Privacy Policy

FEIRIE, a California company (the “Company”, “we”, “us,” or “our,” as the context dictates), provides the website located at https://feirie.com/, other related sites operated by the Company, and all subdomains, subpages, and successor sites thereof (collectively, the “Website”), mobile applications (the “Applications”), and services made available on the Website and/or through the Applications (the “Services”), which, among other things, allow users (“you,” “User,” or “your,” as the context dictates) to share information and access Content (as defined below) (the “Services”).  

This privacy policy (“Privacy Policy”) applies to the Website, the Applications, and the Services and describes, among other things: (i) the information we collect; (ii) how we use it; and (iii) with whom we share it.  If and to the extent we process Personal Information (as defined below) that is subject to requirements not set forth in this Privacy Policy and mandated by data privacy laws applicable to our business, upon request, we will provide you with a data processing addendum to govern our compliance therewith.  

This Privacy Policy has been created to demonstrate our commitment to your right of privacy and to describe our practices for how your Personal Information is being collected and used by us.  

For purposes hereof:

“Content” means any information, test data, test results, suggestions, recommendations, data, communications, messages, files, images, photos, graphics, videos, audio, or other materials uploaded, downloaded, posted, presented, displayed or published on, or transmitted, distributed or otherwise linked through, the Website, the Applications, or the Services by you or by a third party; and

“Personal Information” means all personally identifying data that relates to a specific individual, including, without limitation, data that identifies an individual or that, in combination with any other information or data that you provide to us, or that we collect through your use of the Website, the Applications, the Services, or otherwise that can be used to identify an individual.

The Company processes information collected by and through the Applications and the Services on behalf of User or the organization to which User belongs (the “User Organization”); and may use such information to provide the Services and to build and grow our business in the manner described in this Privacy Policy. In connection with our provision of the Website, the Application and the Services, you understand and acknowledge we are a “service provider” and not a “business” (as such terms are defined under California Civil Code Title 1.81.5, The California Consumer Privacy Act of 2018 (the “CCPA”)).  By visiting the Website, accepting the Services Agreements (as defined herein), and/or accessing the Services, you expressly consent to the use and disclosure of your information as described herein.  Data that you consent to provide to us also will be governed by the agreement between you and the Company or between the User Organization and the Company regarding your use of the Services (the “Services Agreements”).  If you do not agree with the terms set forth in this Privacy Policy, please do not visit the Website, use the Applications, check any of the boxes described herein, or use the Services; and please delete any cookies placed on your web browser and hard drive by the Website or the Applications.  

We do not collect Personal Information through the Website, the Applications, and/or the Services unless you voluntarily provide such information to us through the Website, the Applications, and/or the Services.

We only use Personal Information that you provide to us through the Website, the Applications, and/or the Services for the purposes described in the Services Agreements, including, but not limited to analyzing it in connection with the performance of the Services; for other purposes directly related to the foregoing; and/or for other reasons permitted under the Health Insurance Portability and Accountability Act of 1996, as amended, including its implementing regulations.

We do not share Personal Information you provide to us through the Website or Applications with third parties unless it is necessary for the purposes for which it is provided, you consent to such sharing, or it does not amount to an interference with your privacy (e.g., to respond to feedback or an email enquiry; or for academic research).  We will not provide your Personal Information to the User Organization unless you consent to such provision.

Please read our privacy policy carefully to get a clear understanding of how we collect, use, protect or otherwise handle your Personal Information in providing our Website, the Applications, and the Services. 

General

What Personal Information do we collect from the people that visit our Website or use the Application and/or the Services?

When visiting or registering for an account on our Website, or using the Applications or the Services, you may be asked to provide, and we may collect the following types of Personal Information:

1. personal identifying data (e.g., given and surname, location, time zone, photograph); 
2. communication/contact details (e.g., address, email address, telephone number); 
3. health-related data (e.g., height, weight, medical history, blood test results, diet information); and
4. any other Personal Information you provide through your use of the Website, the Application, or the Services. 

Additionally, when you visit the website and use the Applications or the Services, we may automatically collect online identifiers such as the type of device you use to access the Website, the Applications, and/or the Services, IP addresses, browser type and version, time-zone setting, browser plug-in types and versions, operating system, mobile network information and platform, full Uniform Resource Locator (URL), clickstream to, through and from the Website and the Applications (including date and time), pages you viewed, page response time, download errors, length of visit to certain pages, page interaction information (such as scrolling, clicks and mouse-overs), methods used to browse away from the page, cookie information, and advertising ID (for mobile users). 

When do we collect Personal Information?

We collect Personal Information from you when you:

1. register for an account on our Website and/or the Applications; 
2. post any information on our Website and/or the Applications;
3. access or use our Website, the Applications, and/or the Services;
4. contact or correspond with us; or
5. respond to a survey or marketing communication from us.

