Last Updated and Effective as of June 30, 2022
Children Age 18 and Under:
Alter Health recognizes the special obligation to protect personally identifiable information obtained from individuals age 18 and under. AS SUCH, IF YOU ARE 18 YEARS OLD OR YOUNGER, ALTER HEALTH REQUESTS THAT YOU NOT SUBMIT ANY PERSONAL INFORMATION TO THE SITE OR TO ALTER HEALTH. If Alter Health discovers that anyone age 18 or younger has signed up on the Site or provided us with personally identifiable information, we will delete that child’s identifiable information from our records.
Information We Collect and How We Collect It
When you access the Site and its Services, we will learn certain information about you during your visit. We collect this information:
- Directly from you when you provide it to us.
- Automatically as you navigate through the Site. Information collected automatically may include usage details, IP addresses and information collected through cookies, web beacons and other tracking technologies.
Information You Provide to Us.
We collect and maintain information that you voluntarily submit to us during your use of the Site and our Services (collectively, “personal information”). For example:
- when you register for and purchase an online course or other product or service sold through this Site, you may provide us certain information including your name, e-mail address, screen name, password, and your credit card and billing information;
- if you sign-up to receive our newsletter, a free resource, or to be added to a waitlist, if any of those options are added, you may provide us your name and e-mail address;
- if you fill out any type of form on the Site, including a contact form or e-mail us for customer support or questions, we collect your contact information that you provide such as your name, e-mail, phone number, any comments or messages you provide, and records and copies of your correspondence together with your e-mail address and our responses.
You are not required to provide any personal information to merely access or visit the Site.
If you are located in the European Economic Area (EEA), this means we are regulated under the General Data Protection Regulation which applies across the European Union (including in the United Kingdom), and we are responsible as data controller of that personal information for the purposes of those laws.
Information We Collect Through Automatic Data Collection Technology.
As a general policy, no personally identifiable information, such as your name, address, or e-mail address, is automatically collected from your visit to the Site. However, certain non-personal information is recorded by the standard operation of Alter Health’s internet servers. Information such as the type of browser being used, its operating system, and your IP address is gathered in order to enhance your online experience.
We use analytics cookies to view Site traffic, activity, and other data. This nonpersonal information will generally include information about your location, your traffic pattern through our Site, and any communications between your computer and our Site. Among other things, we may collect data about your computer hardware and software, your Internet connection, your IP address, your operating system, your browser type, domain names, access dates and times, referring website addresses, and information about the areas of the Site you visit and search terms you use on this Site and about the links you may select from within this Site to other areas of the Internet. We also may use these technologies to collect information about your online activities over time and across third-party websites or other online services (behavioral tracking) such as the websites you visited just before and just after this Site.
Any such information collected automatically is used for statistical data and will not include personal information. We use such technologies and the information collected by them to improve the Site and our service as it enables us to analyze our Site performance, estimate our audience size, track usage patterns, save information from your previous visits about your preferences to customize your experience and speed up your searches and recognize you when you return to our Site.
These cookies are restricted for use only on our Site, and do not transfer any personal information to any other party. Most browsers are initially set up to accept cookies. You can, however, reset your browser to refuse all cookies or indicate when a cookie is being sent. Please consult the technical information relevant to your browser for instructions. If you choose to disable your cookies setting or refuse to accept a cookie, some parts of the Site may not function properly or may be considerably slower.
We also reserve the right to use technological equivalents of cookies, including social media pixels. These pixels allow social media sites to track visitors to outside websites so as to tailor advertising messages users see while visiting that social media website. We reserve the right to use these pixels in compliance with the policies of the various social media sites.
If your browser sends a "Do Not Track" signal, only a generic cookie will be placed on your device while the Site is accessed.
To the extent that you voluntarily provide personal information to us, our systems will associate the automatically collected information with your personal information.
This Site may also use Google Analytics so that we can understand and analyze the usage trends and preferences of visitors in order to improve our service and develop new features and functionalities. Google Analytics is a web analytics service offered by Google that tracks and reports website traffic. Google uses the data collected to track and monitor the use of our Site. This data is shared with other Google services. Google may use the collected data to contextualize and personalize the ads of its own advertising network. To learn more about Google Analytics and how they may collect and use your data, please visit: "How Google uses data when you use our partners' sites or apps," located at https://policies.google.com/technologies/partner-sites.
