PRIVACY POLICY

The Couple to Couple League International, Inc. (“CCL”) is committed to your privacy and to providing you with transparency in our information practices. This Privacy Policy describes how we collect, use, protect and share information in connection with our app PeakDay Chart Tool System (the “App”). It also explains your rights and choices with respect to such information and the steps you can take to protect your privacy. Please read this policy carefully and contact us at appsupport@ccli.org if you have any questions. By visiting our website www.peakday.com or installing our App clicking “I agree” or any other button indicating your acceptance of this Privacy Policy, or otherwise providing information to CCL, you are consenting to the collection, use, transfer, manipulation, storage and sharing of your information as described in this Privacy Policy. However, this Policy applies only to information collected by our App and does not apply to information you post to public areas or on third-party App. This Privacy Policy imposes no duties on us not imposed by state, federal, or other applicable law.

INFORMATION WE COLLECT

The purpose of the App is to provide a way for you to submit information (“Submitted Information”) to track and chart human fertility cycles and to share that information and discuss related topics with other users, teachers, and administrators (collectively, “Third-Party Users”). The Submitted information we and our service providers may collect include but is not limited to:

• Account and profile information. We collect information when you create an account or edit your profile, such as your name, username, password, email, address, demographic category information you choose to provide.
• User generated information. While utilizing our services, any image, profile image, video, audio, personal contacts, text, questions, quizzes/forms/survey answers, and other associated data files you choose to upload, edit, and/or share will be collected. We collect any of your health information or personal identifiers you willingly choose to share on the App. Information such as location data, who created the content, when the content was created, who shared the content, when the content was shared, and how the content was edited or transformed may be attached to the content uploaded as file metadata.
• Health data you choose to provide. Menstrual cycle dates, fertility test results & images (including ovulation, pregnancy, progesterone, and other fertility test results), body temperature, symptoms related to your menstrual cycle, pregnancy and health, medication information, health related documents and records, other information about your health and activities.
• Information you provide to us directly or through the App. We collect information that you provide to us directly or through the App, such as when you post questions or comments, respond to surveys, rate the App, or communicate with us.
• Information collected automatically. When you use our App, we or our third-party service providers may automatically receive and record certain information. For example, this may include your device’s IP address, user-agent string, information about your use of the App during your current session and over time (including the pages you view and the files you download), the date and time of your visit, links you click, searches conducted, the website visited before navigating to the App, your software and hardware attributes (including browser and operating system type and version, App version, device type, and device identifiers), and your general location inferred from IP address. To obtain such information, we or our third-party service providers may use the following technologies to recognize your device and collect information about your App usage:
  • Server logs. When you use the App, we automatically receive and record certain information from your computer (or other device) and your browser. To obtain such information, we may use server logs or applications that recognize your device and gather information about its online activity.
  • Cookies. We also use cookies. Cookies are small files that are stored on your device by your web browser. A cookie allows us to recognize whether you have visited before and may store user preferences and other information. If you are concerned about having cookies on your device, you can set your browser to refuse all cookies or to indicate when a cookie is being set, allowing you to decide whether to accept it. You can also delete cookies from your device. However, if you choose to block or delete cookies, certain features of the App may not operate correctly.
  • Web beacons, tags, pixels, and similar technologies. The App or the emails that you receive from us may use an application known as a “web beacon” (also known as a “tag” or “pixel”) and similar technologies. Web beacons are small strings of code that provide a method for delivering a graphic image on a web page or in an email message for the purpose of transferring data. For example, it may allow an email sender to determine whether a user has opened a particular email.

