Wisdom Labs Privacy Policy
Last Updated: October 24, 2023
Welcome, and thank you for your interest in Wisdom Labs, LLC (“Wisdom Labs,” “we,” or “us”). We are committed to respecting your privacy online. We are also committed to providing you with the very best experience we can on our website and apps. In order to do so, we may gather certain personal information about you.
The Wisdom Labs Privacy Policy (this “Privacy Policy” or “Policy”) explains:
- What information we collect and why we collect it.
- How we use that information and when we disclose it.
- How to access and update your information.
- Your rights with regards to the information we collect.
- The steps we take to protect the information we collect.
This Privacy Policy applies to the information that we collect through our services, including our website (https://wisdomlabs.com), our Wise@Work digital learning platform for enhancing mindfulness and wellbeing (the “Wise@Work App”), and all related sites and services (collectively “Services”). We use the personal information we collect from you to operate, maintain, and provide you with the Services. The legal bases for the processing of your personal information are our legitimate interests, namely the management of our client/user relationships and the administration of our website and business, and, in some cases, your consent, which you may withdraw at any time by emailing us at privacy@wisdomlabs.com. This Privacy Policy applies when Wisdom Labs is the data controller with regards to the collected personal information referenced in this Privacy Policy. A “data controller” refers to the person or organization that decides the purposes for which and the way in which any collected personal information is processed. Wisdom Labs’ address is: Wisdom Labs, 201 Post St., Ste 200, San Francisco, CA 94108.
By using our Services, you agree to the privacy practices described in this Policy. This Policy is incorporated into and is subject to the Wisdom Labs Terms of Use for Wise@Work App for Individuals, the current version of which can be found at the following URL: https://wisdomlabs.com/termsofuse-individual/. Please take the time to familiarize yourself with our policies, and if you have any questions please contact us at privacy@wisdomlabs.com.
Wisdom Labs maintains compliance with the General Data Protection Regulation (GDPR). To comply with the EU data protection laws around international data transfer mechanisms, we offer European Union Model Clauses, also known as Standard Contractual Clauses, to meet data security requirements for customers that operate in the EU. While Wisdom Labs remains self-certified under the EU-US and Swiss-US Privacy Shield, we are not currently relying on these frameworks for the transfer of personal data. We monitor the changes to the GDPR, and update our infrastructure, workflows, features, and contractual agreements accordingly.
This Policy applies to all Wisdom Labs’ operating divisions, subsidiaries, affiliates, and branches, including its U.S. affiliates and any additional subsidiary, affiliate, or branch of Wisdom Labs that we may subsequently form.
Information We Collect
Personal Information:
When you sign up and use our Services we collect limited information about you that may include your name and email address.
Engagement Data:
We collect information about your engagement with the Wise@Work App (“Engagement Data”), including your self-assessments and usage data (for example, frequency of use, types of learning series and practice modules used, minutes practiced, and sessions completed).
Web Logs and Analytics Information:
We record certain information and store it in log files when you interact with our Services. This information may include device and browser information, internet protocol (IP) address, URLs of referring/exit pages, information you search for, and locale. We and our analytics providers/data processors also collect and store analytics information when you use our Services to help us improve our Services.
Cookies and Other Tracking Technologies:
We may use various technologies to collect information, including cookies that we save to your device. Cookies are small data files stored on your hard drive or in device memory. We use cookies to improve our Services and your experience and to allow you to access and use our Services without re-entering your username or password. You can instruct your browser, by changing its options, to stop accepting cookies or to prompt you before accepting a cookie from websites you visit. If you do not accept cookies, however, you may not be able to use all aspects of our Services.
Other Information:
We receive and collect information from you when you contact us or we communicate with you, including via email. This may include engagement data (email sends, opens, and clicks) that can be attributed to your email address, and data that is automatically collected by our email service provider like IP address and email client. We also collect information via public social media accounts and Google Analytic.
Data Processors:
In some cases, Wisdom Labs uses third-party service providers as data processors to process personal information. Personal information is collected and/or shared to the extent necessary to enable such processing. These data processors include HubSpot and Google Analytics, and may also include other service providers that facilitate processing of information to enable the Services to function.
