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EMBR Labs Privacy Policy

Interest Based Ads Disclosure

Our Policy

EMBR Labs (“Company,” “we,” or “us”) respects the privacy of our users. This Privacy Policy (“Policy”) describes how we collect, use, and disclose information in connection with our website, mobile application, and Embr™ Wave device (collectively, the “Services”). By using our Services, you are agreeing to the terms of this Policy.

The personal and other information that we collect about you is controlled by EMBR Labs, which is headquartered in Cambridge, Massachusetts. As described in the section below, entitled “Information for Users from Outside the United States,” the information that we collect through or in connection with the Services may be transferred to and processed in the United States.

What personal and other information we collect about you

EMBR Labs collects both “personal information” and “other information” about users. For purposes of this Policy, “other information” is information that the Company cannot directly associate with a specific person without the aid of additional information. By contrast, “personal information,” is information such as a name or email address that the Company can directly associate with a specific person or entity without additional information. When we combine other information with personal information, we treat all of the combined information as personal information.

Personal information. You can visit the website without submitting any personal information. However, if you use certain features on the website or the Services, we will collect some personal information. Such information could include, for example, your name, email address, physical address, precise geolocation data, payment information, telephone number, gender, height, weight, and date of birth. Our online contact form also contains a “comments” field through which you may submit additional personal information.

We may also receive personal information from your social media or other third-party account provider (such as Facebook, Google, or Twitter) if you log into our Services using your social media account or link your social media or other account to the Services. In those circumstances, we may receive information from the third party, such as your email, username, and certain other information.

We may combine personal information collected through the Services with other information that we or third parties collect about you in other contexts—such as our communications with you via email. We will treat such combined information as personal information and protect it in accordance with this Policy.

Other information. We also collect other information through the Services. Such information may be collected passively using variously technologies, or via submission of data by devices configured to work with the Services. We may use such information to track, for example, your usage of the mobile application and Embr™ Wave device. Other information may be collected in the following ways:

Log data. When you use the Services, we automatically receive and record certain information from your computer, mobile phone, or other devices. This may include data such as your IP address and domain name, the pages you visit or the features you use within the Services, the date and time of your activities on the Services, the files that you download, the URLs from the websites you visit before and after navigating to the Services, your software and hardware attributes (including operating system type and version, app version, device type, and device IDs), your browser type and version, your general geographic location (e.g., your city, state, or metropolitan region), and certain cookie information (see below). To obtain such information, we may use web logs or applications that recognize your computer or device and gather information about its online activity.

Cookies. In providing the Services, we may use cookies. Cookies are small files that are stored on your computer or device by your web browser. Our cookies help provide additional functionality to the Services and help us analyze usage of the Services more accurately. For example, cookies can be used to collect information about your use of the Services during your current session and over time (including the pages you view and the files you download), the operating system and browser type of your computer or other device, your Internet service provider, your domain name and IP address, your general geographic location, the website that you visited before the Services, and the link you used to leave the Services. In addition to the cookies used by EMBR Labs, we may permit third parties to set cookies, as well (see below). If you are concerned about having cookies on your computer, you can set your browser to refuse all cookies or to indicate when a cookie is being set, allowing you to decide whether to accept it. You can also delete cookies from your computer. However, if you choose to block or delete cookies, certain features of the Services may not operate correctly.

Web beacons. The Services or the emails that you receive from us may use an application known as a “web beacon” (also known as a “clear gif” or “pixel tag”). A web beacon is an electronic file that usually consists of a single-pixel image. It can be embedded in a web page or in an email to transmit information, which could include personal information. For example, it allows an email sender to determine whether a user has opened a particular email.

Third-party online tracking and interest-based advertising. We also may partner with certain third parties to collect, analyze, and use some of the information described in this section. For example, we may allow third parties to set cookies or use web beacons on the website or in email communications from us. This information may be used for a variety of purposes, including online interest-based advertising, as discussed below (see the section entitled “Third-party analytics and interest-based advertising”).

How we use the personal and other information that we collect

EMBR Labs uses the information that we collect for a variety of purposes. If we have personal information about you, we may use it, for example: to respond to your questions or requests concerning the Services offered by us or our partners; to fulfill the terms of any agreement you have with us; to fulfill your requests for our services or otherwise complete a transaction that you initiate; to send you information about the Services and other topics that are likely to be of interest to you, including newsletters, updates, or other communications; to deliver confirmations, account information, notifications, and similar operational communications; to improve your user experience and the quality of our products and services; to comply with legal and/or regulatory requirements; and to manage our business.

We use the non-personal information that we collect for such purposes as: counting and recognizing users of the Services; analyzing how the Services are used; improving the Services and enhancing users’ experiences with the Services; creating new products and services or improving our existing products and services; enabling additional website analytics and research concerning the Services; and managing our business. EMBR Labs may link information gathered using cookies and web beacons with personal information. But in that event, we will treat the combined information as personal information.

We also may use the personal and other information that we collect to send you marketing emails and promotional communications, including emails about the products and services offered by us or our partners. To opt-out of these communications, see “Choices and Access to Information” below.

