Privacy

ActiveSoul, Inc. (“ActiveSoul,” “Company,” “us,” or “we”) takes the privacy and protection of personal information very seriously. This privacy policy (“Privacy Policy”) discloses ActiveSoul’s privacy practices for information collected by the company whether through https://ActiveSoul.us (the “Site”), the ActiveSoul mobile application (the “App”), the ActiveSoul services or elsewhere (collectively, the “Services”).

What This Privacy Policy Covers

This Privacy Policy covers our collection, use and disclosure of the Personal and Anonymous Information we collect through the Services. This Privacy Policy does not apply to the use of your Personal Information that is collected by third parties that Company does not own or control other than third party contractors working in support of ActiveSoul in providing the Services. “Personal Information” is information that is personally identifiable like names, addresses, e-mail addresses, or phone numbers, as well as other non-public information that is associated with the foregoing. “Anonymous Information” means information that is not associated with or linked to your Personal Information; Anonymous Information does not permit the identification of individual persons.

Personal Information We Collect

• If you register for the Services and create an account (“Account”) to become a Member, we collect your full name, e-mail address, and additional information which you may provide as part of your registration.

• When you contact us by sending us an e-mail, we will collect any information that is contained in (and/or attached to) your e-mail.

Personal Information Collected Via Technology

We collect data from devices and applications that you choose to connect to our Services. For example, we collect data from fitness devices and applications that are connected to the Services (e.g., the details that your wearable shared with the App, such as running pace, number of steps, heartrate).

As you use the Services through our Site, certain information may also be collected passively, including your Internet protocol (IP) address and the browser that you use to visit the Site. Company also stores a small text file called a “Cookie” on your computer to store your login information (if any) and your personal preferences for the Services. Company may use both session Cookies (which expire once you close your web browser) and persistent Cookies (which stay on your computer until you delete them). While you will still be able to use the Services if you disable Cookies in your browser, certain parts of the Services may not function as effectively.

As you access the Services through a mobile device, we may collect specific device information about your mobile device. Information collected may include the type of device you are using, its operating system, and mobile network information which may include your mobile phone number. This information may be associated with your Account and used to customize the Services for you. Since the foregoing information may be collected when you are signed into the Services, this information may be associated by us with Personal Information that we have collected from you.

Personal Information From Other Sources

We may receive Personal Information about you from outside the Site, such as telephone, fax, or mail. Additionally, we offer the ability to sign into our Services via Facebook Connect. This service will authenticate your identity and provide you the option to share certain personal information with us such as your name, e-mail address, employer name, your location at your employer, wellness program provider, ID, and benefits, and similar details, to pre-populate our sign up form. We may add this information to the information we have already collected from you via the Services.

Use Of Information We Collect

We use the Personal Information you provide to:

• Administer your Account with us, deliver our Services and customize the Services we provide to you.

• Respond to your inquiries or customer service requests.

• Give Merchants the information they need to give you access to their products and services.

• Verify and update your allowance and benefits through your Employer or wellness program provider

• Send you service or promotional communications through email and notices on the App.

• Enable you to share your information and communicate with other users, or provide (usually at your option) your personal details to third parties or Merchants offering or advertising their services or products.

In order to deliver our Services, we may share information with third parties who are not Merchants or Employers. For example, to process our payments to Merchants, we may share some of your information with the Merchants’ payment processing companies.

In general, information (including Personal Information) you submit to us is used by us to provide you and others with the Services, to respond to requests that you make, to improve our Services and to better tailor the features, performance and support of the Services.

We may create Anonymous Information records from Personal Information by excluding information (such as your name) that makes the information personally identifiable to you. We may also create Anonymous Information on how you use the Services. We may use this Anonymous Information for internal purposes, such as analyzing usage patterns so that we may enhance the Services, and we also reserve the right to use and disclose any Anonymous Information at our discretion.

Feedback

If you provide feedback about the Services to us, we may use and disclose such feedback for any purpose, provided we do not associate such feedback with your Personal Information. We will collect any information contained in such feedback and will treat the Personal Information in it in accordance with this Privacy Policy.

Disclosure of Personal Information

Except as otherwise stated in this Privacy Policy, we do not disclose to or share your Personal Information with third parties, unless you ask or authorize us to do so. We may disclose your Personal Information with third parties, in our discretion, including for purposes of advertising to you.

