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Oji Life Lab Privacy Policy

Effective Date of Current Policy: December 6, 2018

Your privacy is very important to us and our general policy is simple: we don’t use or share any of your Personal Information except in certain limited ways as detailed in this Privacy Policy. This Privacy Policy explains how Oji Life Lab, Inc. together with our affiliates (“Oji”, “we”, or “us”) collect, use, share, and protect your Personal Information. This Privacy Policy supplements and forms a part of the Oji Life Lab Terms of Service ojilifelab.com/terms.html (the “Terms”). Capitalized terms not defined in Section 15 or otherwise in this Privacy Policy have the meaning given to them in the Terms.

Creating a safe and trustworthy environment within our Services where you feel comfortable expressing yourself is of paramount importance to use. So, here’s our promise to you:

  • All information that you provide while working independently in the App or during the one-on-one chat or video session with a Coach such as description of your response in a given situation (collectively, “Confidential Private Information”) is your information; you alone own it.
  • We will never sell your Confidential Private Information to anyone; we will only access and share your Confidential Private Information to provide and improve our Services as mentioned below and in the Terms. (For more information on how we treat your Confidential Private Information, please visit our Terms available at ojilifelab.com/terms.html).
  • We will never sell any of your Personal Information that can identify you.
  • Individual reports about your emotional intelligence learning and progress with identifiable data is for your eyes only; it will never be shared with your employer or anyone else without your permission.
  • Any reports that we prepare for employers will be a compilation of aggregate data of many participants like you, will be completely anonymized, and will never identify you.
  1. WHAT IS THE SCOPE OF THIS PRIVACY POLICY?

    This privacy policy applies to Personal Information processed by us in our business, including on our websites (each a “Site”), mobile application (the “App”), forums, blogs, and our online and offline service offerings (collectively, the “Services”). All those Processing Personal Information for us are expected to comply with this Privacy Policy.

  2. WHAT PERSONAL INFORMATION DO WE COLLECT?

    We mainly collect information in two ways: (i) information that you voluntarily provide to us when interacting with the Services, and (ii) information that we automatically collect as you navigate the Services; for example via cookies.

    • Information You Provide Directly to Us. When you use the Services, contact us directly, or engage in certain activities, such as registering for an Account with Oji or using our Services or Tools, we may collect following types of information:

      • Account Information. If you create an Account, we’ll collect certain Personal Information that can be used to identify you, such as your name, email address, and any other information collected as part of the registration process.

      • Payment Information. When you choose to purchase Services from us, we, or our third party payment processor, will collect your payment information such as your name, email address, mailing address, phone number, credit card number and/or bank account information and other related information that may be required to complete your purchase (“Financial Information”).

      • Public User Profiles. When you use our Services you may be given the opportunity to create a “User Profile” and when you do so we may ask you to provide certain information about yourself including your Personal Information.

      • Information that you Voluntarily Provide to the Services. You control what information including, any Personal Information or Sensitive Information (defined in Section 15), you provide while using the various Tools we offer. We will collect the information that you share through the Services (including Personal Information and Sensitive Information). For example, you may respond to questions that we may ask about your emotional status in a particular situation with text that reveals your Personal Information (e.g. volunteering your home address to explain some situation, or your political opinion when explaining something that made you exasperated), or recording a video of yourself and others while using the video feature of the Services. Similarly, we will record any information you provide via the live video sessions and chat sessions offered by our Services. We may use these recordings for internal learning, quality assurance, and otherwise improving our Services. So please use discretion when providing information about yourself. Please know, however, that your ability to communicate freely is extremely important to us. To that end, we will never share any Confidential Private Information that you communicate with us via the Services except for the limited purposes provided in this Privacy Policy and our Terms.

      • Communications with Us. We may collect Personal Information from you such as email address, phone number or mailing address when you choose to request information about our Services, request to receive customer or technical support or otherwise communicate with us.

      • Surveys. We may contact you to participate in surveys. If you decide to participate, we may ask you for certain information which may include Personal Information.

