PRIVACY POLICY

BETTERME WEIGHT LOSS WORKOUTS

IMPORTANT PRIVACY INFORMATION

In order to use the app, we will ask you to enter your current weight and height, target weight, fitness level, areas for improvement, and food preferences . We also automatically collect from your device: language settings, IP address, time zone, type and model of a device, device settings, operating system, Internet service provider, mobile carrier, hardware ID, Facebook ID, and some other unique identifiers (such as IDFA and AAID). We need this data to provide our services, analyze how our customers use the app, to serve ads.

For improving the app and serving ads, we use third party solutions. As a result, we may process data using solutions developed by Amplitude, Facebook, Firebase, Google, Apple, Appsflyer, Crashlytics. As a result, some of the data is stored and processed on servers of such third parties. This enables us to (1) analyze different interactions (how often users make subscriptions, the average weight and height of our users, how many users chose a particular area for improvement); (2) serve ads (and are able to show them only to a particular group of users, for example, to subscribers). Consequently, we, in particular, better understand in what of our features and content you see the most value and are able to focus on them to enhance your experience and increase the quality of our products.

This Privacy Policy explains what personal data is collected when you use the BetterMe: Home Workout & Diet mobile application, our websites and the services provided through them (together “App” or “Service”), how such personal data will be processed.

BY USING THE SERVICE, YOU PROMISE US THAT (I) YOU HAVE READ, UNDERSTAND AND AGREE TO THIS PRIVACY POLICY, AND (II) YOU ARE OVER 16 YEARS OF AGE (OR HAVE HAD YOUR PARENT OR GUARDIAN READ AND AGREE TO THIS PRIVACY POLICY FOR YOU). If you do not agree, or are unable to make this promise, you must not use the Service. In such case, you must (a) delete your account using the functionality found in “Settings” in the App, or contact us and request deletion of your data; (b) cancel any subscriptions using the functionality provided by Apple (if you are using iOS) or Google (if you are using Android); and (c) delete the App from your devices.

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

“GDPR” means the General Data Protection Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data.

“EEA” includes all current member states to the European Union and the European Economic Area.

“Process”, in respect of personal data, includes to collect, store, and disclose to others.

This Privacy Policy explains what personal data is collected when you use website located at https://betterme-mealplan.com/ (the "Website", "Service"), how such personal data will be used, shared, and how you can control it.

BY USING THE SERVICE, YOU PROMISE US THAT (I) YOU HAVE READ, UNDERSTAND AND AGREE TO THIS PRIVACY POLICY, AND (II) YOU ARE OVER 18 YEARS OF AGE (OR HAVE HAD YOUR PARENT OR GUARDIAN READ AND AGREE TO THIS PRIVACY POLICY FOR YOU). If you do not agree, or are unable to make this promise, you must not use the Service.

GDPR” means the General Data Protection Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data.

EU/EEA” includes all current member states to the European Union and the European Economic Area.

Process”, in respect of personal data, includes to collect, store and disclose to others.


TABLE OF CONTENT

  1. CATEGORIES OF PERSONAL DATA WE COLLECT
  2. FOR WHAT PURPOSES WE PROCESS PERSONAL DATA
  3. UNDER WHAT LEGAL BASES WE PROCESS YOUR PERSONAL DATA (Applies only to EEA-based users)
  4. WITH WHOM WE SHARE YOUR PERSONAL DATA
  5. HOW YOU CAN EXERCISE YOUR PRIVACY RIGHTS
  6. AGE LIMITATION
  7. CHANGES TO THIS PRIVACY POLICY
  8. CALIFORNIA PRIVACY RIGHTS
  9. DATA RETENTION
  10. HOW “DO NOT TRACK” REQUESTS ARE HANDLED
  11. PERSONAL DATA CONTROLLER
  12. CONTACT US

1. CATEGORIES OF PERSONAL DATA WE COLLECT

We collect data you give us voluntarily (for example, food preferences). In addition, we collect data automatically (for example, your IP address). We also may receive data about you from third parties.

1.1. Data you give us

You provide us information about yourself in the process of ordering a custom meal plan on the Website. For example: age, gender, weight, height, target weight, body type, food preferences, name, email address.

1.2. Data we collect automatically

1.2.1. Data about how you found us

We collect data about your referring app or URL (that is, the app or place on the Web where you were when you tapped on our ad).