We may provide your Personal Information to third party service providers and suppliers who work on behalf of or with us to provide you with some of the Services and features of the Services and to help us communicate with our users (the processing of payments, the submission of e-mail communications on Company’s behalf and the providing of customer service). However, these service providers and suppliers do not have any independent right to use this information except to help us provide the Services.

Employers and wellness program providers (and other designees of your employer) will have access to certain information regarding your use of the Services and use of services of Merchants. For example, we will provide to your employer and wellness program provider: (1) the date, time, duration, and description of the activities you have participated in (e.g., you went to the gym on a certain date for one hour), and (2) details that are collected by the Services from fitness devices and applications that are connected to the Services (e.g., the details that your wearable shared with the App, such as running pace, number of steps, heartrate).

Although we currently do not have a parent company, any subsidiaries, joint ventures, or other companies under a common control

(collectively, “Affiliates”), we may in the future. We may share some or all of your Personal Information with these Affiliates, in which case we will require our Affiliates to honor this Privacy Policy. In the event Company goes through a business transition such as a merger, acquisition by another company, or sale of all or a portion of its assets, your Personal Information will likely be among the assets transferred. You acknowledge that such transfers may occur, and that any acquirer of Company or its assets may continue to use your Personal Information as set forth in this Privacy Policy. You hereby consent to Company sharing your Personal Information under the above circumstances.

We may also disclose personal information as required by law, such as to comply with a subpoena, or similar legal process when we believe in good faith that disclosure is necessary to protect our rights, protect your safety or the safety of others, investigate fraud, or respond to a government request, to any other third party with your prior consent to do so.

Access and Choices Regarding Personal Information

Individuals who seek access to, or seek to correct, amend, or delete inaccurate data should review their Account information.

Your Information Choices

You can:

• Review, enhance or edit your personal information by accessing your Account information.

• Change your settings to control visibility and accessibility of your data through our Site and the App.

• Tell us to close your ActiveSoul Account

Out of respect for your privacy, you may choose to stop receiving our marketing emails by following the unsubscribe instructions included in these emails or you can contact us through the Site or App. We may send you service-related announcements (such as, but not limited to, notice that we have changed the Services, the Terms of Service Agreement, or the Privacy Policy) when we believe it is necessary to do so. You may not opt-out of these communications, which are not promotional in nature, but if you do not wish to receive these announcements, you have the option to terminate the Account you may have with us. You understand that any termination of your Account may involve deletion of your Account information from our live databases and all the information and data stored for such Account in the Services. If you terminate your membership, we will delete your contact information from your records, and retain only Anonymous Information about your use of our Services. Company will not have any liability whatsoever to you for any termination of your Account or related deletion of your information.

When we delete information that we have collected from or about you, it will be deleted from our active databases but may remain in our archives as de-identified data.

Data Retention

We will retain the personal data we process for as long as needed to provide our Services to you and to maintain compliance with our agreements with Employers and Merchants. We will retain and use this personal information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.

Links to Other Web Sites

The Services may contain links to other web sites that are not owned or controlled by Company. The provision of such links is for your convenience and does not signify our endorsement of such web sites or location or its contents. We have no control over, do not review and are not responsible for the privacy policies of or content displayed by such other web sites, your Employer, or any Merchants. Please be aware that the terms of the Privacy Policy do not apply to any outside web sites, your Employer, or any Merchants.

Testimonials

With your consent we may post your testimonial along with your name on our Site. If you wish to update or delete your testimonial, you can contact us via one of the methods listed below.

Privacy of Minors

We do not intentionally collect or maintain information from persons under the age of 13.

Security

Company has put in place commercially reasonable and appropriate physical, electronic, and managerial procedures to safeguard and secure the information we collect online. However, no company, including Company, can fully eliminate security risks associated with Personal Information.

Changes in this Privacy Policy

This Privacy Policy is subject to occasional revision. We will post any revised version of the Privacy Policy on this page. If we make any material changes to it, we will post the modified Privacy Policy on our website. You agree that such amended Privacy Policy will be effective thirty (30) days after being posted, and your continued use of the Services after that time shall constitute your acceptance of the amended Privacy Policy.

Contact Us

If you have any questions or suggestions regarding our Privacy Policy, please contact us by sending us an e-mail to info@activesoul.us.