LifeLoop Privacy Policy

This policy describes how It’s Never 2 Late, LLC, DBA LifeLoop (“LifeLoop”, “we”, “us”, or “our”) collects, uses, and shares personal information. You can jump to particular topics by going to the headings below:

1. Types Of Information We Collect
2. Use And Processing Of Information
3. Cookies
4. Sharing Of Information
5. Your Choices
6. How We Protect Personal Information
7. Miscellaneous
8. Contact Information

Types Of Information We Collect

We collect information about you in a variety of ways depending on how you interact with us and our websites, solutions, and services, including:

• Directly from you when you provide it to us, such as when you register for an account, use our solutions, sign up to receive communications from us, make a purchase, or contact us by phone, email, or otherwise. 
• Automatically through the use of cookies, server logs, and other similar technologies when you interact with our websites, solutions, advertisements, and emails.
• From other sources, including, for example, our affiliates, business partners, service providers, online social media networks, and other third parties, or from publicly available sources. For example, if you submit a job application, or become an employee, we may conduct a background check.

The following provides examples of the type of information that we collect from you and how we use that information.

Additional Notice for U.S. Residents. 

Some jurisdictions require that we described the categories of personal information we collect, disclose for a business purpose, and share with third parties. Please note, in addition to the recipients identified below, we may disclose any of the categories of personal information we collect with our affiliates and subsidiaries, government entities as may be needed to comply with law or prevent illegal activity, and professional services organizations (such as auditors and law firms). We do not “sell” your personal information for money.

In some cases, we may share Identifiers, Commercial information, Network activity data, and Inferences for behavioral advertising purposes with advertising networks and social networks. We collect the following categories of sensitive personal information: account log-in and password information as well as racial and ethnic origin. This information is collected in order to process transactions, comply with laws, manage our business, or provide you with services. If you apply for a job with us we may also collect your government ID in order to comply with laws. Note that we do not use such information for any purposes that are not identified within the California Privacy Rights Act Section 1798.121. We do not “sell” or “share” sensitive personal information for purposes of cross-context behavioral advertising.

Use and Processing of Information

In addition to the purposes and uses described above, we use information in the following ways:

• To identify you when you visit our website or use our solutions.
• To provide and deliver LifeLoop services, and send you related information such as confirmations or receipts.
• To help diagnose problems with our LifeLoop System and solutions, and to enhance the LifeLoop System and solutions for optimal user experience.
• To monitor the usage and performance of our LifeLoop System and solutions, and to determine aggregate information about our users.
• To customize software, content, hardware, and services that may be of interest to our users.
• To provide maintenance, support, and customer service for the LifeLoop System and solutions.
• To contact users for information verification purposes and to administer accounts.

Although the sections above describe our primary purpose in collecting your information, in many situations we have more than one purpose.  For example, if you complete an online purchase we may collect your information to perform our contract with you, but we also collect your information as we have a legitimate interest in maintaining your information after your transaction is complete so that we can quickly and easily respond to any questions about your order.  As a result, our collection and processing of your information is based in different contexts upon your consent, our need to perform a contract, our obligations under law, and/or our legitimate interest in conducting our business.

To the extent we maintain and use personal information in a deidentified form, we will not attempt to reidentify the information, except for the purpose of determining whether our deidentification processes satisfy our legal obligations.

Cookies

What are cookies? A cookie is a small file placed onto your device that enables a variety of features and functionality. Cookies also enable you to easily share content and help us serve relevant ads to you. Cookies can do this because websites can read and write them, enabling websites to recognize you and remember important information that will make your use of a website more convenient (for example by remembering preference settings). We use cookies and other similar technologies to ensure everyone who uses our website has the best possible experience and for marketing purposes.