1.2.2. Device and Location data.

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

1.2.3. Usage data

We record how you interact with our Service. For example, we may log your taps/clicks on certain areas of the interface, the features and content you interact with, how often and for how long you use the Website, and your meal plan orders.

1.2.4. Advertising IDs

We collect your Apple Identifier for Advertising (IDFA) or Google Advertising ID (AAID) (depending on the operating system of your device) when you access our Website from a mobile device. You can typically reset these numbers through the settings of your device’s operating system (but we do not control this).

1.2.5. Transaction data

When you make payments through the Service, you need to provide financial account data, such as your credit card number, to our third-party service providers. We do not collect or store full credit card number data, though we may receive credit card-related data, data about the transaction, including: date, time and amount of the transaction, the type of payment method used.

1.2.6. Cookies

A cookie is a small text file that is stored on a user's computer for record-keeping purposes. Cookies can be either session cookies or persistent cookies. A session cookie expires when you close your browser and is used to make it easier for you to navigate our Service. A persistent cookie remains on your hard drive for an extended period of time. We also use tracking pixels that set cookies to assist with delivering online advertising.

Cookies are used, in particular, to automatically recognize you the next time you visit our Website. As a result, the information, which you have earlier entered in certain fields on the Website may automatically appear the next time when you use our Service. Cookie data will be stored on your device and most of the times only for a limited time period.


2. FOR WHAT PURPOSES WE PROCESS PERSONAL DATA

We process your personal data:

2.2. To provide our Service

This includes enabling you to use the Service in a seamless manner and preventing or addressing Service errors or technical issues. For this purpose we, in particular, will send you your customized meal plan to your email, which you will indicate during the purchase.

To host personal data and enable this Website to operate and be distributed we use Amazon Web Services (AWS), which is a hosting and backend service provided by Amazon.

To monitor Website infrastructure, we use Crashlytics (Google Inc.), which is a monitoring service provided by Google. Here’s its Data Collection Policy.

We use Firebase Performance Monitoring and Firebase Crash Reporting, which are monitoring services provided by Google. To learn more, please visit Google’s Privacy policy and Privacy and Security in Firebase.


2.3. To customize your experience

We process your personal data, such as your goals (for example, target weight), to adjust the content of the Service and make offers tailored to your personal preferences. For example, we ask you to provide us with your body measures in order to calculate, in particular, recommended daily amount of calories.


2.4. To provide you with customer support

We process your personal data to respond to your requests for technical support, Service information or to any other communication you initiate. For this purpose, we may send you, for example, notifications or emails about the performance of our Service, security, payment transactions, notices regarding our Terms and Conditions of Use or this Privacy Policy.


2.5. To communicate with you regarding your use of our Service

We communicate with you, for example, by emails. These may include, for example, emails with information about the Service.

The services that we use for these purposes may collect data concerning the date and time when the message was viewed by the Website’s users, as well as when they interacted with it, such as by clicking on links included in the message.

We use Leanplum, which is a mobile marketing and analytics platform that allows us to customize and send messages to our users (in particular, via email). Leanplum enables us to choose the categories of users, which will receive such messages. Privacy Policy.


2.5. To research and analyze your use of the Service

This helps us to better understand our business, analyze our operations, maintain, improve, innovate, plan, design, and develop the Website and our new products. We also use such data for statistical analysis purposes, to test and improve our offers. This enables us to better understand what features and sections of the Website our users like more, what categories of users use our Website. As a consequence, we often decide how to improve the Website based on the results obtained from this processing.

To perform research and analysis about how users interact with our Website we use Appsflyer. Appsflyer enables us to understand, in particular, how users find us (for example, who was the advertiser that delivered an ad to users, which led you to our Website). Appsflyer also provides us with different analytics tools that enable us to research and analyze your use of the Service. Privacy Policy, Opt Out.

We use Facebook Analytics, which is a service provided by Facebook that allows us to use different analytical tools. On Facebook Analytics we get, in particular, aggregated demographics and insights on how many people access the Website and users’ interactions within the Website. Privacy Policy

To analyse how visitors use our Website and to measure effectiveness of some ads we use Google Analytics, a web analysis program of Google. In order to provide us with analytics, Google Analytics places cookies on your device. On Google Analytics we get, in particular, aggregated information on the data you enter on our Website (for example, we know how many visitors chose lactose-free meal plans) and users’ interactions within the Website. Google allows you to influence the collection and processing of information generated by the Google, in particular, by installing a browser plug-in, available here. You can read more about how google uses information here.