How do we use your Personal Information?

We may use the Personal Information we collect from you in the following ways:

1. to personalize your experience;
2. to manage corporate transactions;
3. to provide access to your account through the Website and/or the Applications;
4. to provide you with the Services;
5. to protect you or the Company from threats (such as security threats or fraud);
6. to respond to your customer service requests;
7. to compile data regarding Website’s and the Applications’ traffic and users’ interactions therewith to improve user experience; 
8. to enable us to administer our business (such as for quality control and customer service); and/or
9. to understand and improve our business and customer relationships generally.

Also, we may share Personal Information with our service providers, business partners, health coaches, program facilitators, suppliers, sub-contractors or agents who perform services for us, as well as our professional advisers (including our lawyers, bankers, auditors and insurers), and analytics and search engine providers that assist us in the improvement and optimization of the Services.

How do we protect your Personal Information?

Your Personal Information is contained behind secured networks and is only accessible by a limited number of Company personnel who have special access rights to such systems and are required to keep the Personal Information confidential.  The Company personnel who have access to such personal information may use it only in accordance with the principles set out in the Privacy Policy and applicable legislation and regulation.  To maintain the safety of your Personal Information, we implement a variety of technical, organizational, administrative, and physical security measures designed to protect against the loss, misuse and alteration of data used by, or transmitted to or from, our system when a user submits or accesses their Personal Information.  No data transmissions over the Internet, however, are guaranteed to be completely secure.  While we strive to protect your data from unauthorized use or disclosure, the Company does not warrant or guarantee the security of the data that you provide to us; any transmission is at your own risk.

You are responsible for maintaining the security of any password, user identification, or other form of authentication involved in obtaining access to password protected or secure areas of the Website, the Applications, or the Services.  If any breach of security is suspected, in order to protect you and your data, we may suspend your use of the Website, the Applications, and/or the Services without notice, pending an investigation.

Further, in connection with making payments on the Website or in the Applications, we will not have access to your payment information such as bank accounts or routing numbers, or your credit and debit card information and no bank accounts or routing numbers or credit or debit card information is stored on our servers.  All credit and debit card information will be submitted to, stored by and processed through a third party payment intermediary service (the “Payment Processor”).  All such interactions between you and the Payment Processor are governed by the Payment Processor’s privacy policy and terms of use. 

Following termination or deactivation of your account with the Applications and/or the Services, we may retain information, including profile information and Personal Information, in order to comply with applicable law, prevent fraud, resolve disputes, troubleshoot problems, assist with any investigation, enforce our rights under our agreements with you, for backup, audit or regulatory purposes, and for other actions permitted by law.  To determine the appropriate retention period for Personal Information, we consider the amount, nature and sensitivity of the Personal Information, the potential risk of harm from unauthorized use or disclosure of your Personal Information, the purposes for which we process your Personal Information and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.

Do we use ‘cookies’?

Yes, we use cookies on the Website and the Applications.

Cookies are text files that web browsers place on a computer’s hard drive to tell website owners, among other things, whether an individual has interacted with the website previously.  The Company uses cookies to recognize repeat visits by users of the Website and the Applications and to collect information about our users’ interactions with the Website, the Applications and the Services.  Please see the Company’s Cookie Policy found at: https://feirie.com/cookie, if you would like to learn more about the Company’s use of cookies and types of data we collect through cookies.

Third party disclosure

We do not sell, trade, or otherwise transfer your Personal Information, or data that you provide to the Website or the Applications to third parties, except we may disclose such information to third parties under the following circumstances: 

1. in order to investigate, prevent, or take action regarding illegal activities, suspected fraud, or pursuant to applicable law, judicial or other government subpoenas, warrants, or orders; 
2. if it is necessary to protect the safety of Company employees, agents, customers or any person; 
3. in connection with a merger, sale, or acquisition of the Company, or the Company files for bankruptcy; and 
4. to our service providers, business partners, suppliers, sub-contractors, or agents who perform services for us, as well as our professional advisers (including our lawyers, bankers, auditors and insurers), and analytics and search engine providers that assist us in the improvement and optimization of the Services.

Third party links

Occasionally, at our discretion, we may include or offer third party websites, products or services on our Website and the Applications.  These third party sites have separate and independent privacy policies.  The privacy policies and applicable terms of use of the third party sites will govern your interaction with such third party sites.  We, therefore, have no responsibility or liability for the content and activities of these linked sites.  Nonetheless, we seek to protect the integrity of our Website and the Applications and welcome any feedback about these sites.

Control, Email and Opt-Out

You have control over your Personal Information related to your use of the Applications and/or the Services.  Accordingly, you may access, review, add, rectify, modify, correct, delete, or update your Personal Information at any time by contacting us at contact@feirie.com.

