Effective: August 1, 2018
Background/Managing Your Information Preferences
Blu Wellbeing provides an online platform that connects massage therapists (“Therapists”) with individuals or businesses that want to purchase and/or receive massage therapy (“Customers”).
You can always review, access, correct, or update your Personal Information by changing the relevant settings in your Blu Wellbeing account (Setmore) or by contacting us as set out below. You can also request access, corrections or updates to other Personal Information in our records, subject to limitation set out under applicable law, by contacting us as set out in the Contact Us section below. We may request certain personal information for the purposes of verifying the identity of the individual seeking access to their personal information records.
You can opt out of receiving certain emails and text messages by changing the notification settings on the Website. Otherwise, you can opt-out, by clicking the unsubscribe link provided in an email or by texting STOP in response to any text message from us. Please note that if you unsubscribe from receiving marketing communications from us, you may continue to receive certain transactional and account-related messages.
Information We Collect
We collect information about you, such as your name, username, email address, mailing address, phone number, photo and other personally identifiable information when you sign up for the Services (“Personal Information”). Specifically, Blu Wellbeing will request that Therapists provide: (i) first and last name, (ii) email address, (iii) mailing address, (iv) bank account number and routing number, and (v) address of the bank account holder. Blu Wellbeing will request that Customers provide: (i) first and last name, (ii) email address, (iii) mailing address, and (iv) a credit card number with the name as shown on the card and billing zip code, expiration month and year and CVV2. If you choose not to provide the requested information, you may not be able to use some or all of the features of the Services. We may also collect Personal Information from you when you access the Services and/or other parts of the Website and voluntarily provide Personal Information.
Usage Data and Website Activity
We automatically collect information regarding your use of and the actions you take using Services (“Usage Data”). Usage Data helps us understand trends in our users’ needs so that we can better consider new features or otherwise tailor or enhance our Services. We may generate aggregated, non-identifiable data from our Usage Data and share such data with third parties for various purposes, including to help us better understand our customers’ needs and improve our Services. For example, each time you use the Website we may automatically collect the type of Web browser you use, your operating system, your Internet Service Provider, your IP address, the pages you view, how you interact with links on the Services, and the time and duration of your visits to the Website. This Usage Data may be associated with your account, but we do not disclose any Personal Information to third parties unless otherwise provided herein. We may store such Usage Data itself and/or such information may be included in databases owned and maintained by Blu Wellbeing affiliates, agents or service providers. We may use such information and pool it with other information to track, for example, the total number of visitors to our Website, the number of visitors to each page of our Website, etc.
Cookies and Web Beacons
How We Use Information
We may use your Personal Information for the purpose for which it was provided, including without limitation, for the purposes described further below:
- Provision and Monitoring of the Services: We will use your Personal Information to provide you with access to and to support your use of the Services, including to connect you with therapists or customers that meet your needs (as applicable), process payments for services on behalf of therapists. For example, if you are a Customer, we may provide your Personal Information to a Therapist as necessary for the Therapist to provide Services to you including your first name, address, any notes you may leave and parking instructions and if you are a Therapist, we may provide your Personal Information to a Customer as necessary for the Customer to receive Services such as gender and first name.
- Surveys, Contests and Other Special Offers: From time to time, we may offer our users the opportunity to participate in surveys, contests and other special offers. If you elect to participate in these services, you may need to provide certain Personal Information in order to administer your participation in the survey, contest or other offer. Blu Wellbeing also has a referral program, if you elect to participate in the program, you may need to provide certain Personal Information in order to administer your participation in the program.
- Questions and Requests: If you contact us by e-mail or otherwise, we will use the Personal Information you provide to respond to your question or resolve your problem.
- Contacting You About Other Products, Services and Events: If you opt-in, Blu Wellbeing and/or third parties may use your Personal Information to contact you in the future to tell you about products, services and events that may be of interest to you. You can opt out of receiving these promotional communications by changing the notification settings on the Website, clicking the unsubscribe link provided in an email or by texting STOP in response to any text message from us. Please note that if you unsubscribe from receiving marketing communications from us, you may continue to receive certain transactional and account-related messages.
- Research and Data Analysis: In an ongoing effort to better understand and serve the users of the Services, Blu Wellbeing may conduct internal research and analysis on its Customers’ demographics, interests and behavior based on Usage Data and other information provided to us. This data may be compiled and analyzed on an aggregate basis, and Blu Wellbeing may share this non-identifiable data with advertisers, researchers, business partners, publications, and other third parties.
