AS OF DATE OF LAST MODIFICATION: February 2, 2021
Your privacy is important to us. Please read this privacy notice (the “Privacy Notice”) carefully, which includes, as applicable, your California Privacy Rights, your rights as a citizen of the European Union, or your rights as a citizen of the United Kingdom, to learn what information we collect from you, how we use the information we collect at this Website www.lifeengineering.com (the “Website”), and how your personal information is made available to third parties. By using this Website, you accept the terms of this Privacy Notice
We reserve the right to make changes to this Privacy Notice from time to time without prior notice to you. Any changes will take effect immediately upon posting the revised privacy notice. However, we will not use your personal information in a manner materially different than what was stated when it was collected unless you consent.
BY ACCESSING OUR WEBSITE, YOU AGREE TO THE TERMS OF THE PRIVACY NOTICE. IF YOU DO NOT AGREE TO THIS PRIVACY NOTICE, OR TO ANY CHANGES WE MAY SUBSEQUENTLY MAKE, WE REQUEST THAT YOU STOP ACCESSING OUR WEBSITE.
Our Website is not intended for children. We do not knowingly collect personal information from children under the age of thirteen (13). If you are a parent or guardian of a child under the age of thirteen and believe he or she has disclosed personal information to us without your permission, please contact our Data Privacy Officer at [email protected] A parent or guardian of a child under the age of thirteen may review and request deletion of such child’s personal information as well as prohibit the use thereof.
This Website is operated in the United States (US) and is intended for users located in the US. If you are located outside of the US and continue to access this Website, please be advised your personal information will be transferred to us in the US, and by using our Website, you consent to that transfer and use of your personal information in accordance with this Privacy Notice.
1. TYPE AND NATURE OF THE DATA COLLECTED AND PROCESSED.
1.1 PERSONAL INFORMATION.
“Personal Information” is any information that identifies you or can be used to identify or contact you, such as your name, date of birth, mailing address, phone number, and other similar information.
1.2 NON-PERSONAL INFORMATION.
Non-personal information is any information that does not personally identify you, including certain Personal Information that has been de-identified or rendered anonymous.
Collectively, Personal Information and Non-Personal Information may be referred to in this Privacy Notice as your data.
2. HOW WE COLLECT DATA
2.1 INFORMATION YOU PROVIDE
When you register with us, we collect and store the following Personal Information: your name, address, email address, phone number, gender, occupation, position, age, education, race, marital status, and languages spoken, as well as additional contact information such as your username and password. We may receive additional information about you if you enter it through the Website (for example, when you set up your personal profile) or through your communication with us. The legal basis for the processing of your sensitive data (e.g. race, religion) is your consent. You may decline to provide sensitive information to us. If you provide it, you give your consent to our processing of that sensitive data as explained in this Privacy Notice. You may withdraw your consent at any time by contacting us using the information provided at the end of this Notice. The basis for our processing of the data you provide to us that is not sensitive in nature is to fulfill your request.
When you place orders through the Website, we need your name, delivery address, billing address, email address, phone number, credit card number, and expiration date to process the transaction and notify you of the status of your order. The legal basis of this processing is the fulfilment of the contract.
We and/or our third-party service providers may obtain non-personal information about you from information that you provide us, either separately or together with your Personal Information. The legal bases for this processing are legitimate interest and to fulfil your request.
Cookies are small ﬁles that are stored on your computer or mobile device, and they identify the device when connecting to our server, as well as providing additional information. Other technologies such as tracking pixels, web bugs, web storage, and similar ﬁles serve the same purpose. Cookies are stored on your computer.
One type of cookie expires automatically at the end of your session and is referred to as a session cookie. Your user settings are stored as session cookies, so that you can always use this Website in the way you prefer. In addition, Life Engineering stores its users’ settings such as language selection, speech recognition settings and user IDs for various applications in both session cookies and permanent cookies to simplify the use of the Website.
Deactivating cookies will mean that a number of website functions will no longer operate as intended.
The legal bases for the processing described above is the fulﬁlment of your request for session cookies and legitimate interest for other cookies. The legitimacy stems ﬁrst from our interest in the evaluation of the data of the website for its optimization and second, based on the reasonable foreseeability of the collection
and processing in view of the circumstances under which it takes place.