If you receive one or more emails from us, it means one of two things: (i) you or the User Organization provided us (and expressly warranted it had the right to provide us) with your consent to receive marketing communications; or (ii) you provided us your email address so that we could contact you.  If you believe you received an email from us in error, please contact us immediately at contact@feirie.com   

You hereby consent to receive marketing communications from us. If you desire to withdraw such consent, we provide you with the opportunity to opt-out of receiving marketing communications from us at any point in time.  If you wish to cease receiving marketing emails and other communications from us, you can opt-out by contacting us at contact@feirie.com.

California Privacy Rights

Shine the Light.  Under California’s “Shine the Light” law, California residents who provide Personal Information in obtaining products or services for personal, family, or household use are entitled to request and obtain from us once a calendar year information about the customer information we shared, if any, with other businesses for their own direct marketing uses.  If applicable, this information would include the categories of customer information and the names and addresses of those businesses with which we shared that information for the immediately prior calendar year (e.g., requests made in 2021 will receive information regarding 2020 sharing activities).  To obtain this information, please send an email message to contact@feirie.com with “Shine the Light Request” on the subject line and in the body of your message.  We will provide the requested information to you at your e-mail address in response.  Please be aware that not all information sharing is covered by the “Shine the Light” requirements and only information on covered sharing will be included in our response.

California Consumer Privacy Act.  The CCPA provides certain rights to California residents regarding their Personal Information.  A California resident has the right to request that the Company disclose certain information, including: (i) the categories of Personal Information it has collected about that California resident; (ii) the categories of sources from which the Personal Information is collected; (iii) the business or commercial purpose for collecting or selling the Personal Information; (iv) the categories of third parties with whom the Company shares Personal Information; (v) the specific pieces of Personal Information it has collected about that resident; and (vi) the categories of Personal Information that the Company has sold about that resident and the categories of third parties to whom that information was sold.  A California resident has the right to request that the Company delete his/her Personal Information.  A California resident also has a right to “opt-out” of the sale of that resident’s Personal Information.  Finally, a California resident has the right not to be discriminated against for exercising his/her privacy rights under the CCPA; provided, however, the CCPA does not prohibit the Company from offering financial incentives, different prices, rates, levels or qualities of goods or services for the collection of personal information if that price or difference is directly related to the value provided by the consumer’s data.  

You will be notified of any Privacy Policy changes:

• On our Privacy Policy Page at Feirie.com

You can change your Personal Information:

• By emailing us at contact@feirie.com

Pursuant to California Civil Code Section 1789.3, California users are entitled to the following consumer rights notice: California residents may reach the Compliant Assistance Unit of the Division of Consumer Services for the California Department of Consumer Affairs by mail at 1625 North Market Blvd., Sacramento, CA 95834, or by telephone at (916) 445-1254 or (800) 952-5210.

Does our Site allow third party behavioral tracking?

We do not allow third party behavioral tracking. 

COPPA (Children Online Privacy Protection Act)

When it comes to the collection of Personal Information from children under the age of 13 years old, the Children’s Online Privacy Protection Act (COPPA) puts parents in control.  The Federal Trade Commission, United States’ consumer protection agency, enforces the COPPA Rule, which spells out what operators of websites and online services must do to protect children’s privacy and safety online.  We do not specifically market to children under the age of 13 years old.

To protect children’s Personal Information, we do not knowingly collect any Personal Information from persons under the age of eighteen (18) that can be used to specifically identify them, and the Company does not permit persons under the age of eighteen (18) to use the Website, the Applications, and the Services.  If we become aware that a child under the age of thirteen (13) has provided us with Personal Information, we will immediately take steps to delete the Personal Information submitted and terminate the account. 

If you believe we might have any information from or about underage children, please contact us at contact@ppivi.com.

CAN-SPAM Act

The CAN-SPAM Act is a law that sets the rules for commercial email, establishes requirements for commercial messages, gives recipients the right to have emails stopped from being sent to them, and spells out tough penalties for violations.  We collect your email address in order to:

• send information, respond to inquiries, and/or other requests or questions;  
• process orders and send information and updates pertaining to orders;
• send you additional information related to your product and/or service; and
• market to our mailing list or continue to send emails to our clients after the original transaction has occurred. 

To be in accordance with the CAN-SPAM Act, we agree to the following:

• not use false or misleading subjects or email addresses;
• identify the message as an advertisement in some reasonable way;
• include the physical address of our business or site headquarters;
• monitor third party email marketing services for compliance, if one is used;
• honor opt-out/unsubscribe requests quickly; and
• allow users to unsubscribe by using the link at the bottom of each email.

If, at any time, you would like to unsubscribe from receiving future emails, you can follow the instructions at the bottom of each email or email us at contact@feirie.com and we will promptly remove you from all correspondence.

Contacting Us

If there are any questions regarding this privacy policy, you may contact us using the information below:  

contact@feirie.com