Privacy Policy
Effective date: October 1, 2023

At WorkUp Health, Inc (“WorkUp”), 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 acknowledge that you accept the practices and policies outlined below, and you hereby consent that we will collect, use and share your information as described in this Privacy Policy.

If you’re under the age of 18, you may only use the Services and disclose information to us with your parent’s or guardian’s consent. For users under the age of 13, only your parent or guardian can sign you up to the Services. Please refer to our Terms of Use regarding how we collect verified parental consent before users under the age of 13 can use the Services. By agreeing to sign up a user under the age of 13 to the Services, you, as such user’s parent or guardian, (i) acknowledge that you accept the practices and policies outlined below on behalf of such user; (ii) hereby consent to our collection, use and sharing of the Personal Data of such user as described in this Privacy Policy; and (iii) represent and warrant that you are such user’s parent or guardian and have the legal authority to accept these terms, and grant such consent, on behalf of such user in compliance with applicable laws and regulations.

Remember that your use of WorkUp’s Services is at all times subject to our Terms of Use, which incorporate this Privacy Policy. Any terms we use in this Policy without defining them have the definitions given to them in the Terms of Use.

You may print a copy of this Privacy Policy at any time.

As we continually work to improve our Services, we may need to change this Privacy Policy from time to time. Upon such changes, we will alert you to any such changes by placing a notice on the WorkUp website, by sending you an email and/or by some other means. Please note that 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 still responsible for reading and understanding them. If you use the Services after any changes to the Privacy Policy have been posted, that means you agree to all of the changes.

TABLES OF CONTENTS

What this Privacy Policy Covers
This Privacy Policy covers how we treat Personal Data that we gather when you access or use our Services. “Personal Data” means any information that identifies or relates to a particular individual and also includes information referred to as “personally identifiable information” or “personal information” under applicable data privacy laws, rules or regulations. This Privacy Policy does not cover the practices of companies we don’t own or control or people we don’t manage.

Personal Data
Categories of Personal Data We Collect
This chart details the categories of Personal Data that we collect and have collected over the past 12 months:

Category of Personal Data Examples of Personal Data We Collect Categories of Third Parties with Whom We Share this Personal Data:
Profile or Contact Data
  • First and last name
  • Email
  • Phone number
  • Unique identifiers such as passwords
  • Service Providers
  • Analytics Partners
  • Business Partners
  • Parties You Authorize, Access or Authenticate
Device/IP Data
  • IP address
  • Email
  • Device ID
  • Service Providers
  • Analytics Partners
  • Parties You Authorize, Access or Authenticate
Web Analytics
  • Web page interactions
  • Referring webpage/source through which you accessed the Services
  • Non-identifiable request IDs
  • Statistics associated with the interaction between device or browser and the Services
  • Service Providers
  • Analytics Partners
  • Business Partners
Consumer Demographic Data
  • Age / date of birth
  • Zip code
  • Service Providers
  • Analytics Partners
  • Business Partners
Non-Public Education Data
  • Education level
  • Graduation year
  • Service Providers
  • Analytics Partners
  • Business Partners
  • Parties You Authorize, Access or Authenticate
Geolocation Data
  • IP-address-based location information
  • Service Providers
  • Analytics Partners
Inferences Drawn From Other Personal Data Collected
  • Inferences reflecting user preferences or abilities/aptitudes
  • Service Providers
  • Analytics Partners
  • Business Partners

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.
  1. When you create an account or use our interactive tools and Services.
  2. When you voluntarily provide information in free-form text boxes through the Services or through responses to surveys or questionnaires.
  3. When you send us an email or otherwise contact us.

Third Parties

  • Vendors
  1. 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.
  • Social Networks
  1. 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.

Our Commercial or Business Purposes for Collecting or Disclosing Personal Data

  • Providing, Customizing and Improving the Services
  1. Creating and managing your account or other user profiles.

How We Disclose Your Personal Data
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:
  1. Hosting, technology and communication providers.
  2. Security and fraud prevention consultants.
  3. Support and customer service vendors.
  • Analytics Partners. These parties provide analytics on web traffic or usage of the Services. They include:
  1. Companies that track how users found or were referred to the Services.
  2. Companies that track how users interact with the Services.
  • Business Partners. These parties partner with us in offering various services. They include:
  1. Healthcare Institutions that use WorkUp as a workforce development resource.
  2. Healthcare Institutions and other entities that we partner with to offer joint promotional offers or opportunities.
  • Parties You Authorize, Access, or Authenticate
  1. Third parties you access through the services.
  2. Social media services.

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 of 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.

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 and promote our business, provided that we will not share such data in a manner that could identify you.

Personal Data of Children
The Children’s Online Privacy Protection Act (“COPPA”) requires that online service providers obtain parental consent before they knowingly collect personally identifiable information online from children who are under 13 years of age. We do not knowingly or intentionally collect or solicit personally identifiable information from a child under 13 without obtaining verifiable consent from that child’s parent or guardian (“Parental Consent”), except for the limited amount of personally identifiable information we need to collect in order to obtain Parental Consent (“Required Information”). Until we have received Parental Consent, we will only use Required Information for the purpose of obtaining Parental Consent. If you are a child under 13 years of age, please do not attempt to send any Personal Data about yourself to us before we obtain Parental Consent, except for the Required Information in the context of the Parental Consent process. If you believe that a child under 13 years of age has provided us with Personal Data (beyond the Required Information) without our obtaining Parental Consent, please contact us at support@workup.health.  We do not condition participation in our Services on disclosure of more Personal Data from a child under 13 years of age than is reasonably necessary for that participation, and we do not retain Personal Data from children under 13 years of age longer than is reasonably necessary in order to fulfill the purpose for which it was disclosed.

If you are a parent or guardian of a user of our Services who is under 13 years of age, you may contact us at any time to ask that (a) we stop collecting Personal Data from such user, (b) we delete any Personal Data already collected from such user (although note that we may further retain information in an anonymous or aggregated form where that information would not identify such user personally), or (c) we stop disclosing Personal Data collected from such user to third parties, but continue to allow for collection and use of Personal Data collected from such user in connection with the Services.

If you’re above the age of 13 but under the age of 18, you represent and warrant that you’ve received your parent’s or guardian’s permission to use the Services and gotten your parent or guardian to agree to our Terms of Use [insert URL] on your behalf and also to agree on their own behalf.

For clarity, we do not collect, maintain, use or share any Personal Data of any users under the age of 13 beyond that needed for purposes of providing the Services or otherwise as authorized by the such user or his/her parent or legal guardian pursuant to this Privacy Policy. In no instance do we sell, as that term is defined in applicable data privacy laws, any Personal Data of users who are under the age of 13 to anyone.

Tracking Tools and Opt-Out
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 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/.


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 clicking [LINK]. To find out more information about Cookies generally, including information about how to manage and delete Cookies, please visit http://www.allaboutcookies.org/.

WorkUp uses [session replay provider], which is a tool that we use to provide a better user experience for you and collect data used to diagnose user issues. It records and captures a user’s session so that we can monitor user actions like mouse clicks, movements, and site interactions. If you would like to opt out, [session replay provider] provides the following link: [insert if available].

Data Security
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.

Data Retention
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 device/IP data for as long as we need it to ensure that our systems are working appropriately, effectively and efficiently.



State Law Privacy Rights

California Resident 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; in order to submit such a request, please contact us at support@workup.health.

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. You can exercise this right by contacting us atsupport@workup.health with the subject line “Nevada Do Not Sell Request” and providing us with your name and the email address associated with your account.

Contact Information:
If you have any questions or comments about this Privacy Policy, the ways in which we collect and use your Personal Data or your choices and rights regarding such collection and use, please do not hesitate to contact us at:

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