How are cookies used for advertising purposes? Cookies and other ad technology such as beacons, pixels, and tags help us serve relevant ads to you more effectively. They also help us provide aggregated auditing, research, and reporting for advertisers, understand and improve our service, and know when content has been shown to you. We may use third party advertising companies to serve ads when you visit our website. These companies may employ cookies and clear GIFs to measure advertising effectiveness. We encourage you to read the privacy policies of these third party advertising companies if you have any concerns. Note: Because your web browser may request advertisements and beacons directly from third party ad network servers, these networks can view, edit, or set third party cookies, just as if you had requested a web page from their site. Ads served by us may also set third party cookies. Unless you clear these cookies from your browser, we may use this information to:

• provide more relevant, interest-based advertising
• provide aggregate reports of ads activity to advertisers and websites hosting the ads
• help website and app owners understand how visitors engage with their sites or apps
• detect and defend against fraud and other risks to protect users and partners
• improve our products

Controlling cookies

Most browsers allow you to control and erase cookies through their settings preferences. However, if you limit the ability of websites to set cookies, you may worsen your overall user experience, since it will no longer be personalized to you. Additionally, some features may work improperly or not at all. It may also stop you from saving customized settings.

Sharing Of Information

In addition to the specific situations discussed elsewhere in this policy, we may disclose personal information in the following situations:

• Affiliates and Acquisitions. We may share information with our corporate affiliates (g., parent company, sister companies, subsidiaries, joint ventures, or other companies under common control). If another company acquires, or plans to acquire, our company, business, or our assets, we will also share information with that company, including at the negotiation stage.
• Other Disclosures with Your Consent. We may ask if you would like us to share your information with other unaffiliated third parties who are not described elsewhere in this policy.
• Other Disclosures without Your Consent. We may disclose information in response to subpoenas, warrants, or court orders, or in connection with any legal process, or to comply with relevant laws. We may also share your information in order to establish or exercise our rights, to defend against a legal claim, to investigate, prevent, or take action regarding possible illegal activities, suspected fraud, safety of person or property, or a violation of our policies, or to comply with your request for the shipment of products to or the provision of services by a third party intermediary.
• Public. Some of our services, such as the Family Portal, may provide the opportunity to post comments, or reviews, in a public forum.  If you decide to submit information on these pages, that information may be publicly available.
• Service Providers. We may share your information with service providers. Among other things service providers may help us to administer our website, provide technical support, process payments, and assist in the fulfillment of orders.
• Communities. We may share your information with the community that you live in, your care facility or similar entities. These entities may use the information to check usage and conduct analytics. Additionally, when you share information with family and associates through our solutions (such as the Family Portal), others can access, view, share, and comment on things you post, upload, or share.

Your Choices

If required under applicable law, you can make the following choices regarding your personal information:

• Access To Your Personal Information. You may request access to your personal information or confirmation that we have information about you. In certain limited circumstances, you may also request to receive access to your data in a portable, machine-readable format.
• Changes To Your Personal Information. We rely on you to update and correct your personal information. Note that we may keep historical information in our backup files as permitted by law.  If our solutions or products do not permit you to update or correct certain information contact us at the address described below and we will correct your information if required by law.
• Deletion Of Your Personal Information. You may request that we delete your personal information.  If required by law we will grant a request to delete information, but you should note that in many situations we must keep your personal information to comply with our legal obligations, resolve disputes, enforce our agreements, or for another one of our business purposes.
• Opt-out of Targeted Advertising. You may opt-out of online tracking based targeted advertising (e.g., cookies) by clicking the cookie settings link here or the “Do Not Share” link on our homepage. Please note that if you change browsers or computers, or if you clear your browser’s cache, you may need to click the link again to apply your preference. You may also opt-out of other forms of targeted advertising by submitting a request as described below. We also recognize Global Privacy Control (GPC) signals enabled by customers on their web browser or web browser extension as valid opt-out requests where required by applicable law. Please note that your opt-out preference signal will be applied only to your current browser and device. For more information about GPC, please visit Global Privacy Control.
• Online Tracking. We do not currently recognize automated browser signals regarding tracking mechanisms, which may include “Do Not Track” instructions.
• Objection to Certain Processing. You may object to our use or disclosure of your personal information by contacting us at the address described below.
• Promotional Emails. You may choose to provide us with your email address for the purpose of allowing us to send promotional materials to you. You can stop receiving promotional emails by following the unsubscribe instructions in e-mails that you receive.  If you decide not to receive promotional emails, we may still send you service related communications.
• Revocation of Consent. Where we process your personal information based upon consent, you may revoke consent. Please note, if you revoke your consent for the processing of personal information then we may no longer be able to provide you with services.
• California Shine the Light. If you are a California resident and would like more information concerning the categories of personal information (if any) we share with third parties or affiliates for those parties to use for direct marketing, please submit a written request to us using the information below.