2.2 LOG FILES FOR WEB PAGE VIEWS
Life Engineering uses external tracking services that implement technology to track non-personal information about visitors to this Website. The access data is stored in a log ﬁle—the server log—every time a page is accessed. The resulting data set contains the following data:
-your IP address (which can be used to uniquely identify your computer)
-the name and IP address of the computer requesting the page (remote host)
-the time, status, amount of data transferred and website from which you accessed the requested page (referrer)
-the product and version information of the browser you used (user agent)
A standardized file format for the web server log is used for this purpose. Provided that this data is not absolutely necessary for the technical maintenance of the system or system security, it is immediately anonymized, and the original logs deleted. Anonymization takes place through the removal or shortening of the IP address by assigning a code that is not assigned to any specific user. This means that assignment to a specific or identifiable person is no longer possible. Life Engineering uses log data (log files) exclusively in anonymous form for statistical evaluations without any link or references to your personally identifying data. This enables us to detect possible program errors or incorrect links and to continuously develop and improve the Website. Life Engineering does not link page views and usage information to individual people. The legal basis for this processing is the fulfillment of your request.
2.3 WEB ANALYSIS SOFTWARE
In addition to the technologies used to execute the page functions, we also employ web analysis software. Data collected by this software may include the time and duration of the visit, the pages visited, the browser used, add-ons/plug-ins, search engines, and referrer URLs.
Web analysis is carried out by Google Analytics, a web analysis service provided by Google, Inc., among others. Google Analytics uses “cookies”—text files stored on your computer—to be able to analyze how you use the Website. Google will use this information to evaluate your usage of the website, to generate reports on website activity for the website operator, and to provide other services associated with website activity and internet use.
The legal basis for the processing described above, in Section 2.3, and below, in Section 2.4, is legitimate interest, where by the legitimacy stems ﬁrst from our interest in the evaluation of the data of the website for its optimization and second, based on the reasonable foreseeability of the collection and processing in view of the circumstances under which it takes place.
2.4 TRACKING PIXELS (WEB BEACONS / WEB BUGS)
We may use software technology called tracking pixels (also known as web beacons / web bugs) to help us manage the content on our Website better by determining the greatest eﬀectiveness.
Tracking pixels are tiny graphics with a unique identiﬁer that function in a manner similar to cookies and are used to track the online movements of web users. Unlike cookies, which are installed on the hard drive of the user’s computer, tracking pixels are invisible. We do not link the data collected by tracking pixels to our customers’ personal data.
We may use tracking pixels in our HTML emails to track which emails have been opened by recipients. This enables us to evaluate the eﬀectiveness of certain communications and of our marketing campaigns.
All email messages sent by us that are subject to archiving requirements are stored by us. Every email that can be regarded as a business letter or is relevant for tax purposes will not be deleted during the period of the legal obligation to keep records in accordance with tax, commercial, and other applicable laws of the United States or the jurisdiction of your residence. Furthermore, we collect all email addresses to which messages could not be delivered to enable us to request a current email address. Email messages from Life Engineering may contain graphics or links, the accessing of which allows us to determine whether an email message has been opened. This is done anonymously. The legal bases for this processing are the fulfilment of your request, the fulfilment of the contract, and legal obligation.
2.6 MOBILE DEVICE IDENTIFIERS
Some mobile service providers uniquely identify mobile devices, and we may receive such device information if you access the Website through mobile devices. Some features of our Website may require collection of mobile phone numbers, and we may associate that phone number to mobile device identification information. Additionally, some mobile phone service providers operate systems that pinpoint the physical location of devices that use their service. Depending on the provider, we may receive this information. The legal basis of this processing is legitimate interest, whereby the legitimacy stems ﬁrst from our interest in the evaluation of the data of the website for the optimization of its features and second, based on the reasonable foreseeability of the collection and processing in view of the circumstances under which it takes place.