We also use Amplitude, which is an analytics service provided by Amplitude Inc. We use this tool to understand how customers use our Service. Amplitude collects various technical information, in particular, time zone, type of device (phone or tablet), unique identifiers (such as IDFA). Amplitude also allows us to track various interactions (entering your target weight) that occur in our App. As a result, Amplitude helps us to decide what features should we focus on (for example, if we see that most of the users enter target weight, which is lower than their current weight, we may develop more variety of meals for weight-loss. Amplitude is EU-US Privacy Shield certified. Amplitude provides more information on how they process data in its Privacy Policy.

To track and analyze behavior of our Website’s users (in particular, how they react to changes of the Website structure, text or any other component), we use Firebase Remote Config. Firebase Remote Config is an A/B testing and configuration service provided by Google. Privacy Policy and Privacy and Security in Firebase.

We also use Firebase Analytics, which is an analytics service provided by Google. In order to understand Google's use of data, consult Google's partner policy. Firebase Privacy information. Google’s Privacy Policy.

To perform standard product analysis, we also use Fabric Answers, which is an analytics service provided by Crashlytics, a business division of Google. Data Processing and Security Terms. Privacy information.


2.6. To send you marketing communications

We process your personal data for our marketing campaigns. We may add your email address to our marketing list. 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.

We use Leanplum, which is a mobile marketing and analytics platform that allows us to customize and send messages to our users (in particular, via email). Leanplum enables us to choose the categories of users, which will receive such messages. Privacy Policy.


2.7. To personalize our ads

We and our partners, including Facebook and Google, use your personal data to tailor ads and possibly even show them to you at the relevant time. For example, if you have accessed our Website, you might see ads of our products, for example, in your Facebook’s feed.

How to opt out or 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 of 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:

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.

We use Facebook pixel on the Website. Facebook pixel is a code placed on the Website collecting data that helps us track conversions from Facebook ads, build targeted audience and remarket to people who have taken some action on the Website (for example, purchased a meal plan).

We also use Facebook Ads Manager together with Facebook Custom Audience, which allows us to choose audiences that will see our ads on Facebook or other Facebook’s products (for example, Instagram). Through Facebook 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 on the Website. As a result, we may ask Facebook 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 Facebook’s products (for example, Instagram). You may learn how to opt out of advertising provided to you through Facebook Custom Audience here.

Facebook 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 Website (for example, show our ads to users who have purchased a custom meal plan). Some other examples of events that may be used for tailoring ads include, in particular, accessing our Website. This could mean that we advertise to previous visitors who haven’t made certain action on our Service. This remarketing could be in the form of an advertisement on the Google search results page, or a site in the Good Display Network. Third-party vendors, including Google, use cookies to serve advertisements based on someone’s past visits to the Service. 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 Website with the Snapchat advertising network and show some of our ads to them. As a result, you may see more of ads on Snapchat in case you use our Website. Snapchat allows you to Opt Out of their audience based ads. Privacy Policy.


2.8. To process your payments

We provide paid products and/or services within the Service. For this purpose, we use third-party services for payment processing (for example, payment processors). As a result of this processing, you will be able to make a payment for a customized meal plan and we will be notified that the payment has been made and will send you the meal plan.

We will not store or collect your payment card details ourselves. This information will be provided directly to our third-party payment processors. Our payment processors adhere to the standards set by PCI-DSS as managed by the PCI Security Standards Council. Payment processors, who follow PCI-DSS requirements are committed to ensuring the secure handling of payment information.


2.9. To enforce our Terms and Conditions of Use and to prevent and combat fraud

We use personal data to enforce our agreements and contractual commitments, to detect, prevent, and combat fraud. As a result of such processing, we may share your information with others, including law enforcement agencies (in particular, if a dispute arises in connection with our Terms and Conditions of Use).


2.10. To comply with legal obligations

We may process, use, or share your data when the law requires it, in particular, if a law enforcement agency requests your data by available legal means.



