California Privacy Rights

California Privacy Policy for the Phase2body, Inc. Website

Last Modified: May 22, 2020

This PRIVACY NOTICE FOR CALIFORNIA RESIDENTS supplements the information contained in the Privacy Statement of phase2body, Inc. (DBA) Heads Up Health, Inc. and its subsidiaries (collectively, “we,” “us,” or “our”) and applies solely to visitors, users, and others who reside in the State of California (“consumers” or “you”). We adopt this notice to comply with the California Consumer Privacy Act of 2018 (“CCPA”) and other California privacy laws. Any terms defined in the CCPA have the same meaning when used in this notice.

The below chart reflects the categories of personal information we have collected from California consumers over the past twelve months, the categories of sources from which the information was collected, the business or commercial purpose for which the information was collected, and the categories of third parties with whom it has been shared.

We obtain the categories of personal data listed below from you, and the inferences we create come from our analysis of the information you provide to us. In the past twelve months, we have not sold personal information to third parties and we will not sell your personal information to third parties.

As further set forth in the chart below, we may use or disclose the personal information we collect for one or more of the following legitimate business purposes:

  • To fulfill or meet the reason for which the information is provided. For example, if you provide us with personal information in order for us to verify identity or provide fraud prevention services, we will use that information to provide the services.
  • To provide you with information, products or services that you request from us.
  • To provide you with email alerts, event registrations and other notices concerning our products or services, or events or news, that may be of interest to you.
  • To carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collections.
  • To improve our website and present its contents to you.
  • For testing, research, analysis and product development.
  • As necessary or appropriate to protect the rights, property or safety of us, our clients or others.
  • To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.
  • As described to you when collecting your personal information or as otherwise set forth in the CCPA.

Category

Examples

Collection Source

Business Purpose for Collection

Categories of Third Parties Receiving Personal Information

A. Identifiers.

A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, Social Security number, driver’s license number, passport number, or other similar identifiers.

We collect some of this information (real name, email address) from you directly from our registration form when you create an account for our software.

You may also provide this information through any forms on our website.

If you connect any medical facilities, devices or apps to our system, they may also share certain information in order to establish the connection and sync your data.

We collect and use this information to provide services to you, respond to question from you and provide you with information about our services. 

If you choose to share your profile with another user (e.g. doctor or family member) via our Care Team Access feature, they will have access to this information.

You can easily disconnect other users at any time you wish.

B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).

A name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver’s license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information. Some personal information included in this category may overlap with other categories.

We store medical information and health insurance information in our system should you choose to enter it.

We display this information to help you track your health inside our system.

If you choose to share your profile with another user (e.g. doctor or family member) via our Care Team Access feature, they will have access to this information.

You can easily disconnect other users at any time you wish.

C. Protected classification characteristics under California or federal law.

Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth, and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information).

Certain medical and genetic information can be stored in your profile if you choose to connect your medical facilities, digital health devices, and apps. You can also enter this data manually into your profile.

We display this information to help you track your health inside our system.

If you choose to share your profile with another user (e.g. doctor or family member) via our Care Team Access feature, they will have access to this information.

You can easily disconnect other users at any time you wish.

D. Commercial information.

Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.

If you purchase a subscription to our service, your payment history will be tracked inside your account for your reference.

We collect this information so you can see your billing history from our service.

We do not disclose this information to any third party.

E. Biometric information.

Genetic, physiological, behavioral, and biological characteristics or activity patterns used to extract a template or other identifier or identifying information, such as fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data.

Our system is designed to help you track your health. You may choose to track activity, sleep and exercise patterns inside your account.

You can enter this data manually or you can sync it from your connected health devices and apps.

We display this information to help you track your health inside our system.

If you choose to share your profile with another user (e.g. doctor or family member) via our Care Team Access feature, they will have access to this information.

You can easily disconnect other users at any time you wish.

F. Internet or other similar network activity.

Browsing history, search history, information on a consumer’s interaction with a website, application, or advertisement.

We collect this information from you directly from you or through devices you may use to access our Site and service offerings. For example, from submissions through our application, website portal or website usage details collected automatically. We also collect this information indirectly, through service providers, such as Facebook Pixel.

We collect and use this information to improve the services we provide to you.

We do not provide this information to any third party.

G. Geolocation data.

Physical location or movements.

We do not collect this information.

 N/A

 N/A

H. Sensory data.

Audio, electronic, visual, thermal, olfactory, or similar information.

We do not collect this information.

 N/A

 N/A

I. Professional or employment-related information.

Current or past job history or performance evaluations.

We do not collect this information for individual subscribers.

Our Professional portal for health coaches does ask for information on their specific area of expertise (e.g. nutritionist, chiropractor, etc.) during the registration process.

We collect and use this information to provide services to you, respond to question from you and provide you with information about our services. 

We do not provide this information to any third party.

J. Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)).

Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records.

We do not collect this information.

 N/A

 N/A

K. Inferences drawn from other personal information.

Profile reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.

We do not collect this information.

 N/A

 N/A

If you are a resident of California, you have other rights under the CCPA:

  • Right of Access: You can access your collected personal information by contacting us at support@headsuphealth.com.
  • Right to correct, update or delete: You can correct, update or request deletion of your personal by contacting us at support@headsuphealth.com. We can’t make changes to or delete your information in some situations where it is necessary for us to maintain your information, for example, if we need the information to complete transactions, continue providing services to you, or comply with applicable law. As an example, in the course of providing fraud prevention services to you or our customers, we may be required to retain your personal information for up to 180 days.
  • Right to Request Disclosure of Information Collected: Please contact us at support@headsuphealth.com to request further information about the categories of personal information we have collected about you, where we collected your personal information, and for what purpose we use your personal information.
  • Right to Disclosure of Information Sold and Right to Opt-Out: You have the right to know what information of yours we have sold, and you have the right to opt-out of any sale of your information. We do not sell any of your information. If you have any questions about these rights, please contact us at support@headsuphealth.com.
  • Right to Non-Discrimination: We do not and will not discriminate against you if you exercise your rights under the CCPA.

When you contact us regarding any of your rights under the CCPA, we will verify your identity before we provide any information. If you have any questions or comments about your rights under the CCPA, please contact us at our toll-free telephone number 1-800-759-9412 or support@headsuphealth.com.