May 14, 2020
Lady Technologies, Inc. is a manufacturer of kegg – fertility monitoring device. We provide fertility and related information on an application (the “App”) using information received from users and their kegg fertility monitors (the “device” or “kegg”). In addition to the App and Device, Lady Technologies operates websites and a webshop (the “Webshop”) where we sell the kegg device.
INFORMATION THAT WE COLLECT
When you use our Services, we collect the following types of information.
INFORMATION THAT YOU PROVIDE TO US
Some information is required to create an account on our Services, such as your name, email address, password, date of birth, information about your cycle, information about your pregnancy. You may also choose to provide other types of information, such as biography, country information, and community username.
To help improve your experience or enable certain features of the Services, you may choose to provide us with additional information, like your temperature, ovulation test result, information about your period, information about frequency of intercourse.
If you contact us or participate in a survey, contest, or promotion, we collect the information you submit such as your name, contact information, and message.
INFORMATION WE RECEIVE FROM YOUR USE OF OUR SERVICES
INFORMATION WE RECEIVE FROM YOUR DEVICE
Your device collects data to estimate the fertile window. The data collected includes electrolyte levels in vaginal fluids. When your device syncs with our applications or software, data recorded on your device is transferred from your device to our servers.
When you access or use our Services, we receive certain usage or network activity information. This includes information about your interaction with the Services, for example, when you view or search content, install applications or software, create or log into your account, or pair your device to your account.
We also collect data about the devices and computers you use to access the Services, including IP addresses, browser type, language, operating system or mobile device information (including device and application identifiers), the referring web page, pages visited, location (depending on the permissions you have granted us), and cookie information.
We receive transaction data relating to your purchases on the Webshop, including details about purchases and payments, delivery address, purchaser name, etc. We do not collect or receive bank account or credit card information.
INFORMATION WE RECEIVE FROM THIRD PARTIES
If you choose to connect your account on our Services to your account on another service, we may receive information from the other service. For example, if you connect to Facebook or Google, we may receive information like your name, profile picture, age range, language and email address. You may also choose to grant us access to your exercise or activity data from another service. You can stop sharing the information from the other service with us by removing our access to that other service.
HOW WE USE INFORMATION
We use the information we collect for the following purposes.
PROVIDE AND MAINTAIN THE SERVICES
We use your identity, contact, transaction and account data to process purchases and manage the delivery of products from the Webshop. This includes logistics, preventing fraudulent payments and contacting you regarding your purchase.
IMPROVE, PERSONALIZE, AND DEVELOP THE SERVICES
We use the information we collect to improve and personalize the Services and to develop new ones. For example, we use the information to troubleshoot and protect against errors; perform data analysis and testing; conduct research and surveys; and develop new features and Services.
We also use your information to make inferences and show you more relevant content. For example, based on your stage in your cycle, age, etc., we may provide you with content that may help you take action in regards to your fertility.
COMMUNICATE WITH YOU
We use your information when needed to send you Service notifications and respond to you when you contact us. We also use your information to promote new features or products that we think you would be interested in. You can control marketing communications and most Service notifications by using your notification preferences in your mobile device settings or via the “Unsubscribe” link in an email.
TO CONDUCT RESEARCH
Women’s health is important to Lady Technologies and we invest in scientific research in sexual and reproductive health in order to advance women’s health. We also conduct research for the purpose of evaluating the effectiveness and suitability of the App for different user groups. Thirdly we use the results of our research to communicate the benefits and limitations of kegg to healthcare professionals.
If we have your consent, we may use the data that we collect or that you provide in pseudonymized form whenever possible for clinical studies, scientific articles and other research purposes as may be disclosed when your data are collected. “Pseudonymized” means that identifying information is replaced with something else so that additional information is needed to re-identify an individual. However, personal data is anonymized and aggregated before any such publications are shared outside of Lady Technologies. We may also contact you with requests to participate in specific research projects run by us or our business partners.
We use identity, contact, and data that we collect about our users of the App to send you newsletters and other marketing communications (e.g. push notifications regarding kegg and our Services, including campaigns and offers). We also process user data to conduct internal usage analysis for the purpose of creating and sending relevant messages about our products. Some marketing data is collected by using cookies. These cookies include third party services that may collect information about your visits to our site for analytics, retargeting and conversion tracking purposes. More information about cookies and related technology is provided below.
We also use tools that help us identify and reach out to existing and new customers, by matching cookies, device identifiers and hashed (a pseudonymisation technique) email addresses of people who have been using our Services with people on social media platforms to create so called “Custom Audiences” (this enables us to send targeted ads to people who have been using our Services), and “Lookalike Audiences” (this enables us to send targeted ads to people who have similar traits to our Custom Audience). The social media platforms will not share the hashed email address with third parties or other advertisers and will delete it promptly after the match process is complete. Please note that we do not share any Sensitive Data or group users based on sensitive data for the purpose of Custom and Lookalike Audiences.
