EXPOND PRIVACY POLICY

Updated and Effective, August 1, 2021

EXPOND INC., is a software and ecommerce company based in Santa Barbara, California (“We” or “EXPOND”). Our mission is to inspire, guide and enable our customers to engage in health and wellness experiences on demand (“EOD”). This Privacy Policy explains how we collect, use and share information we obtain through your use of the internet sites, applications and online services owned and operated by EXPOND (the “Services”). We wish to provide you with information and services that are tailored to your individual needs and, at the same time, help you protect your privacy. This notice explains our online information practices and the choices you can make about the way your personal information is collected and used. By using the Services, you consent to such collection, use and sharing of your information and Personal Data (as defined by applicable law) and agree to the terms of this Privacy Policy.

To request a list of Cookies that are used on our site, please email your request to privacy@goExpond.com. To the extent any personal information is collected through first-party Cookies, our Privacy Policy applies. Personal information collected through a third-party Cookie is subject to the privacy policy of that third party, and not our Privacy Policy.

TYPES OF INFORMATION WE COLLECT

Information You Provide Directly to EXPOND

If you are interested in obtaining information, products, or services from EXPOND, or participating in certain activities through the Services (including without limitation submitted a booking request for an EOD accepting a booking request to deliver, lead or coach an EOD, collectively, “Participate”), you may need to provide us or our service providers with information about yourself. For example:

• If you register for a Service to Participate in an EOD, become a member, receive a newsletter, or get information about EXPOND promotions or events, you may be asked for your name, age, gender, email address, mailing address, phone number and other information.
• If you order a subscription, product or submit a request to book an EOD from us or one of our business or service partners, you may be asked for your name, age, gender, postal address, email address, telephone number and your credit card number.
• You may also occasionally submit information about other people. For example, you might order a gift or book and EOD online for a friend or family members (“Recipients”). If you want the gift, subscription or booking sent directly to the Recipient, you may be required to submit the recipient’s name, age, gender, address, and telephone number.
• If you participate in an activity such as a survey or sweepstakes, you may be asked for your name, age, email address and zip code, and to provide other types of information such as gender and personal interests, which may be associated with other personal information that has been obtained from or about you.
• You also may choose to submit your alias, bio, email, EOD experiences and preferences, photos or any other information that you would like to share with other users of the Services.
• If you register for a Service to become a service provider to provide, coach or lead Experiences on Demand, you may be required to provide certain biographical information, age, gender, email, health and wellness experience, photo, name, likeness, and applicable licenses.

Sensitive Information

We ask that you not send us, and you not disclose, any sensitive personal information (for example, social security numbers, information related to racial or ethnic origin, political opinions, religion or other beliefs, health, criminal background or trade union membership) on or through the Services or otherwise. If you send or disclose any sensitive personal data to us, you consent to our processing and use of such sensitive personal data in accordance with this Privacy Policy. If you do not consent to our processing and use of such sensitive personal data, you must not submit such content to our Services.

Information We May Collect Automatically

In addition to information, you choose to provide to us, EXPOND and our service providers also use standard technologies to automatically collect certain additional information. For example:

• IP Address and Other Identifiers. When you access and interact with our Services, EXPOND and our service providers may collect information about your visits to permit you to connect to and obtain the Services and to understand the frequency with which specific visitors visit various parts of our Services. For example, we may collect your Internet Protocol (“IP”) address, which identifies the computer or service provider that you use to access the Services, or information about your browser type, authentication identifiers, and other software and hardware information. If you access the Services through a mobile or other device we may collect your mobile device identifier, geolocation data (including your precise location), or other transactional information for that device. We may combine this information with other information that we have collected to make our Services and our communications to you more targeted to your interests.
• Social Media Information and Content. If you access or log into a Service through a social media service or connect a Service to a social media service, the information we collect may also include your user ID and/or user name associated with that social media service, any information or content you have permitted the social media service to share with us, such as your profile picture, email address or friends lists, and any information you have made public in connection with that social media service. When you access the Services through social media services or when you connect a Service to social media services, you are authorizing EXPOND to collect, store, and use such information and content in accordance with this Privacy Policy. If you don’t want a social network to collect the information about you as described above, or you don’t want a social network to share it with us, please review the privacy policy, privacy settings and instructions of the applicable social network before you visit and use our Services.
• Cookies and Other Tracking Technologies. Our Services may also use cookies. Cookies are small text files that are stored on a user’s computer and allow websites to remember information about users. We and our service providers use cookies for a variety of purposes in order to enhance the quality of our sites. We use transient (also called “session ID”) cookies to provide continuity from page to page. A session ID cookie expires when you close your browser. We also use persistent cookies. Persistent cookies allow certain other parts of our site to recognize your browser when you return after your first visit to that part of our site. Cookies allow us to personalize your return visits to our site. You have the choice to set your browser to accept all cookies, reject all cookies, or notify you when a cookie is set. (Each browser is different, so check the “Help” menu of your browser to learn how to change your cookie preferences.) You can manage the use of Flash technologies, with the Flash management tools available at Adobe’s website, see http://www.macromedia.com/support/documentation/en/flashplayer/help/settings_manager.html.  It is up to you whether to allow us to send you cookies. Please note that by blocking any or all cookies you may not have access to certain features, content or personalization available through the Services. Please see our Cookie Policy for more information.
• Web beacons and other tracking technologies. The Services may use other tracking tools, including so-called “pixel tags,” “web beacons,” “web bugs,” “clear GIFs,” etc. (collectively “Web Beacons”) to collect user activity information about your activities on the Services. These are small electronic images embedded in web content (including online ads) and email messages and are ordinarily not visible to users. Like Cookies, Web Beacons enable us to track pages and content (including ads) accessed and viewed by users. A Web Beacon can collect information such as the IP address of the computer that downloaded the page on which the tag appears; the URL of the page on which the pixel tag appears; the time (and length of time) the page containing the pixel tag was viewed; the type of browser that retrieved the pixel tag; and the identification number of any cookie previously placed by that server on your computer. 

We may use Web Beacons, either provided by us or by our third-party advertisers, service providers and ad networks, to collect information about your visit, including the pages you view, the links you click, and other actions taken in connection with our sites and Services and use them in combination with our cookies to provide offers and information of interest to you. Web Beacons may also enable ad networks to serve targeted advertisements to you when you visit the Services or other websites.

In addition, we may use a variety of other technologies that collect similar information for security and fraud detection purposes.  Also, when we send HTML-formatted (as opposed to plain text) emails to you, Web Beacons may be embedded in such emails to allow us to monitor readership levels so that we can identify aggregate trends and individual usage to provide our audiences with more relevant content or offers. Web Beacons in emails may recognize activities such as when an email was opened, how many times an email was forwarded, which links in the email were clicked on, etc. Web Beacons cannot be declined when delivered via a regular web page. However, Web Beacons can be refused when delivered via email. If you do not wish to receive Web Beacons via email, you will need to disable HTML images or refuse HTML (select Text only) emails via your email software.

• Third Party Tracking. Third parties that support the Services by serving advertisements or providing services, such as allowing you to share content or tracking aggregate the Services usage statistics, may also use these technologies to collect similar information when you use the Services (such as websites and emails). These third parties may also use these technologies, along with activity information they collect, to recognize you across the devices you use, such as a mobile device and a laptop or other computer. EXPOND does not control these third-party technologies and their use is governed by the privacy policies of third parties using such technologies.

We and our third-party service providers may use such data for a variety of purposes including to diagnose problems with our servers and software, to administer the Services, to gather demographic information and to target advertising to you on the Services and elsewhere online. Accordingly, our third-party advertising networks and ad servers will also provide us with information, including reports that will tell us how many ads were presented and clicked on the Services in a manner that does not identify personally any specific individual. The data we collect is generally non-identifying, but if we associate it with you as a specific and identifiable person, we will treat it as Personal Data.

