Privacy Policy
Habitual Growth Privacy Policy
Effective Date: August 1st, 2025
1.0 Introduction
Habitual Growth, Inc. (“Habitual Growth,” “we,” “our,” or “us”) is committed to protecting the privacy of our users. This Privacy Policy explains how we collect, use, share, and protect personal data from users of our mobile apps, websites, and services.
We take your privacy seriously. Please read this Privacy Policy to learn how we treat your personal data. By using or accessing our services in any manner, you understand and acknowledge that you accept our practices and policies outlined below, and you hereby consent that we will collect, use, and share your information as described in this Privacy Policy. You additionally consent to having your data transferred to and processed in the United States.
Use of Habitual Growth’s services is always subject to our Terms of Service, which incorporates this Privacy Policy. Any terms we use in this policy without defining them have the definitions provided in the Terms of Service.
We are continuously working to improve our service, which may, from time to time, require changes to this Privacy Policy. We will alert users of material changes to this Privacy Policy by placing a notice on the Habitual Growth website, by sending an email, and/or by some other means.
Note: If you’ve opted not to receive legal notice emails from us (or you haven’t provided us with your email address), those legal notices will still govern your use of the Services, and you are responsible for reading and understanding them. Using the Services after any changes to the Privacy Policy have been posted means you agree to all of the changes.
Table of Contents
Introduction
What this Policy Covers
Information We Collect
a. Categories of Personal Data We Collect
b. Categories of Sources of Personal Data
Data Collection
Data That Is Not Personal Data
Research Partners
Habitual Growth for Work
Donations & Giving
Habitual Growth Content Providers
California Resident Rights
Virginia Resident Rights
Exercising Your Rights Under CCPA and VCPDA
Other State and Country Law Privacy Rights
Personal Data We Collect
Transfer of Personal Data
Users From Outside the United States
Data Collection of minors
Policy Revisions
2.0 What This Privacy Policy Covers:
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 and social media pages, responding to emails, or utilizing the Habitual Growth mobile application (collectively, the “Services”).
This Privacy Policy does not cover the 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.
3.0 Information We Collect:
3.a Categories of Personal Data We Collect
Generally, we only collect the Personal Data about website visitors or marketing leads, users, creators, and teachers with respect to our Services. The following content details the categories of personal data that we collect based on your interaction with Habitual Growth. Note: Multiple sets of Personal Data may apply to you, depending on your relationship with the company and its services (for example, if you are both a user of our services and a creator, both sets of Personal Data would apply to you):
WEBSITE AND/OR MARKETING LEADS
Device/IP Data
Examples of Personal Data We Collect:
IP address
Device ID
Domain server
Type of device/operating system/browser used to access the Services
Categories of Third Parties with Whom We Share this Personal Data:
Service Providers
Analytics Partners
Web Analytics
Examples of Personal Data We May Collect:
Browsing or search history
Web page interactions
Referring to the webpage/source through which you accessed the Services
Non-identifiable request IDs
Statistics associated with the interaction between devices or browsers and the services
Categories of Third Parties with Whom We Share this Personal Data:
Service Providers
Analytics Partners
Business Partners
USERS OF OUR SERVICES
Profile or Contact Data
Examples of Personal Data We Collect:
First and last name
Email
Unique identifiers such as passwords
Third Parties with Whom We Share this Personal Data:
Service Providers
Business Partners
Parties You Authorize, Access or Authenticate
Identifiers
Examples of Personal Data We Collect:
Cultural or social identifiers based on your use of our Services (for example, your interest in meditation or breathwork)
Categories of Third Parties with Whom We Share this Personal Data:
Service Providers
Analytics Partners
Business Partners
Parties You Authorize, Access or Authenticate
Payment Data
Examples of Personal Data We Collect:
Financial account information
Payment card type
The last 4 digits of payment card
Billing address, phone number, and email
Categories of Third Parties with Whom We Share this Personal Data:
Service Providers (specifically our payment processing partner)
Commercial Data
Examples of Personal Data We Collect:
Purchase history related to our services
Categories of Third Parties with Whom We Share this Personal Data:
Service Providers
Business Partners
Parties You Authorize, Access or Authenticate
Online Identifiers
Examples of Personal Data We Collect:
Unique identifiers such as account name and passwords
Other unique personal or online identifiers, including Facebook sign-in, Apple Sign-in, and Google Sign-in.
Categories of Third Parties with Whom We Share this Personal Data:
Service Providers
Device/IP Data
Examples of Personal Data We Collect:
IP address
Device ID
Domain server
Type of device/operating system/browser used to access the Services
Categories of Third Parties with Whom We Share this Personal Data:
Service Providers
Analytics Partners
Web and Mobile Analytics
Examples of Personal Data We Collect:
Browsing or search history
Web page interactions
Referring to the webpage/source through which you accessed the Services
Non-identifiable request IDs
Statistics associated with the interaction between devices or browser and the Services
Categories of Third Parties with Whom We Share this Personal Data:
Service Providers
Analytics Partners
Business Partners
Social Network Data
Examples of Personal Data We Collect:
Email
Username
IP address
Device ID
Information from user’s social media profile (including location data from Google and Facebook)
Categories of Third Parties with Whom We Share this Personal Data:
Service Providers
Analytics Partners
Consumer Demographic Data
Examples of Personal Data We Collect:
Year of birth
Gender
Age
Profession
Categories of Third Parties with Whom We Share this Personal Data:
Service Providers
Business Partners
Parties You Authorize, Access or Authenticate
Professional or Employment-Related Data
Examples of Personal Data We Collect:
Job title or role
Department
Seniority level
Categories of Third Parties with Whom We Share this Personal Data:
Service Providers
Business Partners
Parties You Authorize, Access or Authenticate
Geolocation Data
Examples of Personal Data We Collect:
IP-address-based location information
Categories of Third Parties with Whom We Share this Personal Data:
Service Providers
Analytics Partners
Business Partners
Parties You Authorize, Access or Authenticate
Photos, Videos and Recordings
Examples of Personal Data We Collect:
Photos, videos or recordings of you
Photos, videos or recordings of your environment
Categories of Third Parties with Whom We Share this Personal Data:
Service Providers
Parties You Authorize, Access or Authenticate
Health Data
Examples of Personal Data We Collect:
Apple Health data
Emotion or Feeling Check-ins
Sleep data
Categories of Third Parties with Whom We Share this Personal Data:
Service Providers
Business Partners
Parties You Authorize, Access or Authenticate
Categories of Data Considered “Sensitive” Under the CCPA and VCDPA
Examples of Personal Data We Collect:
Contents of communications sent or received through the Services
Mental or physical health conditions or attributes (as described under “Health Data” above)
Categories of Third Parties with Whom We Share this Personal Data:
Service Providers
Business Partners
Parties You Authorize, Access or Authenticate
Inferences Drawn from Other Personal Data Collected
Examples of Personal Data We Collect:
Inferences reflecting user attributes based on your use of our Services
Categories of Third Parties with Whom We Share this Personal Data:
Service Providers
Business Partners
Parties You Authorize, Access or Authenticate
Other Identifying Information that You Voluntarily Choose to Provide
Examples of Personal Data We Collect:
Identifying information in emails, letters, texts, surveys, or other communications you send us, including your comments and other posts within the Services
Categories of Third Parties with Whom We Share this Personal Data:
Service Providers
Parties You Authorize, Access or Authenticate
Teachers, Coaches, Creators, and Consultants
City and state
Social security number (for a small portion of teachers and only in connection with processing payments to such teachers)
Proof of address (for a small portion of teachers)
Cultural or social identifiers (for example, being a skateboarder, an expert in your field, sports enthusiast, life coach, education degrees, etc.)