      • Posting on the Oji Services. We may offer forums, blogs, social media pages, or group sessions. Any content you provide in a group session will be available to all participants of that session including the Coach facilitating the session and other participants like yourself; and any content you provide on the blogs, social media and other public forums will be considered “public” and is not subject to privacy protections. So please use discretion when posting anything on such platforms.

      • Registration for Sweepstakes or Contests. We may run sweepstakes and contests. Contact information you provide may be used to reach you about the sweepstakes or contest and for other promotional, marketing and business purposes, if permitted by law. In some jurisdictions, we are required to publicly share information of winners.

    • Automatic Data Collection. We may collect certain information automatically when you use the Services. This information may include your Internet protocol (IP) address, user settings, IMEI, MAC address, cookie identifiers, mobile carrier, mobile advertising and other unique identifiers, details about your browser, operating system or device, location information, Internet service provider, pages that you visit before, during and after using the Services, information about the links you click, and other information about how you use the Services. Information we collect may be associated with accounts and other devices. We also automatically collect some information regarding your use of the Services by placing cookies and other technologies on our Site. For more information on Cookies, please see Section 5 below.

      • Information sent by Mobile and other Devices. From time to time, Oji may provide Services that are specifically designed to be compatible and used on third party devices, such as mobile phones, smart TVs, and tablets. Oji will collect certain information that your device sends when you use such Services, like a device identifier, user settings, location information, carrier and the operating system of your device.

      • Information from Other Sources. We may receive information about you from other sources, including through third-party services and organizations, to supplement information provided by you. For example, if you access our Services through a third-party application, such as the Apple App Store or Google Play App Store (together with any similar applications, “App Stores”) we may collect information such as, your name, user name, location, sex, birth date, email and profile picture through these App Stores. This supplemental information allows us to verify information that you have provided to Oji and to enhance our ability to provide you with information about our business, products and Services.

  3. HOW DO WE USE YOUR INFORMATION?

    Our primary goals in collecting Personal Information are to provide and improve our Services, to administer your use of the Services (including your Account, if you are an Account holder), and to enable you to enjoy and easily navigate our Services. We may Process your Personal Information for a variety of business purposes, including:

    • To Provide Services. Oji may use your information to provide Services, to fulfill requests for Services (including future products or Services), and managing your Account including, to:

      • provide and improve Services, for internal learning and quality control, and to communicate with you;
      • provide technical support or customer support in relation to the Services, and troubleshoot problems;
      • manage your information and Accounts;
      • respond to questions, comments, and other requests;
      • provide access to certain areas, functionalities, and features of Oji’s Services; and
      • allow you to register for various Tools (including live sessions, chat sessions, etc.) and events.
    • Administrative Purposes. Oji may use Personal Information about you for its administrative purposes, including to:

      • measure interest in Oji’s Services including, interest in the various features;
      • develop new products and Services;
      • ensure internal quality control;
      • verify your identity, your Account, and for fraud prevention;
      • communicate about your Account, activities on our Site and Services and systems, and any Oji policy changes;
      • Account management, customer service or system maintenance;
      • process payment transactions (including via our third-party payment processors);
      • prevent potentially prohibited or illegal activities;
      • enforce our Terms, and send you notices (including push notifications) and alerts;
      • network and information security;
      • comply with the law; and
      • any other legitimate purpose.
    • Marketing Oji Products and Services. We may use Personal Information to provide you with materials about offers, products and services that may be of interest to you including:

      • To tailor content, advertisements and offers;
      • To notify you about offers, products and services that may be of interest to you or about which you have previously expressed an interest;
      • Other purposes disclosed to you, or that you consent to, when you provide Personal Information.

      You may contact us at any time to opt-out of the use of your Personal Information for marketing purposes, as further described in Section 7 below.

    • Research and Development. We may use Personal Information to create non-identifiable information that we may use alone or in the aggregate with information obtained from other sources, in order to help us to optimally deliver our existing Services or develop new products and services. From time to time, we may perform research (online and offline) via surveys. We may engage our academic research partners and third-party service providers to conduct such surveys on our behalf. All survey responses are voluntary, and the information collected will be used for research and reporting purposes to help us better serve our customers by learning more about their needs and the quality of the products and services we provide. De-identified or aggregated information is not Personal Information, and we may use such information in a number of ways, including research, internal analysis, analytics, and any other legally permissible purposes.