• Mobile advertising IDs. We may use mobile advertising identifiers (such as Apple’s IDFA or Google’s Advertising ID) to collect information for analytics purposes, as described in the section below titled “Third-Party Analytics.”
• Bluetooth transfer: The System can be used in combination with a Bluetooth basal thermometer and accesses the services of "Bluetooth SIG", Bluetooth Special Interest Group, Inc. (5209 Lake Washington Blvd NE Suite 350, Kirkland, WA 98033 USA). You can find more information at: www.bluetooth.com.
  • Use of this transfer between hardware and smartphone requires your consent. Bluetooth Low Energy (BLE) data transfer only works if Bluetooth is enabled on your iOS device. When starting the System or first pairing a Bluetooth device, you will be asked if you want to allow this service. In Android, Bluetooth Low Energy transfer is also connected to the location services. Data transfer with Bluetooth Low Energy (BLE) therefore only works if the location services are enabled on your Android device. This applies to all Android versions 6.0 or higher. We only use this permission to perform BLE scans and enable synchronization. The System does not record your location. In Android, you can enable or disable usage under "Settings" > "Location". In Android, you can use the slider to enable or disable Bluetooth under "Settings" > "Connections" > "Bluetooth". In iOS, you can see which apps are allowed to access Bluetooth and allow or withdraw any future access under "Settings" > "Privacy". In iOS, under "Settings" > "PeakDay", you can see whether Bluetooth is enabled for the app.
• Subscription: When you subscribe to a paid subscription, we may collect personal information about you including contact information such as name, address, credit card information, etc. We may combine information collected through the App with information that we collect in other contexts, such as information from our email communications or phone calls with you, or data that we collect in discussion forms or postings. We will treat such combined information in accordance with this Privacy Policy.

HOW DO WE USE THIS INFORMATION? We use your information to:

• Providing the App. To provide our services in the App to you, fulfill the terms of any agreement you have with us, respond to your requests, and for other purposes related to managing our organization;
• Communicating with you. To communicate with you regarding your account, important updates regarding our App, and other administrative issues;
• Sending newsletters or other promotional messages. To send you newsletters or other promotional messages regarding our App;
• Enabling community features. To allow you to ask questions, post comments, and communicate with other users on the App;
• To manage your requests. Including providing responses.
• To deliver targeted advertising to you. Including by using your information to develop and display content and advertising (and work with third-party vendors who do so) tailored to your interests and/or location and to measure its effectiveness.
• For business transfers. Including to evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by us about our Site users is among the assets transferred.
• For other purposes. Including for data analysis, identifying usage trends, determining the effectiveness of our promotional campaigns, and to evaluate and improve our Site, products, content, marketing, and your experience.

HOW WE SHARE INFORMATION?

We do not share, sell, rent, or otherwise distribute your information that you’ve made through our App with outside parties, except to companies that host our data services, process payments, deliver communications on our behalf, fulfill service requests, operate apps, or plug-ins on our behalf, or for a variety of reasons, including as follows

• Third Party Service Providers. We will share your personal information with trusted third parties who assist us in operating our website, conducting our business, or providing service to you, so long as these parties agree to keep the information confidential. We will also share your Submitted Information with Third-Party Users you specify. We may share certain de-identified Submitted Information, such as chart data, with third parties for research and educational purposes.
• Other users of the App. We may allow you to share information directly with other users of the App. For example, if you post questions or comments to other users through the App, add information to your profile, respond to surveys or requests to rate the App, or use other features of the App, then your questions, comments, profile, or other information may be seen by other users of the App. Please ensure when using these features that you do not submit any information that you do not want to be shared with other users or the public.
• Third-party plugins. The App may integrate certain third-party plugins (such as a Facebook “like” button and Twitter “follow” button). Even if you do not click on these plugins, they may collect information about you, such as your IP address and the pages that you view. They also may set and/or access a cookie or use similar tracking technologies. These plugins are governed by the privacy policy of the company providing them.
• Legal purposes. We may use or share your information with third parties when we believe, in our sole reasonable discretion, that doing so is necessary:
  • To comply with applicable law or a court order, subpoena, or other legal process;
  • To investigate, prevent, or act regarding illegal or prohibited activities, suspected fraud, violations of our rules or terms and conditions, or situations involving threats to other employees, volunteers or users, our property, or the property or physical safety of any person or third party;
  • To establish, protect, or exercise our legal rights or defend against legal claims.
• Organizational transfers. We may share your information with third parties to facilitate the financing, securitization, insuring, merger, acquisition, sale, assignment, bankruptcy, or other disposal of all or part of our organization or assets.
• Aggregated and de-identified information. We may share aggregated and de-identified information with third parties, such as by publishing or sharing reports with third parties about trends in the usage of CCL.
• With your Consent. In any situation to which you have given us your consent to disclose. You may choose to restrict the collection or use of your information in the following ways:
• Do not submit information when presented with a form on our App. Your submission of such forms is considered free and voluntary.
• If you have previously agreed to us using your information for marketing purposes, or subscriptions, you may change your mind at any time by using the unsubscribe links in your emails or by emailing us at appsupport@ccli.org.