Bank account information (for a small portion of teachers and only as required)
Billing address
Billing email
Service Providers (Payment Processors Only)
Professional or Employment-Related Data
Any additional required accreditations
3.b Categories of Sources of Personal Data
We collect personal data about you from the following categories of sources:
You
When you provide such information directly to us.
When you create an account or use our interactive tools and services.
When you voluntarily provide information in free-form text boxes through the Services or through responses to surveys or questionnaires.
When you send us an email or otherwise contact us.
When you use the Services, such information is collected automatically.
Through cookies (defined in the “Tracking Tools, Advertising, and Opt-Out” section below).
If you download our mobile application or use a location-enabled browser, we may receive information about your location and mobile device, as applicable.
If you download and install certain applications and software we make available, we may receive and collect information transmitted from your computing device for the purpose of providing you the relevant Services, such as information regarding when you are logged on and available to receive updates or alert notices.
Public Records
We collect information from publicly available sources, including data in the public domain.
Third Parties
Vendors
We may use analytics providers to analyze how you interact and engage with the Services, or third parties may help us provide you with customer support.
We may use vendors to obtain information to generate leads and create user profiles.
Data Brokers
We may receive information about you from some of our vendors who are data brokers to assist with enrichment services.
Social Networks
If you provide your social network account credentials to us or otherwise sign in to the Services through a third-party site or service, some content and/or information in those accounts may be transmitted into your account with us.
Your Workplace Administrator
If you join an Insight Timer group associated with your work or organization (a “Workplace”), we collect information from the administrator designated by your work or organization (“Workplace Administrator”), including your business contact data, to grant you access to the Workplace.
Research Partners
We collect information from our Research Partners (as defined below) that analyze information we provide for research and statistical purposes.
We collect the personal information you provide to us directly. You do not need to sign up for a membership account to use Habitual Growth. However, membership allows us to tailor Habitual Growth to be a more personalized experience. To create a Habitual Growth Membership account, we require that you provide a first name, last name, and a valid email address or phone number. We will use this information to associate you with your specific Habitual Growth Member account. After you have created a Habitual Growth Member account, you may also choose to provide your gender, age, website, description of your location, a brief biography, a profile picture, and other information such as user contributions (defined below). All of these, if provided, will be associated with your account until you delete your account or make a request that the information be deleted as described below.
Beyond the personal information collected to create a member account, you have choices about what additional information you provide for us. We collect personal data from you when you provide, post, or upload it to Habitual Growth. You do not have to provide this information; however, if you do not, it may limit our ability to personalize Habitual Growth and your ability to use Habitual Growth to its fullest extent. Specific Habitual Growth functionality for which you may provide, and we may process your information as discussed below.
Your user contributions
Habitual Growth allows users to publish, distribute, and display certain content (we refer to that as “posted” and the content as “posts”). Posts may be made on public areas of Habitual Growth, websites, and social media accounts you access through Habitual Growth, or transmitted to other users of Habitual Growth or third parties you choose to connect with on Habitual Growth or other platforms or services. For example, this would include commenting on a friend’s post or creating a group, challenge, or plan, etc. Habitual Growth also allows you to create certain content to be maintained in your account, such as a message, notification, or challenge or plan, some of which you can also post to provide to others. We will call the content created by you, whether or not posted, “User Contributions.”
Your user contributions are processed by us to facilitate your ability to create, use, store, and distribute the user contribution as you choose, as well as create new and better experiences for you and the rest of our users and future users. We will associate your user contributions with your account as long as you opt not to delete them. Please keep in mind that if you disclose personal information in a public manner, whether through collaborative postings, social media, message boards, or other public online forums, this information may be collected and used by others.
User contributions are posted and transmitted at your own risk. We cannot control the actions of other users or third parties with whom you choose to share your user contributions. Therefore, we cannot and do not guarantee that your shared user contributions will not be viewed by or used in an unauthorized manner, nor do we accept any liability associated with your user contributions.
Communication from you to us
We collect information about you when you send or receive messages from us or other users or engage with any Challenge, Plan, or other company feature, including when you submit personal information or requests by emailing info@habitualgrowth.com or through the website www.habitualgrowth.com. We retain and use those communications to process your inquiries, respond to your requests, and improve Habitual Growth and our services. If you are a member, we will keep your communications to us in association with your account until you request that they be deleted.
4.0 Data Collection
By agreeing to our Privacy Policy, you agree to the use of cookies and similar technologies (for example, web beacons, pixels, tags, and device identifiers, which we collectively refer to as “cookies”) as described in this policy. If you use Habitual Growth without changing your browser or device settings to disable cookies, we'll assume that you consent to receive all cookies provided through Habitual Growth.
Cookies and other similar technologies
Importantly, we do NOT use cookies or similar technologies to facilitate interest-based ads for third-party goods or services.
We use cookies to recognize you and/or your device(s) on, off, and across the different applications of Habitual Growth. Cookies help to facilitate the best possible user experience of Habitual Growth, as they allow us to recognize you and maintain your user preferences from session to session, help us keep your account safe, and generally improve the functionality of the products and services offered through Habitual Growth. They also help us ensure that member information is used in association with the correct member account.
We use cookies to collect details of your use of Habitual Growth (including traffic data, IP location data, logs, browser type, browser language, the functionality requested, and the timing of your requests) and other communication data and the resources that you access, use, and create on or through Habitual Growth. We use this information to provide a tailored Habitual Growth experience for you and to communicate with you more effectively. The information is also collected to determine the aggregate number of unique devices using Habitual Growth and/or parts of Habitual Growth, track total usage, analyze usage data, and improve Habitual Growth functionality for all users. We may combine this information to provide you with a better experience and to improve the quality of our service.
We generally maintain the data we collect from cookies for 21 days but may save it for a longer period where necessary, such as when required by law or for technical reasons. Although most internet browsers accept cookies by default, you can control cookies through your browser settings and similar tools or refuse cookies altogether. If you refuse to accept cookies, you may be unable to access certain parts of Habitual Growth, you will prohibit us from delivering the full capability of Habitual Growth, and you may prevent the use of certain features and services that require these technologies.
Habitual Growth cannot regulate other sites, content, or applications linked or provided from within Habitual Growth or our various other websites and services that are provided by third parties, including your device manufacturer and your mobile service provider. These third parties may place their own cookies or other files on your computer, collect data, or solicit personal information from you. The information they collect may be associated with your personal information, or they may collect information, including personal information, about your online activities over time and across different websites, apps, and other online services. These third parties may use this information to provide you with interest-based (behavioral) targeted content. We do not control these third parties' tracking technologies or how they may be used. If you have any questions about targeted content, you should contact the responsible provider directly.
Attribution providers
We advertise Habitual Growth on third-party sites such as Facebook and Google and use third-party software development kits (“SDKs”) to attribute a download of Habitual Growth to the advertisement placed on the third-party site. We do not sell your personal information to any third parties nor allow our SDK service providers to sell your personal information to third parties or use your personal information to solicit the sale of third-party goods or services. We may provide these third parties with aggregate, de-identified information concerning ads placed on their sites and Habitual Growth downloads that result from those ads.