    • Reports for Employers. We may compile our users’ responses to our questions and surveys to create statistical and aggregate reports (“Reports”) that we can share with our customers. Your responses to a survey will only be used along with that of other study participants ensuring complete anonymity.

    • Services via Apps and other Devices. Information such as device identifier, user settings, location information, carrier and the operating system of your device that your device sends when using the Services is collected for the following purposes. These versions of our Services may require that users log in with an Account. In such cases, information about use of these versions of the Services may be associated with the Accounts. In addition, we may enable you to download an application, widget or other tool that can be used on mobile, tablet or other devices. Some of these tools may store information on your devices. These tools may transmit Personal Information to us to enable you to access Accounts and to enable us to track use of these tools. Some of these tools may enable users to export reports and other information from the tool. We may use personal or non-identifiable information transmitted to us to enhance these tools, to develop new tools, for quality improvement and as otherwise described in this Privacy Policy.

    • Anonymous and Aggregated Information Use. We may use Personal Information and other information about you to create de-identified and aggregated information, such as de-identified demographic information, de-identified location information, information about the computer or device from which you access our Site and Services, or other analyses we create. De-identified or aggregated information is not Personal Information, and we may use such information in a number of ways, including research, internal analysis, analytics, and any other legally permissible purposes, and may share this information with third parties as we deem fit.

  4. WITH WHOM DO WE SHARE YOUR INFORMATION?

    We may share your Personal Information as follows:

    • Vendors and Service Providers. We may share your information with our vendors and service providers who help us provide and manage our Services. For example, we may share your information with providers of IT, web hosting, and related services, or with our third party payment processors, and other service providers that help us with the provision of the Site and Services.

    • Internal Staff. We may share your Personal Information (including your chat sessions or recordings of your video sessions with Coaches and Reports) with our internal staff for the purposes of internal learning, quality assurance Account management, and providing and improving our Services. These internal staff personnel are legally obligated to maintain confidentiality of your information.

    • Coaches. We offer Tools that allow you to share your responses with either only the Coaches, or with the entire community of our Services including other users of our Services, the Coaches, and internal staff (collectively, “Life Lab Community”). You have 100% control over what you want to share and with whom, and we will share only those of your responses that you ask us to share with the Coaches, or with the Life Lab Community by clicking on the “Share” option on the Services. This is to provide the Coaches proper context and background before they chat with you or have a live session with you, so you can have a more meaningful conversation. We will also share recordings of the chat sessions and live group sessions with Coaches. We will not attach your Personal Information (like name or email address) with your video recording or video session in order to protect your identity (unless you volunteer that information yourself in the live sessions).

    • Researchers (Only on Anonymous Basis). We may share Reports which may contain your de-identified and aggregated information and responses to the surveys in an aggregated, statistical or analytical format with internal and external researchers to improve our Services, for general research and analysis, and for developing future products and services. None of the information shared will identify you or reveal any of your Personal Information.

    • Our Customers/Your Employer (Only on Anonymous Basis). We will share the Reports that only contain de-identified and aggregate data with our customers who, if you’re an Employee, might be your Employer (as these terms are defined in the Terms). These Reports will represent the average and aggregated emotional status of many employees taken together and show overall progress of the program. The Reports will never identify you, or reveal any of your Personal Information, and will always preserve anonymity.

    • Life Lab Community (Only If You Ask Us to Share). We will share only those of your responses that you ask us to share with the Life Lab Community by clicking on the “Share” button on the Services.

    • Live or Video Group Session. Needless to say, whatever information you share in a live or video group session will be disclosed to the Coach facilitating the session as well as other participants in the group session. Please note that while we strive to emphasize the importance of confidentiality to everyone participating, we do not control any of the participants, like yourself. Hence, we cannot promise any confidential treatment or privacy of whatever you share in such group sessions.