PAYMENTS

Our App includes products and services for purchase, which may use third-party services for payment processing (e.g. payment processors). We will not store or collect your payment card details, which are provided directly to our third-party payment processors whose use of your personal information is governed by their Privacy Policy. These payment processors adhere to the standards set by PCI-DSS as managed by the PCI Security Standards Council, which is a joint effort of brands like Visa, MasterCard, American Express and Discover. PCI-DSS requirements help ensure the secure handling of payment information.

THIRD PARTY ANALYTICS

We partner with certain third parties to collect information to engage in analytics, auditing, research, and reporting. These third parties may use server logs, web beacons, tags, pixels, mobile advertising IDs (such as Apple’s IDFA or Google’s Advertising ID), and similar technologies, and they may set and access cookies on your computer or other device. In particular, our App uses Google Analytics to help collect and analyze certain information for the purposes discussed above. You may learn more about Google Analytics’ data practices and how you can control your privacy by visiting: https://policies.google.com/privacy

DATA SECURITY AND RETENTION

We have implemented appropriate data collection, storage, and processing practices designed to secure your information from accidental loss and from unauthorized access, use, alteration, and disclosure. Unfortunately, the transmission of information via the internet is not completely secure. Although we do our best to protect your information, we cannot guarantee the security of your information transmitted to our App. Any transmission of information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on our App.

INFORMATION FOR INDIVIDUALS OUTSIDE THE UNITED STATES

The information that we collect through or in connection with our App may be transferred to and processed in the United States for the purposes described above. CCL also may subcontract the processing of your data to, or otherwise share your data with, third parties in the United States or other countries outside your country of residence. The data protection laws in these countries may be different from, and less stringent than, those in your country of residence. By visiting or using the App, installing our App, clicking “I agree” or any other button indicating your acceptance of this Privacy Policy, or otherwise providing information to CCL, you explicitly consent to such transfer and processing. We may implement standard contractual clauses, contractual arrangements, or other mechanisms, as appropriate, to safeguard your information during such cross-border transfers. We also may transfer information to the United States or another country as necessary for the performance of our agreements with you or to establish, exercise, or defend legal claims.

CHILDREN’S PRIVACY

Our App is not intended for children under 13 years of age or who otherwise require parent consent under applicable law to use the app or provide personal information. CCL does not collect personal information from Commented [MNS1]: Include email address children under 13 and no one under age 13 may provide any information to or on our App. The parent or guardian of any minor using this App is solely responsible for providing supervision of the minor’s use of the App. The parent or guardian assumes full responsibility for ensuring that the registration information is kept secure and that the information submitted is accurate. The parent or guardian also assumes full responsibility for the interpretation and use of any information or suggestions provided through CCL for the minor. We do not knowingly collect information from children under 13. If you are under 13, do not use or provide any information, register an account, enter any subscriptions, make any purchases or submit any applications, or use any of the interactive or public comment features of our App, or provide any information about yourself to us, including your name, address, telephone number, email address, or any screen name or user name you may use. If we learn we have collected or received personal information from a child under 13 without verification of parental consent, we will delete that information. If you believe we might have any information from or about a child under 13, please contact us at appsupport@ccli.org. The parent or guardian is solely responsible for providing supervision of the minor’s use of CCL. The parent or guardian assumes full responsibility for ensuring that the registration information is kept secure and that the information submitted is accurate. The parent or guardian also assumes full responsibility for the interpretation and use of any information or suggestions provided through CCL for the minor.

HOW LONG DO WE KEEP YOUR INFORMATION?

We will retain your Submitted Information and personal information for as long as your account remains active. However, we reserve the right to delete Submitted Information that is over five years old. We may retain certain de-identified Submitted Information, such as chart data, indefinitely for research and educational purposes.

CHANGES TO THIS PRIVACY POLICY

We may revise this Privacy Policy periodically in the future. If we make any material changes, we will post the revised Privacy Policy in our App under “Settings,” with an effective date indicating when the revised Privacy Policy will take effect. By continuing your use of our App, you agree to any changes to this Privacy Policy. We encourage you to review this Privacy Policy periodically.

QUESTIONS/CONCERNS

If you have questions or wish to contact us about this Policy, direct inquiries to:

The Couple to Couple League International, Inc.
5440 Moeller Ave, Suite 149
Cincinnati, Ohio 45212

Phone: 513-471-2000
Email: ccli@ccli.org
Website: www.ccli.org 12207816.1