3. PURPOSE OF DATA COLLECTION AND DATA STORAGE
We collect, store, process, and use your data for following purposes: (1) to deliver the products and services that you have requested (e.g. personal management,
recommendation engine, and goal setting); (2) to manage your account and provide you with customer support; (3) to communicate with you by email, postal mail, telephone and/or mobile devices about products or services that may be of interest to you either from us, our affiliate companies, or other third parties; (4) to develop and display content and advertising tailored to your interests on the Website and other sites; (5) to simplify, administer, and further develop the Website; (6) to resolve disputes and troubleshoot problems; (7) to measure consumer interest in our services; (8) to inform you of updates; (9) to customize your experience; (10) to detect and protect us against error, fraud and other criminal activity; (11) to enforce the terms of our agreements with you; and (12) to do as otherwise described to you at the time of collection.
Life Engineering will send you emails for various reasons (e.g., to confirm orders). These emails may also contain information about our services, new product offers, and promotions, provided you have agreed to the usage of your email address for this purpose. You can unsubscribe from marketing communications by clicking the “unsubscribe” link at the bottom of such emails. You may also contact us directly using the information provided below.
4. TO WHOM DO WE DISCLOSE YOUR PERSONAL DATA?
Life Engineering will not share personal data with third parties for the purposes of their marketing or other purposes unless you have given your explicit consent, or the sharing of information is required by law.
4.1 EMPLOYEES AND CONTRACTUAL PARTNERS
Your data may be shared with Life Engineering employees and third parties who provide technical or organizational services for Life Engineering and are required and have agreed to protect your data. The legal basis for this processing is the fulfilment of your request and order processing.
4.2 REPRESENTATIVES/SERVICE PROVIDERS
We use the services of other companies such as shipping companies for transporting orders and credit card companies for billing. These service providers are prohibited from using your personal information. The legal bases for this processing are the fulfilment of your request and order processing.
4.3 TRANSFER AS A CONSEQUENCE OF A CHANGE IN LEGAL ENTITY
Life Engineering’s ownership rights may be transferred by merger, acquisition by another company, or sale of all or part of its assets, in which case your personal information may also be included in the transferred assets. We will notify you by email and on our Website of any such changes and the protection of your data in this case. The legal basis for this processing is legitimate interest whereby the legitimacy stems from our business interest in the corresponding change in assets and the reasonable foreseeability to the data subject at the time of the collection of the personal data.
4.4 DISCLOSURE OBLIGATIONS
In some cases, we may be required to disclose your data, including your Personal Information, to public authorities to comply with legal requirements. In such cases, we will take appropriate measures to ensure the confidentiality of your data. The legal basis for this processing is our legal obligation.
5. DATA SECURITY
Life Engineering takes precautions to ensure that your data is protected against loss, modification and improper use. Life Engineering uses firewalls that are constantly updated and meet industry standards, and also uses other security systems. Unfortunately, it is impossible to provide absolute protection against attacks by new viruses or other methods of attacking the secure data systems of internet services. However, Life Engineering will initiate civil and criminal proceedings against any attack by hackers and the like. In the event that your personal information (as such may be defined by any applicable law requiring notice upon a security breach) is compromised, we may notify you by email in our sole discretion unless required by law to the last email address you provided us in the most expedient time reasonable under the circumstances. Delays in notification may occur while we take necessary measures to determine the scope of the breach and restore reasonable integrity to the system, as well as for the legitimate needs of law enforcement if notification would impede a criminal investigation.
Life Engineering uses Secure Socket Layer (SSL) for the encrypted transfer of sensitive data, such as the password for your account and billing information, including credit card information, from your web browser to our web server. From time to time we evaluate new technology for protecting information and, when appropriate, we upgrade our information security systems.
6. YOUR PERSONAL INFORMATION
Life Engineering is committed to ensuring the privacy of your Personal Information and will abide by the following commitments regarding your Personal Information.
6.1 REVOCATION OF CONSENT
You can revoke any consents you have given to us with regard to your Personal Information at any time. Data processing based on the revoked consent would no longer be continued in the future, although there may be instances in which Life Engineering must retain information for its legitimate interests or for tax and legal record-keeping purposes as allowed by law.
We will provide you with access to Personal Information about you that we hold.
You may correct any errors in the Personal Information processed by us. To make a correction request, please contact Life Engineering’s Data Protection Officer by sending an email to [email protected]
You may request the deletion of your Personal Information stored with us, so long as the processing
thereof is not necessary to exercise the right to freedom of expression and information, to fulfil a legal obligation, for reasons of public interest or to assert, exercise, or defend legal claims.