    • Friends or Colleagues. We may from time to time, offer Tools that allow you to forward or share certain content with a friend or colleague, such as an email inviting your friend and/or colleague to use our Services. Email addresses that you may provide for a friend or colleague will be used to send your friend or colleague the content or link you request, but will not be collected or otherwise used by Oji or any other third parties for any other purpose.

    • Business Partners. We may share your Personal Information with our affiliates and business partners for our and their internal business purposes, to provide Services you have requested, or to jointly offer products or services. In such cases, our business partner’s name will appear along with ours. Please note, we will not share any of your Confidential Private Information with any of our Business Partners.

    • Disclosures to Protect Us or Others. We may access, preserve, and disclose your Personal Information and other Account information, and content if we believe doing so is required or appropriate to: (i) comply with law enforcement or national security requests and legal process, such as a court order or subpoena; (ii) respond to your requests; (iii) protect your, our or others’ rights, property, or safety; (iv) to enforce our policies or contracts; (v) when we believe disclosure is necessary or appropriate to prevent physical harm or financial loss or in connection with an investigation or prosecution of suspected or actual illegal activity; or (vi) if we, in good faith, believe that disclosure is otherwise necessary or advisable.

    • Merger, Sale, or Other Asset Transfers. If we are involved in a merger, acquisition, financing due diligence, reorganization, bankruptcy, receivership, purchase or sale of assets, or transition of service to another provider, then your information may be sold or transferred as part of such a transaction to the extent permitted by law.

    • Information Posted on our Blogs and Community Forums. If you post any of your Personal Information on any publicly accessible blogs, forums, or social media pages, that may be provided by the Services, you assume the risk that the Personal Information provided by you may be viewed and used by third parties for any number of purposes.

  5. COOKIES, PIXEL TAGS/WEB BEACONS, ANALYTICS INFORMATION, AND INTEREST-BASED ADVERTISING

    We, as well as third-parties that provide content, advertising or other functionality on our Services, may use cookies, pixel tags, local storage and other technologies (“Technologies”) to automatically collect information through the Services. We use Technologies that are essentially small data files placed on your computer, tablet, mobile phone or other devices that allow us to record certain pieces of information whenever you visit or interact with our Site, Services, Apps, messaging, and Tools, and to recognize you across devices.

    • Cookies. Cookies are small text files placed in visitors’ computer browsers to store their preferences. Most browsers allow you to block and delete cookies. However, if you do that, the Site may not work properly.

    • Pixel Tags/Web Beacons. A pixel tag (also known as a web beacon) is a piece of code embedded on the Site that collects information about users’ engagement on that web page. The use of a pixel allows us to record, for example, that a user has visited a particular web page or clicked on a particular advertisement.

    • Social Media Widgets: The Site may include social media features such as links to Facebook, Instagram, Twitter, YouTube and LinkedIn (that might include widgets, such as, the share this button or other interactive mini-programs). These features are generally hosted by a third party and they may collect your IP address, which page you are visiting on the Site and may set a cookie to enable the feature to function properly. Your interactions with these features are governed by the privacy policy of the company providing it.

    • Analytics. We use various analytics services such as Google Analytics to collect information regarding visitor behavior and visitor demographics on some of our Services. This analytics data is not tied to any Personal Information. For more information about Google Analytics, please visit google.com/policies/privacy/partners/. You can opt-out of Google’s collection and Processing of data generated by your use of the Services by going to tools.google.com/dlpage/gaoptout. In addition, you can opt out of collection of such data by most of these analytics services by accessing the link described in Section 7 below (What Choices Do You Have Re. Processing of Your Information?- Cookies and Interest-Based Advertising).