How We Use Information We Collect
We may use the information we collect for a variety of purposes, including to:
- Provide, operate, maintain, improve, personalize, and promote our Services;
- Develop new products, services, features, and functionality;
- Facilitate the administration of our business and website;
- Manage our client/user relationships;
- Enable you to access and use our Services and provide you with reports related to your use of our Services;
- Communicate with you, including responding to your comments, questions, and requests; providing customer service and support; providing you with information about our Services, including technical notices, updates, security alerts, administrative messages, or advertising or marketing messages; and providing other news or information about us;
- Monitor and analyze trends, usage, and activities in connection with our Services; and
- Investigate and prevent fraudulent transactions, unauthorized access to our Services, and other illegal activities.
We will also use anonymized, aggregated information to conduct scientific research related to mindfulness, resilience, wellbeing, productivity, and similar areas.
We may also use the information we collect for other purposes about which we notify you.
Information Sharing and Disclosures
We may share your information in the following ways:
Your consent:
We will share your personal information with companies, organizations, or individuals outside of Wisdom Labs to facilitate the administration of our business and/or your use of the Services when we have your consent to do so. You may withdraw your consent to this sharing of your personal information at any time by emailing us at privacy@wisdomlabs.com.
Your Company; Licensees:
If you are using our Services through a business subscription (or if you are using our Services through a personal subscription and your employer also offers you access to our Services through a business subscription), then we may provide, to your employer, aggregated and anonymized information regarding your and other employees’ use of our Services, including without limitation aggregate Engagement Data (as defined under “Information We Collect” above) as well as the fact that you have registered for an account and are an active user. We do not share any specific information about you or your use of our Services with your employer, except that if in using the Wise@Work App you participate in a team competition sponsored by your employer (a “Challenge“) or in your employer’s incentive program, we may inform your employer whether you completed the Challenge or incentive requirements, as applicable, and disclose to your employer limited Engagement Data regarding your use of the Wise@Work App including the number of sessions and series completed and minutes practiced. If your employer did not license our Services directly from us but from one of our licensees, then we may also disclose to such licensee all of the information described in the immediately preceding two sentences.
Service Providers, Researchers, and Other Third Parties:
We may share de-identified information with our service providers, researchers, and other third parties who perform scientific research and analytics services on our behalf. We also may share your information (including your personal information) with our service providers, data processors, and third parties who perform technology, cloud hosting and marketing services on our behalf, but only for the purpose of performing these services on our behalf. Service providers such as analytics providers may collect information about your online activities over time and across different online services when you use our Services.
Compliance with Laws and Law Enforcement Requests; Protection of Our Rights:
We may disclose your information (including your personal information) to a third party if (a) we believe that disclosure is reasonably necessary to comply with any applicable law, regulation, legal process or governmental request, (b) to enforce our agreements, policies and terms of service or terms of use, (c) to protect the security or integrity of Wisdom Labs’ products and services, (d) to protect the property, rights, and safety of Wisdom Labs, our users, or the public from harm or illegal activities, (e) to respond to an emergency which we believe in the good faith requires us to disclose information to assist in preventing the death or serious bodily injury of any person, or (f) to investigate and defend ourselves against any third-party claims or allegations.
Compliance and Accountability:
If you are an EU or Swiss citizen and feel that Wisdom Labs is not abiding by the terms of this Policy, please contact Wisdom Labs at the contact information provided above.
This Policy shall be implemented by Wisdom Labs and all its operating divisions, subsidiaries and affiliates. Wisdom Labs has put in place mechanisms to verify ongoing compliance with GDPR and this Privacy Policy. Any Employee that violates these privacy principles will be subject to disciplinary procedures.
Business Transfers:
We may share or transfer your information (including your personal information) in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company. We will notify you of such a change in ownership or transfer of assets by posting a notice on our website.
The Rights and Choices You Have With Your Information
You may decline to share certain personal information with us, in which case we may not be able to provide to you some of the features and functionality of our Services. You may update or correct certain personal information at any time by accessing your account settings page on the website or by contacting us at privacy@wisdomlabs.com. You can also email us at privacy@wisdomlabs.com if you would like to close your account or ask us to remove information you think is inaccurate.
