PRIVACY NOTICE

Last Updated: November 27, 2020

Healthy Beings Privacy Notice for California Consumers

Last Updated: November 27, 2020

Healthy Beings, Inc. including its Healthy Beings branded affiliates and subsidiaries, (collectively “Healthy Beings”, “we”, “us”, or “our(s)”) provides this Privacy Notice for California Consumers (the “CCPA Privacy Notice”) to supplement the information contained in the Healthy Beings Privacy Policy. This CCPA Privacy Notice sets forth our privacy practices as required by the California Consumer Privacy Act of 2018 (“CCPA”). Capitalized terms used and not defined herein shall have the meanings as set forth in the Healthy Beings Privacy Policy.

The CCPA Privacy Notice applies only to individuals residing in the State of California who are considered “Consumers” under the CCPA and from whom we collect “Personal Information” as described in the CCPA (“Consumers”). If you are a Healthy Beings employee, employee applicant, or contractor, please refer to the Healthy Beings Privacy Notice for California Consumers (Employees).

Information We Collect

We may collect Personal Information from you in a variety of different situations, including, but not limited to on our websites, our applications, your mobile device, through email, in physical locations, through the mail, and/or over the telephone. More specifically, Healthy Beings may collect the following categories of Personal Information from its Consumers, which will depend on the particular business purpose for which we collect it:

Personal information does not include deidentified or aggregated consumer information.

Healthy Beings obtains the categories of Personal Information listed above from the following categories of sources:

• Directly from you. For example, from forms you complete or products and services you use and/or purchase.
• Indirectly from you. For example, from observing your actions on our website or from information your computer or mobile device transmits when interacting with our Website or App, among other things.

How We Use Personal Information; Business Purpose

We may use or disclose the Personal Information we collect from you or about you to do one or more of the following:

• To fulfill or meet the purpose for which you provided the information. For example, if you share your name and contact information to ask us a question or inquire about our products or services, we will use that Personal Information to respond to your inquiry. If you provide your Personal Information to purchase a membership or other product or service, we will use that information to process your payment and provide the product or service. When you enroll in a class or participate in an event, we may also save your information to facilitate communication about that class or event.
• To contact you and to inform you about products, services, promotions, special offers, and/or events that may interest you.
• To inform you about products and services you have purchased from us such as providing you updates and information about classes you have enrolled in.
• To enable you to participate in online classes, training programs, or other events.
• To manage the health and safety of the workplace, health center and digital environment, including the health and safety of employees and health center and digital members, and/or to respond to or manage public health issues.
• To provide, support, personalize, and develop our Website, Apps, products, and services.
• To create, maintain, customize, and secure your account with us.
• To process your requests, purchases, transactions, and payments and prevent transactional fraud.
• To provide you with support and to respond to your inquiries, including to investigate and address your concerns and monitor and improve our responses.
• To personalize your App or Website experience and to deliver content and product and service offerings relevant to your interests, including targeted offers and ads through our Website, App, third-party sites, and via email or text message (with your consent, where required by law).
• To help maintain the safety, security, and integrity of our App or Website, products and services, databases and other technology assets, and business.
• For research, analysis, and business development, including to develop and improve our website, products, and services.
• To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.
• As described to you when collecting your personal information or as otherwise set forth in the CCPA or subsequently agreed to by you.
• To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of Healthy Beings assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by Healthy Beings about our Consumers is among the assets transferred.

How We Share Personal Information

Healthy Beings may disclose your Personal Information to a third party for a business purpose, including to our service providers. We may share your photo or image, including recorded or live video or digital images, as part of an event or class in which you participate with other participants in the class, the Healthy Beings community, or as otherwise described to you.

Disclosures of Personal Information for a Business Purpose

In the preceding twelve (12) months, Healthy Beings has disclosed the following categories of personal information for a business purpose:

• Category A:Identifiers.
• Category B:California Customer Records personal information categories.
• Category C:Protected classification characteristics under California or federal law.
• Category D:Commercial information.
• Category E:Biometric information (as described above).
• Category F:Internet or other similar network activity.
• Category G:Geolocation data.
• Category H:Sensory data.
• Category K:Inferences drawn from other personal information.

We disclose your personal information for a business purpose to the following categories of third parties:

• Service providers.
• Our affiliates. We may share your information between and among our affiliated entities. Healthy Beings shares your information between and among its affiliated entities to facilitate any services you may obtain from Healthy Beings, to allow our affiliates to offer you and let you know about products and services that may interest you, and for any other purpose set forth in our Privacy Policy.
• Third parties with whom you direct us to share your personal information.  For example, when you participate in a Healthy Beings athletic event such as a race, you intentionally interact with certain third parties associated with that event to whom you direct us to share your personal information.