Device ID, IP address and network access
When you access or leave Habitual Growth websites, we receive the URL of both the site you came from and the one you go to next. We also get information about your proxy server, operating system, web browser and add-ons, device identifier and features, and/or your ISP or mobile carrier when you use Habitual Growth. We also receive data from your devices and networks, including your IP address.
We use the IP addresses we collect from our users to process them with public latitude and longitude information related to your Internet Service Provider or mobile service provider in order to determine, and in some instances depict in an aggregate and de-identified manner, the approximate geographic region for each instance of Habitual Growth use. This latitude and longitude information is stored by us for approximately seven days for troubleshooting and diagnostic purposes but is never associated with any information about you or that would identify you personally.
We also collect and use the wireless (or “WiFi”) permissions of your mobile device to determine if you are connected to a WiFi or cellular network. This information is used to provide an optimized user experience by providing higher-resolution media to a user who is on a high-speed WiFi connection rather than a cellular network. WiFi permissions are also used for casting content with Chromecast and similar devices. This information is not stored or shared by Habitual Growth.
Our Commercial or Business Purposes for Collecting or Disclosing Personal Data
Providing, Customizing and Improving the Services
Creating and managing your account or other user profiles.
Processing orders or other transactions; billing.
Providing you with the products, services, or information you request.
Meeting or fulfilling the reason you provided the information to us. For example, when you create, join, use, and/or interact with a Habitual Growth group or Workplace.
Providing support and assistance for the Services.
Improving the services, including testing, research, internal analytics, and product development.
Personalizing the services, website content, and communications based on your preferences.
Doing fraud protection, security, and debugging.
Carrying out other business purposes stated when collecting your Personal Data or as otherwise set forth in applicable data privacy laws, such as the California Consumer Privacy Act, as amended by the California Privacy Rights Act of 2020 (the “CCPA”).
Corresponding with You
Responding to correspondence that we receive from you, contacting you when necessary or requested, and sending you information about Habitual Growth or the Services.
Sending emails and other communications according to your preferences or that display content that we think will interest you.
Meeting Legal Requirements and Enforcing Legal Terms
Fulfilling our legal obligations under applicable law, regulation, court order, or other legal process, such as preventing, detecting, and investigating security incidents and potentially illegal or prohibited activities.
Protecting the rights, property, or safety of you, Habitual Growth, or another party.
Enforcing any agreements with you.
Responding to claims that any posting or other content violates third-party rights.
Resolving disputes.
We will not collect additional categories of Personal Data or use the Personal Data we collected for materially different, unrelated, or incompatible purposes without providing you with notice. If you are a California resident, please note that we only use or disclose your sensitive personal information for the purposes set forth in section 7027(m) of the CCPA regulations, and we do not collect or process sensitive personal data with the purpose of inferring any characteristics about California residents.
We use data that we collect about you and that you provide as well as the inferences we make from that information as follows:
To provide, support, and personalize Habitual Growth and the Habitual Growth functionality you request.
To create, maintain, customize, and secure your Habitual Growth account, if any.
To process your requests and respond to your inquiries.
To provide information on other products or services.
To maintain the safety, security, and integrity of Habitual Growth and the infrastructure that facilitates use of Habitual Growth.
For development and internal analysis.
To fulfill any other purpose for which you provide it.
To carry out our obligations and enforce our rights, including those under this Privacy Policy and our Terms of Use.
As described in this Privacy Policy.
In any other way we may describe when you provide the information; and
For any other purpose with your consent.
Membership.
We use the personal information you provide to create and maintain your membership account. We also use this information to authorize and authenticate your access to your account. We store this information and information pertaining to your use of Habitual Growth (including User Contributions) in connection with your Membership account for so long as you are a Member. For example, your first and last name and email address or phone number will be stored and used by us in connection with your account name or auto-generated account ID to authenticate you as the correct user of your account. We will also store your user contributions in association with your member account to allow you to access, re-access, post, and otherwise utilize your user contributions as you choose.
Friends and Networks
Habitual Growth will allow you to communicate and connect with other Habitual Growth users to share content. It is your choice whether to communicate or connect with another member and to share your information or user contributions.
To facilitate your connections with other Habitual Growth Members, you will be given the choice of whether to share with us the contact information stored on your device. You do not have to share this information to use Habitual Growth or to connect with any particular member. If you decide to share this information with us, it will only be used to try and associate your contacts with other Habitual Growth members to create potential Habitual Growth connections and will only be stored by us for as long as you have a Habitual Growth member account. When you grant access to your contacts on your device for the purpose of friend suggestions, notification of when a contact joins, or sending an invite to Habitual Growth, that information is stored on our servers in a hashed format for the purpose of offering you this functionality.
Features related to your location
Some Habitual Growth features use your precise location, if you choose to share it, to provide or suggest content and information, like helping you to check in to an event or suggesting content from organizations nearby. We will call these “location-based features.” To use or access location-based features, you will be provided the option to share your precise location with us, and if you choose to do so, we will use that information solely to provide location-based features, personalize your experience with Habitual Growth, and internally analyze and develop our products and services.
After you first grant us this permission, we will assume we have your consent to process your location in this way until you revoke or limit your permission. You may choose to revoke or limit your permissions for location sharing through the settings of your device.
If you choose not to share your precise location, some location-related features may still allow for limited functionality (for example, you may still manually search for events around you), but other such features may not be accessible to you. You will still be able to access and use non-location-dependent features of Habitual Growth.
We share your specific location only with your consent. If you choose to make certain location-related information viewable to your friends or the public, you give explicit consent for us to share that information with the audience you specify. You may change this permission at any time in your app settings.
Habitual Growth content
We collect the way you use Habitual Growth and its content, such as any requests, challenges, and plans that you access, and the language in which you choose to utilize that content or find the content. We also collect and store the user contributions you create, such as bookmarks, highlights, and chats. We process this information to allow you to access and use content you create or wish to access through each Habitual Growth session.
You will have the choice of whether to share certain Habitual Growth content and user contributions to your device. You will have the choice of whether to allow Habitual Growth access to your device’s storage to add and modify this downloaded content. Access to the storage of your device is only used by Habitual Growth for downloading this requested content to your device where applicable or required.
It is your choice whether to create, access, or store Habitual Growth information and content. If you do, we will store it in association with your membership account. We may use information about your use of Habitual Growth and the inferences we make from that use to provide recommendations to you of other Habitual Growth content. For example, based upon a challenge or plan you complete, we may suggest additional challenges and plans to you.
Communication from us to you
We communicate with you through push notification, email, or in-app messages. If we communicate to you with email, you may generally unsubscribe to these messages via the unsubscribe link in the emails providing these messages. You can also tailor your notification settings at any time within the settings menu of the Habitual Growth App or by visiting habitualgrowth.com/settings.
Recommendations and Other Communications
We use the data we have about you and inferences we make from that data to recommend certain content and functionality as well as additional products and services offered through Habitual Growth. We may combine the information you provide us with information we collect through other Habitual Growth services and products and the inferences we make from the same for our internal development to improve the overall quality of all services and products provided by Habitual Growth. We may also make recommendations to you for other Habitual Growth services and products based on the information you provide and we infer. We may also use the data we have about you and inferences we make from that data to contact you regarding other opportunities to engage with Habitual Growth. We may contact you through push notification, email, telephone, or in-app messages to discuss these recommendations and opportunities, how to use Habitual Growth, and other news messages.