Information from Other Sources. To the extent permitted by law, EXPOND and our service providers may supplement the information we collect from and about you with information from other sources, such as publicly available information about your online and offline activity from social media services and commercially available sources.

How We Use Your Information

EXPOND and our service providers may use information that we collect from and about you for a variety of business purposes, including:

• to enable you to use our Services, to create an account or profile, to process information you provide via our Services (including verifying that your email address is active and valid) and to process your transactions;
• to provide related customer service and care, including responding to your questions, complaints, or comments and sending surveys (with your consent) and processing survey responses
• to provide you with information, products, or services that you have requested;
• with your consent, to provide you with information, products, or services that we otherwise believe will interest you, including special opportunities from us and our third-party partners.
• to tailor content, recommendations, and advertisements we and third parties display to you, both on the Services and elsewhere online;
• for internal business purposes, such as to improve our Services;
• to administer and process contests, sweepstakes, and promotions;
• to offer you branded, co-branded or other services, products, or features, such as health and wellness services and products. By virtue of such relationships, we may share the information you submit in connection with the service with the third party (provided that you have consented to this). The third party’s use of your information will be governed by the third party’s privacy policy;
• to contact you with administrative communications and, in our discretion, changes to our Privacy Policy, Terms of Use, or any of our other policies;
• to comply with regulatory and legal obligations; and
• for purposes as disclosed at the time you provide your information, with your consent, and as further described in this Privacy Policy.

To make our content, Services and advertising more interesting and relevant to you, we may use the information we collect from and about you to make inferences and predictions about your potential areas of interest. When the information collected from or about you does not identify you as a specific person, we may use that information for any purpose or share it with third parties, to the extent permitted by applicable law.

Information Sharing Practices

EXPOND will disclose your personal information as described in this Privacy Policy, including:

• with entities and service providers that help us to manage and provide the Services, including development of our websites and applications, maintenance and support, personalization, payment processing, email distribution, measurement and improvement, sweepstakes/contest administration, promotions management, booking, fulfilment, and EOD operations, only to the extent that these entities and service providers need the information to perform their services or as required by law;

• with identified entities and service providers whose products or services you specifically use or request to receive while you use the Services;

• with our business partners, such as health and wellness companies and operators. Their use of your personal information will be governed by their own privacy policies;
• with third parties in in the ordinary course of business to process your requests;

• with your consent, with other selected third parties so that they may send you promotional materials about goods and services that they offer;

• in response to legal process and when we believe that doing so is required by law (including laws applicable to our service providers), may be necessary to protect any person’s property, rights, or safety, or to investigate a potential violation of law, will help to enforce any terms of use or other legal agreement, or in the event of a corporate transaction, such as a divestiture, merger, consolidation, bankruptcy or asset sale;

• in accordance with your consent.

When information we collect is aggregated, anonymized, or otherwise does not identify you, we may use that information for any purpose or share it with third parties, to the extent permitted by applicable law.

The Services are operated in the United States. If you are in another jurisdiction, please be aware that information you provide to us will be transferred to, stored, and processed in the United States. By using the Services or providing us with any information, you consent to this transfer, processing, and storage of your information in the United States, a jurisdiction in which the privacy laws may not be as comprehensive as those in the country where you reside or are a citizen. We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this Privacy Policy.

User Access and Control

If you would like to access, review, correct, update, suppress, delete, or otherwise limit our use of your personal information you have previously provided directly to us, you may contact us using the mechanisms provided below. We will try to comply with your request as soon as reasonably practicable.

