Privacy Policy.

At Habitual Growth, LLC (“Habitual Growth,” “us,” “we,” or “our”), our mission is to help people become the best versions of themselves through the pursuit of personal excellence. We exist to provide a template foundation for self-development, personal growth and individual success by creating value and showing individuals that success is built from daily successes or wins. We believe that each of us should be the standard for those around us that that goes for ourselves – Habitual Growth is the foremost standard for growth and self-development. Because of this, we take your privacy seriously and want to be transparent to how we collect, use and share Personal Data, as well as the measures we take to protect your Personal Data.

This Privacy Policy applies to Personal Data we collect about our members, consumers, partners and others that interact with us or use our services. This includes visiting our websites, social media pages, responding to emails or utilizing the Habitual Growth mobile application (collectively, the “Services”). This Privacy Policy does not cover practices of companies or people associated or affiliated with us that we do not own or control. We are not responsible for the policies and practices of any third parties, or endorse any information, products, or services that may be offered by third parties or accessible on or through the Services.

We collect Personal Data about you from:

· Our members, when they provide such information directly to us, such as when completing profiles, setting goals or entering essential daily actions

· Automatic data collection, such as Cookies, local storage objects, and other similar technologies in connection with your use of the Services

· Customers and partners, such as individuals, employers, companies, coaches, teams, or other organizations that engage with our Services

· Marketing and advertising partners, such as companies that have entered in joint marketing relationships with Habitual Growth or assist with marketing or promotional services or communications

· Social media, other third-party platforms, and linked accounts, devices, or features, interacting with our pages on social media sites, post content to sites using the Services, sign into the Services through a third-party site or service, or otherwise link accounts, devices, or Habitual Growth account; and

· Data providers, such as information services and data licensors, when data is supplemented.

We may collect the following types of Personal Data:

· Contact details, such as first and last names, email and mailing address, social media handle(s) and phone number

· Personal data, such as username and password that are used to establish to create a Habitual Growth account, as well as any additional content, assets or information used to create your account

· Communications that we exchange with our customers, including but not limited to, contact via email, social media page(s), web app, or mobile app with questions, feedback, or reviews

· Wellness Data, such as daily activities, priorities, time usage, and additional metadata; this includes but is not limited to birthday, gender identity, weight, height, fitness/athlete level (e.g., professional or recreational), profession and / or industry, mindfulness practices, spiritual preference(s); and details chosen to submit about diet, physical activity, habits or other. Some of this information may be used to customize experiences with us as part of our Services

· Payment and transactional data needed to complete orders on the website, mobile application or the Services (including name, email address, payment card information, bank account number / routing number, billing information) and your transaction history.

· Marketing data, such as preferences for receiving marketing communications, and engagement details associated with them.

· Device data, such as computer or mobile device details, IP Address, unique identifiers (including identifiers used for advertising purposes), language settings, general location information or geolocation data and areas; and

· Online activity data, such as information about your activity on a page or screen, communications across the mobile app or website, access times, and duration of access.

We process Personal Data to operate, understand, improve and personalize our Services. We use Personal Data for the following purposes:

Service delivery, including to:

· Provide, operate, improve, develop, understand, and personalize the Services and our business, including testing, research, analysis and product development

· Communicate with consumers about the Services, including Service announcements, updates, or offers

· Provide support and assistance for the Services

· Create and manage account or other user profiles;

· Customize website content, communications and suggestions based on personal preferences; and

· Process orders, memberships, connections or other transactions and communications.

Research and development. We may create and use Aggregated Data, De-identified Data or other anonymous data from Personal Data we collect, including Wellness Data, for our business purpose, including to analyze the effectiveness of the Services, to improve and add features to the Services, and to analyze the general behavior and characteristics of users of the Services. We use anonymous data for research purposes to help us and our partners answer performance and growth questions to improve product offerings and experiences.

Marketing and advertising. We do not use personally identifiable data for marketing or advertising purposes.

Compliance and protection, including to:

· Protect against or deter fraudulent, illegal, or harmful actions and maintain the safety, security, and integrity of our Services

· Comply with our legal or contractual obligations, and resolve disputes

· Audit our internal processes for compliance with legal and contractual requirements and internal policies

· Protect the Company’s and consumers rights, privacy, safety, or property (including by making and defending legal claims); and

· Respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.

We share your Personal Data with:

· Service providers, such as payment processors, vendors who advertise our Services, security and fraud prevention consultants, hosting and other technology and communications providers, analytics providers, and staff augmentation and contract personnel, that provide services to us or on our behalf

· Advertising partners that may collect information on our website, including for the interest-based advertising purposes described above.

