Privacy Policy

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The Flexa Commitment

At Flexa, we value your privacy. We design all our products and services with your privacy in mind and are determined to keep your data safe and secure. We sincerely appreciate that you trust us with your information, and we assure you that you can engage with our products and services knowing that we treat your privacy with the utmost respect.

Welcome to the Privacy Policy of Flexa!

The objective of this policy is to explain our approach to collecting, storing, and processing your personal information.

This Privacy Policy is effective from April 25, 2024.

To help you read this Privacy Policy, we have organized it into the following sections:

1. Definitions
2. About Us
3. Applicability of this Privacy Policy
4. Information We Collect
5. How We Use Your Information
6. How We Share Your Information
7. Information Security
8. Your Rights and Choices
9. Retention of Information
10. Additional Information for California Residents
11. No Children Allowed
12. Privacy Policy Changes
13. Contact Us

1. Definitions

“Personal Information” refers to any information that can be used to identify you or that can be linked to you as an individual.

“Processing” refers to any operation or set of operations performed on Personal Information, such as collection, storage, use, disclosure, or deletion.

“Services” refers to all services that we operate under the Flexa brand, including Apps, Websites, Events, and other services.

2. About Us

The company responsible for your information is:

Flexa
P.O. Box 2771
Rancho Santa Fe, CA 92067

3. Applicability of this Privacy Policy

This privacy policy applies to all Services provided by Flexa.

4. Information We Collect

In order to provide our services to you, we are required to collect the following information from you.

• When you sign-up for the Spiral App and create your profile, we collect the following information from you.
  • Name: First Name & Last Name
  • Email ID
  • Year of Birth
  • Sex at Birth
  • ease of navigation and using our App
  • challenges with the assigned exercise routines
  • improvements in your posture or pain levels
  • your likelihood of recommending products and services from Flexa
  • features that you like the most
  • improvements or changes that you suggest
  • Usage Information: details of the features that you are using and how you are using them
  • Device Information: information about the devices that you use to access our services including hardware and software information like IP address, device ID and type, apps setting and characteristics.
  • We collect diagnostic and performance information like log files, timestamps, crash data, websites/app performance logs and error messages or reports.
  • We may also collect data from tracking technologies such as information from cookies, pixels, web beacons and tags.
  5. How We Use Your Information

  We use your information in order to efficiently deliver our services to you. We use your information for various reasons including the following:

  • To manage your account and deliver our services
  • Create your account with Flexa and set-up your profile
  • Provide you customer support services
  • For product testing and development, data analysis and research
  • Conduct surveys and studies to improve our services and develop new features and functionalities
  • To offer you other products and services that could be of interest to you
  • To comply with legal requirements
  6. How We Share Your Information

  We share your information in the following ways:

  • With our service providers and partners: This includes our partners who help us to operate our services such as data hosting, customer care, marketing, advertising and security operations.
  • For corporate transactions: We may share your information if we are involved in a merger, sale, acquisition, restructuring, reorganization or any other change in ownership and control.
  • To comply with a legal process
  • With other 3rd parties with your consent
  7. Information Security

  We take great care to protect the Personal Information we maintain about you. Flexa has a broad information security program designed to protect your Personal Information using administrative, physical, and technical safeguards. We have measures in place to protect against inappropriate access, loss, misuse, or alteration of Personal Information under our control. While we strive to protect your Personal Information, we cannot guarantee the security of information you provide to us. This is especially true for information you transmit to us via email because email may not have the security features that are commonly built into websites. To the fullest extent permitted by applicable law, we do not accept liability for unintentional disclosure of your Personal Information. Additionally, please be aware that we have no control over the information collected by your internet service provider or information that you disclose over a public network. We are not responsible for any information collected by third parties not within our control or how such information is used or maintained.

  In the event of a data breach, Flexa will take all necessary and appropriate steps to mitigate the breach, investigate the cause and extent of the breach, and notify any affected users in accordance with applicable laws and regulations. Notification may be provided via email, postal mail, or other legally required methods. Flexa will also work to promptly address any vulnerabilities or weaknesses in our systems to prevent future breaches.

  8. Your Rights and Choices

  You are in control of your information and you have the following rights and choices:

  • Access/Update: You can access, update and remove your information that you have provided to us.
  • Device Permissions: You can change the settings on your mobile device regarding the collection and processing of your information and display of notifications.
  • Uninstall: You can uninstall the Spiral App from your device.
  • Account Closure: You can close your account with Flexa.
  • Depending upon where you live, you may have the right to request a copy of the information we keep about you and receive it in a readily readable format.
  • Opting-Out of Targeted Advertising: For more information about the collection and use of your information for online behavioral advertising generally, and how you can opt-out of having your data used for certain online behavioral advertising, please visit the Digital Advertising Alliance’s opt-out tool available at https://youradchoices.com/ and the Network Advertising Initiative’s Opt-Out Tool available at: https://networkadvertising.org/choices/.
  • Managing Your Tracking Technology Preferences: When viewing the Flexa website, you can accept or reject the use of cookies. In addition, many browsers allow you to manage your cookie preferences at the individual browser level. You can set your browser to reject and/or delete some or all cookies. If you reject or delete cookies, please be aware that you may not be able to use some or all portions or functionalities of the website. We may use Google Analytics to obtain information about your visits to our website. Google’s ability to use and share information collected by Google Analytics about your visits to our website is restricted by Google Analytics Terms of Service and the Google Privacy Policy. You may prevent your data from being used by Google Analytics by downloading and installing the Google Analytics Opt-out Browser Add-on.
  9. Retention of Information

  We keep your information as long as we need it for business purposes and as required by law. Once you’re account with us is closed, we will delete your personal information as described below:

  • After you close your account with us, we keep your information for a period of three months. We implement this 3-month safety retention window in the event the information is required for any investigation or legal proceedings.
  • After the safety retention window elapses, we only keep limited information to comply with legal data retention obligations.
  • We keep transaction data for 10 years for tax and accounting requirements.
  • We keep records of your consents for 5 years in compliance with applicable law.
  • We also maintain information based on our legitimate interest where there is an outstanding or potential issue, claim or dispute.
  10. Additional Information for California Residents

  If you are a California resident, California law provides you with additional rights regarding our collection, use and disclosure of your Personal Information under the California Consumer Privacy Act, as amended (“CCPA”), the Shine the Light law, and the Do Not Track law.

  11. No Children Allowed

  We do not permit individuals under the age of 18 on our platform. All our services are restricted to individuals who are 18 years of age or older.

  12. Privacy Policy Changes

  This Privacy Policy may change over time and we will inform you before any material changes take effect.

  13. Contact Us

  If you have any questions about this Privacy Policy, you can contact us:

  • Online: support@flexa.health
  • By Post:

  Flexa
  P.O. Box 2771
  Rancho Santa Fe, CA 92067