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Privacy

Website Privacy Statement
US: Medical P.C. Privacy StatementUS: HIPAA Notice of Privacy PracticesInternational: Coaching Privacy StatementPrivacy Notice for California ResidentsCookie Statement

Ginger.io Coaching Services LLC

Privacy Statement

Effective Date: September 1, 2022

INTRODUCTION

Ginger.io Coaching Services LLC (“Ginger” or “we”) has prepared this Privacy Statement to inform recipients of our coaching services (“user” or “you”) about how we collect, use and disclose their personally identifiable information (“Personal Information”).  To receive coaching services from us, you must download the Ginger mobile application (the “App”). 

BY REGISTERING FOR AND RECEIVING OUR COACHING SERVICES, YOU ACKNOWLEDGE THAT YOU HAVE READ AND UNDERSTAND THIS PRIVACY STATEMENT, AGREE TO BE BOUND BY OUR TERMS OF SERVICE, AND CONSENT TO THE COLLECTION, USE AND DISCLOSURE OF YOUR PERSONAL INFORMATION AS SET OUT IN THIS PRIVACY STATEMENT.  

WHAT INFORMATION DO WE COLLECT?

We may collect the following types of Personal Information in connection with our delivery of coaching services to you:

  • When you register to receive coaching services from us, whether in your individual capacity or on behalf of an organization, we collect any Personal Information that you submit through our registration form, including your name, email address, mailing address, phone number, payment card information, and any other Personal Information you voluntarily submit through the online registration form (your “Account Data”).
  • When we provide our coaching services to you, we collect any Personal Information that you voluntarily provide to us and our coaches, including information about your personal goals and circumstances (your “Coaching Data”).
  • When you use the App, we automatically collect information about your device and how and when you use our application, including the manufacturer and model of the device, unique device identifiers, and IP address (“Mobile Data”). 
  • If you use the App to respond to our surveys and questionnaires, we collect the information you voluntarily provide in your responses (your “Survey Data”).

We may also collect Personal Information that you voluntarily provide to us when you contact us with a question or comment about our services.

HOW DO WE USE INFORMATION WE COLLECT?

PERSONAL INFORMATION

We use your Personal Information to provide and optimize the App and our coaching services.  In particular, we use:

  • Account Data to manage your account, communicate with you in relation to your account, process your transactions, and deliver and monitor the performance of our services;
  • Coaching Data to understand your personal objectives and circumstances, help you develop and execute strategies to overcome your challenges and achieve your goals, evaluate the quality and progress of our coaching program, and optimize our coaching services;
  • Mobile Data to monitor and enhance the performance of the App, analyze trends, usage and activities in connection with the App, and ensure its technological compatibility with users;
  • Survey Data to provide insight to your coach about your personal circumstances and to receive feedback on the quality of our services.

We also use the Personal Information you provide us to respond to your comments and questions and personalize our services for you. 

We may use your Personal Information to provide you with product information and marketing communications.  We will only do so with your consent and as permitted by law.  

AGGREGATE INFORMATION

We create statistical, aggregate data (“Aggregate Information”) about our user base for analytical purposes. Aggregate Information includes data derived from Personal Information and obtained by us from other sources in aggregated, anonymous form.  Aggregate Information cannot reasonably be used to identify any individual.  

LEGAL EXCEPTIONS

Under certain circumstances, Personal Information may be subject to disclosure pursuant to judicial or other government subpoenas, warrants, or orders. As such, notwithstanding the above, we may in any event use Personal Information to the extent required or permitted by applicable law to resolve disputes, to enforce our agreements (including the Terms of Service) with you, or as reasonably necessary to protect our legal rights, to protect you against self-harm, or to protect third parties.

WHAT INFORMATION DO WE DISCLOSE TO THIRD PARTIES?

We will not disclose your Personal Information to any third party except as follows:

  • We may disclose your Personal Information to third parties who provide services on our behalf, such as managing our accounts, processing transactions, operating the App, or providing customer service. We enter into confidentiality agreements with such providers which require them to use the Personal Information they receive only to perform services for us.
  • Subject to applicable law, we may disclose your Personal Information to any law enforcement, judicial authority, or governmental or regulatory authority, to the extent required by law or if in our reasonable discretion disclosure is necessary to enforce or protect our legal rights, to protect you, or to protect others.
  • In the event of a reorganization, merger, acquisition, asset sale or similar transaction, we may transfer any and all Personal Information we collect to the relevant third party involved in the transaction, with your consent if and as required under applicable privacy laws.
  • We may otherwise disclose your Personal Information when we have your prior consent to share the information. In such cases, we will have written contracts in place with the third parties requiring them to comply with terms of confidentiality similar to the applicable terms of this Privacy Statement as well as all applicable statutes, regulations and laws pertaining to the protection of such Personal Information.
  • We may share Aggregate Information with third parties where permitted by applicable law.

