Protected Health Information Notice: This Privacy Policy does not apply to protected health information (“PHI”) that is subject to the Health Insurance Portability and Accountability Act and its implementing regulations, as each are amended from time to time (“HIPAA”). For information on how we use and disclose your PHI, as well as, your rights regarding your PHI, please refer to our HIPAA Privacy Policy (“HIPAA Privacy Policy”).

This privacy policy (“Privacy Policy”) describes how LIVE TULA, LLC, its parent company, JRE Star Investment Holdings, LLC, and its subsidiaries and affiliates (“Tula,” “we,” “our” or “us”): (a) collects, uses, retains, shares, or otherwise processes your data (“process” or “processes”); and (b) describes your rights regarding your personal data (as defined below) and how to exercise those rights. As used in this Privacy Policy, “data” means all information or data we process including personal data and excludes PHI. To the extent that your data could be categorized as PHI, we will treat your data as PHI. Wherever appropriate in this Privacy Policy, a singular term shall be construed to mean the plural where necessary, and a plural term the singular.

This Privacy Policy may be modified from time to time. The date this Privacy Policy was last updated is set forth as the “Effective Date” at the top of this page. If we make material changes to this Privacy Policy, we will publish the changes to: https://mytula.com/privacy-policy. We advise you to frequently check this Privacy Notice for any changes. We may also provide notice to you in other ways at our discretion, such as through the contact information you provided to us.  YOUR USE OF THE PLATFORM (defined below), AND CONTINUED USE OF THE PLATFORM FOLLOWING ANY CHANGES TO THIS PRIVACY POLICY, SIGNIFIES THAT YOU HAVE READ AND UNDERSTAND THE TERMS OF THIS PRIVACY POLICY. IF YOU DO NOT AGREE WITH THE TERMS OF THIS PRIVACY POLICY, DO NOT USE THE PLATFORM.

When This Privacy Policy Applies

This Privacy Policy applies to the data we collect from or about you when you take the following actions:

• access, use, or otherwise interact directly or indirectly with our website(s): livetula.com or www.mytula.com (“Sites”);
• legally download, access, use, or otherwise interact directly or indirectly with our Mobile Application (“Mobile App”);
• in email, text, and other electronic messages between you and us (collectively with Mobile App and Sites, “Digital Assets”);
• when you connect with us offline (collectively with Digital Assets, the “Interaction Channels”); or
• in connection with the products or services (“Offerings” and collectively with Interaction Channels, the “Platform”).

This Privacy Policy does not apply to:

• PHI which is governed by our HIPAA Privacy Policy;
• data collected by a third-party, including by a third-party through any application or content that may link to or be accessible from or on the Platform. If you would like more information, please go to Links to Other Websites to learn more; or
• employees of Tula carrying out their obligations as an employee or to job applicants.

Type of Data Collected; Source of Data

The types of data we collect about you depend on your interactions with us and our Platform. In this section, we describe the categories of data we collect, organized by the sources of this data.

By interacting with the Platform, you grant us the right to use your data to enable us to provide the Platform to you, to improve the Platform, and other uses as stated in this Privacy Policy, in our Terms of Service  (“Terms”), and in any ancillary agreements you may have entered with us related to our Platform. If you do not provide your data when requested, you may not be able to use our Platform or certain features of our Platform if that data is necessary to provide you with our Platform or such features or if we are legally required to collect the requested data.

Data You Directly Provide to Us

We may collect the following types of data that you provide directly to us by accessing or using the Platform:

Personal Data. Data by which you may be personally identified such as legal name, preferred name, email, phone number, physical address, profile photo, date of birth, or any other data that could be associated with or used to identify you, such as the last 4 digits of your social security number (“personal data”).

Demographic Data. Data that is about you but that as an individual piece of data, does not specifically identify you, such as employment status.

Login Data. Data related to your account, such as username, password, and security questions or other authentication-related data.

Communications Data. Data contained in your communications with us through our Platform, such as when you request additional information about our Offerings, provide us feedback, fill in forms on the Platform, or interact with our customer service team, including your contact data, the date and time of your communications, and the content of your communications.

Specified Requests. Data we request from you for the reason presented at the time of collection, such as reviews of our Platform when you participate in a survey or product test, or when you enter a contest or other promotional event.

Data We Automatically Collect About You

As you navigate through and interact with our Platform, we may use automatic data collection technologies or other technologies as they become available, to collect certain data about you, the equipment you use to access the Platform, and your browsing activities and patterns. The data we automatically collect via server-side tracking is statistical data and may include personal data. We may maintain it or associate it with data we collect in other ways or receive from third parties. The following is the list of categories of data we collect via automated data collection technologies:

Mobile or Computer Device and Network Data. We may collect certain data when you interact with the Platform such as technical data about your internet connection (e.g., browser type), and the equipment (e.g., operating system) you use to access our Platform, including unique device identifiers, serial numbers, and IP addresses.