Polls and Surveys
Polls and surveys are sometimes conducted by us through Habitual Growth. You are not obligated to respond to polls or surveys, and you have choices about the information you provide. Because the purpose of these polls and surveys may vary, we will provide details related to the disclosure and use of personal information in relation to any poll or survey prior to you providing any information.
Security, Legal and Technical Issues
We may use your information to contact you about account security, legal, and other service-related issues. Please be aware that you cannot opt out of receiving such messages from us. We may use your personal information to investigate, respond to, and resolve legal, security, and technical issues and complaints, including, as necessary, security purposes or possible fraud, violations of law or our Terms of Use or this Privacy Policy, or attempts to harm; however, you agree that we have no obligation to prevent or monitor for any of the foregoing.
Notice
We may use your personal information to provide notice regarding a security incident or data breach by (i) sending a message to the email address you provide (as applicable); (ii) posting to a publicly facing page of Habitual Growth or through an in-app message; (iii) through major statewide media; and/or (iv) telephonic means, including calls and/or text messages, even if sent via automated means, including automated dialers. Standard text and data messaging rates may apply from your carrier. Notices sent by email will be effective when we send the email; notices we provide by posting will be effective upon posting and by in-app messaging when the message is made; and notices we provide through telephonic means will be effective when transmitted or dialed. You consent to receiving electronic communications from Habitual Growth and your use and access of the services provided through Habitual Growth. It is your responsibility to keep your email address and any other contact information you provide to us current so that we may provide these communications to you.
Analytics and performance.
We internally analyze the personal data available to us and the use of Habitual Growth content, as well as the inferences we make from that data, to provide and update Habitual Growth, communicate with you and process information as discussed in this Policy, and for internal analytics such as to observe social, economic, and geographic trends as they pertain to Habitual Growth content. In some cases, we work with trusted third parties to perform this research, under controls that are designed to protect your privacy, as discussed below. We may disclose use of Habitual Growth content in an aggregated manner with de-identified and anonymized information that does not disclose any particular user or that user’s personally-identifying information. For example, we may use your data to generate statistics about overall usage of Habitual Growth worldwide or in specific geographic regions or at specific events or locations.
We also use de-identified and aggregate user data to market Habitual Growth, including communications that promote Habitual Growth Membership and network growth, such as celebrating the total number of Habitual Growth installs. When you see stats we share publicly such as global Habitual Growth engagement, we make sure to analyze and publish the data in an aggregated form, protecting your privacy and keeping your identity and personal information confidential. We use data, including user provided personal information, aggregations of user data, data collected through the use of Habitual Growth, public feedback, and information inferred from this data to conduct internal research and development in order to provide a better overall Habitual Growth experience, measure the performance of Habitual Growth, and increase the use of Habitual Growth and its features. This is done by making changes to Habitual Growth that are generally available, as well as sending users messages through Habitual Growth suggesting Habitual Growth functionality and content.
Sensitive Data
By downloading and using Habitual Growth, we do not assume that you are of any religious affiliation or are expressing to us any particular religious belief; we merely assume that you are interested in the content we provide. We do not require that users provide information about such beliefs or provide any other sensitive data such as race, ethnicity, philosophical beliefs, or physical or mental health to use Habitual Growth or create or maintain a Habitual Growth Member account.
Some features available through Habitual Growth utilize personal information that may reflect your religious or philosophical beliefs. Before we collect or process this information for such features, we will obtain your explicit consent. In addition to these features, you have control over the content of certain things you create, share, and store through Habitual Growth, and if you provide us with sensitive information with any content you create, share, and store, we will assume we have your consent to process that information.
We will not sell your sensitive personal information, but we may need to share it with third-party service providers that enable us to provide certain app features, and those service providers are required to keep your personal information confidential and only use it to provide us with their services. We will process the sensitive information we collect and inferences we make about the same in accordance with our Privacy Policy and for the purpose of allowing and facilitating your use of those specific app features, to personalize your user experience, to suggest other content and services, and internally to improve our services. If you choose to provide any sensitive information to us, we may use that information with other non-sensitive information you provide to create a more personalized Habitual Growth experience for you and to perform the services and actions you request, such as sharing or storing content you create. In any event, Habitual Growth will only process sensitive data you provide to us for Habitual Growth’s legitimate activities on your behalf and solely in accordance with the terms of this policy and any additional requests you make about the information. We will also maintain your information subject to appropriate safeguards discussed in this policy and otherwise provided by Habitual Growth.
You have the right to withdraw your consent to our collection and processing of your sensitive personal information by turning off and ceasing to use Habitual Growth features that use this information or by contacting us via email at Habitual Growth, Attn.: Habitual Growth Support at info@habitualgrowth.com; however, withdrawing your consent may hinder our ability to provide certain functionality.
We disclose your Personal Data to the categories of service providers and other parties listed in this section. Depending on state laws that may be applicable to you, some of these disclosures may constitute a “sale” of your Personal Data. For more information, please refer to the state-specific sections below.
Service Providers. These parties help us provide the Services or perform business functions on our behalf. They include:
Hosting, technology and communication providers.
Security and fraud prevention consultants.
Support and customer service vendors.
Product fulfillment and delivery providers.
Payment processors.
Our payment processing partner may collect your voluntarily provided payment card information necessary to process your payment.
Please see our payment processing partners terms of service and privacy policy for information on its use and storage of your Personal Data.
Analytics Partners. These parties provide analytics on web traffic or usage of the Services. They include:
Companies that track how users found or were referred to the Services.
Companies that track how users interact with the Services.
Business Partners. These parties ’partner with us in offering various services. They include:
Businesses that you have a relationship with.
Companies that we partner with offer joint promotional offers or opportunities.
Third parties you access throughout Services.
Your Workplace Administrator, if you choose to join a Workplace or participate in a challenge hosted by your Workplace Administrator.
Social media services that you choose to share information with.
Other users of our Services that you are friends with, in any communities you join, you participate in challenges with, teachers whose content you engage with, or others you otherwise communicate or engage with through our Services.
Researchers, to the extent you consent to participate in their research or surveys.
Public or Private Profiles
Please note that by default, your profile will be deemed “public,” meaning that other users and teachers of our platform will be able to see certain Personal Data about you, such as your name, profile picture, and public reviews or recommendations you’ve posted on our Services. If you make your profile private, you can limit what other users can see about you. You can modify your profile settings by going to “Privacy” under your “Settings” within your mobile application.
Legal Obligations
We may share any Personal Data that we collect with third parties in conjunction with any of the activities set forth under “Meeting Legal Requirements and Enforcing Legal Terms” in the “Our Commercial or Business Purposes for Collecting Personal Data” section above.
Business Transfers
All your Personal Data that we collect may be transferred to a third party if we undergo a merger, acquisition, bankruptcy or other transaction in which that third party assumes control of our business (in whole or in part). Should one of these events occur, we will make reasonable efforts to notify you before your information becomes subject to different privacy and security policies and practices.
