Nudge Privacy Policy

Effective Date: January 17, 2025

This Privacy Policy describes how Nudge Workbench OpCo, LLC ("Nudge", "we", "us", or "our") handles personal information that we collect through our website or through any other websites that we own or control and that link to this Privacy Policy.

Personal information we collect

Information you submit to us:

  • Contact information, such as your first and last name, email address and phone number you may provide when you contact us or when you sign up for our studies or Services.
  • Demographic information, such as gender and age.
  • Account information, such as the username and password you use to access our Services.
  • Health information, such as information regarding medical conditions, prescriptions, treatments, self-assessments or symptoms that you upload or make available to us when engaging with our Service, including our studies. For more information, please also refer to our Consumer Health Data Privacy Policy.
  • Payment information needed to complete your transactions with us, including name, payment card information, and billing information. This information is processed by our payment service providers, which may handle your payment information in accordance with its own privacy policies. We do not have access to your full payment card information.
  • User generated information, such as photos or other user-generated content that you upload or otherwise provide through the Services.
  • Feedback or correspondence, such as information you provide when you contact us with questions, feedback, or otherwise correspond with us online.
  • Other data not specifically listed here, which we will use as described in this Privacy Policy or as otherwise disclosed at the time of collection.

Information we obtain from third parties:

We may maintain pages on social media platforms, such as LinkedIn, and other third-party platforms. When you visit or interact with our pages on those platforms, the platform provider's privacy policy will apply to your interactions and their collection, use, and processing of your personal information.

Automatic data collection. We and our service providers may automatically log information about you, your computer or mobile device, and your interactions over time with our website, our communications and other online services, such as:

  • Device data, such as your computer's or mobile device's operating system type and version, manufacturer and model, browser type, screen resolution, RAM and disk size, CPU usage, device type (e.g., phone, tablet), IP address, unique identifiers, language settings, mobile device carrier, radio/network information (e.g., WiFi, LTE, 4G), and general location information such as city, state or geographic area.
  • Online activity data, such as pages or screens you viewed, how long you spent on a page or screen, browsing history, navigation paths between pages or screens, information about your activity on a page or screen, access times, duration of access, and whether you have opened our marketing emails or clicked links within them.

We use the following tools for automatic data collection:

  • Cookies, which are text files that websites store on a visitor's device to uniquely identify the visitor's browser or to store information or settings in the browser for the purpose of helping you navigate between pages efficiently, remembering your preferences, enabling functionality, helping us understand website user activity and patterns, and for advertising purposes.
  • Local storage technologies, like HTML5, that provide cookie-equivalent functionality but can store larger amounts of data, including on your device outside of your browser in connection with specific applications.
  • Web beacons, also known as pixel tags or clear GIFs, which are used to demonstrate that a webpage or email was accessed or opened, or that certain content was viewed or clicked.

How we use your personal information

To provide, operate, maintain, and secure our website and services.

To communicate with you, including to respond to your requests, provide support, and otherwise communicate with you about our services, including by sending announcements, surveys, updates, security alerts, and support and administrative messages.

Improve, monitor, and personalize our website, including by understanding your needs and interests, and personalizing your experience with the website and our communications.

For research and development. We may use your personal information for research and development purposes, including to analyze and improve our services and our business. As part of these activities, we may create aggregated, de-identified, or other anonymous data from personal information we collect. We may use this data and disclose it to third parties for our lawful business purposes, including to analyze and improve our services and promote our business.

Direct marketing. We may from time-to-time send you direct marketing communications as permitted by law, including, but not limited to, newsletters, and updates on news and events.

You may opt out of our marketing emails as described in the "Opt out of marketing communications" section below.

Compliance and protection. We may use personal information to:

  • Comply with applicable laws, lawful requests, and legal process, such as to respond to subpoenas or requests from government authorities.
  • Protect our, your or others' rights, privacy, safety or property (including by making and defending legal claims).
  • Audit our internal processes for compliance with legal and contractual requirements and internal policies.
  • Enforce the terms and conditions that govern our website.
  • Prevent, identify, investigate and deter fraudulent, harmful, unauthorized, unethical or illegal activity, including cyberattacks and identity theft.