Usage Data. We may collect data about details of your visits to and usage of our Platform including, usage details (e.g., date/time/duration on a given page), traffic logs, general location based on your IP address, and other communication data and the resources that you access and use on the Platform.

The technologies we use for this automated data collection may include:

Cookies (or browser cookies). A cookie is a small file placed on the hard drive of your computer or mobile device. You may refuse to accept browser cookies by activating the appropriate settings on your browser. However, if you select this setting, you may be unable to access certain parts of our Platform. Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies when you direct your browser to our Digital Assets.

Flash Cookies. Certain features of our Platform may use locally stored objects (or Flash cookies) to collect and store data about your preferences and navigation to, from, and on our Platform. Flash cookies are not managed by the same browser settings that are used for browser cookies.

Web Beacons. Pages of our Platform may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit us, for example, to count users who have visited those pages on which we use web beacons or for other related Platform statistics (for example, recording the popularity of certain Platform content and verifying system and server integrity).

Data We Collect from Other Sources

We work with third parties and other sources and may receive data about you from them. The other sources we may receive data from include the following:

Unaffiliated parties, such as our service providers, contractors, subcontractors, vendors, analytics companies, communication service providers (physical mail, email, text messaging, and Platform in-chat), fraud prevention service providers, and other third parties that provide us with data so we can better serve you and provide you with information and offers that may be of interest to you.

How We Use Your Data

For information on how we use your PHI, please refer to our HIPAA Privacy Policy. We use data that we collect about you or that you provide to us for various purposes, including the following:

Provide our Platform to You. Our Platform is designed to assist you with tracking activities including plans or goals to improve your wellness. We use your data to provide our Offerings and any other way in which you request, and we provide. We also use your data to try to effectively deliver the Platform to you such as administering, presenting, supporting, or maintaining our Platform, and its contents to you, including creating and maintaining your account with us.

Improve our Platform’s Experience for You. Certain data we collect through automated data tracking technologies help us improve our Platform and to deliver a better and more personalized experience to you, including by enabling us to: estimate our audience size and usage patterns; store data about your preferences, allow us to customize our Platform according to your interests; improve our Platform for your use; or recognize you when you return to our Digital Asset. In addition, we may link or combine the data we collect and/or receive about you and data we collect automatically from you to provide and improve the Platform and provide you with a personalized experience.

Communicate with You. We may process your data to communicate with you, including when you request additional information from us, or when we contact you about your account such as reminders about upcoming appointments or your subscription renewal, recommendations on how to achieve your goals, sponsored and non-sponsored clinical information, Food and Drug Administration and product safety alerts, or a material change to our policies that affect you, or in connection with the Offerings you have purchased from us.

Advertise and Market our Offerings. We may process your data to send advertising or marketing communications about products, or services offered by us and provide news and information that we believe may be of interest to you (for information about managing your marketing preferences, see the Your Choices About Your Data section below).

Provide Safety and Security. We may process your data to detect and protect against malicious, deceptive, or illegal activity, including fraudulent transactions, error, negligence, breach of contract, security incidents, and harm to the rights, property, or safety of us and our users, customers, employees, or others.

Troubleshoot. We may process your data to debug, identify, and repair errors that impair existing intended functionality of our Platform.

Facilitate Corporate Transactions. We may process your data in anticipation of or in connection with a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of Tula’s assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which data held by Tula is among the assets transferred.

Obtain Your Consent. We may process your data in accordance with your consent when you intentionally direct or instruct us to do so, or any other way we may describe when you provide the data.

Comply with Legal Obligations. We may process your data to comply with our legal or regulatory obligations, including our tax obligations and those related to the prevention of fraud and money laundering, and those required for you to benefit from rights recognized by law, or any regulatory requirements or provisions.

Who We Share Your Data With & the Purpose of Disclosure

For information about who we disclose your PHI with, please refer to our HIPAA Privacy Policy. We may disclose data that we collect from you or that you provide as described in this Privacy Policy to the following categories of third parties and for the purposes set forth below:

Partners; Service Providers; Vendors; Suppliers; Subcontractors. We disclose data to unaffiliated companies or individuals we hire or work with that perform services on our behalf, including customer support, web hosting, software developers, information technology, payment processing, financing, marketing and database management, direct mail and email distribution, and advertising and analytics services. These service providers and contractors may have access to data to perform services for us.

Corporate Transaction. Your data may be disclosed or transferred to in anticipation of or in connection with a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of Tula’s assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal data held by Tula is among the assets transferred.

Your Consent or at Your Direction. We disclose data, such as profile data and communications data, to third parties when we have your consent to do so. We may also disclose your data to third parties when you expressly direct us to do so or when you use our products or services to intentionally interact with third parties. In these cases, we disclose your data to carry out your request.