    We use such Technologies for these purposes:

    • Operationally Necessary. This includes Technologies that allow you access to our Site, Services, Apps, and tools that are required to identify irregular site behavior, prevent fraudulent activity and improve security or that allow you to make use of our functions such as saved searches, or similar functions;

    • Performance Related. We may use Technologies to assess the performance of our Services, including as part of our analytic practices to help us understand how our visitors use the Services and so we can improve our Services;

    • Functionality Related. We may use Technologies that allow us to offer you enhanced functionality when accessing or using our Site and Services. This may include identifying you when you sign into our Site or Services or keeping track of your specified preferences, interests, or past items viewed;

    • Advertising or Targeting Related. We may use first party or third party Technologies to deliver content, including ads relevant to your interests, on our Site and Services or on third party sites.

      If you would like to opt-out of the Technologies we employ on our Sites, Services, or Apps, you may do so by blocking, deleting or disabling them as your browser or device permits, but in that case you may not be able to use all many features of our Services.

  6. INTERNATIONAL DATA TRANSFERS

    All information Processed by us may be transferred, Processed, and stored anywhere in the world- the European Union, the United States or other countries. Personal Information may be stored in the cloud, on our servers, on the servers of our affiliates or the servers of our service providers. Accordingly, Your Personal Information may be transferred to, and maintained on, computers located outside of your state, province, country or other governmental jurisdiction where the privacy laws may not be as protective as those in your jurisdiction.

  7. WHAT CHOICES DO YOU HAVE RE. PROCESSING OF YOUR INFORMATION?

    • General. You may opt out of collection and uses of certain types of Personal Information, or even withdraw your previously provided consent at any time and prevent further Processing by contacting us as described below. Please note, however, that the opt out does not apply to, and we may still collect and use, any non-Personal Information regarding your activities on our Site, Services and/or information from the advertisements on third party websites for other legal purposes as described above.

    • Email, Text, and Telephone Communications. We may periodically send you free newsletters and e-mails that directly promote our Services. When you receive such promotional communications from us, you will have the opportunity to use the unsubscribe link found at the bottom of the email to opt out of receiving future emails. Note that you will continue to receive transaction-related emails regarding Services you have requested, and you will not be able to opt out of those communications (e.g., communications regarding the Services, your Account, or updates to our Terms or this Privacy Policy).

    • Mobile Devices. We may occasionally send you push notifications through our Apps with updates, information, and other notices that may be of interest to you. You may at any time opt-out from receiving these types of communications by changing the settings on your device.

    • Do Not Track”. Do Not Track (“DNT”) is a privacy preference that users can set in certain web browsers. Sorry- we do not respond to or honor DNT signals or similar mechanisms transmitted by web browsers.

    • Cookies and Interest-Based Advertising. You may stop or restrict the placement of Technologies on your device or remove them by adjusting your preferences as your browser or device permits. You may opt out of receiving targeted ads from data partners and other advertising partners that participate in self-regulatory programs via the following links: www.aboutads.info/choices/, www.networkadvertising.org/managing/opt_out.asp, http://www.youronlinechoices.eu/, and https://youradchoices.ca/choices/.

      Please note you must separately opt out in each browser and on each device. Advertisements on third party websites that contain the AdChoices link may have been directed to you based on information collected by advertising partners over time and across websites. These advertisements provide a mechanism to opt out of the advertising partners’ use of this information for interest-based advertising purposes.

  8. WHAT ARE YOUR RIGHTS OF ACCESS, RECTIFICATION, ERASURE, AND RESTRICTION?

    In accordance with applicable law, you may have the right to: (i) request confirmation of whether we are Processing your Personal Information; (ii) obtain access to or a copy of your Personal Information; (iii) receive an electronic copy of Personal Information that you have provided to us, or ask us to send that information to another entity (the “right of data portability”); (iv) restrict our uses of your Personal Information; (v) seek correction or amendment of inaccurate, untrue, incomplete, or improperly Processed Personal Information; and (vi) request erasure of Personal Information held about you by Oji, subject to certain exceptions prescribed by law. If you would like to exercise any of these rights, please contact us as set forth below.

    We will process such requests in accordance with applicable laws. To protect your privacy, Oji will take steps to verify your identity before fulfilling your request.