How we share personal and other information with third parties

We share your personal information and other information with other parties for a variety of purposes, as described below.

Affiliates. We may share personal and other information with our corporate affiliates for the purposes described in this Policy.

Third-party service providers and business partners. EMBR Labs uses third-party service providers to help us manage and improve the Services. These service providers may collect and/or use your personal or other information to assist us in achieving the purposes discussed above in the section entitled “How we use the personal and other information that we collect.” For example, we use third parties to help us target and implement our email communications, host our website, collect payment for our products, and manage our information system. We also use third-party platforms to help us manage our relationships with the people and companies that use our services.

We may share your personal or other information with other third parties when necessary to fulfill your requests for services; to complete a transaction that you initiate; to meet the terms of any agreement that you have with us or our partners; or to manage our business.

Your direct sharing of personal information through third-party websites and services. The Services may enable you to directly share personal information with websites or services operated by third parties. For example, the website contains links to third-party websites that incorporate comment and social media features. The website also contains a Facebook “like” button and a Twitter “follow” button. If you choose to use these features, you may disclose your personal information not just to those third-party websites and services, but also to their users and the public more generally. Because these third-party websites and services are not operated by us, we are not responsible for the content or practices of those websites or services. The collection, use, and disclosure of your personal and other information will be subject to the privacy policies of the third-party websites or services, and not this Policy.

Please note that any information and material you post or disclose on message boards, forums, online chat programs, profile pages, and blogs will become public information and may be available to users and to the general public. We urge you to be very careful when deciding to disclose your personal information, or any other information, online.

Surveys. We may ask you to participate in surveys (processed by us or third parties) that help us understand your use of the Services. Any personal or other information provided to EMBR Labs (or supplied by you or EMBR Labs to such third-party survey providers) in connection with these surveys will only be used in relation to that survey and as stated in this Policy.

Third-party plugins. The Services integrate certain third-party plug-ins (such as a Facebook “like” button). Even if you do not click on these plug-ins, they may collect information about you, such as your IP address and the pages that you view. They also may set and/or access a cookie. These plugins are governed by the privacy policy of the company providing them.

Facebook Custom Audiences and Similar Programs. We may partner with Facebook and other social media partners to deliver advertisements to our users via the Facebook Custom Audiences program or a similar third-party program. In order to identify and reach our users on Facebook or another third-party service, we may share information such as an email address or phone number with Facebook or another third-party service. For more information about custom audience targeting and how to adjust your social media advertising preferences, please review the privacy policy of your social media provider.

Legal purposes. We also may use or share your personal or other information with third parties when we believe, in our sole discretion, that doing so is necessary:

· to comply with applicable law or a court order, subpoena, or other legal process;

· to investigate, prevent, or take action regarding illegal activities, suspected fraud, violations of our terms and conditions, or situations involving threats to our property or the property or physical safety of any person or third party;

· to establish, protect, or exercise our legal rights or defend against legal claims; or

· to facilitate the financing, securitization, insuring, sale, assignment, bankruptcy, or other disposal of all or part of our business or assets.

Aggregated information. From time to time, we may also share anonymized and aggregated information about users, such as by publishing a report on trends in the usage of the Services.

Third-party analytics and interest-based advertising

Analytics. We partner with certain third parties to collect information for the purpose of engaging in analysis, auditing, research, and reporting on the Services and to understand the effectiveness of our advertising and email marketing. These third parties may use web logs or web beacons, and they may set and access cookies or use similar tracking technologies on your computer or other device. Among other providers, the Services use Google Analytics to help collect and analyze certain information for the purposes discussed above. You may opt out of the use of cookies by Google Analytics here.

Online interest-based advertising. The Services also enable third parties to collect information through cookies, web beacons, and device identifiers, such as IDFA or Advertising ID, for use in online interest-based advertising. For example, third parties may use the fact that you visited our website or used our app to target online ads for EMBR Labs to you on non-EMBR Labs websites or mobile apps. In addition, we or our third-party advertising networks might use information about your use of the Services to help target non-EMBR Labs advertisements to you on unaffiliated websites or mobile apps based on your online activity in general. For information about behavioral advertising practices, including privacy and confidentiality, visit the Network Advertising Initiative website or the Digital Advertising Alliance website.

We and our third-party providers may use collected information to establish connections among related web browsers and devices (such as smartphones, tablets, and computers) for advertising, analytics, attribution, and reporting purposes. We may match your browsers or devices if you log into the same online service on multiple devices or if your devices share similar attributes that support an inference that they are used by the same person or household. This means that information about your activity on websites or apps on your current browser or device may be combined and used with information collected from your other browsers or devices. For example, we or our third-party providers may use this information to deliver the same ad on multiple devices, to limit the number of times you see an ad across your devices, and to help measure the effectiveness of advertising campaigns across devices.

You may opt out of our third-party service providers’ interest-based advertising practices and cross-device technologies in web browsers and mobile apps by following the instructions below. Please note that the opt-out will apply only to the specific browser or device from which you opt out, and therefore you will need to opt out separately on all of your browsers and devices. If you delete or reset your cookies or mobile identifiers, change browsers, or use a different device, any opt-out cookie or tool may no longer work and you will have to opt out again.

