PRIVACY POLICY

INTRODUCTION

Our privacy policy (the “Privacy Policy”) explains the information we collect, how we use and share it, how to manage your privacy controls and your rights in connection with our websites and the related mobile applications and services (collectively, the “Services”). Please also read our Terms of Service which sets out the terms governing the Services.

Lifeing is headquartered in London and our Services are provided to you by Revolutioneyes Me Ltd. If you are a resident of the European Economic Area (“EEA”), Revolutioneyes Me Ltd, Inc. is the controller of your personal data for the purposes of EEA data protection law.

This policy was written in English. To the extent a translated version conflicts with the English version, the English version controls. Unless indicated otherwise, this Privacy Policy does not apply to third party products or services or the practices of companies that we do not own or control, including other companies you might interact with on or through the Services.

Questions or comments about this Privacy Policy may be submitted by mail to the address below:

Revolutioneyes Me Ltd 18 Sulgrave Road, London, W6 7RP Attn: Legal hello@howmental.com

INFORMATION lifeing COLLECTS

Revolutioneyes Me Ltd collects information about you, including information that directly or indirectly identifies you, if you or your other members choose to share it with Revolutioneyes Me Ltd. We receive information in a few different ways, including when you track, complete or upload activities using the Services. Revolutioneyes Me Ltd also collects information about how you use the Services. There are also several opportunities for you to share information about yourself, your friends, and your activities with Revolutioneyes Me Ltd. For example:

CONTENT YOU SHARE

We gather information from the feelings and other content you share on the Services.

TECHNICAL INFORMATION AND LOG FILES

We collect information from your browser, computer, or mobile device, which provide us with technical information when you access or use the Services. This technical information includes device and network information, cookies, log files and analytics information. Learn more about how we use cookies and manage your preferences by visiting our Cookies Policy.

The Services use log files. The information stored in those files includes IP addresses, browser type, internet service provider (ISP), referring/exit pages, platform type, date/time stamp, and number of clicks. This information is used to analyze trends, administer, protect and secure the Services, track member movement in the aggregate, and gather broad demographic information for aggregate use. IP addresses may be linked to session IDs and device identifiers.

OTHER INFORMATION

We may collect information from you through third parties, such as when we collect your feedback through surveys.

We may also collect information about you from other members such as when they give you like or comment on activities.

HOW lifeing USES INFORMATION

Revolutioneyes Me Ltd uses the information we collect and receive as described below.

TO PROVIDE THE SERVICES

We use the information we collect and receive to provide the Services, including providing you with the ability to:

  • Record your activities and analyze your performance. For example, to compare your past feelings and analyze your feelings to provide you with interesting and useful performance analysis.

TO PROTECT YOU AND THE SERVICES

We use the information we collect to protect members, enforce our Terms of Service, and promote safety. For example, we find and remove content that violates our terms, such as hate speech or spam, as well as suspend or terminate accounts that share such content.

TO IMPROVE OUR SERVICES

We also use the information we collect to analyze, develop and improve the Services. To do this, Revolutioneyes Me Ltd may use third-party analytics providers to gain insights into how our Services are used and to help us improve the Services.

TO COMMUNICATE WITH YOU

We use the information we collect to provide support in response to your requests and comments.

AGGREGATE INFORMATION

We do not sell your personal information. Revolutioneyes Me Ltd may aggregate the information you and others make available in connection with the Services and post it publicly or share it with third parties. Revolutioneyes Me Ltd may use, sell, license, and share this aggregated information with third parties for research, business or other purposes such as to improve wellbeing.

HOW INFORMATION IS SHARED

In addition to sharing aggregated data about our members as described above, we also share personal information in accordance with your preferences, as needed to run our business and provide the Services, and where required for legal purposes, as set forth below.

SERVICE PROVIDERS

We may share your information with third parties who provide services to Revolutioneyes Me Ltd such as supporting, improving, promoting and securing the Services, processing payments, or fulfilling orders. These service providers only have access to the information necessary to perform these limited functions on our behalf and are required to protect and secure your information. We may also engage service providers to collect information about your use of the Services over time on our behalf, so that we or they may promote Revolutioneyes Me Ltd or display information that may be relevant to your interests on the Services or other websites or services.

AFFILIATES AND ACQUIRORS OF OUR BUSINESS OR ASSETS

We may share your information with affiliates under common control with us, who are required to comply with the terms of this Privacy Policy with regard to your information. If Revolutioneyes Me Ltd becomes involved in a business combination, securities offering, bankruptcy, reorganization, dissolution or other similar transaction, we may share or transfer your information in connection with such transaction.