You may also be contacted and enabled to complete surveys or take part in interviews for marketing purposes. We will process the profile data that you provide in such surveys and interviews to analyze user preferences, improve and assess the effectiveness of marketing activities, use as marketing material or other promotional purposes as disclosed when your personal data are collected. Participation in surveys and interviews is voluntary.
You always have the right to opt-out of receiving marketing communication or having your data processed to identify Custom and Lookalike Audiences from us by opting out, by contacting us at email@example.com.
PROMOTE SAFETY AND SECURITY
We use the information we collect to promote the safety and security of the Services, our users, and other parties. For example, we may use the information to authenticate users, protect against fraud and abuse, respond to a legal request or claim, conduct audits, and enforce our terms and policies.
HOW INFORMATION IS SHARED
We never sell the personal information of our users. We do not share your personal information except in the limited circumstances described below.
WHEN YOU AGREE OR DIRECT US TO SHARE
You may direct us to disclose your information to others, such as when you use our community features like the forums or message boards and other social tools. You may also direct us to share your information in other ways, for example, when you give third-party application access to your account. Their use of your information will be governed by their privacy policies and terms. You can revoke your consent to share with third-party applications using your account settings.
FOR EXTERNAL PROCESSING
We transfer information to our corporate affiliates, service providers, and other partners who process it for us, based on our instructions, and in compliance with this policy and any other appropriate confidentiality and security measures. These partners provide us with services globally, including for customer support, information technology, payments, sales, marketing, data analysis, research, and surveys.
When you make purchases through the Webshop, your payments are processed through a third-party payment processor. In these instances, the third-party payment processor may collect certain financial information from you to process a payment, including your name, email address, address and other billing information. In that case, the use and storage of your financial information is governed by the third-party payment processor’s terms, conditions and privacy policies. For more information on our use of third-party payment processor, including the name(s) of the entities that we partner with, please email us at firstname.lastname@example.org.
FOR LEGAL REASONS TO PREVENT HARM
We may preserve or disclose information about you to comply with a law, regulation, legal process, or governmental request; to assert legal rights or defend against legal claims; or to prevent, detect, or investigate illegal activity, fraud, abuse, violations of our terms, or threats to the security of the Services or the physical safety of any person.
We may share non-personal information that is aggregated or de-identified so that it cannot reasonably be used to identify an individual. We may disclose such information publicly and to third parties, for example, in public reports about exercise and activity, to partners under agreement with us, or as part of the community benchmarking information we provide to users of our subscription services.
YOUR RIGHTS TO ACCESS AND CONTROL YOUR PERSONAL DATA
We give you account settings and tools to access and control your personal data, as described below, regardless of where you live. If you live in certain jurisdictions, you may have legal rights with respect to your information, which your account settings and tools allow you to exercise, as outlined below.
Accessing and Exporting Data. By logging into your account, you can access much of your personal information, including your dashboard. Using your account settings, you can also download information in a commonly used file format.
Editing and Deleting Data. By logging into your account using the application and using your profile settings, you can change and delete your personal information. For instance, you can edit or delete the profile data you provide and delete your account if you wish.
If you choose to delete your account, while most of your information will be deleted within 30 days, it may take up to 90 days to delete all of your information, like the data recorded by your device and other data stored in our backup systems. This is due to the size and complexity of the systems we use to store data. We may also preserve data for legal reasons or to prevent harm, including as described in the How Information Is Shared section.
Objecting to Data Use. We give you account settings and tools to control our data use. For example, through your privacy settings, you can limit how your information is visible to other users of the Services; using your notification settings, you can limit the notifications you receive from us; and under your application settings, you can revoke the access of third-party applications that you previously connected to your kegg account.
We keep your account information, like your name, email address, and password, for as long as your account is in existence because we need it to operate your account. We keep other information, like your monitoring data, until you delete the data or your account because we use this data to provide you with your personal statistics and other aspects of the Services. We also keep information about you and your use of the Services for as long as necessary for our legitimate business interests, for legal reasons, and to prevent harm.
ANALYTICS AND ADVERTISING SERVICES PROVIDED BY OTHERS
OUR POLICIES FOR CHILDREN
Users under the age of 21 are not allowed to use the Services.
We work hard to keep your data safe. We use a combination of technical, administrative, and physical controls to maintain the security of your data. This includes using Transport Layer Security (“TLS”) to encrypt many of our Services. No method of transmitting or storing data is completely secure, however.