INFORMATION SECURITY

We have implemented technical and organizational security measures to protect the security and integrity of your Personal Information in accordance with this Privacy Statement and applicable law.  Such measures include restricting access to Personal Data on a “need-to-know” basis and an Information Security Management System (ISMS) aligned with ISO 27001 and 27002, We secure information using industry standard administrative, physical, and technical safeguards including encryption of information that is stored and transmitted.   

While we endeavour to always protect our systems, sites, operations and information against unauthorized access, use, modification and disclosure, it is important for you to know that, despite using these current industry-recommended practices, we cannot guarantee against breaches in security.

You have an important role in protecting Personal Information. You are responsible for maintaining the security of your login ID, password, and mobile device. If you believe that your login ID, password, or mobile device may have been compromised, you should immediately change your password and contact our support services. We are not responsible if someone else accesses your account through information they have obtained from you or through a violation by you of the Terms of Service.

LINKS

The App may contain links to other websites. Ginger  is not responsible for the privacy practices or the content of those websites. Users should be aware of this when they leave our Service and are encouraged to review the privacy statements of each third party website. This Privacy Policy applies solely to information collected by Ginger.

CHILDREN

Ginger does not knowingly collect or maintain personally identifiable information from persons under 13 years of age.  Individuals under the age of 18 must receive consent from their parent or guardian in order to access Ginger Services.

ACCESSING AND UPDATING YOUR INFORMATION

You have the right to review, amend, or correct your Account Data or other Personal Information held in our database. 

Subject to certain exceptions, you have the following rights:

  • to request a copy of your Personal Information
  • to have us correct or amend any inaccurate Personal Information 
  • to request that we erase Personal Information that we process about you
  • to request that we restrict the processing of your Personal Information 
  • to object to the processing of your Personal Information
  • to send us a complaint regarding our handling of your Personal information.

To exercise these rights please contact us by sending an email to privacy@ginger.io with a clear description of your request. We will respond to try to comply with your request as soon as reasonably practicable and always under the timeframes set forth by applicable laws.

You may have additional statutory rights under applicable regional law.  If you are in the European Economic Area (EEA) you also have the right to request that we transmit your data to another data controller and you have the right to withdraw your consent at any time. You also have the right to lodge a complaint with the local data protection authority if you believe that we have not complied with applicable data protection laws. 

RETENTION OF YOUR DATA

We store your Account Data and Personal Information for as long as we need it to provide you our services, to serve the purpose(s) for which your personal information was processed, or as necessary to comply with our contractual and legal obligations, resolve disputes, or enforce our agreements to the extent permitted by law.

If you would like your Account Data or other Personal Information permanently removed from our database, please contact us at privacy@ginger.io. We will then terminate your account, you will no longer be able to use our services, and you will no longer receive emails from Ginger.  Subject to applicable law and necessary record retention requirements, your identifying Personal Information shall be deleted from our records. Please note that we may need to retain certain information for recordkeeping purposes, to complete any transactions that you began prior to your request, or for other purposes as required or authorized by law.  

CROSS-BORDER TRANSFERS

Your information, including your Personal Information, is processed at our offices and data centers in the United States of America.   In connection with your access and use of our services, your Personal Information will be transferred to and processed in the United States, which may have different privacy protections compared to your jurisdiction, 

If you are located in the European Economic Area (“EEA”), please note that we implement standard contractual clauses approved by the European Commission and take all necessary measures to ensure that transfers of your Personal Information out of the EEA are adequately protected as required by applicable data protection law.

CHANGES

We may modify or amend this Privacy Statement from time to time. If we make any material changes in the way in which Personal Information is collected, used or transferred, this Privacy Statement will be revised to reflect such changes.  We will post the updated Privacy Statement and ask for your consent if legally required.  The effective date appears at the top of this Privacy Statement. 

QUESTIONS

You may contact us  if you have any questions about this Privacy Statement.  Please contact us at privacy@ginger.io or write to us at the following address: Ginger.io Coaching Services LLC, 2415 Michigan Avenue, Santa Monica, California 90404 USA.

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Ginger is a licensed medical provider in the United States. Ginger therapy and psychiatry services as described on the website are available for customers in the United States only. For information about Ginger services outside of the United States, please contact us here.

© 2022 Ginger. All rights reserved.