5.0 Data that is Not Personal Data
We may create aggregated, de-identified, or anonymized data from the Personal Data we collect, including by removing information that makes the data personally identifiable to a particular user. We may use such aggregated, de-identified, or anonymized data and share it with third parties for our lawful business purposes, including to analyze, build, and improve the Services, promote our business, and work with our Research Partners, provided that we will not share such data in a manner that could identify you.
6.0 Research Partners
The data we collect through your use of our Services gives us valuable insight into wellbeing and health. As such, many educational and scientific institutions want to further enhance society’s understanding of wellbeing and health by carrying out scientific research on the information we collect, this includes the information we collect through your voluntary participation in our surveys.
Although there is a clear common benefit in providing Research Partners with this data we respect our obligations to provide you with appropriate safeguards and to treat your data with respect. Where we share your information with our Research Partners for scientific research and study, we will only provide them with aggregated or de-identified data.
Furthermore, when we share your information with our Research Partners, we stipulate that they protect this information and do not use it for any other purposes than for scientific research or study. We take these relationships seriously and oblige all our Research Partners to sign contracts with us that clearly set out their commitment to respecting individual rights, their commitments to assisting us to help you exercise your rights (as applicable) and that they have in place suitable technological or organizational measures so that the data is secure and protected. Our major Research Partners include a variety of universities and educational institutions.
7.0 Habitual Growth for Work
All registered users of the Services have access to a “Team” functionality (i.e. moving forward referred to as “Workplace” if the user has paid for this functionality or the users company has purchased a license on their behalf. To join a Workplace and access the Workplace features, you must activate your account under the Workplace tab by entering and verifying your work email. If you use your work email to sign up for a Habitual Growth account generally, we may recognize it as a work email and use that information to recommend that you join the available Workplace on the App or Services. If we recommend a Workplace to you, we will show you the Workplace name, number of members, and also inform you if your Workplace is on a Habitual Growth for Work plan. If you choose to join a Workplace, your name and profile photo may be shown to other members of the Workplace and your work email address may be shared with your Workplace Administrator.
If your Workplace Administrator pays for your access to our Habitual Growth for Work paid Services or you register for a Work Account with your work email address, we may create aggregated data by combining data about your use of the Services with data about your co-workers’ use of the Services in order to identify generalized usage trends. If there are five or more registered users in a given period are in a Workplace, your Workplace Administrator will receive access to aggregated data about the use of the Services by the members of such Workplace. Additionally, if your access to the Habitual Growth for Work paid Services is paid for by your Workplace Administrator, we will provide your Workplace Administrator with access to the aggregated data about the use of the Services by members of the Workplace. We will not share information about your use of the Services in a way that could identify you and we will not provide the aggregated data to other users or your Workplace Administrator unless such data set includes information about five or more individuals’ use of the Services.
Challenges and Plans
From time to time, you may be provided the opportunity to join a “Challenge” or a “Plan”. If you choose to participate in a challenge, certain Personal Data (including, but not limited to, your name, profile photo, and statistics of your total number of active days and total active minutes with respect to the given challenge), may be shared with your Workplace Administrator and other participants of the challenge. We won’t share information about the specific features or content you engage with unless it is explicitly required to compete in a given challenge (in which case we will inform you of such requirement before the challenge begins). We may, however, provide aggregate information about how participants engage with our Services with respect to the challenge (for example, that 30% of participants engaged in a live event). Your Workplace Administrator may choose to provide you with prizes or other incentives for joining such challenge. Please note that your Workplace Administrator will be solely responsible for the terms of any such incentive or challenge.
Communities
To help you connect with other users of our Services, we allow users to create communities – this includes Groups, Challenges, and Plans -, generally built on a common interest. If you choose to join or engage with a community, information such as your identifiers or other information you may put into the chat of a community will be made available to other members of the community.
Disclosure of Your Information
We do not sell or share your personal data with any third-party advertisers or ad networks for their advertising purposes. We may disclose your personal information to third parties in order to process information as described above and otherwise enable our ability to provide Habitual Growth, as further discussed below.
Disclosure on your behalf
We may disclose personal information that we collect or you provide as described in this Privacy Policy to fulfill our obligations under our Terms of Use, to accomplish the purpose for which you provide it, for any other purpose you request when you provide the information, or for any other purpose for which we have your consent.
Disclosure by you
When you share information through Habitual Growth, that information is viewable by you and by anyone else you choose to share it with. If you give access to your Habitual Growth account to other applications and services, based on your approval, those services would then have access to your shared information. The use, collection, and protection of your data by such third-party services is subject to those third parties’ policies.
Internal disclosure
We will process your personal data internally within Habitual Growth and its affiliates to help combine the personal information covered across the different aspects of Habitual Growth and our other products and services to help provide services to you in a manner that is personalized and useful to you and others.
Service providers and locations
We may disclose personal information that we collect or provide as described in this Privacy Policy to contractors, service providers, and other third parties we use to support Habitual Growth (such as cloud hosting, cookie providers, maintenance, analysis, audit, external marketing, payment, fraud detection, and development), as well as to support our operations (such as communicating with you for potential employment purposes). We may combine information we have with information of these service providers to facilitate their support. For example, some of the platforms used to send emails and notifications provided through Habitual Growth are built and managed by third parties, so some of your information is sent securely to those services to provide such functionality. They will have access to your information only as reasonably necessary to perform these tasks on our behalf and are obligated not to disclose or use it for other purposes. We may also provide aggregate, de-identified information concerning connections by Habitual Growth users with third-parties and their events or locations.
8.0 Donations and Giving
If you choose to provide a voluntary donation through Habitual Growth or a third-party website linked to Habitual Growth, then and only then will you be prompted and required to provide credit card, bank account, and other financial information necessary to process the transaction. We will collect the designation for your donation, if you provide one, and personal information such as your name, address, country, phone number, and/or email address to ensure that your donation is used for the purpose you request and to provide you with an “Annual Giving Statement” that itemizes your donation(s) for tax purposes or your personal use. We will not store or otherwise process financial information provided to us online for the purposes of donating. If you designate a donation to an institution other than Habitual Growth, to facilitate your donation, we share your name, email, mailing address, and phone number with the designated institution as well as the date, amount, payment method, and the last four digits of the card or account number used for your donation. As of the date of this Policy, we have not determined a specific company to process your online donation payments. It may vary from individual to individual.
9.0 Habitual Growth content providers
We utilize certain third parties to provide certain Habitual Growth content, such as Habitual Growth Challenges and Plans. We do not share personal information of Habitual Growth users with these third parties. We do, however, provide these third parties with aggregate analytics concerning the use of their content by country using de-identified and anonymized data.
Legal process
It is possible that we will need to disclose information about you when required by law, subpoena, or other legal process. We attempt to notify Users about legal demands for their personal data when appropriate in our judgment, unless prohibited by law or court order or when the request is an emergency. We may dispute such demands when we believe, in our discretion, that the requests are overbroad, vague, or lack proper authority, but we do not promise to challenge every demand. We may also disclose your information if we have a good faith belief that disclosure is reasonably necessary to (i) investigate, prevent, or take action regarding suspected or actual illegal activities or to assist government enforcement agencies; (ii) enforce our agreements with you; (iii) investigate and defend ourselves against any third-party claims or allegations; (iv) protect the security or integrity of Habitual Growth; or (v) exercise or protect the rights and safety of Habitual Growth, Users, our personnel, or others. We also reserve the right to confidentially disclose personal information we have about you in connection with a potential or actual merger or acquisition such as the sale of all or substantially all of our assets.
