discuss our services, and communicate about agreements with your company (if applicable).
6. Marketing Communications: To send promotional or informational messages, track marketing preferences, and for our internal marketing strategies.
7. Customer Service: To handle customer service and membership issues.
8. Service Improvement: To develop, refine, and enhance our services, customer support, and overall member experience.
9. Fraud Prevention: To prevent and detect fraud, financial crimes, hacking, security breaches, and other illegal activities related to our Site or services.
10. Legal Compliance: To enforce customer agreements, adhere to legal/regulatory obligations, and manage legal claims.
11. Notifications: To inform you about updates to our Site, services, or significant changes to this Policy.
12. Feedback and Surveys: To provide surveys or solicit your feedback.
13. Other Purposes: For functions as described at the time of collection or to which you have consented.
Marketing Communications
Launch Health may periodically send you direct marketing messages containing news, updates, offers, and promotions about our services and activities. We ensure that our marketing efforts comply with applicable laws, and we provide you the option to opt out if you no longer wish to receive such communications. You can unsubscribe at any time using the link provided in the footer of our marketing emails or by contacting us directly using the contact information provided.
Sharing Personal Information
We may use or disclose information that is aggregated, anonymized, or otherwise non-identifiable for any purpose, as allowed by law.
Your personal information may be disclosed to the following entities:
- Affiliated Businesses: We may share your information with our affiliates offering relevant products or services. - Service Providers: Third-party service providers facilitating our operations may access your personal information for specific tasks, such as IT support, member access to content, data storage, and payment processing.- Marketing and Advertising Partners: We work with vendors for lead generation, client information hosting, marketing automation, advertisement placement and targeting, and marketing campaigns.- Analytics Providers: To analyze Site traffic and usage patterns, improve our Site, and identify prospective customers.- Legal and Regulatory Authorities: When necessary to comply with laws and regulations, respond to legal requests, or protect our rights, we may disclose your information to authorities, law enforcement, or courts.- Potential Acquirers: In case of a business sale, merger, or similar event, personal information may be part of the transferred assets.- Other Disclosures: We may also share your information for purposes disclosed at the time of providing your information or as consented by you.
This section outlines our practices regarding the dissemination of your personal data, underlining our commitment to respecting your privacy while ensuring compliance with legal obligations.
Control Over Your Personal Data
At Launch Health, we value your right to control how your personal information is collected, used, and shared. We strive to provide you with meaningful options concerning your data. Here are some choices you have:
- Marketing Emails: In compliance with applicable laws, you can opt out of receiving promotional emails by clicking the “opt out” link in any such email and following the provided instructions.
- Cookies: Your browser or device may offer settings to manage cookies, including accepting or rejecting all cookies, receiving notifications when cookies are set, or deleting cookies. We recommend reviewing your browser's or device's tools and instructions for these settings. Further details on managing cookies are available in our Cookie Statement.
- Google Analytics: We use Google Analytics for our Site. If you prefer not to have your data collected by Google Analytics, Google offers an opt-out browser add-on. More information about Google's data usage can be found here.
- Choosing Not to Provide Information: You have the option not to provide certain information requested by our Site. However, this might limit your ability to use specific features, request service information, or engage in transactions with us.
- Do Not Track Mechanisms: Please note that our Site does not respond to “Do Not Track” signals, and such requests will not alter the operation of our Site.
For further inquiries about your personal information choices, please contact us using the details provided at the end of this Policy.
Third-Party Website Links
Our Site includes links to external, third-party websites. We advise you to review the privacy policies of these websites, as they have their own distinct terms. Launch Health does not exercise control over these third-party sites and assumes no responsibility for their content or data management practices.
Residents of California
Rights of California Residents
This section adheres to the California Consumer Privacy Act (CCPA) and its amendments, addressing the rights of California residents. As a "business" under the CCPA, we explain our practices concerning personal information, both online and offline.
A. Collection and Disclosure of Information
Over the past year, we've collected and disclosed various personal information categories to third parties for business purposes. The categories and examples of personal information, along with the types of third parties to whom they were disclosed, are outlined below.
B. Information Collection Methods
We collect personal information:- Directly: When you fill out forms, engage in transactions, subscribe, communicate about our services, or directly provide us information.- Indirectly and Technologically: Through cookies, pixels, and tracking technologies when you visit or use our site.- Via Social Media: Depending on your social media interactions, the information collected may include profile details, content, and metadata.- From Third Parties: Occasionally, we may acquire information, like marketing lists, from external sources.
C. Usage of Personal Information
We use personal information for:- Enhancing your Site experience and content presentation.- Processing transactions and managing business relationships.- Communication about services and products, including promotions.- Service and product development and improvement.- Fraud, crime prevention, and legal compliance.- Various purposes described at the time of collection or with your consent.
D. Retention Periods
The retention duration for each personal information category is determined by specific criteria detailed in the "Data Retention and Storage" section.
E. Sensitive Personal Information
We don't collect "sensitive personal information" for profiling California consumers, treating any such data as regular personal information under the CCPA.
F. Information Sharing and Advertising
In the past year, we've shared personal information categories with marketing and analytics providers for targeted and cross-context behavioral advertising.
G. CCPA Rights
California residents have rights under the CCPA, including information requests, data portability, deletion, correction, and opt-out rights. The process to exercise these rights is outlined in this section.