How We Use Your Information
We use information that we collect about you or that you provide to us, including any personal information, in the ways described below or described at the time that the information is collected. In general, we use the information we collect about you as necessary or appropriate to:
- administer your account when you register for one of our Services such as an online course or program;
- register you and provide you access to the Site or our Services;
- respond to your inquiries or requests that you direct to us or provide you with information you request from us;
- fulfill orders, complete customer transactions, and process payments if you make a payment or purchase through this Site;
- send you e-mails when you sign up for our e-mail newsletter;
- send communications and administrative e-mails about the Site or our Services;
- personalize and better tailor the features, performance, and support of the Site and our Services for your use;
- send you promotional/marketing information, offers or other information regarding opportunities and functionality that we think would be of particular interest to you;
- improve the quality of the Site and our Services;
- analyze, benchmark and conduct research on, user data and user interactions with the Site and our Services so that we can improve the quality and performance of the Site and our Services; and
- carry out our obligations and enforce our rights arising from any agreements entered into between you and us.
Email Policies and CAN-SPAM Act
In compliance with the CAN-SPAM Act, all e-mails sent from Alter Health will clearly state who the e-mail is from and provide clear information on how to contact the sender. In addition, all e-mail messages from us provide the opportunity to opt-out of receiving future communications from us by clicking on the unsubscribe link located at the bottom of any such e-mail at any time. After unsubscribing, we will discontinue sending the messages as soon as technically feasible.
Disclosure of Your Information: Who We Share Your Information With
Who Has Access to Your Data Within Alter Health
Within Alter Health, access to your data is limited to those persons who require access in order to provide you with the Services you purchase from us, to contact you, and to respond to your inquiries. Employees and contractors of Alter Health, if any, will only have access to data on a “need to know” basis.
How We Disclose Information to Third Parties
Alter Health respects your privacy and we do not sell, rent, lease, trade or otherwise transfer any information collected, whether automatically or through your voluntary action, to third parties (beyond what is necessary for the basic functionality of an online service or for fulfilling a customer transaction if applicable) without your consent.
- To our subsidiaries and affiliates if any.
- To third parties including, for example: contractors, service providers and ‘data processors’ as described below, that we use to support our business and our Site. All such third parties will always be bound by contractual obligations to keep personal information confidential and use it only for the purposes for which we disclose it to them.
- To any successor in interest in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of Alter Health’s assets and/or business.
- If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of Alter Health, other users of the Site or the general public. This includes exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction.
- To comply with any legal obligations such as court order, law or legal process, including to respond to any government or regulatory request and when compelled by a court or other governmental entity to do so.
- For any other purpose disclosed by us when you provide the information.
- With your consent.
As previously noted, if you are located in the European Economic Area (EEA), this means we are the ‘data controller” under the General Data Protection Regulation of any personal information collected through the Site, and we determine the purposes for which and the manner in which any personal information is used and processed. However, we pay for the services of third party ‘data processors’ who hold and/or process personal information of users of the Site on our behalf. We may have multiple data processors at any given time, including, but not limited to:
- our email marketing and email management software service provider;
- our Site hosting and platform service provider Kajabi;
- payment merchants for purchases directly through our Site;
- Instagram; and
- other social media sites.
Note that, while the above entities act as data processors on our behalf, some or all of them may also act as data controllers in their own rights. For example, if you purchase a product or service directly through our Site, payment merchants decide which information they need from our customers in order to process their payments correctly. The payment merchants or other data processing entities may also exercise control over the other purposes that a customer's data is used for, for example direct marketing of their products and services, which is not within our control. The payment merchants or other data processing entities also have legal requirements of their own to meet, such as regulations relating to the use and retention of payment card data or other personal data. And, finally, each data processor has its own terms and conditions and privacy policies that apply directly to our Site users.
Because the Site is hosted on Kajabi, we agreed to Kajabi’s Data Processing Addendum, which addresses how Kajabi processes data of our Site visitors on our behalf.
Message Boards, Chats and Interactive Forums
We may make message boards and other interactive forums available as part of the Services such as private member or community groups. You should be aware that any information which you post to these interactive forums or otherwise choose to make publicly available may be disclosed and available to all users who have access to that portion of the Site or Services and is therefore no longer private. By using these interactive forums, you agree that we are not responsible for any information that you disclose or communicate in such forums, and any disclosures you make are at your own risk.
Use and Transfer of Your Information Out of the European Economic Area (EEA), the UK and Switzerland
The General Data Protection Regulation (GDPR) requires certain safeguards when transferring personal data from outside the European Economic Area (EEA), the United Kingdom (UK) and Switzerland to "third countries," which are all countries outside these protected areas, including the United States. This Site is operated in the United States, and third parties with whom we might share your personal information as explained above are also located in the United States and Canada. If you are located in the EEA, the UK, Switzerland or elsewhere outside of the United States or Canada, please be aware that any information you provide to us will be transferred to the United States and Canada. By using this Site, participating in any of our Services and/or providing your information, you consent to this transfer.