The Services use cookies and similar technologies such as pixel tags, web beacons, clear GIFs and JavaScript (collectively, “Cookies”) to enable our servers to recognize your web browser, tell us how and when you visit and use our Services, analyze trends, learn about our user base and operate and improve our Services. Cookies are small pieces of data– usually text files – placed on your computer, tablet, phone or similar device when you use that device to access our Services. We may also supplement the information we collect from you with information received from third parties, including third parties that have placed their own Cookies on your device(s). Please note that because of our use of Cookies, the Services do not support “Do Not Track” requests sent from a browser at this time.
We use the following types of Cookies:
Essential Cookies
Essential Cookies are required for providing you with features or services that you have requested. For example, certain Cookies enable you to log into secure areas of our Services. Disabling these Cookies may make certain features and services unavailable.
Functional/Personalization Cookies
Functional Cookies are used to record your choices and settings regarding our Services, maintain your preferences over time and recognize you when you return to our Services. These Cookies help us to personalize our content for you, greet you by name and remember your preferences (for example, your choice of language or region).
Performance/Analytical Cookies
Performance/Analytical Cookies allow us to understand how visitors use our Services. They do this by collecting information about the number of visitors to the Services, what pages visitors view on our Services and how long visitors are viewing pages on the Services. Performance/Analytical Cookies also help us measure the performance of our advertising campaigns in order to help us improve our campaigns and the Services’ content for those who engage with our advertising. For example, Google LLC (“Google”) uses cookies in connection with its Google Analytics services. Google’s ability to use and share information collected by Google Analytics about your visits to the Services is subject to the Google Analytics Terms of Use and the Google Privacy Policy. You have the option to opt-out of Google’s use of Cookies by visiting the Google advertising opt-out page at www.google.com/privacy_ads.html or the Google Analytics Opt-out Browser Add-on at https://tools.google.com/dlpage/gaoptout/.
Retargeting/Advertising Cookies
Retargeting/Advertising Cookies collect data about your online activity and identify your interests so that we can provide advertising that we believe is relevant to you. For more information about this, please see the section below titled “Information about Interest-Based Advertisements.”
You can decide whether or not to accept Cookies through your internet browser’s settings. Most browsers have an option for turning off the Cookie feature, which will prevent your browser from accepting new Cookies, as well as (depending on the sophistication of your browser software) allow you to decide on acceptance of each new Cookie in a variety of ways. You can also delete all Cookies that are already on your device. If you do this, however, you may have to manually adjust some preferences every time you visit our website and some of the Services and functionalities may not work.
To explore what Cookie settings are available to you or to modify your preferences with respect to Cookies, you can access your Cookie management settings by accessing your "Cookie Settings" at the bottom left of our website. To find out more information about Cookies generally, including information about how to manage and delete Cookies, please visit http://www.allaboutcookies.org/ or https://ico.org.uk/for-the-public/online/cookies/ if you are located in the European Union.
Session Replay Technology
We may use session replay technology to identify and resolve customer issues, to monitor and analyze how you use our Services, to better understand user behavior, and to improve our Services. By continuing to use the Services, you consent to the use of session replay technology. If you would like to change your settings with respect to session replay technology, you can press "Cookie Settings" on the bottom left of our website.
Information about Interest-Based Advertisements
We may serve advertisements, and allow third-party ad networks, including third-party ad servers, ad agencies, ad technology vendors and research firms, to serve advertisements through the Services. These advertisements may be targeted to users who fit certain general profile categories or display certain preferences or behaviors (“Interest-Based Ads”). Information for Interest-Based Ads (including Personal Data) may be provided to us by you, or derived from the usage patterns of particular users on the Services and/or services of third parties. Such information may be gathered through tracking users’ activities across time and unaffiliated properties, including when you leave the Services. To accomplish this, we or our service providers may deliver Cookies, including a file (known as a “web beacon”) from an ad network to you through the Services. Web beacons allow ad networks to provide anonymized, aggregated auditing, research and reporting for us and for advertisers. Web beacons also enable ad networks to serve targeted advertisements to you when you visit other websites. Web beacons allow ad networks to view, edit or set their own Cookies on your browser, just as if you had requested a web page from their site.
We seek to protect your Personal Data from unauthorized access, use and disclosure using appropriate physical, technical, organizational and administrative security measures based on the type of Personal Data and how we are processing that data. You should also help protect your data by appropriately selecting and protecting your password and/or other sign-on mechanism; limiting access to your computer or device and browser; and signing off after you have finished accessing your account. Although we work to protect the security of your account and other data that we hold in our records, please be aware that no method of transmitting data over the internet or storing data is completely secure.
We maintain physical, electronic, and procedural safeguards to protect the confidentiality and security of information transmitted to us. For example, we use industry-standard Secure Sockets Layer (SSL) encryption to protect the transmission of information. We also maintain ISO 27017-certified infrastructure. However, no data transmission over the Internet or other network can be guaranteed to be 100% secure. As a result, while we strive to protect information transmitted on or through Habitual Growth, we cannot and do not guarantee the security of any information you transmit on or through Habitual Growth, and you do so at your own risk.
We retain Personal Data about you for as long as necessary to provide you with our Services or to perform our business or commercial purposes for collecting your Personal Data. When establishing a retention period for specific categories of data, we consider who we collected the data from, our need for the Personal Data, why we collected the Personal Data, and the sensitivity of the Personal Data. In some cases we retain Personal Data for longer, if doing so is necessary to comply with our legal obligations, resolve disputes or collect fees owed, or is otherwise permitted or required by applicable law, rule or regulation. We may further retain information in an anonymous or aggregated form where that information would not identify you personally.
For example:
We retain your profile information and credentials for as long as you have an account with us.
We retain your payment data for as long as we need to process your purchase or subscription.
We retain your device/IP data for as long as we need it to ensure that our systems are working appropriately, effectively and efficiently.
You can also submit a request to delete your account and Personal Data at any time by emailing us at info@habitualgrowth.com.
We provide you with the ability to access, rectify, port, and erase your personal data. You may also object to or limit the use of your personal data. You may make these requests by contacting us at info@habitualgrowth.com. We will respond to your request within a reasonable timeframe. We may require you to verify your identity before we are able to respond to your request.
You may delete your account at any time. When you delete your account, we do not delete your data in the event that you may want to restart your subscription and engagement with Habitual Growth. We will delete your data if you specifically request to have your information deleted. We will also delete your User Contributions unless you have shared them with others and they have not deleted them, or you have posted them to public areas of Habitual Growth. We may retain some personal data if necessary to comply with our legal obligations, resolve disputes, or enforce our agreements. For example, we may retain your email address to ensure that you do not create another account with the same email address.
10.0 California Resident Rights
If you are a California resident, you have the rights set forth in this section. Please see the “Exercising Your Rights” section below for instructions regarding how to exercise these rights. Please note that we may process Personal Data of our customers’ end users or employees in connection with our provision of certain services to our customers. If we are processing your Personal Data as a service provider, you should contact the entity that collected your Personal Data in the first instance to address your rights with respect to such data.
If there are any conflicts between this section and any other provision of this Privacy Policy and you are a California resident, the portion that is more protective of Personal Data shall control to the extent of such conflict. If you have any questions about this section or whether any of the following rights apply to you, please contact us at info@habitualgrowth.com.