· Professional advisors, such as lawyers, auditors, bankers and insurers, where necessary in the course of the professional services they render to us

· Authorities and others, including law enforcement, government authorities, and private parties we believe in good faith to be necessary or appropriate to comply with the law or legal process; and

· Business transferees, such as acquirers and other relevant participants in business transactions (or negotiations for such transactions) involving a corporate divestiture, merger, consolidation, acquisition, reorganization, sale, or other disposition of all or any portion of the business or assets of, or equity interests in, Habitual Growth or affiliates.

Depending on your use of the Services, you may share Personal Data with:

· Other users of the Services, such as through our Habitual Growth Services or features, which allow you to share information and content with other users of the Service, and users are by default searchable by other users

· Third-party social media platforms, or linked accounts, devices, or features, when you choose to connect your account on those services with Habitual Growth or post content to social media, such as through the Habitual Growth social media page and website;

· Public. When you make Personal Data visible to other users of the Services, including the Habitual Growth social media page and website, it may become publicly available and can be collected, viewed and used by anyone

· Managing entity. If your use of the Services is on behalf of or managed by a managing entity, such as a coach, team, organizing body, or other entity with which you are affiliated, your account information and Personal Data may be shared with the managing entity subject to your consent, and you consent to that managing entity allowing that information to be publicly shared, subject to any features of the Services that expressly override that control. The managing entity will determine how the relevant information and content is shared; and

· Corporate wellness programs. If you use the Services in connection with an employer or organizational corporate wellness program, we may share your information with that organization. Typically, we will share only Aggregated Data with these organizations.

Habitual Growth provides several methods for Personal Data sharing choices, including but not limited to:

· Access, update, or delete. When you log in to your account, you may access, and, in some cases, edit or delete certain information you’ve provided to us, such as first and last name, username and password, email and mailing address, and other information in your profile. When you update information, however, we may maintain a copy of the unrevised information in our records. You may request a full deletion of your account and corresponding data by emailing habitualgrowthinfo@gmail.com. You will be asked to complete a verification form in connection with such deletion request in order to ensure that you have the authority to delete your account. We may need to retain certain Personal Data in our records, as well as Aggregated Data or De-identified Data derived from or incorporating your Personal Data that does not identify you after you date or delete it.

· Privacy settings. You can change certain privacy settings, such as whether you are searchable on the Habitual Growth mobile app at any time.

· Push notifications and device permissions. When you use our mobile application, you may initially opt-out of push notifications that we may send you or revoke any permissions you previously granted to us at any time such as permission to access your camera or camera roll, Bluetooth, microphone, Siri, search, push notifications, background app refresh and/or cellular data access, by changing the settings on your mobile device.

· Geolocation data. You may allow or disallow Habitual Growth to collect geolocation data by enabling or disabling location services on your device. If you decline to grant Habitual Growth access to this data, we will not be able to provide certain Services, capabilities, or features to you.

· Habitual Growth social media pages. If you have joined a Habitual Growth social media page, you may stop the sharing of your Personal Data with the members of the page at any time by unfollowing or deleting the social media page from your account.

· Marketing communications. We will give you the ability to opt-out of marketing-related emails and other communications by going to our preferences management page, or by following the opt-out or unsubscribe instructions contained in the message. You cannot opt-out of receiving certain non-marketing emails regarding the Service.

The Services may contain links to websites and other online services operated by Third Parties. In addition, our content may be integrated into web pages or other online services that are not associated with us. These links and integrations are not an endorsement of, or representation that we are affiliated with, any Third Party. We do not control websites or online services operated by Third Parties, and we are not responsible for their actions. You can learn about and control how these Third Parties use and share Personal Data about you, including with Habitual Growth, by reviewing their privacy notices and exercising the privacy choices the Third Party may offer.

We employ a number of physical, technical, organizational, and administrative security measures designed to protect the Personal Data we collect. While we endeavor to protect the privacy of your account and other Personal Data we hold in our records, no security measures are failsafe, and we cannot guarantee the security of your Personal Data.

We retain Personal Data for as long as reasonably necessary for the purposes described in this Privacy Policy, while we have a business need to do so, or as required by law (e.g., for tax, legal, accounting, or other purposes), whichever is longer.

If you are under 13, or 16 where applicable, please do not attempt to register for the Services or send any Personal Data about yourself to us. If we learn that we have collected Personal Data from a child under age 13, or 16 where applicable, we will delete that information as quickly as possible. If you believe that a child under 13, or 16 where applicable, may have provided us Personal Data, please contact us at info@habitualgrowth.com.

If you have any questions or concerns regarding our privacy policies, please send us a detailed message to info@habitualgrowth.com.

We are providing this supplemental privacy notice to consumers in California, pursuant to the California Consumer Privacy Act of 2018 (the “CCPA”).