- Service Improvement: We may use your Personal Information, Usage Data, aggregated information and non-personally-identifiable information collected through the Services to help us improve the content and functionality of the Website, to better understand our users and to improve the Services.
- We may use a third party such as Google Analytics to help us gather and analyze information about the areas visited on the websites (such as the pages most read, time spent, search terms and other engagement data) in order to evaluate and improve the user experience and the convenience of the websites. For more information or to opt-out, see “How Google uses data when you use our partners’ sites” and “Google Analytics and Privacy”.
Information You Make Available to Others
By using the Services, including creation of a profile on Blu Wellbeing or submission of public queries, you may make certain of your Personal Information available to others, such as your name, your username, and your picture. This information may be accessed by users who use the Services and may be accessed by commercial search engines. You should you caution prior to sharing any personal information on these public spaces.
Be Careful When You Share Information with Others
Please be aware that whenever you share information on a publicly available page or any other public forum, others may access that information. In addition, please remember that when you share information in any other communications with third parties, that information may be passed along or made public by others. This means that anyone with access to such information can potentially use it for any purpose, including sending unsolicited communications.
When We May Share and Disclose Personal Information
From time to time, we may establish a business relationship with other businesses or affiliates that we believe to be trustworthy and have privacy practices consistent with ours (“Service Providers”). For example, we may contract with Service Providers to provide certain services on our behalf, such as hosting and maintenance, data storage and management, advertising and analytics, and marketing and promotions. We only provide our Service Providers with the information necessary for them to perform these services on our behalf. Each Service Provider must agree to use reasonable security procedures and practices, appropriate to the nature of the information involved, in order to protect your Personal Information from unauthorized access, use or disclosure. Service Providers are prohibited from using Personal Information other than as specified by Blu Wellbeing.
If Blu Wellbeing is merged, acquired, or sold, or in the event of a transfer of some or all of our assets or equity, we may disclose or transfer Personal Information and Usage Data in connection with such transaction (including in the course of determining whether to proceed with such transaction).
Compliance with Laws and Law Enforcement
Blu Wellbeing and its affiliates and service providers may provide your Personal Information in response to a search warrant or other legally valid inquiry or order, to other organizations in the case of investigating a breach of an agreement or contravention of law or detecting, suppressing or preventing fraud or as otherwise required or permitted by applicable Canadian, US or other law. We may also disclose Personal Information where necessary for the establishment, exercise or defense of legal claims, to detect, suppress or prevent fraud, and to investigate or prevent actual or suspected loss or harm to persons or property.
We may work with third-party advertisers, search providers, and ad networks (“Advertisers”). These companies may collect and use information about your use of the Website in order to provide advertisements about goods and services that may be of interest to you. These Advertisers may place or recognize a unique cookie on your computer or use other technologies such as Web beacons to report certain information about your visits to our Website and other websites across your difference devices (such as web pages you visit and your response to ads) in order to make predictions about your preferences and deliver advertisements that are more relevant to you, both on and off our Website. This information may also be used to evaluate the effectiveness of our online advertising campaigns.
Opting-out of Interest-Based Advertising
For more information about interest-based advertising on your desktop or mobile browser and to understand your options, including how you can opt-out of receiving behavioural ads from third-party advertising companies participating in the Digital Advertising Alliance of Canada’s (DAAC) Self-Regulatory Principles for Online Behavioural Advertising, please visit the DAAC website at http://youradchoices.ca/choices
To successfully opt-out, you must have cookies enabled in your web browser. Please see your browser’s instructions for information on cookies and how to enable them. Your opt-out only applies to the web browser you use so you must opt-out of each web browser on each device that you use. Once you opt out, if you delete your browser’s saved cookies, you may need to opt-out again.
Please note that even if you opt-out interest-based advertising by a third party, these tracking technologies may still collect data for other purposes including analytics and you will still see ads from us, but the ads will not be targeted based on behavioural information about you and may therefore be less relevant to you and your interests.
We maintain reasonable physical, electronic, and procedural safeguards to protect the confidentiality and security of Personal Information and other information transmitted to us.
We have Personal Information retention processes designed to retain personal information for no longer than necessary for the purposes stated above or to otherwise meet legal requirements.
Processing Outside of Canada
Please be aware that your Personal Information and communications may be transferred to and maintained by Blu Wellbeing, its affiliates or service providers on servers or databases located outside your state, province, or country (including in the United States) and will be subject to the laws of those jurisdictions (which may include lawful access by US or other foreign courts, law enforcement or governmental agencies).
You may contact our Privacy Officer by email at firstname.lastname@example.org
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