Lief Privacy Policy

Last Updated: January 8th, 2019


This Privacy Policy explains our practices regarding the collection, use and disclosure of information that we receive through our Services. This Privacy Policy does not apply to any third-party websites, services or applications, even if they are accessible through our Services. Also, please note that, unless we define a term in this Privacy Policy, all capitalized terms used in this Privacy Policy have the same meanings as in our Terms of Service. So, please make sure that you have read and understand our Terms of Service.

Please read the following carefully to understand our views and practices regarding your Personal Information and how we treat it. For the purposes of Applicable Data Protection Laws, including the European Economic Area data protection law (the “Data Protection Law”) the data controller is Lief Therapeutics, 2443 Fillmore St #380-6060, San Francisco, CA 94115-1814.

1
Revisions to this Privacy Policy. Any information that is collected via our Services is covered by the Privacy Policy in effect at the time such information is collected. We may revise this Privacy Policy from time to time. If we make any material changes to this Privacy Policy, we’ll notify you of those changes by posting them on the Services or by sending you an email or other notification, and we’ll update the “Last Updated Date” above to indicate when those changes will become effective.

2
Information Collected or Received from or about You.

(a) Account Information. If you create an Account, we’ll collect certain information that can be used to identify you, such as your name, email address, postal address, phone number and Payment Information (“Personal Information”). We may also collect your gender, date of birth, height, weight and other information that is not considered Personal Information because it cannot be used by itself to identify you.

(b) Health Information. We may also collect Health Information from you in connection with your use of the Services, which may include Personal Information.

(c) Information Collected Using Cookies and other Web Technologies. Like many website owners and operators, we use automated data collection tools such as Log Data, Cookies, Web Beacons and similar technologies to automatically collect certain information, which may contain Personal Data, from your computer or mobile device as you navigate our websites or interact with emails we have sent you. As is true of most websites, we gather certain information automatically via Log Data.

“Cookies” are small text files that are placed on your device by a web server when you access our Services. We may use both session Cookies and persistent Cookies to identify that you’ve logged in to the Services and to tell us how and when you interact with our Services. We may also use Cookies to monitor aggregate usage and web traffic routing on our Services and to customize and improve our Services. Unlike persistent Cookies, session Cookies are deleted when you log off from the Services and close your browser. Although most browsers automatically accept Cookies, you can change your browser options to stop automatically accepting Cookies or to prompt you before accepting Cookies. Please note, however, that if you don’t accept Cookies, you may not be able to access all portions or features of the Services. Some third-party services providers that we engage (including third-party advertisers) may also place their own Cookies on your device. Note that this Privacy Policy covers only our use of Cookies and does not include use of Cookies by such third parties.

“Web Beacons” (also known as web bugs, pixel tags or clear GIFs) are tiny graphics with a unique identifier that may be included on our Services for several purposes, including to deliver or communicate with Cookies, to track and measure the performance of our Services, to monitor how many visitors view our Services, and to monitor the effectiveness of our advertising. Unlike Cookies, which are stored on the device, Web Beacons are typically embedded invisibly on web pages (or in an e-mail).

“Log Data” means certain information about how a person uses our Services, including both Account holders and non-Account holders (either, a “User”). Log Data may include information such as a User’s Internet Protocol (IP) address (or proxy server), your location, browser type, device and application identification numbers, operating system and system configuration information, your internet service provider and/or mobile carrier, the web page that a User was visiting before accessing our Services, the pages or features of our Services to which a User browsed and the date/time spent on those pages or features, search terms, the links on our Services that a User clicked on and other statistics. We use Log Data to administer the Services and we analyze (and may engage third parties to analyze) Log Data and overall trends to improve, customize and enhance our Services by expanding their features and functionality and tailoring them to our Users’ needs and preferences and to guarantee their security and continued proper functioning. We may use a person’s IP address from users when they log into the services as part of the Company’s security features and to generate aggregate, non-identifying information about how our Services are used.