LEGAL REQUIREMENTS

We may preserve and share your information with third parties, including law enforcement, public or governmental agencies, or private litigants, within or outside your country of residence, if we determine that such disclosure is allowed by the law or reasonably necessary to comply with the law, including to respond to court orders, warrants, subpoenas, or other legal or regulatory process. We may also retain, preserve or disclose your information if we determine that this is reasonably necessary or appropriate to prevent any person from death or serious bodily injury, to address issues of national security or other issues of public importance, to prevent or detect violations of our Terms of Service or fraud or abuse of Revolutioneyes Me Ltd or its members, or to protect our operations or our property or other legal rights, including by disclosure to our legal counsel and other consultants and third parties in connection with actual or potential litigation.

DMCA NOTICES

We may share your information with third parties when we forward Digital Millennium Copyright Act (DMCA) notifications, which will be forwarded as submitted to us without any deletions.

HOW WE PROTECT INFORMATION

We take several measures to safeguard the collection, transmission and storage of the data we collect. We employ reasonable protections for your information that are appropriate to its sensitivity. The Services use industry standard Secure Sockets Layer (SSL) technology to allow for the encryption of personal information and credit card numbers. Revolutioneyes Me Ltd engages providers that are industry leaders in online security, including Services verification, to strengthen the security of our Services. The Services are registered with site identification authorities so that your browser can confirm Revolutioneyes Me Ltd's identity before any personal information is sent. In addition, Revolutioneyes Me Ltd's secure servers protect this information using advanced firewall technology.

YOUR RIGHTS AND OUR LEGAL BASES

We provide the same suite of privacy tools and controls to all of our members worldwide. Particular rights may be available to you if you reside in certain locations, such as the EEA, Brazil or California. Learn more about your rights and how to exercise them.

YOUR LEGAL RIGHTS IN THE EEA

If you are habitually located in the EEA, you have the right to access, rectify, download or erase your information, as well as the right to restrict and object to certain processing of your information. Revolutioneyes Me Ltd's lead supervisory authority in the EEA is the Data Protection Commission of Ireland. Learn more.

OUR LEGAL BASES

Revolutioneyes Me Ltd relies on a number of legal bases to collect, use, share, and otherwise process the information we have about you for the purposes described in this Privacy Policy, including:

  • as necessary to provide the Services and fulfill our obligations pursuant to the Terms of Service. For example, we cannot provide the Services unless we collect and use your location information;

  • where you have consented to the processing;

  • where necessary to comply with a legal obligation, a court order, or to exercise and defend legal claims;

  • to protect your vital interests, or those of others, such as in the case of emergencies; and

  • where necessary for the purposes of Revolutioneyes Me Ltd's or a third party’s legitimate interests, such as our interests in protecting our members, our partners’ interests in collaborating with our members, and our commercial interests in ensuring the sustainability of the Services.

TRANSFERS

The Services are operated from the United Kingdom. If you are located outside of the United Kingdom and choose to use the Services or provide information to us, you acknowledge and understand that your information will be transferred, processed and stored in the United Kingdom, as it is necessary to provide the Services and perform the Terms of Service. United States privacy laws may not be as protective as those in your jurisdiction.

RETENTION OF INFORMATION

We retain information as long as it is necessary to provide the Services to you and others, subject to any legal obligations to further retain such information. Information associated with you will generally be kept until it is no longer necessary to provide the Services or until your account is deleted. Additionally, we may retain information to comply with the law, prevent fraud, collect fees, resolve disputes, troubleshoot problems, assist with investigations, enforce the Terms of Service and take other actions permitted by law. The information we retain will be handled in accordance with this Privacy Policy.

Information connected to you that is no longer necessary and relevant to provide our Services may be de-identified or aggregated with other non-personal data to provide insights which are commercially valuable to Revolutioneyes Me Ltd, such as statistics of the use of the Services. For example, we may retain publicly available segments or routes and other depersonalized geolocation information to continue to improve the Services. This information will be de-associated with your name and other identifiers.

PRIVACY POLICY INFORMATION

Revolutioneyes Me Ltd reserves the right to modify this Privacy Policy at any time. Please review it occasionally. If Revolutioneyes Me Ltd makes changes to this Privacy Policy, the updated Privacy Policy will be posted on the Services in a timely manner and, if we make material changes, we will provide a prominent notice. If you object to any of the changes to this Privacy Policy, you should stop using the Services and delete your account.

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