The United States and Canada do not have the same data protection laws as the EEA, United Kingdom and Switzerland. While the European Commission has not given a formal decision that United States or Canada provide an adequate level of data protection similar to those which apply in the EEA, the UK and Switzerland, any transfer of your personal information will be subject to the derogation in Article 49 permitting non-repetitive transfers that concern only a limited number of data subjects, as permitted by Article 49 of the General Data Protection Regulation that is designed to help safeguard your privacy rights and give you remedies in the unlikely event of a misuse of your personal information.
If you would like further information, see How to Contact Us below. We will not otherwise transfer your personal data outside of the EEA, the UK or Switzerland, or to any organization (or subordinate bodies) governed by public international law or which is set up under any agreement between two or more countries.
How Long Your Personal Information Will Be Kept
We will retain all non-customer personal information until you let us know you would like for us to delete it or unsubscribe from our e-mail contacts, which you are free to do at any time. However, if you make a purchase from our Site, you will be considered a customer, and we will hold personal data in our files for at least six years as advised by the IRS.
How We Protect Your Information: Data Security and Information Storage
We employ commercially reasonable methods to ensure the security of the information you provide to us and the information we collect automatically. This includes using standard security protocols and working only with reputable third-party vendors. We limit access to your personal information to those who have a genuine business need to know it. Those processing your information will do so only in an authorized manner and are subject to a duty of confidentiality.
If Alter Health collects sensitive personal information (such as credit card data), that information is encrypted and transmitted to Alter Health in a secure way, such as the Secure Socket Layer (SSL) protocol. Customers can verify this by looking for a closed lock icon at the bottom of their web browser or looking for “https” at the beginning of the address of the web page.
However, please note that unfortunately no data transmission over the Internet or any wireless network can be guaranteed to be 100% secure. As a result, while we strive to protect your personal information, we cannot guarantee the security of your personal information transmitted to our Site. You acknowledge that (a) there are security and privacy limitations of the Internet which are beyond our control; (b) the security, integrity, and privacy of any and all information and data exchanged between you and us through this Site cannot be guaranteed; and (c) any such information and data may be viewed or tampered within transit by a third party. Any transmission of personal information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on the Site.
We will notify you and any applicable authorities of a suspected data security breach where we are legally required to do so.
Passwords to Access Purchased Products and Services
To use certain features of our Site and access our Services such as courses and programs you purchase, you may be issued a unique username and password, which you will receive through your registration and/or purchase process. You are responsible for maintaining the confidentiality of the password and account, and you are responsible for all activities (whether by you or by others) that occur under your password or account.
You are not permitted to share your username and/or password with anyone. If you share your username and/or password with another person, we reserve the right to immediately terminate your access to the Site or Service. We cannot and will not be liable for any loss or damage arising from your failure to protect your password or account information. You are responsible for activities that take place using your password(s) and within your account. If you share your password(s) with anyone, they may be able to obtain access to your personal information at your own risk.
You agree to notify Alter Health immediately of any unauthorized use of your password or account or any other breach of security, and to ensure that you exit from your account at the end of each session.
By using this Site, you agree to enter true and accurate information as part of the registration, purchase process and otherwise. If you enter a false email address, or other false or inaccurate information, we have the right to immediately inactivate your account or block your participation in any feature or Service delivered on or through this Site.
We will use our best efforts to keep your password(s) private and will not otherwise share your password(s) without your consent, except as necessary when the law requires it or in the good faith belief that such action is necessary, particularly when disclosure is necessary to identify, contact or bring legal action against someone who may be causing injury to others or interfering with our rights or property.
Facebook and Instagram
We abide by Facebook’s Data Use Restrictions.
- Any ad data collected, received or derived from our Facebook ad (“Facebook advertising data”) is only shared with someone acting on our behalf, such as our service provider. We are responsible for ensuring that our service providers protect any Facebook advertising data or any other information obtained from us, limit our use of all of that information, and keep it confidential and secure.
- We do not use Facebook advertising data for any purpose (including retargeting, commingling data across multiple advertisers’ campaigns, or allowing piggybacking or redirecting with tags), except on an aggregate and anonymous basis (unless authorized by Facebook) and only to assess the performance and effectiveness of our Facebook advertising campaigns.
- We do not use Facebook advertising data, including the targeting criteria for a Facebook ad, to build, append to, edit, influence, or augment user profiles, including profiles associated with any mobile device identifier or other unique identifier that identifies any particular user, browser, computer or device.
- We do not transfer any Facebook advertising data (including anonymous, aggregate, or derived data) to any ad network, ad exchange, data broker or other advertising or monetization related service.
Your Rights: Accessing, Correcting and Deleting Your Information
As noted above, if you want to unsubscribe from receiving e-mails from Alter Health, you may do so at any time. Each e-mail from Alter Health includes instructions for unsubscribing from these e-mail communications.