  9. UNTIL WHEN DO WE RETAIN YOUR DATA?

    Oji retains the Personal Information we receive as described in this Privacy Policy for as long as you use our Services or as necessary to fulfill the purpose(s) for which it was collected, provide our Services, resolve disputes, establish legal defenses, conduct audits, pursue legitimate business purposes, enforce our agreements and comply with applicable laws.

  10. SECURITY OF YOUR INFORMATION

    We take steps to ensure that your information is treated securely and in accordance with this Privacy Policy. Unfortunately, the Internet cannot be guaranteed to be 100% secure, and we cannot ensure or warrant the security of any information you provide to us. To the fullest extent permitted by applicable law, we disclaim liability for unintentional disclosure.

    We may communicate with you electronically regarding security, privacy, and administrative issues relating to your use of the Services. If we learn of a security system’s breach, we’ll attempt to notify you electronically by posting a notice on the Services, by mail or e-mail.

  11. CHILDREN’S PRIVACY

    The Site and Services are not directed to children under 13 (or other age as required by local law), and we do not knowingly collect Personal Information from children. If you learn that your child has provided us with Personal Information without your consent, you may contact us as set forth below, and we’ll promptly take steps to delete such information and terminate the child’s account.

  12. CALIFORNIA PRIVACY RIGHTS

    California law permits users who are California residents to request and obtain from us once a year, free of charge, a list of the third parties to whom we have disclosed their Personal Information (if any) for their direct marketing purposes in the prior calendar year, as well as the type of Personal Information disclosed to those parties. Except as otherwise provided in this Privacy Policy, Oji does not share Personal Information with third parties for their own marketing purposes.

  13. REDRESS/COMPLIANCE AND ACCOUNTABILITY

    If you have any questions about our privacy practices, this Privacy Policy, or how to submit a complaint with the appropriate authority, please contact Oji by email at support@ojilifelab.com or by mail at the below address. We will address your concerns and attempt to resolve any privacy issues in a timely manner. If you are located in the European Economic Area, you have the right to lodge a complaint with a supervisory authority if you believe our Processing of your Personal Information violates applicable law.

    Oji Address: One Embarcadero Center, #26072 San Francisco, CA 94126

  14. CHANGES TO OUR PRIVACY POLICY AND PRACTICES

    We may revise this Privacy Policy from time to time in our sole discretion. If there are any material changes to this Privacy Policy, we will notify you as required by applicable law, by posting the updated Privacy Policy on our Services or other communication to you, and updating the “Effective Date” above. You understand that the new Privacy Policy will apply if you continue to use the Services after such notification.

    Please note that before we use any of your Personal Information that we have already collected for any new purpose not originally notified to you, or authorized by you, we will give you the opportunity to opt-out of such use.

  15. DEFINITIONS

    The following capitalized terms have the meanings set forth below.

    • Account” means the account that users create by registering into the Services, in order to use certain features of the Services.

    • Coach” means an Oji employee or consultant who is appropriately trained by Oji to provide consultation to users on the topics that the Services explore, and serves as an advisor, trainer, and facilitator in conversations with the users, whether during one-on-one chat, video sessions, or group sessions.

    • Personal Information” is any information relating to an identified or identifiable natural person (“Individual”).

    • Process” or “Processing” means any operation which is performed upon Personal Information, whether or not by automatic means, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure, or destruction.

    • Sensitive Data” or “Sensitive Personal Information” is a subset of Personal Information which, due to its nature, has been classified by law or by policy as deserving additional privacy and security protections. Sensitive Personal Information includes, certain Financial Information, and Personal Information regarding EU residents that is classified as a “Special Category of Personal Data” under EU law, which consists of the following data elements: (1) race or ethnic origin; (2) political opinions; (3) religious or philosophical beliefs; (4) trade union membership; (5) genetic data; (6) biometric data where Processed to uniquely identify a person; (6) health information; (7) sexual orientation or information about the Individual’s sex life; or (8) information relating to the commission of a criminal offense.

    • Tool” means an application or feature within the Services that allows users to interact with the Services in a certain way. Examples include, features such as video capability to allow users to record video and send to Services in response to the questions, or the ability to join one-on-one or group video session and discussion.