We do not sell Personal Data. As we explain in this Privacy Policy, we use Cookies and other tracking technologies to analyze website and application traffic and use, and to facilitate advertising. To limit use of Cookies and other tracking technologies, please review the instructions provided in the “Online tracking opt-outs” section. You may also direct us to share your data, as described in the “How You Share Personal Data Through Habitual Growth” section of the Privacy Policy.

California Privacy Rights. If you are a California resident, you have the following rights:

· Information: The Privacy Policy describes the types of Personal Data we collect in the “Personal Data We Collect” section above and the sources through which we collect Personal Data in the “How We Collect Personal Data” section above. We describe the purposes for which we use and share this data in the “How We Use Personal Data” section above and the “How We Share Personal Data” section above.

· Access: You can request a copy of the personal information that we maintain about you.

· Deletion: You can ask to delete the personal information that we have collected from you.

· Opt-out of sale of your Personal Data: We do not sell Personal Data. We offer instructions on how to limit online tracking in the “Online tracking opt-outs” section of the Privacy Policy.

Please note that the CCPA limits these rights by, for example, prohibiting businesses from providing certain sensitive information in response to an access request and limiting the circumstances in which they must comply with a deletion request.

You are entitled to exercise the rights described above free from discrimination.

Exercising your rights. To exercise these rights, you can submit requests as follows:

· To request access to or deletion of Personal Data collected via your use of the Services, please email us at habitualgrowthinfo@gmail.com

· To learn how to opt-out of interest-based ads and other online tracking, see the “Online tracking opt-outs” section of the Privacy Policy.

· To verify your identity prior to responding to your requests, we may ask you to confirm information that we have on file about you or your interactions with us. Where we ask for additional Personal Data to verify your identity, we will only use it to verify your identity or your authority to make the request on behalf of another consumer.

· Authorized agents: California residents can empower an “authorized agent” to submit requests on the resident’s behalf. Your authorized agent may submit requests in the same manner, although we may require the agent to present signed written permission to act on your behalf, and you may also be required to independently verify your identity with us and confirm that you have provided the agent permission to submit the request.

Legal bases for processing. The “How We Use Personal Data” section above explains how we use your Personal Data. We will only process your Personal Data if we have a lawful basis for doing so. Lawful bases for processing include consent, contractual necessity and our “legitimate interests” or the legitimate interest of others but will depend on the type of Personal Data and the specific context in which we process it. However, the legal bases we typically rely on for each category of processing activity are set out below.

· Service delivery: Processing is necessary to perform our contract, or to take steps that you request prior to engaging our Services. Where we cannot process your Personal Data as required to operate the Services on the grounds of contractual necessity, we process your personal information for this purpose based on our legitimate interest in providing you with the products or Services you access and request.

· Research and development: These activities constitute our legitimate interests.

· Marketing and advertising: Processing is based on your consent where that consent is required by applicable law. Where such consent is not required by applicable law, we process your personal information for these purposes based on our legitimate interests in promoting our business.

· Compliance and protection: From time to time, we may also need to process Personal Data to comply with a legal obligation, if it is necessary to protect the vital interests of you or other data subjects, or if it is necessary for a task carried out in the public interest.

· Consent: To the extent that Wellness Data that we collect is considered health data or another special category of Personal Data, we ask for your explicit consent to process this data. In some cases, such as when you direct us to share it, we process Personal Data based on the consent you expressly grant to us at the time we collect such data. When we process Personal Data based on your consent, you have the right to withdraw it any time in the manner indicated at the time you give consent or in as listed in our Services.

We may use your Personal Data for reasons not described in this Privacy Policy, where permitted by law, and where the reason is compatible with the purpose for which we collected it. If we need to use your Personal Data for an unrelated purpose, we will notify you and explain the applicable legal basis.

Retention. To determine the appropriate retention period for your Personal Data, we consider the amount, nature, and sensitivity of the information, the potential risk of harm from unauthorized use or disclosure of your Personal Data, the purposes for which we process your Personal Data and whether we can achieve those purposes through other means, and the applicable legal requirements.

Data subject rights. You have certain rights with respect to your Personal Data, including:

· Access. You can request more information about the Personal Data we hold about you and request a copy of such Personal Data. You can also access certain elements of your Personal Data by logging into your account.

· Rectification. If you believe that any Personal Data that we are holding about you is incorrect or incomplete, you can request that we correct or supplement such data. You can also correct some of this information directly by logging into your account.

· Erasure. You can request that we erase some or all of your Personal Data from our systems.

· Withdrawal of consent. If we are processing your Personal Data based on your consent (as indicated at the time of collection of such data), you have the right to withdraw your consent at any time. Please note, however, that if you exercise this right, you may have to then provide express consent on a case-by-case basis for the use or disclosure of certain of your Personal Data, if such use or disclosure is necessary to enable you to utilize some or all of our Services.