Sales of Personal Information

In the preceding twelve (12) months, Healthy Beings has not sold Personal Information.

Your Consumer Rights and Choices

The CCPA provides Consumers with specific rights regarding their Personal Information. This section describes your CCPA rights and explains how to exercise those rights.

Access to Specific Information and Data Portability Rights

The CCPA provides Consumers with specific rights regarding their Personal Information. This section describes your CCPA rights and explains how to exercise those rights.

You have the right to request that Healthy Beings disclose certain information to you about our collection and use of your Personal Information over the past 12 months. Once we receive and confirm your verifiable consumer request (see Exercising Access, Data Portability, and Deletion Rights), we will disclose to you:

• The categories of Personal Information we collected about you.
• The categories of sources for the Personal Information we collected about you.
• Our business or commercial purpose for collecting that Personal Information.
• The categories of third parties with whom we share that Personal Information.
• The specific pieces of Personal Information we collected about you.
• If we disclosed your Personal Information for a business purpose, a list identifying the Personal Information categories that each category of recipient obtained.

Deletion Request Rights

You have the right to request that Healthy Beings delete any of your Personal Information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request (see Exercising Access, Data Portability, and Deletion Rights), we will delete (and direct our service providers to delete) your Personal Information from our records, unless an exception applies.

In accordance with the CCPA, we may deny your deletion request under certain circumstances, and will inform you of the basis for the denial, which may include, but is not limited to, our need to retain the information for us or our service provider(s) to:

• Complete the transaction for which we collected the Personal Information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you.
• Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
• Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
• Comply with a legal obligation.
• Make other internal and lawful uses of that information that are compatible with the context in which you provided it.

Exercising Access, Data Portability, and Deletion Rights

To exercise the access, data portability, and deletion rights described above, please submit a verifiable consumer request to us by either:

• Accessing our online CCPA portal
• Calling us at 1-888-430-6432

Only you, or a person registered with the California Secretary of State that you authorize to act on your behalf, may make a verifiable consumer request related to your Personal Information. You may also make a verifiable consumer request on behalf of your minor child.

You may only make a verifiable consumer request for access or data portability twice within a 12-month period. The verifiable consumer request must:

• Provide sufficient information to allow us to reasonably verify you are the person about whom we collected Personal Information or an authorized representative.
• Describe your request with sufficient detail to allow us to properly understand, evaluate, and respond to it.

We cannot respond to your request or provide you with Personal Information if we cannot verify your identity or authority to make the request and confirm the Personal Information relates to you. Making a verifiable consumer request does not require you to create an account with us. However, in order to facilitate the request, and the secure electronic delivery of Personal Information you may request, you may be asked to create an account solely for such purpose, including to access such Personal Information.

We will only use Personal Information provided in a verifiable consumer request to verify the requestor's identity or authority to make the request.

Response Timing and Format

We endeavor to respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time (up to an additional 45 days), we will inform you of the reason and extension period in writing.

If you have an account with us, we will deliver our written response to that account or an account you create specifically to facilitate the secure delivery of electronic information. If you do not have an account with us, or you opt out of electronic access, we will deliver our written response by mail at your option.

Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request’s receipt. The response we provide will also explain the reasons we cannot comply with a request, if applicable.

If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.

Other California Privacy Rights

California’s “Shine the Light” law (Civil Code Section § 1798.83) permits users of our website that are California residents to request certain information regarding our disclosure of Personal Information to third parties for their direct marketing purposes. Healthy Beings, however, does not disclose your Personal Information to third parties for their direct marketing purposes.

Changes to Our CCPA Privacy Notice

Healthy Beings reserves the right to amend this privacy notice at our discretion and at any time. When we make changes to this privacy notice, we will post the updated notice on the App and Website with a “Last Updated” date at the top reflecting the date of the change. All changes are effective as of the time of posting. Your continued use of our App or Website or interaction with us through other methods following the posting of changes and/or our directing you to the updated CCPA Privacy Notice constitutes your acceptance of such changes.

Contact Information

If you have any questions or comments about this notice, the ways in which Healthy Beings collects and uses your information described above, your choices and rights regarding such use, or wish to exercise your rights under California law, please do not hesitate to contact us at:

• Email:  Privacy@HealthyBeings.com
• Postal Address:
  ATTN: Privacy Team
  Healthy Beings, Inc.
  5400 Carillon Point
  Kirkland, WA 98033