State Privacy Notices

State Privacy Notice for California Residents

Last updated March 14, 2024

EXERCISE YOUR CA/WA RIGHTS

We provide this Privacy Notice for California Residents (this “California Notice”) to supplement the information and disclosures contained in our General Privacy Notice. This California Notice applies to all customers, website visitors, and others who reside in the State of California. We adopt this California Notice to comply with the California Consumer Privacy Act (“CCPA”). Any terms defined in the CCPA have the same meaning when used in this California Notice.

California residents have the right to request that a business disclose what personal information it collects, uses, discloses, and sells, as well as other rights described below. The CCPA allows California residents to request that a business that collects consumers’ personal information disclose to consumers the categories of personal information that the business collects from consumers, the business or commercial purposes for collecting the information, and the categories of third parties with which the information is shared. California residents also have the right to submit a “Consumer Request” to a business to request access in a portable and readily usable form (if technologically feasible) to the specific pieces and categories of personal information that the business has collected about the consumer, the business purpose for collecting, sharing or selling their personal information, the categories of third parties to whom the business discloses personal information, to request the deletion or correction of information under certain circumstances, among other rights described below. Also, consumers have the right not to receive discriminatory treatment by a business for the exercise of the privacy rights conferred by the CCPA.

I. Notice at Collection

At or before the time of collection, you have a right to receive notice of our practices, including the categories of personal information and sensitive personal information to be collected and the purposes for which such information is collected or used, whether such information is sold or shared (see directly below), and how long such information is retained. You can find those details in this statement by clicking on the provided links or scrolling below.

II. Sale or Sharing of Personal Information

Note that the CCPA defines “sell,” “share,” and “personal information” very broadly, and some of our data sharing described in our Privacy Notice and this State Privacy Notice may be considered a “sale” or “sharing” under those definitions. As described further below, we let advertising and analytics providers collect identifiers (such as IP addresses, cookie IDs, and mobile IDs), activity data (such as browsing, clicks, app usage), device data, and geolocation data through our website and Services, but do not “sell” or “share” any other types of personal information. If you do not wish for us or our partners to “sell” or “share” personal information relating to your visits to our sites for advertising purposes, you can make your request by using our privacy rights form below, using a Global Privacy Control, or using other controls described in the Your Choices section of our Privacy Notice. If you opt-out using these choices, we will not share or make available such personal information in ways that are considered a “sale” or “sharing” under the CCPA. However, we will continue to make available to our partners (acting as our service providers) some personal information to help us perform advertising-related functions. Further, using these choices will not opt you out of the use of previously “sold” or “shared” personal information or stop all interest-based advertising.

III. Collection of Personal Information

We collect personal information about consumers and in some cases allow third parties to collect personal information on our behalf, such as IP address. In the last twelve months, We have collected the following categories of personal information both online and offline for the business purpose(s) identified below (some categories may overlap):

In the last twelve months, We have disclosed the following categories of personal information with the following categories of third parties (some categories may overlap):

We may combine your personal information that you provide us through our website with other information We have received from you, whether online or offline, or from other sources such as from our service providers. For more information, please see our General Privacy Notice.

V. Data Retention Policy

Unless otherwise required by law, We will retain your personal information to the extent necessary to fulfill the purpose for which that personal information was collected. Please note that We may be required to retain your personal information for a reasonably longer period of time to the extent necessary to comply with regulatory or legal obligations, resolve disputes, enforce our agreements or for any other business purpose in accordance with applicable laws.

We generally retain your personal information based on the following criteria:

1. The length of time We are required to store your personal information based on State and/or Federal law;
2. The period by which We are required to purge your personal information in accordance with State and/or Federal law;
3. Whether the purpose for which the personal information was collected has been fulfilled;
4. Whether the personal information is no longer required for analytics or performance purposes;
5. Whether We have received a valid deletion request from a California resident under applicable law.

VI. Consumer Rights

If you are a California resident, you may exercise certain privacy rights related to your personal information. You may exercise these rights free of charge except as otherwise permitted under applicable law. We may limit our response to your exercise of these privacy rights as permitted under applicable law.

You may submit your request in person, using our toll-free number or via online form. Please see Contact Information below.

1. The Right to Know, Access, Rectify, and/or Delete Personal Information

Where the CCPA applies to the services We provide, you may have the right to know, access, correct, opt-out of the sharing and/or delete personal information about you which We have collected.

The Right to Know/Access: You have the right to know about the information contained in this Notice and our General Privacy Notice, and to request access to a copy of the personal information that We have collected about you directly or indirectly, including personal information collected by a service provider or contractor on our behalf. Generally, you may be able to access your personal information through your online user account if you have created one.