3. UNDER WHAT LEGAL BASES WE PROCESS YOUR PERSONAL DATA (Applies only to EEA-based users)

In this section, we are letting you know what legal basis we use for each particular purpose of processing. For more information on a particular purpose, please refer to Section 2. This section applies only to EEA-based users.

We process your personal data under the following legal bases:

3.1. to perform our contract with you;

Under this legal basis we:

  • Provide our Service (in accordance with our Terms and Conditions of Use)
  • Customize your experience
  • Manage your account and provide you with customer support
  • Communicate with you regarding your use of our Service
  • Process your payments

3.2. for our (or others') legitimate interests, unless those interests are overridden by your interests or fundamental rights and freedoms that require protection of personal data;

We rely on legitimate interests:

  • to communicate with you regarding your use of our Service

    This includes, for example, sending you push notifications reminding you to meditate at appropriate times. The legitimate interest we rely on for this purpose is our interest to encourage you to use our Service more often. We also take into account the potential benefits to you, which may lead you to a better and healthier lifestyle.

  • to research and analyze your use of the Service

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

  • to send you marketing communications

    The legitimate interest we rely on for this processing is our interest to promote our Service in a measured and appropriate way.

  • to personalize our ads

    The legitimate interest we rely on for this processing is our interest to promote our Service in a reasonably targeted way.

  • to enforce our Terms and Conditions of Use and to prevent and combat fraud

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

3.3. to comply with legal obligations.



4. WITH WHOM WE SHARE YOUR PERSONAL DATA

We share information with third parties that help us operate, provide, improve, integrate, customize, support, and market our Service. We may share some sets of personal data, in particular, for purposes indicated in Section 2 of this Privacy Policy. The types of third parties we share information with include, in particular:

4.1. Service 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 may share your personal information with the following types of service providers:

  • cloud storage providers
  • data analytics providers
  • measurement partners
  • marketing partners (in particular, social media networks, marketing agencies, email delivery services)

4.2. 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.

4.3. Third parties as part of a merger or acquisition

As we develop our business, we may buy or sell assets or business offerings. Customers’ 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.



5. 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 may review, edit, or change the personal data that you had previously provided in the Website in the settings section of the Website.

You may also request a copy of your personal data collected during your use of the Website at [email protected].

Deleting your personal data. You can request erasure of your personal data by sending us an email at [email protected].

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; in such event, we will fulfill your request after we have complied with our obligations.

Objecting to or restricting the use of your personal data. You can ask us to stop using all or some of your personal data or limit our use thereof by sending a request at [email protected].

Additional information for EEA-based users:

If you are based in the EEA, you have the following rights in addition to the above:

The right to lodge a complaint with supervisory authority. We would love you to contact us directly, so we could address your concerns. Nevertheless, you have the right to lodge a complaint with a competent data protection supervisory authority, in particular in the EU Member State where you reside, work or where the alleged infringement has taken place.

The right to data portability. If you wish to receive your personal data in a machine-readable format, you can send respective request at [email protected].



6. 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 [email protected].



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 Service or by other available means and will have an opportunity to review the revised Privacy Policy. By continuing to access or use the Service after those changes become effective, you agree to be bound by the revised Privacy Policy.



8. CALIFORNIA PRIVACY RIGHTS

California’s Shine the Light law gives California residents the right to 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 statute.

To obtain this information from us, please send an email message to [email protected] which includes “Request for California Privacy Information” on the subject line and your state of residence and email address in the body of your message. If you are a California resident, we will provide the requested information to you at your email address in response.

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.



9. 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 (including providing the Service to you), which includes (but is not limited to) the period during which you have an account with the Website. We will also retain and use your personal data as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.



10. HOW “DO NOT TRACK” REQUESTS ARE HANDLED

This Service does not support “Do Not Track” requests. To determine whether any of the third-party services it uses honor the “Do Not Track” requests, please read their privacy policies.



11. PERSONAL DATA CONTROLLER

BetterMe Limited, a company with registered office at Florinis 7, Greg Tower, 2nd Floor, 1065, Nicosia, Cyprus will be the controller of your personal data.



12. CONTACT US

You may contact us at any time for details regarding this Privacy Policy and its previous versions. For any questions concerning your account or your personal data please contact us at [email protected].

Effective as of: 07 November 2019