· Web Browser Opt-Out. To opt out in web browsers, please visit:

· Network Advertising Initiative Consumer Opt-Out Page at www.networkadvertising.org/choices

· Digital Advertising Alliance Consumer Choice page at www.aboutads.info/choices

· Digital Advertising Alliance of Canada Consumer Choice page at www.youradchoices.ca/choices

· European Interactive Digital Advertising Alliance Choice page at www.youronlinechoices.eu.

· Mobile Application Opt-Out. To opt out in mobile apps, please download and follow the instructions provided in the Digital Advertising Alliance’s AppChoices tool at www.aboutads.info/appchoices. In addition, some mobile operating systems allow you to opt out by adjusting the advertising preferences on your mobile device. For example:

· In iOS, visit Settings > Privacy > Advertising > Limit Ad Tracking.

· In Android, visit Settings > Google > Ads > Opt out of interest-based ads.

The use of online tracking mechanisms by third parties is subject to those third parties’ own privacy policies, and not this Policy. If you prefer to prevent third parties from setting and accessing cookies on your computer or other device, you also may set your browser to block cookies. Our website currently uses the WorldPress DoNotTrack plugin which will respond to “do not track” browser headers, you can also limit tracking through these third-party programs by taking the steps discussed above.

Security

EMBR Labs uses commercially reasonable physical, electronic, and procedural safeguards to protect your personal information against loss or unauthorized access, use, modification, or deletion. However, no security program is foolproof, and thus we cannot guarantee the absolute security of your personal or other information.

California Residents

If you are a California resident, you have a right to request certain information with respect to the types of personal information we have shared with third parties for their direct marketing purposes, and the identities of those third parties, within the immediately preceding calendar year, subject to certain exceptions. All requests for such information must be sent to [email protected]

This same California law permits us to provide you, in response to your written request, with a cost-free means to choose not to have your information shared rather than providing the above described information. To that end, you may request that we do not disclose your personal information to unaffiliated third parties for their own direct marketing purposes by contacting us by email at [email protected]

If you are a California resident under 18 years of age and a registered user of our Services, you may request that we remove content and information that you post on our Services. To obtain removal of such content and information, please send us an email at [email protected] with a short description of the content or information you would like to have removed. Please note that such a request does not necessarily ensure complete or comprehensive removal of content posted by you, since the content and information may remain in our databases, may remain visible in a manner that does not identify you, or may have been re-posted by another user.

Choices and Access to Information

If you no longer wish to receive marketing communications from EMBR Labs, please follow the “unsubscribe” instructions that are included at the bottom of each message or email us at [email protected] We may still send you certain communications relating to the Services you use, such as service announcements and administrative messages.

You have the right and ability to edit certain account information on our Services at any time by logging into your account using the mobile application. Users may also have additional rights to access, review, correct, delete, or inquire about information that we hold about them. To make such a request, please send us an email at [email protected] Please note that we may need to verify your identity or request additional information from you before we are able to comply with your request.

Data Retention and Deletion

We retain information for as long as reasonably necessary to deliver our Services to you or to fulfill the purposes described in this Policy, or as required by law. To request the deletion of your personal information, please send us an email at [email protected] We will make our best effort to delete all personal information about you. However, please note that certain information, including other information, may be retained in backup databases or for analytic purposes.

Information for Site users from outside the United States

The personal and other information that we collect through or in connection with the Services is transferred to and processed in the United States for the purposes described above. We also may subcontract the processing of your data to, or otherwise share your data with, affiliates or third parties in the United States or countries other than your country of residence. The data-protection laws in these countries may be different from, and less stringent than, those in your country of residence. By using the Services or by providing any personal or other information to us, you expressly consent to such transfer and processing.

Children’s Privacy

The Services are not directed to children under the age of 13, and EMBR Labs does not knowingly collect personal information from anyone who is under the age of 13. We recommend that persons over 13 but under 18 years of age ask their parents for permission before using the Services or sending any information about themselves to anyone over the Internet.

Links to Other Websites or Services

The Services may contain links to and from the websites or apps of other third parties. If you follow a link to any of these websites or apps, please note that these websites and apps, and any services that may be accessible through them, have their own privacy policies. A link to any third-party site does not imply that we endorse or accept any responsibility for the content or use of such site. We encourage our users to be aware when they leave the Services and to read the privacy policies applicable to such third-party websites and apps. This Privacy Policy applies only to information collected in connection with the Services.

Changes to this Policy

Our Services may change from time to time. As a result, we may need to change this Privacy Policy. We reserve the right to update or modify this Privacy Policy at any time and without prior notice. We will post any revised Privacy Policy on our website with an “effective date” indicating when the changes will take effect. We encourage you to review this Privacy Policy periodically.

Questions or comments

If you have any questions or comments regarding our Policy, please feel free to contact us at any time at [email protected]

 

Effective date: June 6, 2017.