H. Exercising CCPA Rights
To exercise CCPA rights, contact us via email or phone. Verifiable consumer requests must include identification and request details. We use information provided in requests solely for verification purposes.
I. Opt-Out of Information Sharing
To opt-out of personal information sharing, use the specified methods, and we will comply within 15 business days.
J. Non-Discrimination Commitment
In line with CCPA, we don't discriminate against individuals exercising their CCPA rights.
K. California's Shine the Light Act
California residents can request information about our sharing of personal information with third parties for direct marketing under the Shine the Light Act. Preferences can be communicated through our contact information.
Rights of Virginia Residents
Under the Virginia Consumer Data Protection Act (VCDPA), this section details the rights of Virginia residents regarding personal data when we act as a "controller."
A. Personal Data Categories and Sharing
We process personal data categories for Virginia consumers as previously outlined in the California residents section of this Policy. This data is shared with third parties specified in that section as well.
B. Purpose of Data Processing
The purposes for processing personal data of Virginia consumers are previously described in California residents section of this Policy.
C. VCDPA Consumer Rights
Virginia consumers have specific rights under the VCDPA:- Confirmation and access to their personal data being processed.- Correction of inaccuracies in their personal data.- Deletion of personal data provided or obtained by us.- Obtaining a copy of their personal data in a portable, usable format.- Opting out of personal data processing for targeted advertising, sale of personal data, or profiling in significant decision-making.
For more details refer to the California section.
D. Exercising Consumer Rights
Virginia consumers, or their authorized representatives, can exercise the above rights (1-4) by submitting a verifiable request to [email protected], with "VCDPA Request" as the subject. California residents section also gives details on this process.
Opt-out requests for targeted advertising are handled as per Section 9(H). We do not sell personal data or profile for significant decision-making, hence requests of this nature are not applicable.
E. Appeal Process In case of denial or non-action on a request, we provide a written rationale, as in the California residents section. Appeals can be made by emailing [email protected] with "VCDPA Appeal" as the subject. A detailed explanation should accompany the appeal. Within 60 days, we will respond to your appeal. If we don't act on your appeal, you may file a complaint with the Virginia Attorney General using the provided form or contacting the Consumer Protection Hotline.
Rights of Nevada Residents
Under Nevada law, residents who have purchased services from Launch Health can opt out of the "sale" of "covered information" (as defined by Nevada law), where such sale involves monetary transactions allowing others to license or resell this information. Covered information typically includes personal details such as first and last name, address, email address, phone number, or any identifier enabling contact with a specific person physically or online. It's important to note that Launch Health does not participate in activities that would constitute a sale of personal information as per Nevada law.
Rights of Canadian Residents
Canadian residents are afforded specific rights regarding their personal information under various national laws, including the Personal Information Protection and Electronic Documents Act (PIPEDA). These rights include:
- Information Request: You can request details about the collection, use, and disclosure of your personal information.- Access to Personal Information: You have the right to access your personal information held by us.- Correction of Information: If your personal information is inaccurate or incomplete, you have the right to challenge its accuracy and have it amended as necessary.
To exercise these rights, Canadian residents should send a request to [email protected] with the subject line “Canada Resident Request,” or contact us as outlined in the “How to Contact Us” section. We will respond promptly, though we may request additional information to locate your personal data or clarify its use or disclosure. Access to your information will be provided at minimal or no cost.
This is intended for use in Canada and the United States. If you are from any other location please refrain from using this service.
Protection of Children's Privacy
Launch Health is designed for a general audience and is not targeted towards children under 16 years of age. We do not intentionally collect personal information from children below 16. If we become aware that a child under the required age has provided us with personal information, we will use this information solely to contact the child and inform them that parental consent is required. We are committed to protecting the privacy of young users and adhere strictly to this policy.
Safeguarding Personal Information
At Launch Health, we implement various administrative, technical, and physical safeguards to protect your personal information against loss, theft, and unauthorized access, disclosure, or alteration. However, it's important to note that no internet-based data transmission can be guaranteed as completely secure. Although we are committed to protecting your personal information, we cannot assure or warrant its absolute security during transmission. Therefore, any information you transmit to us is done at your own risk.
Retention of Personal Data
Launch Health retains your personal information only for the duration necessary to serve the purposes for which it was collected. This includes compliance with legal, accounting, or reporting obligations. In determining the retention period, we consider various factors:
1. Nature and Sensitivity: We assess the volume, nature, and sensitivity of the personal data.2. Risk of Harm: Potential risks from unauthorized use or disclosure of your data are taken into account.3. Processing Purposes: The specific purposes for processing your information and whether these purposes can be achieved through other means are considered.4. Legal Requirements: Applicable legal, accounting, and reporting requirements are factored into the retention period.5. Limitation Periods: Any relevant limitation periods under applicable laws are also considered in determining how long to retain your data.
Policy Updates
Launch Health's Privacy Policy is subject to change. Should we modify the Policy, updates will be posted on this page along with a revision of the "Last Updated" date at the top. Your continued use of our Site following any changes signifies your acceptance of these updates. Therefore, we recommend regularly reviewing the Policy for any modifications.
Contact Information
If you have any inquiries or need more information about our privacy practices, please feel free to contact us. You can reach us via email at [email protected]. We are here to assist and address any concerns or questions you might have.