· Portability. You can ask for a copy of your Personal Data in a machine-readable format. You can also request that we transmit the data to another controller where technically feasible.

· Objection. You can contact us to let us know that you object to the further use or disclosure of your Personal Data for certain purposes, such as for direct marketing purposes.

· Restriction of processing: You can ask us to restrict further processing of your Personal Data.

· Right to file complaint. You have the right to lodge a complaint about our practices with respect to your Personal Data with the supervisory authority of your country or European Economic Area Member State.

For more information about these rights, or to submit a request, please email habitualgrowthinfo@gmail.com . Please note that in some circumstances, we may not be able to fully comply with your request, such as if it is frivolous or extremely impractical, if it jeopardizes the rights of others, or if it is not required by law, but in those circumstances, we will still respond to notify you of such a decision. In some cases, we may also need to you to provide us with additional information, which may include Personal Data, if necessary to verify your identity and the nature of your request.

Processing of Personal Data in the United States. To provide the Services, we will process your Personal Data in the United States, where Habitual Growth is based. If such processing involves the transfer of Personal Data to the U.S. in a manner governed by European data protection law, the transfer will be performed pursuant to the applicable requirements of the law, such as standard contractual clauses, the individual’s consent, or other circumstances permitted by European data protection law.

If you have any questions about this section or our data practices generally, please contact us at habitualgrowthinfo@gmail.com using the contact information above.

We use some specifically defined terms in our Privacy Policy and when we communicate about our Privacy Policy. We want to be clear on how the terms we use are defined to help you better understand our policies. The defined terms are provided below.

Aggregated Data

Aggregated Data is data that has undergone a process whereby raw data is gathered and expressed in a summary form for statistical analysis. Raw data can be aggregated over a given time period, across individuals, or both, to provide statistics such as average, minimum, maximum, sum, and count. After the data is aggregated analysis can be performed to gain insights about particular data sets. When data is aggregated across a number of individuals, the resulting aggregation is considered anonymized such that it is no longer Personal Data.

CCPA

The California Consumer Privacy Act, or CCPA, is a state law that provides California consumers with robust data privacy rights. These rights include the right to know, the right to delete, and the right to opt-out of “sale” of personal information that businesses collect, as well as additional protections for minors. A “sale” under the CCPA is defined as “selling, renting, releasing, disclosing, disseminating, making available, transferring, or otherwise communicating orally, in writing, or by electronic or other means, a consumer’s personal information by the business to another business or to a third party for monetary or other valuable consideration.”

Cookies

Cookies are small files which are stored on a user’s computer. They are designed to hold a modest amount of data specific to a particular user and website and can be accessed either by the web server or the user computer. This allows the server to deliver a page tailored to a particular user, or the page itself can contain some script which is aware of the data in the cookie and is therefore able to carry information from one visit to the website (or related site) to the next.

De-Identified Data

De-Identified Data is data where all the personally identifiable information has been removed, rendering the data anonymous by stripping out information that would allow an individual’s identity to be determined from the remaining data. Data is “de-identified” to protect the privacy and identity of individuals associated with the data. De-identified Data is no longer Personal Data.

GDPR

The General Data Protection Regulation, or GDPR, is a data privacy and security regulation under European law that sets guidelines for the collection and processing of personal information from individuals who live in the European Economic Area, Switzerland and United Kingdom (collectively, “Europe” or “European”). The GDPR provides data protection rights to European residents and applies to any organization that offers goods or services to individuals in Europe, even if that organization is not based in Europe.

IP Address

An IP Address is a unique address that identifies a device on the internet or a local network. It allows a system to be recognized by other systems connected via the internet protocol. An IP Address may be considered Personal Data and is at times used by advertisers to serve interest-based ads.

Personal Data

Personal Data is any data that identifies or relates to you as a particular individual, including information referred to as “personally identifiable information” or “personal information” under applicable data privacy laws, rules, or regulations.

Services

Services means, collectively, our websites, social media pages, and mobile apps, any software utilized on behalf of Habitual Growth, and any features, content, or applications offered, from time to time, by Habitual Growth in connection therewith.

Third Parties

Third Parties in the context of the relationship between Habitual Growth LLC, Habitual Growth Members (our end users), and third parties are entities or businesses involved in an arrangement, contract, deal, or transaction but are not one of the principals (i.e., Habitual Growth LLC or Habitual Growth Members). We use Third Parties to enable us to do business with our members, such as charging for transactions or storing data. Third Parties also include advertisers that serve interest-based ads to visitors to our website.

Habitual Growth, we, us, our

The terms “Habitual Growth,” “we,” “us,” or “our” mean Habitual Growth. and each of its wholly owned subsidiaries.