CALIFORNIA PRIVACY DISCLOSURES
If you are a California resident, please review the following additional privacy disclosures under the California Consumer Privacy Act (“CCPA”).
HOW TO EXERCISE YOUR LEGAL RIGHTS
You have the right to understand how we collect, use, and disclose your personal information, to access your information, to request that we delete certain information, and to not be discriminated against for exercising your privacy rights. You may exercise these rights using your account settings and tools as described in the Your Rights To Access and Control Your Personal Data section, for example:
- By logging into your account and using your account settings, you may exercise your right to access your personal information and to understand how we collect, use, and disclose it.
- Your profile settings also let you exercise your right to delete personal information.
If you need further assistance regarding your rights, please contact us at email@example.com, and we will consider your request in accordance with applicable laws.
CATEGORIES OF INFORMATION WE COLLECT, USE, AND DISCLOSE FOR BUSINESS PURPOSES
As described in the Information We Collect section, we collect the categories of personal information listed below. We receive this information from you, your device, your use of the Services, third parties (like the other services you have connected to your account), and as otherwise described in this policy. We use and disclose these categories of information for the business purposes described in the How We Use Information and How Information Is Shared sections, respectively. The categories are:
- Identifiers, like your name or username, email address, mailing address, phone number, IP address, account ID, device ID, cookie ID, and other similar identifiers.
- Demographic information, such as your gender, age and physical characteristics or description.
- Commercial information, including your payment information and records of the Services or devices you purchased, obtained, or considered (for example, if you added them to your shopping cart on our online store but did not purchase them).
- Biometric information, such as your electrolyte levels of vaginal fluid, menstruation, ovulation test results, information on your sexual activity. .
- Internet or other electronic network activity information, such as the usage data we receive when you access or use our Services. This includes information about your interactions with the Services and about the devices and computers you use to access the Services.
- Geolocation data, including GPS signals, device sensors, Wi-Fi access points, and cell tower IDs, if you have granted us access to that information.
- Other information that you provide, including account information such as your biography or country.
- Inferences drawn from any of the above, including your ovulation cycle.
We never sell the personal information of our users. We do work with partners who provide us with advertising services as described in the Analytics and Advertising Services Provided By Others section.
COOKIES AND SIMILAR TECHNOLOGY
- Cookies are small data files stored on your browser or device. For example, we partner with third-party analytics providers, like Google, which set cookies when you visit our websites. This helps us understand how you are using our Services so that we can improve them.
- Pixels are small images on a web page or in an email. Pixels collect information about your browser or device and can set cookies.
OUR USE OF THESE TECHNOLOGIES
Below are the ways that we and our partners use these technologies on our Services.
CATEGORY OF USE
PURPOSE OF THE USE
To help us remember your settings and preferences, like your preferred language or the country you are in, so that we can provide you with a more personalized experience.
Authentication and Security
To log you into the Services; enable us to show you your account data; and help us keep your data and the Services safe and secure.
Service Features and Performance
To provide you with functionality and optimize the performance of the Services. For example, to keep track of products you add to your shopping cart on the Webshop.
Analytics and Research
To help us understand how you are using the Services so that we can make them better, faster, and safer.
To enable our partners to serve ads for our products and services; deliver relevant ads to people who may be interested in them on other services; measure the performance of ads; and opt you out of receiving interest-based ads if that is your choice.
- Although most browsers and devices accept cookies by default, their settings usually allow you to clear or decline cookies. If you disable cookies, however, some of the features of our Services may not function properly.
- To prevent your data from being used by Google Analytics, you can install Google’s opt-out browser add-on.
- The online advertising industry also provides websites from which you may opt-out of receiving targeted ads from our data partners and our other advertising partners that participate in self-regulatory programs. You can access these, and also learn more about targeted advertising and consumer choice and privacy, at www.networkadvertising.org/managing/opt_out.asp, www.youronlinechoices.eu/ or www.youradchoices.ca/, and www.aboutads.info/choices/.
- To opt out of ads on Facebook, Pinterest, or Google that are targeted to your interests, use your Facebook, Pinterest, or Google Ads settings.
- Check your mobile device for settings that control ads based on your interactions with the applications on your device. For example, on your iOS device, enable the “Limit Ad Tracking” setting, and on your Android device, enable the “Opt out of Ads Personalization” setting.
CHANGES TO THIS POLICY
We will notify you before we make material changes to this policy and give you an opportunity to review the revised policy before deciding if you would like to continue to use the Services.
WHO WE ARE AND HOW TO CONTACT US
If you have questions about this policy, or need help exercising your privacy rights, please contact us at firstname.lastname@example.org.
You also may contact us at:
Lady Technologies, Inc.
San Francisco, CA 94103