(d) Information Sent by Your Mobile Device. We collect certain information that your mobile device sends when you use our Services, like a device identifier, user settings and the operating system of your device, as well as information about your use of our Services.

(e) Location Information. When you use our Application, we may collect and store information about your location by converting your IP address into a rough geo-location or by accessing your mobile device’s GPS coordinates or coarse location if you enable location services on your device.

(f) Information from Third-Party Sources.Lief may collect information about you from thirdparty sources to supplement information provided by you. This supplemental information allows us to verify information that you have provided to Lief and to enhance our ability to provide you with information about our business, products and services.

3
How We Use the Information we Collect. Our primary goals in collecting information are to provide and improve our Services, to administer your use of the Services (including your Account, if you are an Account holder), and to enable you to enjoy and easily navigate our Services. For example, Lief may use your Personal Information in the following ways:
(a) Providing the Services or Information You Requested. Lief may use your Personal Information to provide the Services. In addition, Lief may use the Personal Information about you to provide you information that you may request, e.g. information about our Services or our other products. Such use may include: (a) generally managing your information and Account; (b) responding to questions, comments and requests; (c) providing access to certain areas and features of the Services; and (d) sending you communications related to use of the Services, including alerts and notifications.

(b) Administrative Purposes. Lief may use the Personal Information about you for its administrative purposes, including, without limitation, to: (a) measure interest in the Services, or Lief’s other programs or services; (b) perform internal quality control; (c) verify identity; (d) send communications regarding the Lief Services, or any changes to any Lief policy or terms of service; (e) process payments; (f) prevent potentially prohibited or illegal activities; and (g) enforce our Terms of Use.

(c) Regulatory Purposes. Lief may use the Personal Information about you to comply with regulatory or legal requirements, including to investigate and report on adverse effects you have experienced when using our products.

(d) Sharing Content. The Services may provide functionality that will allow you to forward or share certain content, including Health Information, with third parties. Email addresses that you may provide for will be used to send such third party the content or link you request, but will not be collected or otherwise used by Lief or any other Third Parties for any other purpose.

(e) Creating Non-Identifiable Information. Lief may use your Personal Information to create non-identifiable information, such as de-identified demographic information, de-identified location information, information about the computer or device from which you access the Lief Site or other online services, or other analyses we create (“De-Identified Information”). We may use such DeIdentified Information, alone or in the aggregate with information obtained from other sources, in order to help us to optimally develop new products, processes and services or for public health, research, analytics and any other legally permissible purposes.

(f) Marketing Products and Services. Lief may use the Personal Information about you to provide you with materials about offers, products and services offered by us, including new content or services on Lief Sites. Lief may provide you with these materials by phone, postal mail, facsimile or email, as permitted by applicable law. If you do not wish us to use your Personal Information for marketing purposes, you may contact us at any time to opt out of the use of your Personal Information for such purposes, as further described below.

(g) Other Uses. Lief may use your Personal Information for other purposes disclosed to you at the time you provide Personal Information, with your consent.

4
Information that We Share with Third Parties. We will not share any Personal Information that we have collected from or regarding you except as described below:

(a) Information Shared at Your Request. Account holders may choose to download, copy and distribute their Health Information through the Services or otherwise. You acknowledge sole responsibility for and assume all risk arising from your download, copy and distribution of such Health Information. Lief is not responsible for any consequences of any use or disclosure of your Health Information by you or any third parties to whom you provide your Health Information.

(b) Information Shared with Our Services Providers. We may engage third-party services providers to work with us to administer and provide the Services, including for: (i) provision of IT and related services; (ii) provision of information and services you have requested; (iii) payment processing; and (iv) customer service activities. These third-party services providers have access to your Personal Information only for the purpose of performing services on our behalf. We may share your Personal Information and any necessary payment information, such as credit card number, expiration date and billing address, with our payment processing services providers in order to complete Purchases that are initiated through the Services.