How we share your personal information

We do not sell your personal information and we do not share your personal information with third parties for advertising purposes. We may share your personal information in the following limited circumstances:

  • Service providers. We depend on trusted partners to help us provide the Services. Accordingly, we may disclose your personal information to third party companies and individuals that provide services on our behalf or help us operate our services (such as lawyers, bankers, auditors, insurers, customer support, hosting, analytics, email delivery, and database management).
  • Authorities and others. We may disclose your personal information to law enforcement, government authorities, and private parties, as we believe in good faith to be necessary or appropriate for the compliance and protection purposes described above.
  • Business transfers. We may sell, transfer or otherwise share some or all of our business or assets, including your personal information, in connection with a business transaction (or potential business transaction) such as a corporate divestiture, merger, consolidation, acquisition, reorganization or sale of assets, or in the event of bankruptcy or dissolution. In such a case, we will make reasonable efforts to require the recipient to honor this Privacy Policy.

Your choices

Opt out of marketing communications. You may opt out of marketing-related emails by following the opt-out or unsubscribe instructions at the bottom of the email. You may continue to receive service-related and other non-marketing emails.

Consumer health data rights. Depending on your location, if you provide us with health information (e.g. by participating in one of our research studies) you may make requests related to such health information. For more information, please also refer to our Consumer Health Data Privacy Policy.

Limit online tracking. There are a number of ways to limit online tracking, which we have summarized below. Please note that these tools are not associated with us and we cannot guarantee that they work as their providers advertise them:

  • Blocking cookies in your browser. Most browsers let you remove or reject cookies. To do this, follow the instructions in your browser settings. Many browsers accept cookies by default until you change your settings. For more information about cookies, including how to see what cookies have been set on your device and how to manage and delete them, visit https://www.allaboutcookies.org/.
  • Using privacy plug-ins or browsers. You can block our websites from setting cookies by using a browser with privacy features, like Brave, or installing browser plugins like Privacy Badger, Ghostery, or uBlock Origin, and configuring them to block third party cookies/trackers. You can also opt out of Google Analytics by downloading and installing the browser plug-in available at: https://tools.google.com/dlpage/gaoptout.
  • Blocking advertising ID use in your mobile settings. Your mobile device settings may provide functionality to limit use of the advertising ID associated with your mobile device for interest-based advertising purposes.
  • Platform opt-outs. The following advertising partners offer opt-out features that let you opt out of use of your information for interest-based advertising:

○ Google

○ LinkedIn

○ Microsoft

Advertising industry opt-out tools. You can also use these opt-out options to limit use of your information for interest-based advertising by participating companies:

○ Digital Advertising Alliance

○ Digital Advertising Alliance of Canada

Note that because these opt-out mechanisms are specific to the device or browser on which they are exercised, you will need to opt out on every browser and device that you use.

Do Not Track. Some Internet browsers may be configured to send "Do Not Track" signals to the online services that you visit. We currently do not respond to "Do Not Track" or similar signals. To find out more about "Do Not Track," please visit http://www.allaboutdnt.com.

Other sites, mobile applications and services

Our website may contain links to other websites, mobile applications, and other online services operated by third parties. These links are not an endorsement of, or representation that we are affiliated with, any third party. In addition, our content may be included on web pages or in mobile applications or online services that are not associated with us. We do not control third party websites, mobile applications or online services, and we are not responsible for their actions. Other websites and services follow different rules regarding the collection, use and disclosure of your personal information. We encourage you to read the privacy policies of the other websites and mobile applications and online services you use.

Security

We employ a number of technical, organizational, and physical safeguards designed to protect the personal information we collect. However, no security measures are failsafe and we cannot guarantee the security of your personal information.

Retention of Personal Information

Where required under applicable laws, we retain personal information for as long as is necessary to fulfill the purposes for which it was collected and processed, in accordance with our retention policies, and in accordance with applicable laws and regulatory obligations.

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 personal information, the purposes for which we use personal information and whether we can achieve those purposes through other means, and the applicable legal and regulatory requirements.

Children

We do not knowingly collect personal information from anyone under 18 years of age. If we learn that we have collected personal information through the website from anyone under 18 without the consent of the child's parent or guardian as required by law, we will delete it.

Changes to this Privacy Policy

We reserve the right to modify this Privacy Policy at any time. If we make material changes to this Privacy Policy, we will notify you by updating the date of this Privacy Policy and posting it on the website.

How to contact us

Please direct any questions or comments about this Policy or our privacy practices to [email protected].