You also have the right to know what personal information the business has collected about you, including:

• The categories of personal information;
• The categories of sources from which the personal information is collected;
• The business or commercial purpose for collecting, selling or sharing personal information;
• The categories of third parties to whom the business discloses personal information; and,
• The specific pieces of personal information the business has collected about the consumer.

The Right to Correct: You have the right to correct inaccurate personal information that We maintain about you. You may access your account through our websites or mobile app and update your personal information. For personal information that cannot be changed via your account or as an alternative means of updating your personal information, you may contact us to request the change – please see Contact Information below. We will use commercially reasonable efforts to honor your requests within the limits defined by applicable law.

The Right to Delete: You have the right to request that We delete the personal information We have collected about you, subject to certain limited exceptions. For example, We may retain an archived copy of your records consistent with applicable law, to continue to provide our services to you, or for other legitimate business purposes.

2. The Right to Opt-out of the Sale or Sharing of Personal Information

You have a right to opt-out of the sale or sharing of your personal information by us, except in certain circumstances as permitted by law.  For information on how to exercise that right, please see the “Sale of Sharing of Personal Information” section above.

3. The Right to Limit the Use of Sensitive Personal Information

We collect, process or disclose sensitive personal information solely to the extent required to comply with legal requirements and as necessary to perform the services or provide the goods that you reasonably expect from us. We do not collect sensitive person information to infer characteristics about you or for the purposes of cross-context behavioral advertising.

4. The Right to Non-Discrimination

We will not discriminate or retaliate against you for exercising your consumer rights under the CCPA/CPRA, including by (a) denying you goods or services; (b) charging different prices or rates for goods or services, including through the use of discounts or other benefits or imposing penalties; or (c) providing you a different level or quality of goods or services (or suggesting that We will do so). We may, however, charge different prices or rates, or provide a different level or quality of goods or services, if there is a legitimate business purpose such as labor, varying product offerings and other commercial reasons.

VII. Your California Privacy Rights

Section 1798.83 of the California Civil Code permits California residents to request from a business, with whom the California resident has an established business relationship, certain information about the types of personal information the business has shared with third parties for those third parties’ direct marketing purposes and the names and addresses of the third parties with whom the business has shared such information during the immediately preceding calendar year. You may make one request each year by contacting us as provided in Section XI, above.

VIII. Processing Your Request

As required or permitted under applicable law, We may take steps to verify your request is not fraudulent before providing personal information to you, deleting personal information, or otherwise processing your request. Such steps may include being asked to verify your ability to control the email address or phone number you have provided to us.

To process your request, you must provide your name, address, your relationship to the business, email address, phone number, and state of residence. If We believe We need further information to verify your identity or as necessary to complete your request (in accordance with applicable laws), We may ask you to provide additional information for these purposes. We will review each request carefully and respond accordingly within the timeframe established by the CCPA/CPRA.

IX. Agent Authorization

You may designate an authorized agent to request any of the above rights on your behalf. You may make such a designation by providing the agent with written permission, signed by you, to act on your behalf. Your agent may contact us as set forth in this Notice. Even if you choose to use an agent, as permitted by law, We may require you to confirm you have authorized the agent to act on your behalf or require you to verify your own identity.

X. Contact Information

If you have questions or comments about this Notice, our privacy policies, the ways in which We collect and use your information, your choices and rights regarding such use, or wish to exercise your rights under California law, please contact us at:

Toll-Free Phone: 833-989-1425

Mail: Keepr
Attn: Legal Dept, Privacy
11035 Aurora Ave
Des Moines, IA 50322

Alternatively, you can submit a CCPA/CPRA request using the form below.

XI. How to Submit a Request

To submit a request under the CCPA, please call our toll-free number: 833-989-1425 or submit a request using our form.
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Consumer Health Data Privacy Notice For Washington Residents

Last updated March 14, 2024 

This Consumer Health Data Privacy Notice supplements the Keepr Privacy Notice and applies to personal data defined as “consumer health data” subject to the Washington My Health My Data Act (MHMDA).

I. Consumer Health Data We Collect

As described in the Information We Collect section of the Privacy Notice, the data We collect depends on how you interact with us, the services you use, and the choices you make. Because consumer health data is defined very broadly, some of the categories of data We collect could be considered consumer health data.