7. YOUR EUROPEAN UNION AND UNITED KINGDOM PRIVACY RIGHTS
The General Data Protection Regulation (EU) 2016/679 (“GDPR”) and the United Kingdom General Data Protection Regulation (“UK-GDPR”) give residents of the European Union (“EU”) and the United Kingdom (“UK”), respectively, special rights. In addition to the rights listed above in Section 6, if you are a resident of the EU or the UK, you are entitled to the following:
7.1 RESTRICTION OF PROCESSING
You may request that the processing of your personal data be restricted if you dispute the accuracy of the data or if the processing is unlawful but you refuse the deletion of it. You also have this right if we no longer need the data, but you need it to assert, exercise, or defend legal claims. In addition, you have this right if you have objected to the processing of your personal data. If we process your personal data based on a legitimate interest, you have the right to object to the processing by notifying us in writing.
You may request that we provide you with the personal data you have provided to us in a structured, common and machine-readable format. You can alternatively request the direction transmission of the personal data you have provided to us to another responsible party, where possible.
7.3 RIGHT TO LODGE A COMPLAINT
You may complain to the supervisory authority responsible for us if you believe that we are processing your personal data illegally.
8. YOUR CALIFORNIA PRIVACY RIGHTS
California’s “Shine the Light” law, Civil Code section 1798.83, provides residents of the State of California the right to request a list of all third parties to which we have disclosed certain personal information as defined under California law during the preceding year for third-party direct marketing purposes. You are limited to one request per calendar year. To make your request, please write to us at Life Engineering, Data Protection Officer, 262 North University Avenue, Farmington, UT 84025, or via email to [email protected] In your request, please provide a current California address for our response.
9. LINKS TO OTHER WEBSITES
This Website may contain links to other websites that are neither owned by Life Engineering nor under the control of Life Engineering. Please note that Life Engineering bears no responsibility for the data protection practices of such websites. When you leave this site, you should read the website privacy policies of each target website that collects personal information. This Privacy Notice only applies to the information collected on this Website.
10. SOCIAL MEDIA
10.1 CONNECTED ACCOUNTS
We may provide you the option to connect your account on the Website to your account on some social networking sites for the purpose of logging in, uploading information, or enabling certain features on the Website. When logging in using your social network credentials, we may collect personal information you have made publicly available on the social networking site, such as your name, profile picture, cover photo, username, gender, friends network, age range, locale, friend list and any other information you have made public. Once connected, other users may also be able to see information about your social network, such as the size of your network and your friends, including common friends. By connecting your account on the Website to your account on any social networking site, you hereby consent to the continuous release of information about you to us. We will not send any of your account information to the connected social networking site without first disclosing that to you. Each social network may further allow you to set privacy controls around your information on their system, and our collection of information will always follow such controls and permissions. This feature is subject to continuous change and improvement by us and each social networking site involved, and therefore the available features and shared information are subject to change without notice to you.
10.2 HYPERLINKS AND PLUGINS
We may use hyperlinks on the Website which will redirect you to a social network if you click on the respective link. However, when you click on a social plug-in, such as Facebook’s “Like” button, Twitter’s “tweet” button or the Google+, that particular social network’s plugin will be activated and your browser will directly connect to that provider’s servers. If you do not use these buttons, none of your data will be sent to the respective social network’s plugin provider. So for example, when you click on the Facebook’s “Like” button on the Website, Facebook will receive your IP address, the browser version and screen resolution, and the operating system of the device you have used to access the Website. Settings regarding privacy protection can be found on the websites of these social networks and are not within our control.
We have embedded plugins from the social network Facebook, 1601 South California Avenue, Palo Alto, CA, 94304, USA, into our website. You can recognize these plugins by the Facebook logo on this website. A list of Facebook plugins can be found at: http:// developers.facebook.com/docs/plugins/. When you visit a page on our Website with a Facebook plugin, a direct connection is established between your browser and a Facebook server. Using this connection, the plugin provides Facebook with the information that you have accessed a speciﬁc page of our Website with your IP address. If you click the “like” button on Facebook while logged into your Facebook account, you can link content from our Website to your Facebook proﬁle. Facebook can then connect your Facebook account to your visit to this Website. Information on Facebook’s data protection policy can be found at: https://www.facebook.com/policy.php. If you do not want Facebook to be able to connect your visit to our Website with your Facebook account, please log out of Facebook.