Access
You have the right to request certain information about our collection and use of your Personal Data over the past 12 months. In response, we will provide you with the following information:
The categories of Personal Data that we have collected about you.
The categories of sources from which that Personal Data was collected.
The business or commercial purpose for collecting or selling your Personal Data.
The categories of third parties with whom we have shared your Personal Data.
The specific pieces of Personal Data that we have collected about you.
If we have disclosed your Personal Data to any third parties for a business purpose over the past 12 months, we will identify the categories of Personal Data shared with each category of third-party recipient. If we have sold your Personal Data over the past 12 months, we will identify the categories of Personal Data sold to each category of third-party recipient.
Deletion
You have the right to request that we delete the Personal Data that we have collected about you. Under the CCPA, this right is subject to certain exceptions: for example, we may need to retain your Personal Data to provide you with the Services or complete a transaction or other action you have requested, or if deletion of your Personal Data involves disproportionate effort. If your deletion request is subject to one of these exceptions, we may deny your deletion request.
Correction
You have the right to request that we correct any inaccurate Personal Data we have collected about you. Under the CCPA, this right is subject to certain exceptions: for example, if we decide, based on the totality of circumstances related to your Personal Data, that such data is correct. If your correction request is subject to one of these exceptions, we may deny your request.
Personal Data Sales and Shares Opt-Out and Opt-In
In this section, we use the terms ‘sell’ and ‘share’ as it is defined in the CCPA. As of the date that this Privacy Policy has been published we do not currently sell any data to third-parties. However, in the future that may change. We may sell and/or share your Personal Data, subject to your right to opt-out as described in this section.
As described in the applicable sections above, we have incorporated Cookies from certain third parties into our Services. These Cookies allow those third parties to receive information about your activity on our Services that is associated with your browser or device. Those third parties may use that data to serve you relevant ads on our Services or on other websites you visit. Under the CCPA, disclosing your data through third party Cookies for online advertising may be considered “selling” and “sharing” of information. You can opt out of this “selling” and “sharing” by following the instructions in this section.
We may sell and/or share your Personal Data to the following categories of third parties:
Ad Networks
Marketing providers
Over the past 12 months, we may have sold and/or shared the following categories of your Personal Data to categories of third parties listed above:
We may have sold and/or shared the foregoing categories of Personal Data for the following business or commercial purposes:
Improving the Services, including testing, research, internal analytics and product development.
Marketing and selling the Services.
Showing advertisements, including interest-based or online behavioral advertising.
You have the right to opt-out of the selling or sharing of your Personal Data. You can opt-out using the following methods:
By accessing your cookie consent mechanism by accessing your "Cookie Settings" at the bottom left of our website.
By implementing Global Privacy Control or similar universal privacy control that is legally recognized by a government agency or industry standard and that complies with the CCPA. The signal issued by the control must be initiated by your browser and applies to the specific device and browser you use at the time you cast the signal. We will process signals from the Global Privacy Control in a frictionless manner. Please note this does not include Do Not Track signals.
Once you have submitted an opt-out request, we will not ask you to reauthorize the sale of your Personal Data for at least 12 months.
To our knowledge, we do not sell the Personal Data of minors under 16 years of age. Under the CCPA, we disclose the Personal Data of minors under 16 years of age in a way that may be considered a sale.
We Will Not Discriminate Against You for Exercising Your Rights Under the CCPA
We will not discriminate against you for exercising your rights under the CCPA. We will not deny you our goods or services, charge you different prices or rates, or provide you a lower quality of goods and services if you exercise your rights under the CCPA. However, we may offer different tiers of our Services as allowed by applicable data privacy laws (including the CCPA) with varying prices, rates or levels of quality of the goods or services you receive related to the value of Personal Data that we receive from you.
11.0 Virginia Resident Rights
If you are a Virginia resident, you have the rights set forth under the Virginia Consumer Data Protection Act (“VCDPA”). Please see the “Exercising Your Rights” section below for instructions regarding how to exercise these rights. Please note that we may process Personal Data of our customers’ end users or employees in connection with our provision of certain services to our customers. If we are processing your Personal Data as a service provider, you should contact the entity that collected your Personal Data in the first instance to address your rights with respect to such data. Additionally, please note that these rights are subject to certain conditions and exceptions under applicable law, which may permit or require us to deny your request.
If there are any conflicts between this section and any other provision of this Privacy Policy and you are a Virginia resident, the portion that is more protective of Personal Data shall control to the extent of such conflict. If you have any questions about this section or whether any of the following rights apply to you, please contact us at info@habitualgrowth.com.
You have the right to request confirmation of whether or not we are processing your Personal Data and to access your Personal Data.
You have the right to correct inaccuracies in your Personal Data, to the extent such correction is appropriate in consideration of the nature of such data and our purposes of processing your Personal Data.
Portability
You have the right to request a copy of your Personal Data in a machine-readable format, to the extent technically feasible and you have the right to request to have your Personal Data deleted..
Opt-Out of Certain Processing Activities
You have the right to opt-out of the processing of your Personal Data for targeted advertising purposes. You can opt-out by:
By implementing the Global Privacy Control or similar universal privacy control that is legally recognized by a government agency or industry standard and that complies with the VCDPA. The signal issued by the control must be initiated by your browser and applies to the specific device and browser you use at the time you cast the signal. Please note this does not include Do Not Track signals.
You have the right to opt-out to the sale of your Personal Data. We do not currently sell your Personal Data as defined under the VCDPA.
You have the right to opt-out from the processing of your Personal Data for the purposes of profiling in furtherance of decisions that produce legal or similarly significant effects to you, if applicable.
Appealing a Denial
If we refuse to act on a request within a reasonable period of time after receiving your request in accordance with this section. In such appeal, you must (1) provide sufficient information to allow us to verify that you are the person about whom the original request pertains and to identify the original request, and (2) provide a description of the basis of your appeal. Please note that your appeal will be subject to your rights and obligations afforded to you under the VCDPA. We will respond to your appeal within 60 days of receiving your request. If we deny your appeal, you have the right to contact the Virginia Attorney General using the methods described at https://www.oag.state.va.us/consumer-protection/index.php/file-a-complaint.
You may appeal a decision by emailing us at: info@habitualgrowth.com (title must include “VCDPA Appeal”)
12.0 Exercising Your Rights under CCPA and VCPDA
To exercise the rights described in this Privacy Policy, you or, if you are a California resident, your Authorized Agent (defined below) must send us a request that (1) provides sufficient information to allow us to verify that you are the person about whom we have collected Personal Data, and (2) describes your request in sufficient detail to allow us to understand, evaluate and respond to it. Each request that meets both of these criteria will be considered a “Valid Request.” We may not respond to requests that do not meet these criteria. We will only use Personal Data provided in a Valid Request to verify your identity and complete your request. You do not need an account to submit a Valid Request.
We will work to respond to your Valid Request within the time period required by applicable law. We will not charge you a fee for making a Valid Request unless your Valid Request(s) is excessive, repetitive or manifestly unfounded. If we determine that your Valid Request warrants a fee, we will notify you of the fee and explain that decision before completing your request.
