Soovu Labs Inc (“SLI,” “we” or “us”) provides a wearable therapeutic product and digital coaching to users through our mobile application (the “App”), our website, www.soovu.com (the “Site”), and related features and services that SLI provides through our App and Site (collectively, “Services”).
In this Privacy Policy (“Policy”), we describe how we collect, maintain, use, disclose, and otherwise process certain information about our users. Your use of our Services, and any dispute over privacy, is subject to this Policy and our Terms and Conditions. Our Terms and Conditions are incorporated by reference in to this Policy. Any capitalized terms that are not defined in this Privacy Policy will have the meanings given to those terms in the Terms and Conditions.
We take your privacy seriously, including how we collect, use, and share personal information from you. Please carefully read this Policy as it contains important information about your legal rights. If you are a resident of California, please also refer to the “Additional Privacy Information for California Residents” section below, for information about the categories of personal information we collect and your rights under California privacy laws.
This Policy does not apply to the personal information that we collect and process about our employees, personnel, or job applicants. Also, this Policy does not apply to the extent we process personal information as part of our agreements with our business clients (“Client Data”). Our processing of Client Data is subject to the terms of our contracts with each business client. If you are participating in a program sponsored by your employer, insurance provider, or healthcare provider (collectively, “Providers”), this Privacy Policy does not cover the privacy practices of your Provider—please refer to your Provider’s privacy policy for more information.
In certain circumstances, SLI may collect or use your information through our Services while acting as a “business associate” under the Health Insurance Portability and Accountability Act of 1996 (“HIPAA”), which may constitute “Protected Health Information.” A “business associate” includes an entity that provides services to a HIPAA covered entity that involves the use or disclosure of Protected Health Information. If your health care provider or health insurance company qualifies as a HIPAA covered entity, and we provide services to them or on their behalf, we may qualify as their business associate. “Protected Health Information” as defined under HIPAA, generally means information about you that identifies you and that relates to your physical or mental health or condition, the provision of health care to you, or payment for health care provided to you. To the extent we are acting as a business associate, we will only use and disclose your information as permitted by HIPAA, which may include, but not be limited to, fulfilling our service obligations, our internal management and administration, to carry out our legal responsibilities, de-identify or aggregate data, or as otherwise required by law.
We collect information directly from you, from non-affiliated entities, and by automated means as set out below. The type of information that we collect from you depends on your particular interaction with our Services or with our Site, but generally includes the below information.
In order to sign up with SLI’s Soovu Pain Relief Program, you will be asked to provide information such as your name, email address, mailing address, and phone number. This information, plus a password you create, will be used to mail the Soovu Pain Relief System to you and to allow you to create an account in the App. Setting up your account with us is required to ensure secure access to your Pod(s), and to your personal Heatwave Therapy usage history. We may also use the information you provide to us to contact you from time to time, to provide you with important App and/or Pod update information, wellness information, and SLI-specific marketing promotions.
During program sign-up and at different points in the program, you will be asked to provide information about your health condition, activity, sleep, pain levels, and similar data points which will allow the App to maintain a history of your responses both to enhance future performance of the Pod in providing more effective heatwave therapy, and to provide you with a visual means of tracking your pain management via your Soovu Pod(s). The SLI Customer Care team may use some of this data to help inform how they support you best as you use the Soovu Pain Relief System.
If you are participating in a program sponsored by your Employer, your Employer may provide us with information regarding your eligibility and information needed to enroll you into our Services such as your name and contact information.
We maintain records related to customer support and customer service related requests, including the nature of the request, name and contact information of the requestor, and information related to the resolution of the request.
You can sign up to receive our newsletter, updates, and other information we think may interest you by providing your email address. You may opt out of these messages at any point.
In addition, our Services will collect certain information automatically, about your use of our Services, including, but not limited to, your Pod usage history (e.g., Heatwave Therapy settings, therapy session history, your treated pain location). Your Pod usage history is collected so that you can recall it at any time for personal use, and so that SLI can continuously improve the Pod’s clinical effectiveness.
The App will also collect your Pod’s unique device ID, the IP address of your mobile device, and your mobile operating system. This information is collected to make the App more convenient for your personal use by remembering the Soovu Pod(s) that are uniquely bonded with your mobile App, and to tailor the particular version of App software that will work on your mobile device. The Site will collect information through cookies, web beacons, log files and other methods: IP address, browser type, device type, domain name, the website that led you to our Services, the website to which you go after leaving our Services, the dates and times you access our Services and perform certain activities; device name and model; operating system type, name, and version; the length of time that you are using our Services, and the links you click and your other activities within the Services. The information described herein will be collectively referred to as “Usage Data.” We may combine Usage Data with other information that we have collected about you, including your personal information. We may combine Usage Data with other information that we have collected about you. Please see the section “Analytics and Tracking” below for more information.