You may send us an e-mail to [email protected] in order request access to, correct or delete any personal information that you have provided to us.
Please note that we may retain some or all of the information you submit for backups, archiving, prevention of fraud and abuse, analytics, satisfaction of legal obligations, or where we otherwise reasonably believe that we have a legitimate reason to do so.
You may also decline to share certain personal information with us, in which case we may not be able to provide you with some of the features and functionality of our Services.
If you place an order through the Site, we will maintain your order information for our records unless and until you ask us to delete this information. We are required to keep some basic information about our customers including transaction data for tax and legal purposes and therefore there is some information that cannot be deleted.
Visitors’ GDPR Rights
If you are located within the European Union, you are entitled to certain information and have certain rights under the General Data Protection Regulation. Those rights include:
- Fair processing of information and transparency over how we use your use personal information
- Require us to correct any mistakes in your information which we hold
- Require the erasure of personal information concerning you in certain situations
- Receive the personal information concerning you which you have provided to us, in a structured, commonly used and machine-readable format and have the right to transmit those data to a third party in certain situations
- Object at any time to processing of personal information concerning you for direct marketing
- Object to decisions being taken by automated means which produce legal effects concerning you or similarly significantly affect you
- Object in certain other situations to our continued processing of your personal information
- Otherwise restrict our processing of your personal information in certain circumstances
- You may also have the right to claim compensation for damages caused by our breach of any data protection laws.
We hope that we can resolve any question or concern you raise about our use of your information.
If you are covered by the General Data Protection Regulation, you may lodge a complaint with a supervisory authority, in particular in the European Union (or European Economic Area) state where you work, normally live, or where any alleged infringement of data protection laws occurred.
For further information on each of those rights, including the circumstances in which they apply, see the Guidance from the UK Information Commissioner’s Office (ICO) on individuals’ rights under the General Data Protection Regulation, available at: https://ico.org.uk/for-organisations/guide-to-the-general-data-protection-regulation-gdpr/individual-rights/.
We require only the information that is reasonably required to enter into a contract with you. We will not require you to provide consent for any unnecessary processing as a condition of entering into a contract with us.
If you would like to exercise any of those rights, please:
- Email us at [email protected]
- Provide us enough information to identify you (e.g., name, e-mail address, or other information, as applicable) and verify proof of your identity
- Provide us with the information to which your request relates.
Your Access to and Control Over Your Personally Identifiable Information
At any time, but only once per calendar year, or as otherwise required under applicable law, users may contact Alter Health to review the personally identifiable information that Alter Health has collected about you. If you discover any errors, please notify Alter Health and the information will be corrected. To review the personally identifiable information that company has collected about you, please send an email to [email protected] with the subject line: “Personal Information Review Request.” Users may also request that Alter Health delete a user account(s) or, if you have not established a user account, your email address, and any related data at any time. If you wish to delete your user account(s), please email us at [email protected] with the words “Delete Account” in the subject line. If you do not have a user account and wish to delete your email address or other personally identifiable information that you might have provided through your use of the Site and/or any Services, please email us at [email protected] with the words “Delete My Information” in the subject line.
Your California Privacy Rights
California Civil Code Section 1798.83 permits California residents to request from companies conducting business in California a list of third parties to which Alter Health has disclosed personally identifiable information during the preceding year for direct marketing purposes. Alter Health has not and will not share your personally identifiable information with third parties for their direct marketing purposes; accordingly, it will not maintain such a list of third parties. If you are a resident of California and want additional information confirming how Company does not share your personally identifiable information with third parties for their direct marketing purposes, you may contact us at [email protected] with the words “California Privacy” in the subject line of your email.
California Online Privacy Protection Act
Pursuant to CalOPPA we agree to the following:
- Users can visit our Site anonymously
- Users are able to change their personal information:
- By emailing us
- By logging into their account on our Site if they have one
As noted above, if your browser sends a "Do Not Track" signal, only a generic cookie will be placed on your device while the Site is accessed.
California Consumer Privacy Act (CCPA)
The California Consumer Privacy Act (CCPA) took effect on January 1, 2020 and is intended to protect the personal information of California residents. The CCPA has certain threshold requirements which a company must meet in order to be required to comply with its provisions. Upon information and belief, we do not meet those thresholds. In the event of a change in our status, and if the data that you provide in the course of your use of the Site is governed by CCPA, we will abide by the relevant portions of the CCPA.
If you are a resident of the state of California, you may have the right to: request disclosure of the personal information we have collected about you and the types of third parties with whom it has been shared; request a portable copy of your information; opt out from marketing messages or the sale of your information to third parties; and request deletion of your personal information. To make these requests, please contact us at [email protected]