(c) Information Shared with other Third Parties We may share De-Identified Information with third parties, including, without limitation, for industry research and analysis, demographic profiling, to promote the Services, and other similar purposes.

(d) Information Disclosed in Connection with Business Transactions. Information that we collect from our users, including Personal Information, is considered to be a business asset. Thus, if we are acquired by a third party as a result of a transaction such as a merger, acquisition or asset sale or if our assets are acquired by a third party in the event we go out of business or enter bankruptcy, some or all of our assets, including your Personal Information, may be disclosed or transferred to a third party acquirer in connection with the transaction.

(e) Information Disclosed for Our Protection and the Protection of Others. We cooperate with government and law enforcement officials or private parties to enforce and comply with the law. We may disclose any information about you to government or law enforcement officials or private parties as we, in our sole discretion, believe necessary or appropriate: (i) to respond to claims, legal process (including subpoenas); (ii) to protect our property, rights and safety and the property, rights and safety of a third party or the public in general; and (iii) to stop any activity that we consider illegal, unethical or legally actionable activity.

5
Web Analytics.

(a) Google. We use Google Analytics, a service provided by Google, Inc. (“Google”), to gather information about how users engage with our Site and Services. For more information about Google Analytics, please visit www.google.com/policies/privacy/ partners/. You can opt out of Google’s collection and processing of data generated by your use of the Services by going to http://tools.google.com/dlpage/gaoptout.

(b) Mixpanel. We use a service provided by Mixpanel, Inc. (“Mixpanel”) to provide us with analytics data regarding user's interactions with our Site and Services. You may optout of Mixpanel’s automatic retention of data that is collected while using the Services by visiting https://mixplanel.com/optout/. To track opt-outs, Mixpanel uses a persistent opt-out cookie placed on your device. Please note that if you get a new computer, install a new browser, erase or otherwise alter the browser’s cookie file (including upgrading certain browsers), you may delete the Mixpanel opt-out cookie.

(c) Facebook. We may use certain tools offered by Facebook, Inc. (“Facebook”) that enable it to collect or receive information about actions users take on: (a) our Site and elsewhere on the internet through use of Cookies, Web Beacons and other storage technologies; or (b) our Application and other mobile applications, in order to provide measurement services, targeted ads and other services. For more information regarding the collection and use of such information by Facebook, please see the Facebook Data Policy, available at: https://www.facebook.com/policy.php.

6
Retention. . Lief retains the Personal Information we receive as described in this Privacy Policy for as long as you use our Services or as necessary to fulfill the purpose(s) for which it was collected, provide our Services, resolve disputes, establish legal defenses, conduct audits, pursue legitimate business purposes, enforce our agreements and comply with applicable laws and up to 5 years after the account is closed. At the end of this five-year period, we will remove your personal information from our databases and will request that any of our business partners remove your information from their databases.

7
Your Choices. We offer you choices regarding the collection, use and sharing of your Personal Information and we’ll respect the choices you make. Please note that if you decide not to provide us with the Personal Information that we request, you may not be able to access all of the features of the Services.

(a) Opt-Out of our Mailings. We may periodically send you free newsletters and e-mails that directly promote our Services. When you receive such promotional communications from us, you will have the opportunity to “opt-out” (either through your Account or by following the unsubscribe instructions provided in the e-mail you receive). We do need to send you certain communications regarding the Services and you will not be able to opt out of those communications – e.g., communications regarding updates to our Terms of Service or this Privacy Policy or information about billing.

(b) Opt-out of Ad Tracking. You can opt out of the collection and use of your information for ad targeting by going to http://www.aboutads.info/choices or http:// www.youronlinechoices.eu/ to limit collection through the Site or by configuring the settings on your mobile device to limit ad tracking through the App.

(c) Modifying Your Information. You can access and modify the Personal Information associated with your Account by contacting us at getlief.com/support. If you want us to delete your Personal Information and your Account, please contact us at getlief.com/support with your request. We’ll take steps to delete your information as soon we can, but some information may remain in archived/backup copies for our records or as otherwise required by law.