For example, we may share your data through integrations. You have the option to link your account with third-party integrations, and in doing so, we’ll share your data with those third parties. Keep in mind that if you choose to connect an integration, the terms and privacy policies of that third party may apply to the shared data. We recommend reviewing those terms before setting up the integration. For instance, if you’re using iOS, when you connect our Offerings to Apple’s privacy policy and terms of use will apply to data from our products that you access through the iOS integration. You can find these details at www.apple.com/legal/privacy.

Law Enforcement Authorities and Individuals Involved in Legal Proceedings. We disclose data when we believe doing so is reasonably necessary to comply with applicable law or legal process (including an enforceable request from authorities), to respond to claims (including inquiries by you in connection with your purchases from us), enforce or apply our other policies, or to protect the rights, property, or personal safety of us, our users, employees, or others.

Aggregated, Anonymized or De-identified Data. We may also disclose aggregated, anonymized, or de-identified data, which cannot reasonably be used to identify you, without restriction. We process, maintain, and use this data only in a de-identified fashion and will not attempt to re-identify such data, except as permitted by law. We may use that aggregated data to enhance and personalize your experience with us, for promotional purposes, testing our IT systems, research, data analysis, improving our Platform, developing new products and features, and for other purposes described in this Privacy Policy.

How We Protect Your Data

We have implemented measures designed to secure your data from accidental loss and unauthorized access, use, alteration, and disclosure. All data you provide to us is stored on third-party vendors’ secured servers that are behind firewalls. However, we cannot guarantee your data is 100% safe or secure.

The safety and security of your data also depend on you. Where we have given you (or where you have chosen) a password for access to certain parts of our Offerings, you are responsible for keeping this password confidential. Do not share your password with anyone.

Unfortunately, the transmission of data via the Internet is not completely secure. Although we use reasonable efforts to protect your data, we cannot guarantee the security of your data transmitted in connection with your use of our Platform. Any transmission of data is at your own risk. We are not responsible for the circumvention of any privacy settings or security measures contained in the Platform.

Retention of Your Data

Tula may store and process information in the United States and other countries.

We may retain your data for as long as we need it to provide you with the Platform. If you ask us to delete your data or if you have an account with us and you delete your account, there may be some latency in deleting this data from our servers and back-up storage and some data may not be completely removed from our logs and other records. In addition, we may retain this data if necessary to comply with our legal obligations such as complying with applicable laws, resolving disputes, or enforcing our agreements.

We determine the retention period of any personal data by taking into account various criteria, such as the type of Offerings provided to you, the nature and length of our relationship with you, the impact on the Offerings we provide to you if we delete some data from or about you, and mandatory retention periods provided by law.

Your Choices About Your Data

For information about your rights regarding your PHI, please refer to our HIPAA Privacy Policy. We strive to provide you with choices regarding the personal data you provide to us. Below are options for your personal data.

Our Email Marketing to You

If you do not wish to receive our emails, you may unsubscribe by following the unsubscribe instructions at the bottom of the email, updating your preferences in the settings of your account profile, or by contacting us through the contact information in the How to Contact Us section at the bottom of this Privacy Policy. After you unsubscribe, however, you may continue to receive service-related and other non-marketing emails.

Accessing and Correcting Your Data

You may amend certain inaccuracies or update your account profile, including your personal data and email preferences on your own through the Platform. If you are unable to amend the data, please email us at the email in the How to Contact Us section below with your request and we will do our best to assist you.

Do Not Track Signals

Some web browsers (including Safari, Internet Explorer, Firefox, and Chrome) incorporate a “Do Not Track” (“DNT”) or similar feature that signals to websites that a user does not want to have his or her online activity and behavior tracked. If a website that responds to a particular DNT signal receives the DNT signal, the browser can block that website from collecting certain data about the browser’s user. Not all browsers offer a DNT option and many digital service operators do not recognize or respond to DNT signals, including Tula.

Links to Other Websites

We may provide links to digital assets such as websites, applications of services that we do not own or operate (“third-party digital assets”). Those links are provided for your convenience. If you follow the link and visit those third-party digital assets, they too may collect data about you. We do not own or control any third-party digital assets, and we are not responsible for the practices employed by third-party digital assets linked to or from our Digital Assets. We recommend that you review the privacy notices of other third-party digital assets before authorizing third-party access to your data.

Children Under the Age of 16

Our Platform is not directed at or intended for children under 16 years of age. No one under age 16 may provide any data to or on the Digital Asset. We do not knowingly collect data from children under 16. If you are under 16, do not use or provide any data on the Digital Asset or on or through any of its features/register or in connection with the Platform. If we learn we have collected or received data from a child under 16 without verification of parental consent, we will delete that data. If you believe we might have any data from or about a child under 16, please contact us through the data at the How to Contact Us section at the bottom of this Privacy Policy.

How to Contact Us

To ask questions or comment about this Privacy Policy and our practices in general, contact us at:

Physical Address
Live Tula, LLC
686 N Arbinger Way, STE 300
Farmington, UT 84025

Phone Number
855.528.0773

Email
compliance@livetula.com