Except as otherwise provided above (for instance, instructions to opt-out from the "selling" or "sharing" of your Personal Data are described in the "Personal Data Sales and Shares Opt-Out and Opt-In" section above), you may submit a Valid Request using the following methods:
Email: info@habitualgrowth.com
Visiting the Contact Us page on our website: www.habitualgrowth.com/contact
If you are a California resident, you may also authorize an agent (an “Authorized Agent”) to exercise your rights on your behalf. To do this, you must provide your Authorized Agent with written permission to exercise your rights on your behalf, and we may request a copy of this written permission from your Authorized Agent when they make a request on your behalf.
13.0 Other State and Country Law Privacy Rights
Under California Civil Code Sections 1798.83-1798.84, California residents are entitled to contact us to prevent disclosure of Personal Data to third parties for such third parties’ direct marketing purposes; to submit such a request, please contact us at info@habitualgrowth.com. Please note that we do not currently disclose Personal Data to third parties for such third parties’ direct marketing purposes.
Nevada Resident Rights
If you are a resident of Nevada, you have the right to opt-out of the sale of certain Personal Data to third parties who intend to license or sell that Personal Data. You can exercise this right by contacting us at info@habitualgrowth.com with the subject line “Nevada Do Not Sell Request” and providing us with your name and the email address associated with your account. Please note that we do not currently sell your Personal Data as sales are defined in Nevada Revised Statutes Chapter 603A.
European Union and United Kingdom Data Subject Rights
If you are a resident of the European Union (“EU”), United Kingdom (“UK”), Lichtenstein, Norway or Iceland, you may have additional rights under the EU or UK General Data Protection Regulation (the “GDPR”) with respect to your Personal Data, as outlined below.
For this section, we use the terms “Personal Data” and “processing” as they are defined in the GDPR, but “Personal Data” generally means information that can be used to individually identify a person, and “processing” generally covers actions that can be performed in connection with data such as collection, use, storage and disclosure. Habitual Growth will be the controller of your Personal Data processed in connection with the Services.
If there are any conflicts between this section and any other provision of this Privacy Policy, the policy or portion that is more protective of Personal Data shall control to the extent of such conflict. If you have any questions about this section or whether any of the following applies to you, please contact us at info@habitualgrowth.com. Note that we may also process Personal Data of our customers’ end users or employees in connection with our provision of certain services to customers, in which case we are the processor of Personal Data. If we are the processor of your Personal Data (i.e., not the controller), please contact the controller party in the first instance to address your rights with respect to such data.
14.0 Personal Data We Collect
The “Categories of Personal Data We Collect” section above details the Personal Data that we collect from you.
Personal Data Use and Processing Grounds
The “Our Commercial or Business Purposes for Collecting 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, as further described below.
Contractual Necessity: We process the following categories of Personal Data as a matter of “contractual necessity”, meaning that we need to process the data to perform under our Terms of Service with you, which enables us to provide you with the Services. When we process data due to contractual necessity, failure to provide such Personal Data will result in your inability to use some or all portions of the Services that require such data.
Legitimate Interest: We process the following categories of Personal Data when we believe it furthers the legitimate interest of us or third parties:
We may also de-identify or anonymize Personal Data to further our legitimate interests.
Examples of these legitimate interests include (as described in more detail above):
Providing, customizing and improving the Services.
Marketing the Services.
Corresponding with you.
Meeting legal requirements and enforcing legal terms.
Completing corporate transactions.
Consent: In some cases, 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, it will be expressly indicated to you at the point and time of collection.
Other Processing Grounds: 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.
Sharing Personal Data
The “How We Share Your Personal Data” section above details how we share your Personal Data with third parties.
EU and UK Data Subject Rights
You have certain rights with respect to your Personal Data, including those set forth below. For more information about these rights, or to submit a request, please email us at info@habitualgrowth.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 you to provide us with additional information, which may include Personal Data, if necessary to verify your identity and the nature of your request.
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 of your Personal Data by logging on to your account.
Rectification: If you believe that any Personal Data 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 on to 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 Habitual Growth’s practices with respect to your Personal Data with the supervisory authority of your country or EU Member State. A list of Supervisory Authorities is available here: https://edpb.europa.eu/about-edpb/board/members_en.
15.0 Transfers of Personal Data
The Services are hosted and operated in the United States (“U.S.”) through Habitual Growth and its service providers, and if you do not reside in the U.S., laws in the U.S. may differ from the laws where you reside. By using the Services, you acknowledge that any Personal Data about you, regardless of whether provided by you or obtained from a third party, is being provided to Habitual Growth in the U.S. and will be hosted on U.S. servers, and you authorize Habitual Growth to transfer, store and process your information to and in the U.S., and possibly other countries. In some circumstances, your Personal Data may be transferred to the U.S. pursuant to a data processing agreement incorporating standard data protection clauses.
16.0 Users From Outside the United States
If you are a user located outside the United States, please be aware that any information you provide to us, including personal information, will be transferred to and processed in the United States. The United States has not sought nor received a finding of “adequacy” from the European Union under Article 45 of the GDPR. We rely on derogations for specific situations as set forth in Article 49 of the GDPR. In particular, we collect and transfer to the U.S. personal data only: with your consent; to perform a contract with you; or to fulfill a compelling legitimate interest of Habitual Growth in a manner that does not outweigh your rights and freedoms. We endeavor to apply suitable safeguards to protect the privacy and security of your personal data and to use it only consistent with your relationship with us and the practices described in this Privacy Policy. We also enter into data processing agreements and standard contractual clauses with our vendors and partners whenever appropriate.
17.0 Data Collection of Minors
As noted in the Terms of Service, we do not knowingly collect or solicit Personal Data about children under 16 years of age; if you are a child under the age of 16, please do not attempt to register for or otherwise use the Services or send us any Personal Data. If we learn we have collected Personal Data from a child under 16 years of age, we will delete that information as quickly as possible. If you believe that a child under 16 years of age may have provided Personal Data to us, please contact us at info@habitualgrowth.com.
We are committed to protecting the privacy of children. Habitual Growth is not intended for children under 13 years of age. No one under age 13 may provide any personal information to or on Habitual Growth. We do not knowingly collect personal information from children under 13. If you are under 13, do not use or provide any information on Habitual Growth or through any of its features, register on Habitual Growth, make any purchases through Habitual Growth, use any of the interactive or public comment features of Habitual Growth or provide any information about yourself to us, including your name, address, telephone number, email address, or any screen name or user name you may use. If you believe we might have any information from or about a child under 13, please contact us at info@habitualgrowth.com.
As described in the “Cookies and Tracking Technologies” section above, we have incorporated Cookies from certain third parties into our Services. These Cookies allow those third parties to receive information about your activity on our Services that is associated with your browser or device. Those third parties may use that data to serve you relevant ads on our Services or on other websites you visit. Under the CCPA, disclosing your data through third party Cookies for online advertising may be considered “selling” and “sharing” of information. You can opt out of this “selling” and “sharing” by following the instructions shared in the applicable sections noted above.
18.0 Policy Revisions
We will maintain archived versions of our Privacy Policy for your review. The date the Privacy Policy was last revised is identified at the top of the page. You are responsible for ensuring we have an up-to-date active and deliverable email address for you, and for periodically visiting this Privacy Policy to check for any changes.
You can learn more about historical revisions by contacting Habitual Growth through the following:
Email: info@habitualgrowth.com
Website: www.habitualgrowth.com/contact
Previous versions of our Privacy Policies: