Privacy Policy

Last Revised, May 2018

Basis Labs, Inc. (“Basis Labs,” “we,” or “us”) is committed to protecting your privacy. We have prepared this Privacy Policy to describe the types of information we may collect from you when you visit our website located at [www.mybasis.com] and all Basis Labs-owned websites and domains (collectively, the “Site”), our mobile application (“Application(s)”), and products and services enabled via the Site and/or Application (collectively with the Site and Application, the “Services”).

Questions; Contacting Basis Labs; Reporting Violations. If you have any questions or concerns or complaints about our Privacy Policy or our data collection or processing practices, or if you want to report any security violations to us, please contact us at the following address or phone number:

Basis Labs, Inc.
Attn: Privacy Compliance Officer
450 Townsend St, San Francisco, CA, 94107, United States

User Consent. By submitting personal information through our Services, you agree to the terms of this Privacy Policy and you expressly consent to the collection, use and disclosure of your personal information in accordance with this Privacy Policy.

A Note About Children. The Services are not directed to, and we do not intentionally gather personal information from, visitors who are under the age of 13. If a child under 13 submits personal information to Basis Labs and we learn that the personal information is the information of a child under 13, we will attempt to delete the information as soon as possible. If you believe that we might have any personal information from a child under 13, please contact us at help@mybasis.com

Data Transfers. Basis Labs is based in the State of California in the United States. When we obtain information about you, we may transfer, process, and store such information outside of the country in which you reside, including in the United States. By using the Services, you consent to the transfer to and processing and storage of your information in countries outside of your country of residence, which may have different data protection laws than those in the country where you reside.

Types of Data We Collect.

5.1 Information You Provide to Us.

5.1.1 We may collect personal information from you, such as your first and last name, gender, e-mail and mailing addresses, and password when you create an account (“Account”) or download the Application.

5.1.2 When you use our Services, we collect the information you provide about yourself in response to the questions that our Service presents to you. For example, we will collect your response in connection with the question “What’s on your mind?”, in order to assist you with finding another peer you can talk to you about the issue(s) relevant to your response.

5.1.3 When you purchase Services such as a discussion session with one of your peers, our third party payment processor may collect all information necessary to complete the transaction, including your name, credit card information, billing information.

5.1.4 We retain information on your behalf, such as files and messages that you store using your Account.

5.1.5 If you provide us feedback or contact us via e-mail, we will collect your name and e-mail address, as well as any other content included in the e-mail, in order to send you a reply.

5.1.6 When you post content (text, images, photographs, messages, comments or any other kind of content that is not your e-mail address) on our Service, the information contained in your posting will be stored in our servers and other users will be able to see it, along with your profile photo and any other information that you choose to make public on your public profile page (“Profile”). The information that you provide in your Profile will be visible to others, including anonymous visitors to the Site.

5.1.7 When you post messages on the message boards of our Site or Application, the information contained in your posting will be stored on our servers and other users will be able to see it.

5.1.8 When you participate in one of our surveys, we may collect additional profile information.

5.1.9 If you participate in a sweepstakes, contest or giveaway through our Services, we may ask you for your e-mail address and/or home number (to notify you if you win or not). We may also ask for first and last names, and sometimes post office addresses to verify your identity. In some situations we may need additional information as a part of the entry process, such as a prize selection choice. These sweepstakes and contests are voluntary. We recommend that you read the rules for each sweepstakes and contest that you enter.

5.1.10 We may also collect personal information at other points in our Site that state that personal information is being collected.

5.2 Information You Provide to Facebook and other Social Networking Sites. We may enable you to log into the Services using a social media account, and if you do so you may be asked to grant us access to certain information from your social media profile, such as your friends or contacts lists, photographs, and updates. Social media networks operate independently from Basis Labs, and we are not responsible for social media networks’ interfaces or privacy or security practices. Please refer to the privacy settings of the applicable social media platform or application to determine how you may manage the interactivity between Basis Labs and your social media account.

5.3 Information Collected via Technology.

5.3.1 Log Files. As is true of most websites, we gather certain information automatically and store it in log files. This information includes IP addresses, browser type, Internet service specialist (“ISP”), referring/exit pages, operating system, date/time stamp, and clickstream data. We use this information to analyze trends, administer the Services, track users’ movements around the Services, gather demographic information about our user base as a whole, and better tailor our Services to our users’ needs. For example, some of the information may be collected so that when you visit the Site or the Services again, it will recognize you and the information could then be used to serve advertisements and other information appropriate to your interests. Except as noted in this Privacy Policy, we do not link this automatically-collected data to personal information.

5.3.2 Cookies. Like many online services, we use cookies to collect information. “Cookies” are small pieces of information that a website sends to your computer’s hard drive while you are viewing the website. We 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) to provide you with a more personal and interactive experience on our Services. This type of information is collected to make the Services more useful to you and to tailor the experience with us to meet your special interests and needs.

5.3.3 Pixel Tags. In addition, we use “Pixel Tags” (also referred to as clear Gifs, Web beacons, or Web bugs). Pixel Tags are tiny graphic images with a unique identifier, similar in function to Cookies, that are used to track online movements of Web users. In contrast to Cookies, which are stored on a user’s computer hard drive, Pixel Tags are embedded invisibly in Web pages. Pixel Tags also allow us to send e-mail messages in a format users can read, and they tell us whether e-mails have been opened to ensure that we are sending only messages that are of interest to our users. We may use this information to reduce or eliminate messages sent to a user. We do not tie the information gathered by Pixel Tags to our users’ personal information.

5.3.4 Mobile Services. We may also collect non-personal information from your mobile device if you have downloaded our Application(s). This information is generally used to help us deliver the most relevant information to you. Examples of information that may be collected and used include your geographic location, how you use the Application(s), and information about the type of device you use. In addition, in the event our Application(s) crash on your mobile device, we will receive information about your mobile device model software version and device carrier, which allows us to identify and fix bugs and otherwise improve the performance of our Application(s). This information is sent to us as aggregated information and is not traceable to any individual and cannot be used to identify an individual.

5.3.5 Analytics Services and Interest-Based Advertising. In addition to the tracking technologies we place, other companies may set their own cookies or similar tools when you access or use the Services. This includes third party analytics services, including but not limited to [Google Analytics] (“Analytics Services”) that we engage to help analyze how users use the Services, as well as third parties that deliver content or offers. We may receive reports based on these parties’ use of these tools on an individual or aggregate basis. We use the information we get from Analytics Services only to improve our Services. The information generated by the Cookies or other technologies about your use of our Services (the “Analytics Information”) is transmitted to the Analytics Services. The Analytics Services use Analytics Information to compile reports on user activity. The Analytics Services may also transfer information to third parties where required to do so by law, or where such third parties process Analytics Information on their behalf. Each Analytics Services’ ability to use and share Analytics Information is restricted by such Analytics Services’ Terms of Use and Privacy Policy. By using our Services, you consent to the processing of data about you by Analytics Services in the manner and for the purposes set out above. We may also partner with ad companies to support our marketing efforts, including by serving you ads better tailored to your likely interests. If you don’t want to take advantage of these services, you may be able to opt-out by visiting http://www.aboutads.info/ or http://networkadvertising.org/choices/.

5.3.6 How We Respond to Do Not Track Signals. We do not currently respond to “do not track” signals or other mechanisms that might enable consumers to opt out of tracking on our Website.

5.4 Location Information. If you have enabled location services on your phone, we collect your location information to make a map available to the recipients of your messages showing your location. If you do not want this information collected by us, you can disable location services on your phone.

Use of Your Personal Information

6.1 General Use. In general, personal information you submit to us is used either to respond to requests that you make, or to aid us in serving you better. We use your personal information in the following ways:

6.1.1 facilitate the creation of and secure your Account on our network;

6.1.2 identify you as a user in our system;

6.1.3 send you a welcome e-mail to verify ownership of the e-mail address provided when your Account was created;

6.1.4 process orders you place and complete other transactions you have requested using the Services, and provide you with products and services you request;

6.1.5 maintain a record of your purchases and other transactions using the Services;

6.1.6 respond to your questions and comments and provide customer support.

6.1.7 Send you information or materials you request;

6.1.8 operate, evaluate, and improve our business and the products and services we offer;

6.1.9 communicate with you about our products, services, offers, and promotions and third party products and services that may be of interest to you;

6.1.10 analyze and enhance our marketing communications and strategies, including by identifying when emails sent to you have been received and read;

6.1.11 analyze trends and statistics regarding use of the Services and transactions conducted using the Services;

6.1.12 protect against and prevent fraud, unauthorized transactions, claims, and other liabilities, and manage risk exposure, including by identifying potential hackers and other unauthorized users;

6.1.13 enforce our terms of use and other agreements with you; and

6.1.14 comply with applicable legal requirements and industry standards.

6.2 User Testimonials and Feedback. We often receive testimonials and comments from users who have had positive experiences with our Services. We occasionally publish such content. When we publish this content, we may identify our users by their first and last name and may also indicate their home city. We obtain the user’s consent prior to posting his or her name along with the testimonial. We may post user feedback on the Services from time to time. We will share your feedback with your first name and last initial only. If we choose to post your first and last name along with your feedback, we will obtain your consent prior to posting you name with your feedback. If you make any comments on a blog or forum associated with our Services, you should be aware that any personal information you submit there can be read, collected, or used by other users of these forums, and could be used to send you unsolicited messages. We are not responsible for the personally identifiable information you choose to submit in these blogs and forums.

6.3 Creation of Anonymous Data. We may create anonymous data records from personal information by excluding information (such as your name) that makes the data personally identifiable to you. We use this anonymous data to analyze request and usage patterns so that we may enhance the content of our Services and improve Site navigation. We reserve the right to use anonymous data for any purpose and disclose anonymous data to third parties in our sole discretion.

Disclosure of Your Personal Information. We disclose your personal information as described below and as described elsewhere in this Privacy Policy.

7.1 Peer Specialists. Our Services enable users to connect with their peers who have experience and expertise in providing emotional support, life coaching and advice (each, a “Specialist”). In order to enable them to contact you and provide you the types of services you request, we may provide our Specialists with the username you provide and the answers you provided to our preliminary survey, such as your answers to the question “What’s on your mind?”

7.2 Third Party Service Specialists. We may share your personal information with third party service specialists to: provide you with the Services that we offer you; to conduct quality assurance testing; to facilitate creation of accounts; to provide technical support; and/or to provide other services to the Basis Labs. These third party service specialists are required not to use your personal information other than to provide the services requested by Basis Labs.

7.3 Affiliates. We may share some or all of your personal information with our parent company, subsidiaries, joint ventures, or other companies under a common control (“Affiliates”), in which case we will require our Affiliates to honor this Privacy Policy.

7.4 Corporate Restructuring. We may share some or all of your personal information in connection with or during negotiation of any merger, financing, acquisition or dissolution transaction or proceeding involving sale, transfer, divestiture, or disclosure of all or a portion of our business or assets. In the event of an insolvency, bankruptcy, or receivership, personal information may also be transferred as a business asset. If another company acquires our company, business, or assets, that company will possess the personal information collected by us and will assume the rights and obligations regarding your personal information as described in this Privacy Policy.

7.5 Other Disclosures. Regardless of any choices you make regarding your personal information (as described below), Basis Labs may disclose personal information if it believes in good faith that such disclosure is necessary (a) in connection with any legal investigation; (b) to comply with relevant laws or to respond to subpoenas or warrants served on Basis Labs; (c) to protect or defend the rights or property of Basis Labs or users of the Site or Services; and/or (d) to investigate or assist in preventing any violation or potential violation of the law, this Privacy Policy, or our Terms of Service.

Third Party Websites. Our Site may contain links to third party websites. When you click on a link to any other website or location, you will leave our Site and go to another site, and another entity may collect personal information or anonymous data from you. We have no control over, do not review, and cannot be responsible for, these outside websites or their content. Please be aware that the terms of this Privacy Policy do not apply to these outside websites or content, or to any collection of your personal information after you click on links to such outside websites. We encourage you to read the privacy policies of every website you visit. The links to third party websites or locations are for your convenience and do not signify our endorsement of such third parties or their products, content or websites.

Your Choices Regarding Information. You have several choices regarding the use of information on our Service:

9.1 Email Communications. We will periodically send you free newsletters and e-mails that directly promote the use of our Site or Services. When you receive newsletters or promotional communications from us, you may indicate a preference to stop receiving further communications from us and you will have the opportunity to “opt-out” by following the unsubscribe instructions provided in the e-mail you receive or by contacting us directly (please see contact information above). Despite your indicated e-mail preferences, we may send you service related communications, including notices of any updates to our Terms of Service or Privacy Policy.

9.2 Cookies. If you decide at any time that you no longer wish to accept Cookies from our Service for any of the purposes described above, then you can instruct your browser, by changing its settings, to stop accepting Cookies or to prompt you before accepting a Cookie from the websites you visit. Consult your browser’s technical information. If you do not accept Cookies, however, you may not be able to use all portions of the Service or all functionality of the Service. If you have any questions about how to disable or modify Cookies, please let us know at the contact information provided above.

9.3 Changing or Deleting Your Personal Information. You may change any of your personal information in your Account by editing your profile within your Account or by sending an e-mail to us at the e-mail address set forth below. You may request deletion of your personal information by us, and we will use commercially reasonable efforts to honor your request, but please note that we may be required to keep such information and not delete it (or to keep this information for a certain time, in which case we will comply with your deletion request only after we have fulfilled such requirements). When we delete any information, it will be deleted from the active database, but may remain in our archives. We may also retain your information for fraud or similar purposes.

9.4 Applications. You can stop all collection of information by the Application(s) by uninstalling the Application(s). You may use the standard uninstall processes as may be available as part of your mobile device or via the mobile application marketplace or network.

10 Changes to This Privacy Policy. This Privacy Policy may be updated from time to time for any reason. We will notify you of any changes to our Privacy Policy by posting the new Privacy Policy at mybasis.darwinapps.com/privacy-policy/ and we will change the “Last Revised” date above. You should consult this Privacy Policy regularly for any changes.

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