Such data may be categorized as follows:

• Measurements of bodily functions, vital signs, or characteristics, such as blood alcohol levels. We may also collect photographs, which may also be considered biometric information under the MHMDA.
• Precise location information that could reasonably indicate your attempt to acquire or receive health services or supplies. For example, we may collect GPS location data that could reveal your location being adjacent to or at a health care facility.
• Information that could identify your attempt to seek health care services or information, including services that allow you to assess, measure, improve, or learn about your or another person’s health. For example, if you request to share information with a health care provider, that could reveal the types of health or wellness care or services you are seeking.
• Other information that may be used to infer or derive data related to the above or other health information.

II. Sources of Consumer Health Data

As described further in the Information We Collect section of the Privacy Notice, We collect personal data (which may include consumer health data) directly from you, from your interactions with our products and services, from third parties, and from publicly available sources.

III. Why We Collect and Use Consumer Health Data

We collect and use consumer health data for the purposes described in the How We Use Your Information section of the Privacy Notice. Primarily, We collect and use consumer health data as reasonably necessary to provide you with the Services you have requested or authorized. This may include delivering and operating the Services and their features, personalization of certain features, enabling you to disclose your information to third parties that you authorize, ensuring the secure and reliable operation of the Services and the systems that support them, troubleshooting and improving the Services, and other essential business operations that support the provision of the products (such as analyzing our performance, meeting our legal obligations, developing our workforce, and conducting research and development).

We may use consumer health data for other purposes for which We give you choices and/or obtain your consent as required by law – for example, for advertising or marketing purposes. See the Your Choice Regarding Your Information section of the Privacy Notice and the How to Exercise Your Rights section below for more details on the controls and choices you may have. 

We may share each of the categories of consumer health data described above for the purposes described in the How Your Information Is Disclosed section of the Privacy Notice. In particular, We may share personal data, including consumer health data, with your consent or as reasonably necessary to complete any transaction or provide any Services you have requested or authorized, as described in the previous section above.

For example, We share your information with third parties when you tell us to do so, such as when you direct us to provide reports to third parties or when you would like to provide those reports yourself. If you make a purchase, We will share information about the transaction as necessary to process the payment, including protection against fraud. And We may disclose data when We believe that doing so is necessary to comply with applicable law or respond to valid legal process.

V. Third Parties with Which We Share Consumer Health Data

As necessary for the purposes described above, We share consumer health data with the following categories of third parties:

• Service providers. Vendors or agents (“processors”) working on our behalf may access consumer health data for the purposes described above. For example, companies we’ve hired to provide customer service support or assist in protecting and securing our systems and services may need access to data to provide those functions. 
• Business partners. We may share consumer health data with other companies, for example, where you use a service that is cobranded and jointly operated with another company, or where you use the Services to interact with another company.
• Financial institutions & payment processors. When you make a purchase or enter into a financial transaction, We will disclose payment and transactional data to banks and other entities as necessary for payment processing, fraud prevention, credit risk reduction, analytics, or other related financial services.
• Parties to a corporate transaction. We may disclose consumer health data as part of a corporate transaction or proceeding such as a merger, financing, acquisition, bankruptcy, dissolution, or a transfer, divestiture, or sale of all or a portion of our business or assets.
• Affiliates. We enable access to data across our subsidiaries, affiliates, and related companies, for example, where We share common data systems or where access helps us to provide our services and operate our business. A list of specific affiliates is available here.
• Government agencies. We will disclose consumer health data to law enforcement or other government agencies when We believe doing so is necessary to comply with applicable law or respond to valid legal process.
• Other third parties. In certain circumstances, it may be necessary to provide data to other third parties, for example, to comply with the law or to protect our rights or those of our customers.
• Other users and individuals. If you use our services to interact with other users of the service or other recipients of communications, We will share data, including consumer health data, as directed by you and your interactions.

VI. How to Exercise Your Rights

MHMDA provides certain rights with respect to consumer health data, including rights to access, delete, or withdraw consent relating to such data, subject to certain exceptions. You can request to exercise such rights using the various tools and mechanisms described in the Your Choices Regarding Your Information section of the Privacy Notice or by using our web form.

If your request to exercise a right under the MHMDA is denied, you may appeal that decision by contacting our privacy support team via our web form. If your appeal is unsuccessful, you can raise a concern or lodge a complaint with the Washington Attorney General at https://www.atg.wa.gov/file-complaint.

VII. Contact Information

If you have questions or comments about this Notice, our privacy policies, the ways in which We collect and use your information, your choices and rights regarding such use, or wish to exercise your rights under Washington law, please contact us at:

Toll-Free Phone: 833-989-1425

Mail: Keepr
Attn: Legal Dept, Privacy
11035 Aurora Ave
Des Moines, IA 50322