The legal bases for the processing described above are the fulfilment your request and your consent.
11.MOBILE DEVICE INFORMATION
11.1 MOBILE DEVICE IDENTIFIERS
If you use a mobile device to access the Website or download any of our applications, we may collect mobile device information such as your mobile device ID, model, and manufacturer, operating system, version information, and IP address.
11.2 GEO-LOCATION INFORMATION.
Unless we have received your prior consent, we do not access or track any location-based information from your mobile device at any time while downloading or using our mobile application or our services, except that it may be possible for Company to determine from an IP address the geographic location of your point of connectivity, in which case we may gather and use such general location data.
11.3 PUSH NOTIFICATIONS.
We send you push notifications if you choose to receive them, letting you know when someone has sent you a message or for other service-related matters. If you wish to opt-out from receiving these types of communications, you may turn them off in your device’s settings.
11.4 MOBILE ANALYTICS.
We use mobile analytics software to allow us to better understand the functionality of our mobile software on your phone. This software may record information, such as how often you use the application, the events that occur within the application, aggregated usage, performance data and where the application was downloaded from. We do not link the information we store within the analytics software to any information you submit within the mobile application that would identify you personally.
12. DATA INTEGRITY
Life Engineering limits the personal information it collects to information that is relevant for the purposes of processing and delivering orders, facilitation the transfer of and communication between customer and demonstrator, and the other specific purposes set forth in this Privacy Notice. Life Engineering takes reasonable and appropriate measures to retain personal data only for as long as Life Engineering has a legitimate legal or business need to do so, such as customer service, compliance with legal or contractual obligations, retention for audit purposes, security and fraud prevention, preservation of legal rights or other reasonable purposes consistent with the purpose of the collection of the information.
13. INTERNATIONAL TRANSFER
Life Engineering uses the controller to controller standard contractual clauses (adopted by Commission Decision 2004/915/EC dated 27 December 2004 made under Directive 95/46/EC of the European Parliament and of the Council as amended or superseded from time to time) (the “C2C Standard Contractual Clauses“) to legally transfer EU personal information to Life Engineering and any of its affiliated entities in the United States or other third countries.
Your trust is important to us. Life Engineering will not sell or provide your information to any third party for any use other than that specified in this Privacy Notice. Life Engineering will not use your Personal Information in any way that is inconsistent with the purposes outlined in this Privacy Notice or for which you agreed to be contacted. The Website may include subscription and registration management tools, including opt-in or opt-out fields, that allow you to make changes regarding your preferences for receiving communications. Regardless of whether these tools are available through the Website, you may contact us using the contact information provided at the end of this Privacy Notice if (a) you have questions, complaints, or problems with our Privacy Notice; (b) you wish to make corrections to any personal information you have provided to us; (c) you want to opt-out from receiving future commercial correspondence from us (we may still send you transactional messages from us such as responding to your inquiries); or (d) you wish to withdraw your consent to the future sharing of your personal information with third parties for their direct marketing purposes.
We will respond to your request and, if applicable and appropriate, make the requested change in our databases as soon as reasonably practicable. Please note that we may not be able to fulfill certain requests while allowing you access to certain benefits and features of our Website. Also, please note that it is not always possible to completely change, remove, or delete all of your information from our databases and that residual data may remain on backup media. We may retain certain information that we are legally obligated or allowed to keep for tax reporting and other reasons.
15. DO NOT TRACK
Some web browsers and mobile device operating systems include a Do-Not-Track (“DNT”) feature or setting you can activate to signal your privacy preference not to have data about your online browsing activities monitored and collected. Because there is not a common understanding of how to interpret the DNT signa, this Website currently does not respond to DNT browser signals or mechanisms.
If you have questions about the contents of this Privacy Notice, please contact us.
Life Engineering Inc.
Attn: Data Protection Officer
262 North University Avenue
Farmington, UT 84025
Email: [email protected]