You may update or correct certain account information and email preferences at any time by logging in to your account or by contacting us at privacy@wisdomlabs.com. You may opt out of receiving promotional communications from Wisdom Labs by using the unsubscribe link within each email. Even after you opt out from receiving promotional messages from us, you will continue to receive administrative and security messages from us regarding our Services.
Please be aware that you have the following additional rights with regards to your personal information:
Access to personal information:
This is your right to request a copy of the personal information that we hold about you. If you would like a copy of some or all of your personal information, please email us at privacy@wisdomlabs.com or write to us at the following address: Wisdom Labs, 201 Post St., Ste 200, San Francisco, CA 94108.
Deletion of personal information:
Should you wish for Wisdom Labs to delete your personal information, please email us at privacy@wisdomlabs.com or write to us at the above mailing address. Please be aware that information may be retained despite a request for deletion in certain situations, including where processing is required for Wisdom Labs’ compliance with a legal obligation or Wisdom Labs’ establishment, exercise, or defense of legal claims.
Restrict/suspend/object to processing of personal information:
In certain circumstances, you have the right to restrict or suspend processing of your personal information, as well as the right to object to the processing of your personal information. You also have the right to object to the processing of your personal information for direct marketing purposes.
Complaining to an authority:
If you feel that your personal information has been processed in a way that does not meet the requirements of the law, you may lodge a complaint with a relevant supervisory or regulatory authority.
Data Portability:
When processing of personal information is based on consent or contract, and carried out by automated means, you have the right to receive the personal information which you have provided to Wisdom Labs in a structured, commonly used, and machine-readable format, and have the right to transmit that information to another data controller without delay.
Data Security and Retention
We employ reasonable measures to protect your personal information from unauthorized access. Please be aware, however, that despite our efforts, no security measures are perfect or impenetrable, and no method of data transmission can be guaranteed against any interception or other type of misuse.
Collected personal information will be retained for no longer than is necessary to fulfill the purposes for which it was collected or as required by applicable laws or regulations.
Your California Privacy Rights
Under California Civil Code Section 1798.83, California customers are entitled to request information relating to whether a business has disclosed personal information to any third parties for the third parties’ direct marketing purposes. Wisdom Labs will not sell or transfer your personal information to third party companies for their direct marketing purposes without your consent. You may withdraw your consent to our sale or transfer of your personal information to third parties for the third parties’ direct marketing purposes at any time by emailing us at privacy@wisdomlabs.com.
Children’s Privacy
You may use our site and our Services only if you are 13 years or older and are not barred from using the Services under applicable law. To purchase a paid subscription to the Services you must be 18 years or older and capable of forming a binding contract. We do not knowingly collect personal information from children under 13. If we become aware that a child under 13 has provided us with personal information, we will take steps to delete such information. If you become aware that a child under 13 has provided us with personal information, please contact us at privacy@wisdomlabs.com.
International Users
Our Services are hosted in the United States. If you choose to use the Services from other regions of the world with laws governing data collection and use that may differ from U.S. law, your personal information may be transferred, stored or processed on servers outside of your home country. Where this is the case, we transfer information on the basis of mechanisms approved under applicable laws, and will take steps to make sure the right security measures are taken so that your privacy rights continue to be protected as outlined in this Privacy Policy. By providing your information, you consent to the collection, transfer, use, storage, and disclosure of your information in accordance with this Privacy Policy. Your information will be stored and processed in the United States.
Changes to Our Privacy Policy
We may change this Privacy Policy from time to time. If we make any changes, we will notify you by revising the “Last Updated” date at the top of this Privacy Policy and, in some cases, where appropriate, we may provide you with additional notice (such as adding a statement to the home page or sending you an email notification). Changes are effective when they are posted on this page. Your continued use of our Services after the revised Policy has become effective indicates that you have read, understood, and agreed to the current version of this Privacy Policy.
We encourage you to periodically review this Privacy Policy for the latest information on our privacy policies.
Contact Information
Please contact us with any questions or comments about this Privacy Policy, your personal information, our use and disclosure practices, or your consent choices by email at privacy@wisdomlabs.com or mail at:
Wisdom Labs
att: Privacy Policy
201 Post St., Ste 200
San Francisco CA 94108