(d) Rights of Access Rectification, Erasure and Restrictions. Where otherwise permitted by applicable law, you may use any of the methods set out in Section (c) of this Privacy Policy to request access to, receive (port), restrict processing, seek rectification or request erasure of Personal Information held about you by Lief. Such requests will be processed in line with local laws. Although Lief makes good faith efforts to provide individuals with access to their Personal Information, there may be circumstances in which Lief is unable to provide access, including but not limited to: where the information contains legal privilege, would compromise others’ privacy or other legitimate rights, where the burden or expense of providing access would be disproportionate to the risks to the Individual’s privacy in the case in question or where it is commercially proprietary. If Lief determines that access should be restricted in any particular instance, we will provide you with an explanation of why that determination has been made and a contact point for any further inquiries. To protect your privacy, Lief will take commercially reasonable steps to verify your identity before granting access to or making any changes to your Personal Information.

(d) EU Data Subject Rights. If you are an EU data subject, you have the right under certain circumstances:

(ii) to receive communications related to the processing of your personal data that are concise, transparent, intelligible and easily accessible;

(iii) to be provided with a copy of your personal data held by us;

(iv) to request the rectification or erasure of your personal data held by use without undue delay;

(v) to request that we restrict the processing of your personal data (while we verify or investigate your concerns with this information, for example;

(vi) to request that your Personal Information be moved to a third party;

(vii) to receive your Personal Information in a structured, commonly used and machinereadable format;

(viii) to lodge a complaint with a supervisory authority

Where processing of your Personal Information by use is based on consent, you have the right to withdraw that consent without detriment at any time by going here. You can also exercise the rights listed above at any time by contacting us at support@getlief.com

8
Responding to Do Not Track Signals. Our Site does not have the capability to respond to “Do Not Track” signals received from various web browsers.

9
The Security of Your Information. We take reasonable administrative, physical and electronic measures designed to protect the information that we collect from or about you (including your Personal Information) from unauthorized access, use or disclosure. Please be aware, however, that no method of transmitting information over the Internet or storing information is completely secure. Accordingly, we cannot guarantee the absolute security of any information you transmit to Lief, and you do so at your own risk. You are responsible for maintaining the secrecy of your own passwords. If you have reason to believe that your passwords or Personal Information is no longer secure, please promptly notify Company at getlief.com/support.

10
Links to Other Sites. Our Services may contain links to websites and services that are owned or operated by third parties (each, a “Third-party Service”). Any information that you provide on or to a Thirdparty Service or that is collected by a Third-party Service is provided directly to the owner or operator of the Third-party Service and is subject to the owner’s or operator’s privacy policy. We’re not responsible for the content, privacy or security practices and policies of any Third-party Service. To protect your information we recommend that you carefully review the privacy policies of all Third-party Services that you access.

11
International Transfer. YYour Personal Information may be transferred to, and maintained on, computers located outside of your state, province, country or other governmental jurisdiction where the privacy laws may not be as protective as those in your jurisdiction. If you’re located outside the United States and ormation to us, we may transfer your Personal Information to the United States and process it there.

12
Our Policy Toward Children. Our Services are not directed to children under 13 and we do not knowingly collect Personal Information from children under 13. If we learn that we have collected Personal Information of a child under 13 we will take steps to delete such information from our files as soon as possible.

13
Your California Privacy Rights. California residents may request and obtain from us, once a year, free of charge, a list of third parties, if any, to which we disclosed their Personal Information for direct marketing purposes during the preceding calendar year and the categories of Personal Information shared with those third parties. If you are a California resident and wish to obtain that information, please submit your request by sending us an email at getlief.com/support with “California Privacy Rights” in the subject line.

Questions. Please contact us at getlief.com/support if you have any questions about our Privacy Policy.