You may opt out of having your personal information used or disclosed as follows:

• We offer you the opportunity to manage your communications from us. Even after subscribing to one or more newsletters and/or opting in to one or more offers to receive marketing and/or promotional communications from us or our third-party partners, users may elect to modify their preferences by going to the Communications Preferences page anytime or by following the “Communications Preferences” and/or “Unsubscribe” link provided in an email or communication received. You may also be able to change your preferences by updating your profile or account, depending on which of our Services you are using. Please be aware that if you wish to remove yourself from a newsletter and/or other marketing emails from third parties that you consented to through the Services, you must do so by contacting the relevant third-party. Even if you do opt-out of marketing emails, we reserve the right to send you transactional and administrative emails including those related to the Services, service announcements, notices of changes to this Privacy Policy or other Services policies, and to contact you regarding any goods or services you have ordered.

• We do not rent or sell our users’ email addresses. However, unless you request otherwise, we may rent or share your name and address with carefully selected companies who we believe can offer you services and products of interest to you. If you do not wish to have your information shared, write to us at privacy@goExpond.com. We will not use or transfer personally identifiable information provided to us in ways unrelated to the ones described above without also providing you with an opportunity to opt out of these unrelated uses.

• If you continue to receive our communications in error after expressing an opt-out preference, please let us know so that we can investigate the situation.

• If you are under 18 and a registered user of the Services, you may request removal of content or information that you have publicly posted to the Services. To make such a request, please go email us at privacy@goExpond.com. Please provide your name, email address, and a detailed description of your content removal request. Please note that your request does not ensure complete or comprehensive removal of the content or information, as, for example, some of your content may have been reposted by another user. There may also be circumstances where the law does not allow removal of your content even if requested.

Public Information

If you identify any User Information as public, you are authorizing us to share such information publicly. For example, you may elect to make certain of your User Submissions (such as your alias, bio, email or photos) publicly available. Also, there may be areas of the Services (for example, contributing experiences or photos to place pages on goExpond.com) in which you are able to post information that automatically will be available to all other users of the Services. By choosing to use these areas, you understand and agree that anyone may access, use, and disclose any information that you post to those areas. Some of this information may be republished elsewhere on the Web in accordance with our Terms of Service.

Third-party Sites

If you click on or interact with a hyperlink or advertisement that you find on the Services, you may leave our Services or send information to a different website or application. Our Privacy Policy does not apply to your interactions with third-party websites or mobile apps, even if you find a link to them on or access them through our Services, and so you should read the privacy policy of the third-party provider to see how your personal information will be treated on its site. We have no control over such third parties, their Internet sites, or their products or services.

Advertising

We may use other companies under agreements with us to serve third-party advertisements when you visit and use the Services. These companies may collect, and use click stream information, browser type, time and date, subject of advertisements clicked or scrolled over during your visits to the Services and other Web sites to provide advertisements about goods and services likely to be of greater interest to you. These companies typically use tracking technologies to collect this information. Other companies’ use of their tracking technologies is subject to their own privacy policies, not this one.

• In order to serve offers and advertisements that may be of interest to our users, we may display targeted advertisements on the Services, or other digital properties or applications in conjunction with our content, based on information provided to us by our users and information provided to us by third parties that they have independently collected. We do not provide Personal Data to our advertisers when you interact with an advertisement.

• Some of the third-party services providers and/or advertisers may be members of the Network Advertising Initiative (“NAI”) or the Digital Advertising Alliance (“DAA”) Self-Regulatory Program for Online Behavioral Advertising. You may want to visit

http://www.networkadvertising.org/managing/opt_out.asp,

which provides information regarding targeted advertising and the “opt-out” procedures of NAI members. You can opt-out of our use of your Web site viewing behavior data to serve you interest-based advertising on third-party sites and email newsletters here http://www.aboutads.info/choices/.

• If you are accessing the Services through an application (i.e., mobile phone or tablet) you can download the AppChoices application from your device’s application store (i.e., Google Play, Apple App Store, and Amazon Store). This DAA application allows participating companies to offer an opt-out of customized advertisements that are based on predictions about your interests generated from your application usage. For more information, visit http://www.aboutads.info/appchoices

Please note opting out through these mechanisms does not opt you out of being served advertising. You will continue to receive generic ads while online or on your device.