While the purposes for which we may process Personal Information will vary depending upon the circumstances, in general, we use Personal Information for the business and commercial purposes set forth below.
In general, we may disclose information:
SLI may share, transfer, or otherwise disclose certain elements of your Protected Health Information to entities that are authorized to receive that information for legally permitted purposes under HIPAA, which may include the companies paying for your participation in an SLI Program. We only share your Protected Health Information in accordance with HIPAA and other applicable legal requirements.
SLI may share, transfer, or otherwise disclose certain elements of your Protected Health Information to organizations with the goal of safeguarding our customer data. These organizations perform services on our behalf and are listed in the table below.
Airtable
Amazon Web Services
Microsoft Azure
Zendesk, Inc.
Jira
Slack
Webflow
We and our third-party service providers use cookies, pixels, java script, and other tracking mechanisms to track information about your use of our Site. We may combine this information with other personal information we collect from you (and our third-party service providers may do so on our behalf).
Cookies are alphanumeric identifiers that we transfer to your device’s hard drive through the Services for record-keeping purposes. Some cookies allow us to make it easier for you to navigate our Services, while others allow us to track your activities in our Services. Most web browsers automatically accept cookies, but if you prefer, you can edit your browser options to block them in the future. The Help portion of the toolbar on most browsers will tell you how to prevent your computer from accepting new cookies, how to have the browser notify you when you receive a new cookie or how to disable cookies altogether.
Clear GIFs are tiny graphics with a unique identifier, similar in function to cookies. In contrast to cookies, which are stored on your computer’s hard drive, clear GIFs are embedded invisibly on web pages. We may use clear GIFs (a.k.a. web beacons, web bugs or pixel tags), in connection with our Site to, among other things, track the activities of Site visitors, help us manage content, and compile statistics about Site usage. We and our third-party service providers also use clear GIFs in HTML emails to our customers, to help us track email response rates, identify when our emails are viewed, and track whether our emails are forwarded.
We may use non-affiliated analytics companies, for example Google Analytics (see privacy policy and opt-out), to evaluate use of our Services. We use these tools to help us understand use of, and to improve, our Services, performance, ad campaigns, and user experiences. These entities may use cookies and other tracking technologies, such as web beacons or local storage objects (LSOs), to perform their services.
Currently, our systems do not recognize browser “do-not-track” requests. You may, however, disable certain tracking as discussed in this section (e.g., by disabling cookies).
Our Services may contain links to third-party websites. Any access to and use of such linked websites is not governed by this Policy, but instead is governed by the privacy policies of those third-party websites. We are not responsible for the information practices of such third-party websites.
You have certain choices and rights regarding our processing of your Personal Information. For example:
You may elect to remove Personal Information linking you to the collected therapy information that resides in the SLI cloud database. Following this action, you will no longer be able to view your usage history. You may submit a request to help@soovu.com to delete your personal information.
At any time, you may delete the App from your mobile device using the delete-application mechanism provided by the iOS or Android OS, which will uninstall the App and corresponding local data (to your device).
As noted above, you can manage your preferences for cookies (including advertising cookies) on our Site.
In our App, we may send push notifications from time-to-time in order to update you about the Services. If you no longer wish to receive these types of communications, you may turn them off at the device level.
When you receive an email or message from us, you can opt out of receiving further emails by following the included instructions to unsubscribe. If you would like assistance in unsubscribing from email communications, please contact right in help@soovu.com.
If you are a California resident, please review Additional Information for California Residents below, for specific information about your California privacy rights and how to exercise them.
The Services are contraindicated for use with children and we do not use the App to knowingly solicit data from, or market to, children under the age of 13. If a parent or guardian becomes aware that his or her child has provided us with information without their consent, he or she should contact us at help@soovu.com. If provided with such notice or if we otherwise discover that a child under 13 has provided us with Personal Information, we will delete such information from our systems.
We are concerned about safeguarding the confidentiality of your information. We provide physical, electronic, and procedural safeguards to protect information we process and maintain. For example, we limit access to this information to authorized employees and contractors who need to know that information in order to operate, develop or improve our App. Please be aware that, although we endeavor to provide reasonable security for information we process and maintain, no security system can prevent all potential security breaches. You should take steps to protect against unauthorized access to your password, phone, and computer by, among other things, signing off after using a shared device.
This Policy is current as of the Effective Date set forth above. This Privacy Policy may be updated from time to time. We will notify you of any changes to our Privacy Policy that materially affect our practices with regard to the Personal Information we have previously collected from you by posting the new Privacy Policy here, informing you via email, or via the About page of the App.