Please note, not all of the rights described above are absolute, and they do not apply in all circumstances. In some cases, we may limit or deny your request because the law permits or requires us to do so, or if we are unable to adequately verify your identity. We will not discriminate against individuals who exercise their privacy rights under applicable law.

Submitting Requests

You can address written requests and questions about your rights to privacy@lifeloop.com or call us at (303) 806-0797. If you disagree with our denial of a request, you may appeal our decision by contacting us with the subject line “Appeal.”

As required by law, we will require you to prove your identity.  We may verify your identity by phone call or email. Depending on your request, we will ask for information such as your name, the last item you purchased from us, or the last time you interacted with one of our solutions. We may also ask you to provide a signed declaration confirming your identity. Following a request, we will use reasonable efforts to respond to your request.

In some circumstances, you may designate an authorized agent to submit requests to exercise certain privacy rights on your behalf. If you are an authorized agent, you must also submit a written and signed letter authorizing you to act on the individual’s behalf.

How We Protect and Retain Personal Information

No method of transmission over the Internet, or method of electronic storage, is fully secure. While we use reasonable efforts to protect your personal information from unauthorized access, use, or disclosure, we cannot guarantee the security of your personal information. In the event that we are required by law to inform you of a breach to your personal information we may notify you electronically, in writing, or by telephone, if permitted to do so by law.

When you create an account, you will be prompted to create a password.  You are responsible for maintaining the confidentiality of your password, and you are responsible for any access to or use of your account by someone else that has obtained your password, whether or not such access or use has been authorized by you.  You should notify us of any unauthorized use of your password or account.

We retain your personal information for only as long as necessary to fulfil the purposes outlined in this policy, including for the purposes of satisfying any legal, accounting, or reporting requirements, unless a longer retention period is required or permitted by law. To determine the appropriate retention period for personal information, we consider the amount, nature, and sensitivity of the information, the potential risk of harm from unauthorized use or disclosure of the information, the purposes for which we obtained the information and whether we can achieve those purposes through other means, as well as applicable legal requirements.

Miscellaneous

The following additional information relates to our privacy practices:

• Transmission Of Information To Other Countries. Our company is based out of the United States. By submitting your personal information to us you agree to the transfer, storage and processing of your information in a country other than your country of residence where privacy laws may be less stringent than the laws in your country including, but not necessarily limited to, the United States. Where possible, we take steps to treat personal information using the same privacy principles that apply pursuant to the law of the country in which we first received your information. If you would like more information concerning our attempts to apply the privacy principles applicable in one jurisdiction to data when it goes to another jurisdiction you can contact us using the contact information below. You may also request a copy of any Standard Contractual Clauses we use for the transfer of your data outside of the EEA, which includes the categories of information transferred by contacting us using the contact information below.
• Third Party Applications/Websites. We have no control over the privacy practices of websites or applications that we do not own.
• Changes To This Privacy Policy. We may change our privacy policy and practices over time.  To the extent that our policy changes in a material way, the policy that was in place at the time that you submitted personal information to us will generally govern that information unless we receive your consent to the new privacy policy. Our privacy policy includes an “effective” and “last updated” date. The effective date refers to the date that the current version took effect. The last updated date refers to the date that the current version was last substantively modified. If we make a material change to our privacy notice, we will attempt to notify you through email or through a website pop-up.

Contact Information

If you have any questions, comments, or complaints concerning our privacy practices, or if you need to access this policy in an alternative format due to having a disability, please contact us at the appropriate address below.  We will attempt to respond to your requests and to provide you with additional privacy-related information.

It’s Never 2 Late, LLC, DBA LifeLoop
Attention: LifeLoop Privacy Officer
5889 Greenwood Plaza Blvd., Suite 210
Greenwood Village, CO 80111
privacy@lifeloop.com
(303) 806-0797

If you are not satisfied with our response, and are in the European Union or United Kingdom, you may have a right to lodge a complaint with your local supervisory authority.

Last Revised: 9/11/2023
Effective Date: 10/20/2019