Mobile

We may from time-to-time offer (and certain of our Services require) certain location or pinpoint based services, such as location assisted navigation instruction. If you elect to use such location-based services, we must periodically receive your location to provide such location-based services to you. By using the location-based services, you authorize us to: (i) locate your hardware; (ii) record, compile and display your location; and (iii) publish your location to third parties designated by you by means of location publication controls available within the applications (for example, settings, user preferences). As part of the location-based services, we may also collect and store certain information about the users who elect to use such location-based services, such as a device id. This information will be used to provide you the location-based services. We may use third-party providers to help provide location-based services through mobile systems (unless you opt out of such location-based services with such providers) and we may provide the information to such providers to enable them to provide their location-based services, provided that such providers may use the information in accordance with our Privacy Policy.

How Long We Keep Your Information

We keep your information for no longer than is necessary. We will retain your information for any period required by law. Where we are not under a legal obligation to retain your information, we will determine what is necessary by reference to the lawful basis for processing set out above and our legitimate interests.

If you have any questions about how long we keep your information, please contact us using the information provided in the Contact Us section below.

How We Respond to “Do Not Track” Signals

Some Internet browsers may be configured to send “Do Not Track” signals to the online services that you visit. California Business & Professions Code Section 22575(b) (as amended effective January 1, 2014) provides that California residents are entitled to know how EXPOND responds to “Do Not Track” browser settings.

While some internet browsers offer a “do not track” or “DNT” option that lets you tell websites that you do not want to have your online activities tracked, these features are not yet uniform and there is no common standard that has been adopted by industry groups, technology companies or regulators. Therefore, we do not currently commit to responding to browsers’ DNT signals with respect to our website. EXPOND takes privacy and meaningful choice seriously and will make efforts to continue to monitor developments around DNT browser technology and the implementation of a standard.

Information Security

We take several commercially reasonable administrative, technical, personnel and physical measures designed to safeguard information in our possession from loss, theft and unauthorized use, disclosure, or modification. However, no one can guarantee the complete safety of your information.

Location of Data

The Services are hosted in and managed from the United States. If you are a user located outside the United States, you understand and consent to having any personal information (which may include information collected using cookies and other technologies, as described above) processed in the United States or in any other country in which we have facilities or in which we engage service providers. United States and other countries’ data protection laws may not be the same as those in your jurisdiction. In certain circumstances, courts, law enforcement agencies, regulatory agencies or security authorities in the United States may be entitled to access your personal information.

California Privacy Rights

Your Californian Privacy Rights: A Notice to California Users (California Civil Code Section 1798.83). Under the California “Shine The Light” law, California residents may opt-out of EXPOND’s disclosure of personal information to third parties for their direct marketing purposes. Any California resident may choose to opt-out of the sharing of such personal information with third parties for marketing purposes at any time by directing such request privacy@goExpond.com.

Children

The Services are intended for a general audience and are not intended for and may not be used by children under the age of 18. We do not knowingly collect information from children under the age of 18 and we do not target the Services to children under the age of 18. If a parent or guardian becomes aware that his or her child has provided us with information without their consent, he or she should contact us using the details in the Contact Us section below. We will delete such information from our files as soon as reasonably practicable.

Changes

We may amend this Privacy Policy at any time by posting the most recent version of the Policy on the Services, along with an indication of the date on which the Policy was amended most recently. Any changes to this Privacy Policy will become effective when we post the revised Privacy Policy on the Services. If we make any material changes to this Privacy Policy in the way we collect, use, and/or share personal information through the Services in a manner that expand our rights to use the personal information we have already collected from you, we will notify you and provide you with a choice about our future use of that information.

Contact Us

If you have any questions about this Privacy Policy, please feel free to contact us by email at privacy@goExpond.com or writing to us at our designated address below.

For the purposes of UK and EU data protection legislation, the data controller is:

Expond Inc.
Attn: Privacy Policy
2020 Alameda Padre Serra Suite 223
Santa Barbara, CA 93103

Santa Barbara, California 93103