If you have any questions regarding privacy while using any SLI Services, or have questions about our practices, please contact us via email at help@soovu.com or by postal mail at:
Soovu Labs
10115 Greenwood Ave N
Suite 121
Seattle, WA 98133
In this section, we provide additional information to California residents about how we handle their “personal information” as defined and required under California privacy laws, including the California Consumer Privacy Act (“CCPA”). This section does not address or apply to our handling of publicly available information lawfully made available by state or federal government records or other personal information that is exempt under the CCPA. Under California privacy laws, California residents have the right to receive certain disclosures regarding our processing and sharing of personal information.
While our processing of personal information varies based upon our relationship and interactions with you, in this section we describe, generally, how we have collected, used, shared and disclosed personal information about California residents in the prior 12 months (from the Last Updated date above).
Categories of Personal Information Collected and Disclosed. The table below identifies, generally, the categories of personal information we have collected about California residents, as well as the categories of third parties to whom we may disclose this information for a business or commercial purpose.
Includes direct identifiers, such as [name, alias, user ID, username, account number or unique personal identifier, email address, phone number, address and other contact information, IP address and other online identifiers].
Includes personal information, such as name, alias, user ID, username, account number or unique personal identifier, email address, phone number, address and other contact information, IP address and other online identifiers that individuals provide us in order to obtain our products and services.
Includes records of personal property, products or services purchased, obtained, or considered, or other purchasing or use histories or tendencies.
Including, but not limited to, browsing history, clickstream data, search history, and information regarding interactions with an internet website, application, or advertisement, including other usage data related to your use of any of our Services or other online services.
Includes audio, electronic, visual, thermal, olfactory, or similar information, photographs and images (e.g., that you provide us or post to your profile) and call recordings (e.g., of customer support calls).
Includes professional and employment-related information [(such as current and former employer(s) and position(s), business contact information and professional memberships)].
Information about an individual’s educational history [(such as the schools attended, degrees you were awarded, and associated dates)].
Including inferences drawn from any of the information identified above to create a profile reflecting a consumer’s preferences, characteristics, behavior or attitudes.
We collect some information that is considered a protected classification under California/federal law (e.g., your gender, date of birth, citizenship, marital status, and disability status).
Physiological, biological or behavioral characteristics that can be used alone or in combination with each other to establish individual identity.
In general, we may collect the categories of personal information identified in the table above from the following categories of sources:
As described in more detail in the Use of Information section, in general, we collect and otherwise process the above personal information for the following business or commercial purposes:
As described in more detail in the Disclosure of Information section, generally, we disclose the personal information we collect in order to provide our Services to you, respond to and fulfil your orders and requests, as otherwise directed or consented to by you, and for the purposes otherwise described in this Policy.
The CCPA also requires that we disclose how we ‘sell’ personal information. Under the CCPA, a ‘sale’ is defined broadly to include disclosing or making available personal information to a third-party in exchange for monetary compensation or other benefits or value. As such, while we do not disclose personal information to third parties in exchange for monetary compensation, we may, pursuant to the CCPA, sell or share:
CCPA Rights. In general, California residents have the following rights with respect to their personal information:
California residents may exercise their California privacy rights as set forth below.
Request to know (access) and delete. California residents may submit CCPA requests to opt out of sales, access/know, and delete their personal information maintained by us through one of the following methods:
Logging into their account and contacting help@soovu.com
In addition, you may opt out of third-party tags and cookies on our Site using our cookie preference manager, which you can access by clicking the “Cookie Settings” link in the footer of our Site.
When you submit a request to know or a request to delete, we will take steps to verify your request by matching the information provided by you with the information we have in our records. You must complete all required fields on our webform or otherwise provide us with this information via the above toll-free number. In some cases, we may request additional information in order to verify your request or where necessary to process your request. If we are unable to adequately verify a request, we will notify the requestor. Authorized agents may also submit requests on behalf of consumers using the online form above; authorized agents will be required to provide proof of their authorization and we may also require that the relevant consumer directly verify their identity and the authority of the authorized agent.
Under California’s “Shine the Light” law (Cal. Civ. Code § 1798.83), California residents who provide us certain personal information are entitled to request and obtain from us, free of charge, information about the personal information (if any) we have shared with third parties for their own direct marketing use. Such requests may be made once per calendar year for information about any relevant third-party sharing in the prior calendar year. To submit a “Shine the Light” request, email us at help@soovu.com, and include in your request a current California address and your attestation that you are a California resident.
For more information about our privacy practices, you may contact us as set forth in the Contact Us section, above or email help@soovu.com.
